ML20204J264
| ML20204J264 | |
| Person / Time | |
|---|---|
| Issue date: | 04/12/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20204J261 | List: |
| References | |
| FOIA-87-714 PROC-850412, NUDOCS 8504190269 | |
| Download: ML20204J264 (64) | |
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Enclosure 1 4/12/85 ORAFT MANUAL CHAPTER U.S. NUCLEAR REGULATORY COPNISSION NRC KANUAL Yolume: 0000 General Administration Part: 0500 Health and Safety CHAPTER 0514 NRC PROGRAM FOR MANAGEMENT OF PLANT-SPECIFIC BACXFITTING OF NUCLEAR POWER PLANTS 0514-01 PURPOSE This chapter defines the objectives, authorities, and responsibilities and establishes basic requirements for actions to be taken in instances where the NRC staff imposes new plant-specific regulatory staff positions on a nuclear power plant licensee.I This practice is connonly referred to as "backfitting" and occurs when the NRC staff takes a new position, or changes its interpretation of an existing position, with respect to a nuclear power plant licensee, it should be clearly understood that backfits are expected to occur and are deemed an important part of the regulatory process to assure the safety of nuclear power plants. However, it is important for sound and effective regulation that backfitting be conducted in a controlled process.
Plant-specific backfitting is different from generic backfitting in that the former involves the imposition on a licensee of positions unique to a 1 See Section 05 of this Chapter for a definition of "licensee."
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Enclosure 1 4/12/85 particular plant, whereas generic backfitting invclves the imposition of the same or similar, positions on two or more plants.
The management of plant-specific backfitting, for whien guidance is provided in this document, does not relieve licensees from compliance with the Comission's regulations. The management process is intended to provice disciplined review of new or changed positions that may be imposed at plants that have already implemented or otherwise invested heavily in meeting previously applicable requirements or positions which were considered by the staff to provide acceptable levels of safety. The plant-specific backfit management process will enhance regulatory stability by assuring that changen in regulatory staff positions do in fact provide substantial additional safety protection that is wa rranted. 'uch plant-specific backfitting 1s entirely proper given the conditions of substantial safety benefit which offset the cost to implement the benefit. This process is intended to provide for effective and efficient use of staff and licensee resources when developing and implementing backfits which enhance nuclear power plant safety.
0512-02 OBJECTIVES It is the overall objective of this program to assure tha. plant-specific backfitting of nuclear power plants is justified and documented and to specify that NRC senior management is responsible for the proper implementation of the backfit process. The specific objectives of this progrcm are to provide for improvements in the levels of protection of public health and safety while
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Enclosure 1 4,*12/85 avoiding a y unwarranted burdens on licensees in implementing ba:kfits. The program should assure to the extent possible that backfits to be issued wil' in fact contribute effectively and significantly to the health and safety of the public or the comon defenso and security.
Identified plant-specific backfits will be comunicated to the licensee only after required regulatory analyses are completed and approved as described in Section 0514-042 of this Chapter. The backfit and supporting regulatory analyses shall be approved by the appropriate Office Director or Deputy Director, or Regional Administrator or Deputy Regional Administrator before the backfit and supporting analysis are comunicated to the licensee.
This Manual Chapter governs those plant-specific backfits comunicated to the licensees or identified by licensees after May 1,1985.
0514-03 PESPONSIBILITIES AND AUTHORITIES 031 The EDO is responsible to the Comission for plant-specific backfit actions. Office Directors and Regional Admiteistrators have the authority to review cases and make decisions for the agency on individual actions, as described in other sections of this Manual Chapter.
032 The Director, Regional Operations and Generic Requirements (ROGR) Staff, shall assure that process controls for overall agency management of the plant-specific backfit process are developed and maintained. These
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Enclosure 1 4/1?/85 process controls shall include specific procedures, training, progress monitoring systems, and provisions for obtaining and evaluating both staff and industry views on the conduct of the backfit process. The Director, ;
ROGR Staff, is also responsible for assuring that each licensee is informed of the existence and structure of the NRC program described in this Manual Chapter. The Director, ROGR Staff, is responsible to assure that substantive changes in the Manual Chapter and related proceogres are !
comunicated to the licensees.
033 The Director, Office of Nuclear Reactor Regulation (NRR) shall assure that 1
an overall procedure for managing plant-specific backfitting that involves positions taken by NRR is developed, implemented, and maintained, in accordance with this Manual Chapter. The overall procedure will be j approved by the EDO, The Director, NRR, shall consult and coordinate with Regional Administrators and the Directors of the Office of Inspection and
- Enforcement and the Office of Nuclear Materials Safety and Safeguards, as appropriate, to develop resolutions of proposed plant-specific backfits in program areas for which NRR has responsibility.
For backfits within NRR's program area of responsibility which are proposed by NRR staff, the Director or Deputy Director, NRR, without further delegation, shall approve the regulatory analysis prior to i comunicating the backfit and analysis to the 11censee. For backfits within the NRR program area of responsibility, but whi<h are proposed by l other NRC staff who have been delegated NRR progran implementation and i
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Enclosure 1 4/12/85 decision authority, regulatory analysis shall be aa oved by the staff Office Director / Administrator or Deputy Director / Administrator of the NRC staff person proposing the backfit, prior to consnunicating the backfit and analysis to the licensee. For all backfits within the NRR program area responsibility which are appealed by a licensee, the Director, NRR, snall make the final decision on imposition of the backfit. The Director, NRR, sh,01 assure NRR staff perfortnance in accordance with this Manual Chapter.
034 The Director, Office of Inspection and Enforcement (IE) shall assure that an overall procedure for managing plant-specific backfitting that involves positions taken by IE is developed, implemented, and maintained, in accordance with this Manual Chapter. The overall procedure shall be approved by the EDO. The Director, IE, shall consult and coordinate with Regional Administrators and the Directors of Nuclear Reactor Regulation and Nuclear Material Safety and Safeguards as appropriate, to develop resolutions of proposed plant-specific backfits in program areas for which IE has responsibility.
For backfits within the IE progran area of responsibility which are proposed by IE staff, the Director or Deputy Director, IE, without further delegation, shall approve the regulatory analysis prior to consnunicating the backfit and analysis to the licensee. For backfits within the IE program area of responsibility, but which are proposed by other NRC staff who have been delegated IE program implementation and decision authority, the regulatory analysis shall be approved by the staff Office
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Enclosure 1 4/12/85 Director / Administrator or Deputy Director / Administrator of the NRC staff person proposing the backfit, prior to comunicating the backfit and analysis to the licensee. For all backfits within the IE program area of responsibility which are appealed by the licensee, the Director, IE, shall make the final decision on imposition of the backfit. The Director, IE, shall assure IE staff performance in accordance with this Manual Chapter.
035 The Director Office of Nuclear Material Safety and Safeguards (NMSS),
shall assure that an overall procedure for managing plant-specific backfitting that involves positions taken by NMSS is developed, implemented, and maintained, in accordance with this Manual Chapter. The overall procedure shall be approved by the EDO. The Director, NMSS, shall consult and coordinate with Regional Administrators and the Directors of the Offices of Nuclear Reactor Regulati:n and Inspection and Enforcement, as appropriate, to develop resolutions of proposed plant-specific backfits in program ar.es for w.'ich NMSS has responsibility.
For backfits within the NHSS program area of responsibility which are proposed by NMSS staff, the Director or Deputy Director NHSS, without further delegation, shall approve the regulatory analysis prior to comunicating the backfit and analysis to the licensee. For backfits within the NHSS program area of responsibility, but which are proposed by other NRC staff who have been delegated NtiSS program implementation and decision authority, the regulatory analysis shall be approved by the staff Office Director /Adninistrator or Deputy Director / Administrator of the NRC 1
Enclosure 1 4/12/85 staff person proposing the backfit, prior to connunicating the backfit and analysis to the licensee. For all backfits within the NMSS program area of responsibility which are appealed by a licensee, the Director, NHSS, shall make the final decision on imposition of the backfit. The Director, NHSS, shall assure NMSS staff performance in accordance with this Manual
. Chapter.
036 The Regional Administrator of each region shall assure that an overall procedure for managing plant-specific backfitting that involves positions taken by the region in any program area for which the region has beA delegated authority, is developed, implemented, and maintained, in accordance with this Manual Chapter. The overall procedure shall be j approved by the EDO.
The Regional Administrator of each Region shall consult and coordinate with the Directors of the Offices of Nuclear Reactor Regulation, inspection and Enforcement, and Nuclear Material Safety and Safeguards as 1
appropriate, to identify issues and develop resolutions of proposed plant-specific backfits Mers such backfitting would result from positions taken by the Region.
i For backfits proposed by the Region, the Regional Administrator or Deputy Regional Administrator, without further delegation, shall approve the regulatory analysis prior to corrunicating the backfit and analysis to the l licensee, For backfits proposed by the Region and appealed by the l
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I licensee, the Administrator is responsible for the conduct of the appeal process within the region; however, if agreement cannot be reacheo at the regional level, the final decision on imposition of the backfit shall be :.
mde by the Director of the program office having responsibility for the l program area relevant to the backfit. Each Regional Administrator shall i assure Regional staff performance in accordance with this Manual Chapter. I i
037 The Director Office of Resource Management shall, in coordination with the Director, Regional Operations and Generic Requirements Staff, the Office Directors, and Regional Administrators, develop and maintain the i overall NRC data base management system identified and described in i
Section 045 of this Chapter, j 038 NRC staff positions may be identified as backfits by persons who are not l members of the NRC staff. Such identifications will be considered by the Office Director / Administrator having responsibility to develop staff i positions on the matter at issue. This Office Director / Administrator will l be responsible to make the determination as to whether the staff position f is a backfit. If the staff position is determin6d to be a backfit, a regulatory analysis shall be completed prior to comunicating the backfit ;
and analysis to the licensee. If the staff position is determined not to !
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be a backfit, the Office Director / Administrator having the responsibility to develop a staff position on the issue will deal with the matter in accordance with appropriate office procedures,
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Enclosure 1 4/12/85 0514-04 BASIC REQUIREMENTS 041 Identifying Plant-Specific Backfits The NRC staff shall be alert to the possibility that certain staff positions may be recognized and identified as plant-specific backfits as defined by Section 05 of this Manual Chapter. Appendix A to this Manual Chapter provides additional infonnation to help in identifying backfits arising from selected staff activities. The staff will promptly consider a licensee claim of backfit to determine if the claimed oau'it qualifies as such in accordance with Section 05 of this Chapter. Licensees identifying such items should send them to the Office Director or Regional -
Administrator of the NRC staff person who issued the position with a copy to the Director, Regional Op r.itions and Generic Requirements Staff. If the NRC determination is that the issue is a backfit, the appropriate staff office should proceed imediately with the preparation of the regulatory analysis, If the determination is that the issue is not a backfit, no further action to process the issue under the provisions of this Chapter need be taken. In either case, the appropriate Office Director / Regional Administrator shall report to the EDO and infonn the licensee, within 3 weeks after receipt of the backfit identification or claim, of the results of the determination and the plas for resolving the issue.
,Y Enclosure 1 4/12/85 042 Regulatory Analysis
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Positions identified as plant-specific backfits shall be imposed on !
licensees only after a determination, based on a systematic and documented !
l analysis, that there is a substantial increase in the overall protection ;
of the public health arid safety or the common defense and security to be ;
derived from the backfit, and that the direct and indirect costs of implementation for that facilit3 are justified in view of the increased protection. The analysis need not be performed, however, if the Director of NRR, NMSS or IE detemines that imediate imposition of the backfit is required to protect the public health and safety or the comen defense and security. '
If imediate imposition is not required, the backfit and supporting I regulatory analysis must be approved by the appropriate Program Office Director or Deputy Director, or Regional Administrator or Deputy Regional Administrator before the backfit and its supporting regulatory arialysis I L
are transmitted to the licensee.
The regulatory analysis shall generally confom to the directives and (
guidance of NUREG/BR-0058 and NUREG-CR-3568, which are the NRC's governing i
documents concerning the preparation of regulatory analyses. In preparing j 1
regulatory analyses, the staff should note that the complexity and :
comprehensiveness of an analysis should be limited to that necessary to provide an adequate basis for decision-making among the alternatives [
i available. NUREG/BR-0058 Section III.A.2 Scope of the Analysis l indicates that, "The emphasis in (doing the analysis) should be on
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- Enclosure 1 4/12/85 simplicity, flexibility, and comon sense, both in tenns of the type of information supplied and in the level of detail provided." However, as a minimum, the following infonnation shall be included in the regulatory analysis:
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- 1. A succinct statement of the backfit to be imposed, and how it provides a subjtantial increase in overall protection.
i 2. A statement describing how the backfit meets the definition of
] "plant specific backf$t" and is therefore subject to the provisions of this Manual Chapter.
- 3. A benefit versus cost analysis that includes consideration of at least the following listed factors. Infomation should be used to the extent that it is reasonably available, and a qualitative assessment of benefits may be made in lieu of the quantitative analysis where it would provide more meaningful insights, or is the only analysis practicable.
(1) The net effect on public risk from the accidental off-site release of radioactise material. The relationship of the pro-posed backfit to other current proposed and existing positions should be considered.
l (2) The net effect on radiological exposure of onsite workers due l
i both to installation of procedural or hardware changes and to I
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s Enclosure 1 4/12/85 the effects of the changes for the remaining lifetime of the l plant.
l (3) The installation and continuing costs related to the backfit changes, including the replaceent power cos'es of facility down- I time or construction delay.
(4) The estimated resource burden on the NRC associated with the proposed backfit and the availability of such resources.
f 4 A consideration of important qualitative factors bearing on the need I for the backfit at the particular facility, such as, but not limited to, opr. rational trends, significant plant events, management effectiveness, or results of perfonnance reports such as the Systematic Assessment of Licensee Performance, i
- 5. The staff position concerning whether the proposed backfit is interim i or final, and, if interim, the justification for imposing the proposed backfit on an interim basis.
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l 6. A statement affirming appropriate inter-office coordination related [
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- 7. The basis for requiring or pemitting implementation on a particular
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Enclosure 1 4/12/85 i schedules are realistic and provide adequate time for in-depth engineericg, evaluation, design, procurement, installation, testing, development of operating procedures, and training of operators and other plant personnel, as appropriate. For those plants with approved integrated schedules, the integrated scheduling process can -
be used for implementing this step and the following tro procedoral l steps.
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- 8. A schedule for staff actions involved in implementation and !
verification of implementation of the backfit, as appropriate.
- 9. Prioritization of the proposed backfit considered in light of other j safety-related activities underw:y at the affected facilit". .
I I 043 Appeal Process 1
Af ter a backfit has been identified, or claimad and then verified to be a f backfit, in accordance with this Chapter (see Section 041), and a licensee f i
has been notified of staff intent to impose a backfit, a licensee ray '
choose to appeal a plant-specific backfit to NRC staff renagement to !
request that the proposed backfit be withdrawn or modified.
I Staff positions that have been evaluated and found not to be backfits with respect to a particular licensee are not to be appealed in the context of l this Manual Chapter. Such appeals are to be dealt with within the norral I
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i Enclosure 1 4/12/85 licensing - or ir.spection appeal process and are not subject to the requirements of this Manual Chapter.
4 Licensees will address appeals of backfit to the Office Director or Regional Administrator whose staffs proposed the backfit with copies to the Director, Regional Operations and Generic Requirements Staff. The appropriate Office Director or Regional Administrator shall report to the EDO within 3 weeks after receipt of the appeal concerning the pisn for resolving the issue. The licensee shnuld also be promptly informed in writing regarding the staff plans.
1 The final decision of the NRC staff on appeals of plant-specific backfits shall be made by the Director of the program office having responsibility
- for the program area relevant to the backfit unless resolution is achieved l at a lower nanagerr.ent level. Sumaries of all appeal meetings shall be j
prepared pronptly, provided to the licensee, and placed in appropriate Public Document Rooms. During the appeal process, primary consideration l shall be given to how and why the proposed backfit provides a substantial increase in overall protection and that the associated costs of
- implenntation are justified in the view of the increased protection, i
This consideration should be made in the context of the regulatory analysis provided initially by the staff to the licensee.
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Enclosure 1 4/12/85 044. Implementation of Backfits i
Following approval of the regulatory analysis by the appropriate Office Director or Regional Administrator, and issuance of the backfit to the f licensee, the licensee will either implement the backfit or appeal it.2 After an appeal and subsequent final decision by the appropriate Office ,
Director, the licensee may elect to implement a backfit resulting from the
- decision. If the licentee does not elect to implement the backfit, it may be imposed by Order of the appropriate Office Director.
v Implementation of plant-specific backfits will nomally be accomplished on a scheduled negotiated between the licensee and the flRC. Scheduling !
f criteria should include the priority of ti.e backfit relative to other .
safety related activities underway, or the plant construction or maintenance planr,ed for the facility, in order to maintain high quality r construction and operations. For plants that have integrated ichedules, (
the integrated scheduling piecess can be used for this purpose. I I
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! 4 A staff-proposed backfit may be imposed prior to completing any of the !
I procedures set forth in this Manual Chapter provided the appropriate [
Office Director deter 1 nines that prornpt imposition is necessary to protect !
i public health and safety or the corren defense and security. In such i cases, the EDO shall be notified promptly of the action. l i
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h 2 It should be noted that Orders must be implemented by the licensee, !
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Enclosure 1 4/12/85 If "prompt imposition" is not necessary, st6ff proposed backfits shall not be imposed, and plant operation shall not be interrupted, during the staff's evaluation and backfit transmittal process, r" a subseque.it appeal process, until a final action is completed by either the licensee or by the Director, NRR, the Director, IE, or the Director, NMSS.
045 Recordkeeping and Reporting The proposing Headquarters Office or Regional Office shall administratively manage each plant-specific backfit using a recordkeeping system that provides for prompt retrieval of current status, planned and accomplished schedules, and ultimate disposition. Office systems shall be compatible with an overall NRC data base accessible to appropriate NRC ma nagers . The systems shall provide reference to all documents issued or received by NRC staff relative to a L'. ant-specific backfit, including requests, position, sta tements , and sunm.a ry reports. Specific dat6 required will include, but are not limited to:
- 1. Licensee and facility affected.
- 2. Whether a backfit is identified by staff or by a licensee.
- 3. Identification and description of the document that either transnits a staff-identified backfit or a licensee request for consideration of a licensee-identified backfit.
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- 4. Substance of the backfit issue.
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- 5. In the case of a licensee-identifiert backfit, the dates (predicted !
and completed) that deteminations are ude as to whether or not a staff position qualifies as a backfit, the substance of the determination, and the organization and official responsible to make I
, the determination.
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- 6. A brief description of what action is pending, and the officials responsible to complete the action.
- 7. Action closing data, to include a description of licensee or staff action and date of agreement or order to irplementt, responsible officials and organization for each action, i r
I 046 Exceptions i Nothing in this Manual Chapter shall be interpreted as requiring the staff to make plant specific assessments for generic backfits that have been j reviewed by the CRGR and approved by the E00, or for generic backfits f
approved prior to Noveaber 1981, unless the EDO deterviines that I significant plant-specific issues were not considered during the prior reviews.
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047 References NUREG/8R-0058. Rev. 1 i
NUREG/CR-3's68 f
0514-05 DEFINITIONS 051 Licensee f
Except where defined otherwise, the word licensee ,is used in this Manual Chapter shall mean that person that holds a license to operate a nuclear r i
power plant, or a construction pennit to build a nuclear power plant, or a Preliminary Design Approval or Final Design Approval for a Standardized Plant Design.
t 052 Plant-$pecific Backfit
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A plant-specific backfit is defined by (1) the substance of the elements of the proposed staff position and (2) the time of the identification of f the proposed staff position: -
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- 1. A backfit is a staff position that would cause a licensee to change i t
the design, construction or operation of a facility from that [
consistent with already applicable regulatory staff positions.
L Applicable regulatory staff positions are described in Section 053. I t
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- ?. The time of issuance of a backfit position is such that important design, construction or operation n.ilestcnes, involving NRC approvals of varying kind, previously have been achieved. Those times af ter which a staff position will be considered a backfit are as follows
- a. Af ter the date of issuance of the construction permit for the facility (for facilities having construction permits issued af ter May 1,1985); or i
- b. after 6 months before the date of docketing of the OL application for the facility (for facilities having construction permits issued before May 1,198$); or
- c. after the date of issuance of the operating license for the facility (for facilities having an operating license on May 1, 1985).
053 Applicable Regulatory Stsff Positions Applicable regulatory staff pusitions are those already specifically imposed upon or committed to by a licensee at the time of the identification of a plant-opecific backfit, and are of several different types and sources:
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- 1. Legal requirements such as in explicit regulations, orders, plant j licenses (amendments, conditions, technical specifications). Note I that some regulations have update features built in, as for example, j 10 CFR 50.55a. Codes and Standards. Such update requirements are !
applicable as described in the regulation. }
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- 2. Written cortnitments such as contained in the FSAR, LERs, and docketed ;
I correspondence, including responses to IE Bulletins, responses to Generic letters, Confireatory Action Letters, responses to Inspection l
- Reports, or responses to Notice of Violation.
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- 3. NRC staff positions that are documented, approved, explicit f
, interpretations of the more general regulations, and are contained in I 1
r documents such as the SRP, Branch Technical Positions, Pegulatory l l
Guides, Generic letters and IE Bulletins. Positions contained in l
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- these documents are not considered applicable staff positions to the i
- extent that staff has, in a previous licensing or inspection action, j 1
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,e Enclosure 1 4/12/85 0514-06 APPENDIX A - Guidance for Making Backfit Deteminations A. General in this section selected regulatory activities and documents are discussed in order to enable members of the NRC staff and the regulated industry to better understand the conditions under which a staff position may be viewed as a plant-specific backfit. It is important to understand that the aecessity for making backfit determinations should not inhibit the normal informal dialogue between technical reviewar or inspector and the licensee. The intent of this process is to manage backfit imposition, not to quell it. The discussinn in this Appendix is intended to aid in identifying backfits in accordance with the principles and the practices that should be implemented by all staff members. This Appendix is not intended to be an exhaustive, comprehensive workbook in which can be found a parallel example for each situation that may arise. As is evident from the definitions in Sectiu 05 of this 'anual d Chapter, a plant-specific backfit has the elements of a change from an already applicitle staff position where an applicable staff position is defined as that established before certain defined milestones in the affected plant's licensing history. There will be some judgment necessary to determine whether a staff position would cause a licensee to change the design, construction or operation of a facility. In making this determination, the fundamental question is whether the staff's action is directing, telling, or coercing, or is merely suggesting or asking the licensee to consider a staff proposed tetion.
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Actions proposed by the licensee are not backfits even though such actions may result from norinal discussions between staff and licensee concerning an issue, and even though the change or additions may meet the definitions of Section 052 and 053.
i 8. Licensing
- 1. Standard Review Plan (SRP) - The SRP delineates the scope and depth of staff review of licensee submittals associated with various licensing activities. It is a dcfinitive NRC staff interpretation of measures which, if taken, will satisfy the requirements of the more generally stated, legally binding body of regulations, primarily found in title 10 CFR. $1nce October 1981, changes to the SRP are to have been reviewed and approved through a generic review process involving the Consnittee to Review Generic Requirements (CRGR), and the extent to which the changes apply to classes of plants is de fined. Consequently, application of a current SRP in a specific operating license (OL) review generally is not a plant-specific backfit, provided the SRP was effective 6 months prior to the start of the OL review. Asking an applicant for an operating license questions to clarify staff understanding of proposed actions, in order to detemine whether the actions will meet the intent of the SRP, is not considered a backfit, c
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,4 Enclosure 1 4/12/85 i On the othee hand, using acceptance criteria more stringent than l those contained in the SRP or taking positions more stringent than or i
in addition to those specified in the SRP, whether in writing or l orally, are p11nt-specific backfits. During meetti.gs with the licensee, staff discussion or coments regarding issues and licensee (
i' actions volunteered which are in excess of the criteria in the SRP generally do not constitute plant-specific backfits; however, if the l l
staff implies or suggests that a specific action in excess of already l
applicable staff positions is the only way for the staff to be f
satisfied, the action is considered a plant-specific backfit whether i i
or not the licensee agrees to take su h action. However, the staff :
should recognize that a verbally implied or suggested action should not be accepted by a licensee as an NRC position of any kind, backfit or not; only written and authoritatively approved position statements l 1
should be taken as NRC positions.
Application of an SRP to an operating plant af ter the Itcense is granted gener.11y is conridered a backfit unless the SRP was approved specifically for operating plant implementation and is applicable to such operating plant. It is irportant to note, however, that in order to issue an amendment to a license, there must be a current finding of coepliance with regulations applicable to the amendment.
As a specific exampit, review of a plant owner's application for a license amendment to authorize installation and operation of a new reactor core, comonly called a "reload application," may necessitate i
.U Enclosure 1 4/12/85 review of new fuel designs or new thermal-hydraulic correlations and associated .;perating limits. Such changes that are clear 1*r advances in design or operation may involve new or unreviewed safety issues, and my warrant review to SRP criteria which were approved subsequent to initial license issuance to the licensee. This is . net considered a backfit. However, such review to newer SRP revisions is not necessarily required to determine current compliance with reg',la tions. Licensee proposed revisions in design or operation that rdise questions only about potential reduced margins of safety as defined in the basis for any technical specification may be reviewed by reanalysis of the same accident sequences and associated assumptions as analyzed in the FSAR for the initial license issuance.
During reload reviews, staff proposed positions with regard to technical matters not related to the changes proposed by a licensee shall be considered backfits.
- 2. Regulatory Guides - As part of the generic review process pursuant to the CRGR Charter, it is decided which plants or groups of plants should be affected by new or modified Regulatory Guide provisions.
Such implementation is therefore not governed by the plant-specific backfit procedures. However, any staff proposed plant specific implementation of a Regulatory Guide provision, whether orally or in writing, for a plant not encompassed by the generic implementation determination is considered a plant specific backfit. A staff action
.O Enclosure 1 4/12/85 with respect to a specide licensee that expands on, adds to, or l modifies a generically approved regulatory guide, such that the position taken is wre demanding than intended in the generic positions, is a plant-specific backfit.
l l 3. Plant-Specific Orders - An order issued to cause a licensee to take actions which are not otherwise applicable regulatory staff positions is a plant-specific backfit. As described in Section 044 of this Manual Chapter, an order effecting prompt trposition of a backfit may be issued prior to completing any of the procedures set forth in this Manual Chapter provided that the appropriate Office Director detemines that prompt imposition is necessary.
l An order issued to confim a licensee comitment to take specific action even if that action is in excess of previously applicable staff positions, is not a plant-specific backfit provided the consnitment was not obtained by the staff with the expressed or implied direction that such a comitment was necessary to gain acceptance in the staff review process. Discussion or convents by the NRC staff identifying deficiencies observed, whether in meetings or written reports, do not constitute backfits. Definitive statements to the licensee directing a specific action to satisfy staff positions are backfits unless the action is an explicit already applicable regulatory staff position.
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C. Inspection and Enforcement
- 1. Inspections - NRC inspection procedures are to govern the scope and depth of staff inspections associated with licensee activities such as design, construction and operation. As such, they define those items the staff is to consider in its detemination of whether the licensee is conducting its activities in a safe manner. The conduct of inspection establishes no new staff positions for the licensee and is rLot, a plant-specific backfit.
Staff statements to the licensee that the contents of an NRC inspection procedure are positions that must be met by the licensee constitute e plant-specific backfit unless the iten is an applicable
- regulatory staff position. Discussion or cceent t / the NRC staff regarding deficiencies observed in the licensee conduct of activities, whether in peetings or in written inspection reports, do not censtitute backfits, unless the staff suggests that specific corrective actions different from previous applicable regulatory staff positions are the only way to satisfy the staff. In the nomal course of inspecting to detemine whether the licensee's activities ,
l are being conducted safely, inspectors may examine and make findings in specific technical areas wherein prior NRC positions and licensee l cemitments do not exist. Examination of such areas and naking findings is not considered a backfit. Likewise, discussion of findings with the licensee is not considered a backfit. If during !
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,v Enclosure 1 4/12/85 such discussions, the licensee agrees that it is appropriate to take action in response to the inspector's findirgs, such action is not a backfit provided the inspector does not indicate that the specific actions are the only way to satisfy the staff. On the other hand, if !
the inspector indicates that a specific action must be taken, such action is a backfit unless it constitutes an applicable regulatory '
staff position.
For example. if the licensee comits to ANSI-N18.7 in thc SAR and the inspector finds the licensee's implementing procedures do not contain all the elements required by ANSI-N18.7, telling the licensee he nust take action to include all the elements in the implenenting ,
procedures is not a backfit. If the inspector finds the licensee has included all the required elements of ANSI-N18.7, but has not included certain of the optional elenents in the implementing procedures , inspector discussion with the licensee regarding the l i
nerits of including the optional elenents is not a backfit. On the other hand, if the inspector tells the licensee that the implenenting (
! procedures trust include any ur all of th') optional elements ir order I to satisfy the staff, inclusion of such elements is a backfit, whether or not agrad to by the licensee.
- 2. Notice of Violations (NOV) -a NOV requesting description of a licensee's proposed corrective action is not a backfit. The licensee's comitments in the description of corrective action are 1
?
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- Enclosure 1 4/12/85 not backfits. A request by the staff for the licensee to consider !
i some specific action in res;:sase to an NOV is not a backfit. ;
However, if the staff is not satisfied with the licensme's proposed corrective actions .nd requests that the licensee take additional actions, those additional actions (whether requested orally or in writing) are a backfit unless they are an applicable regulatory staff
) position.
Discussions during enforcement conferences and responses to the l
licensees requests for advict regarding corrective actions are ,n3 backfits; however, definitive statements to the licensee directing a specific action to satisfy staff positions are backfits, unless the
!, action is an explicit applicable regulatory staff position.
I J
- 3. Bulletins - IE Bulletins and resultant actions requested of licensees i
undergo the generic review process pu.suant to the CRGR Charter.
, Therefore, in gene ral, it is not necessary to apply the plant specific backfit process to the actions -
.asted in a Bulletin. However, if the staff expands the action requested by a
- Bulletin during its application to a specific licensee, such 1
expansion is considered a pla :t specific backfit.
I 4 Reanalysis of Issues - Throughout plant lifetime, many individuals on i the NRC seaff have an opportunity to review the requirements and 3
] comitments incumbent upon a licensee. Undoubtedly, there will be i
i
,d Enclosure 1 4/12/85 1
occasions when a reviewer concludes the licensee's program in a specific area does not satisfy a regulatici, license condition or comitment. In the e,ase where the staff previously accepted the licensee's progran as adequate, any staff specified change in the l
program would be classified as a backfit.
, Fo r example, in ;he case of an NTOL, cace the e , ,s issued l Signifying staff acceptance of the programs described in the SAR, the licensee should be able to conclude that his comitments 'n the SAR satisfy the NRC requirements for a particular area. If the staff was to subsequently require that the licensee comit to additional action other than that specified in the SAR for the particular area, such action would constitute a backfit, l
A somewhat different situacion exists when the licensee has made a submittal comitting to a specific course of action to meet an applicable position, and the staff has not yet responded, therefore has not indicated that the coseitMnt is or is not sufficient to meet the applicable position. Subsequent staff action, taken within a reasonable tire, to cause the licensee to meet the applicable regulatory staff position is not a backfit, even if the licensee has moved ahead in the intervening time to implement that which the licensee proposed to do in its submittal.
f s
e Enclosure 1 4/12/85 :
l The situation described in the prior paragraph, however, should not !
be taken to mean that the staff can allow a licensee submittal to f
remain unreviewed and unresponded to indefinitely. If a liceniee has f implemented a technical resolution intended to meet an applicable !
I regulatory staff position, and staff for an extended period simply l I
1 allows the licensee resolution to Stand with tacit act entance L t
indicated by nonsetion on the pa of NRC, thei a subsequent action i
to change the Itcensee's design, construction, or operation is a [
] backfit,
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] _ _ - _ _ _ _ _ _______---_-J
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- O Enclosure 2 i
TENTATIVE _ SEMINAR SCHEDULE NRR - - April 18 IE ~ April 22 NMSS -
not scheduled Region ! - May 1 or 2 Region II - April 17 ,
Region III - May 15 l Region IV -
June 5 :
Region V -
late May [
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Encloi,ure 3 4/11/85 REGIONAL OFFICE INSTRUCTION PLANT SPECIFIC BACKFIT PROCEDURES A.
Purpose:
To prescribe procedures for implementation of Mr.C plant-specific backfit policy in accordance with draf t NRC Manual Chapter 0514 dated May 1,1985.
B. Objectives:
It is the ocerall objective of this instruction to assure the plant-specific backfitting of nuclear power plants is justified and documented and that Regional senior management is responsible for the proper imple-mentation of the backfit program. The specific objective Of the backfit program is to provide for improverrents in the levels of protection of public health and safety while avoiding any unwarranted burdens on licensees in implementing these backfits. We should assure to the extent possible that backfits to be issued will in fact contribute effectively and significantly to the health and safety of the public or the coninon defease and security.
Identified plan ^-specific backfits will be coninunicated to the licensee only after required regulatory analyses are completed and approved as m , .. , ,, )
j Enclosure 3 4/11/85 cescribed in Sections D.3 and 0.4 of this instruction. The backfit and supporting regulatory analyses shall be approved by the Regional Administrator, or Deputy Regional Administrator before the backfit and supporting analysis are communicated to the licensee.
This instruction governs those plant-specific backfits comunicated to licensees or identified by licensees after May 1,1985.
C. Discussion It should be clearly understood that backfits are expected to occur and are deemed an important part of the regulatory process to provide for the safety of nuclear power plants. However, it is important that backfitting be conducted in a controlled process if we are to have effective and consistent regulation. The management of plant-specific backfitting as described in this instruction in no way is meant to relieve licensees from complying with the Comission's requirements. The provisions of this instruction are intended to provide for a cogent regional M. view of new or changed positions that we may desire to impose on licensees who have already implemented previously applicable requirements or positions which were considered by the NRC to have provided acceptable levels of safety or compliance. The plant-specific backfit process described in this instruction will enhance both regulatory stability and safety by assuring
! that changes in staff position do in fact provide substantial additional I
safety protection that is warranted prior to iriposing such changes on the
~
,e Enclosure 3 4/11/85 licensee. This assurance will be provided through conduct of a regulatory analysis as descrf bed in Section 0.3.
A plant-specific backfit is different from a generic backfit in that the former involves the imposition of a position unique to a particular plant, whereas a generic backfit involves the imposition of the same or similar position on tw or more plants. Management of generic backfits is not governed by this instruction, but by the CRGR process.
A backfit is a staff position that would cause a licensee tol change the design, construction, or operation of a facility from that consistent with 1 Licensee, as used in this instruction, means that person that holds a license to operate a nuclear power plant, or a construction permit to l
build a nuclear power plant, or a construction pennit to build a nuclear power plant, or a Preliminary Design Approval or Final Design Approval for l
a Standardized Plant Design.
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Enclosure 3 4/11/85 already applicable staff positions,2 and the time of issuance 3 of the backfit position is such that important design, construction or operation milestones, involving various NRC approvals, have previously been achieved.
2 Applicable regulatory staff positions are those already specifically irgsed upon or committed by a licensee at the time of the identification of plant-specific backfit, and are of several different types and sources:
- 1. Legal requirements such as in explicit regulations, orders, plant licenses (amendments, conditions, technical specifications). Note that some regulations have update features built in; as for example, 10 CFR 50.55a, Codes and Standards. Such update requirements are applicable as described in the regulation.
- 2. Written comitment such as contained in the FSAR, LERs, and docketed correspondence, including responses to IE Bulletins, responses to Generic Letters, responses to Inspection Reports, or responses to 1 Notice of Violations, and Confirntory Action Letters.
- 3. NRC staff positions that are documented, approved, explicit '
- interpretations of the more general regulations, and are contained in
- documents such as the SRP, Branch Technical Positions, Regulatory l
Guides, Generic Letters and IE Bulletins. Such positions as these ;
, are not considered applicable staff positions to the extent that staff has tacitly or explicitly excepted the licensee from part of all of the position in an action taken previous to the time of identification of the proposed plant-specific backfit at issue. ,
3 Those times after which a staff position will be considered a backfit are as follows:
- 1. After the date of issuance of the construction permit for the '
facility (for facilities having construction permits issued after May1,1985);or
- 2. After 6 months before the date of docketing of the OL application for the facility (for facilities having construction pennits issued
- before May 1, 1985); or
- 3. After the date of issuance of the operating icense for the facility (or facilities having an operating license on M4 1, 1985). !
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4
,4 Er. closure 3 4/11/85 Working level examples of staff positions which constitute backfits and those that do not constitute backfits are discussed in Appendix A.
D. Action:
The overall backfit process should be perfomed in accordance with the following instructions.
[ ADMINISTRATIVE PROCESS MAY BE CHANGED TO SUIT THE REGION. FOR EXAMPLE, SOME REGIONS MAY WANT TO USE A REGUI ATORY ANALYSIS BOARD OR OTHERWISE HANDLE THE PROCESS THR0llGH A CENTRAL GROU
- 1. Regional Backfit Identification Any Regional staff member who identifies the need for imposition of a poteritial backfit will verbally identify this need for imposition to his Section Chief. If the issue is determined to be a backfit candidate by the Sectior: Chief, in accordance with the guidance of Section C above, then a Backfit Identification Fom (BIF) (see Appendix B) will be completed by the identifying staff member, and forwarded by the staff member's Section Chief, through his Branch Chief, to his Division Director for disposition.
- 2. Division Director Disposition
,i Enclosure 3 4/11/85 I i
Each Division Director receiving a BIF will disposition the potential !
backfit as follows:
- a. If thc Division Director determines that the position, if imposed, would constitute a backfit, and that imposition of the backfit on the licensee appears to provide substantial additional safety protection, then a Regulatory Analysis (RA) will be perfonned by the originating section in accordance with Section D.3 below. If however, the Division Director believes that innediate imposition of the position is required to protect the public health and safety or the connon defense and security, then the Immediate Imposition Procedure (IIP) of Section D.5 below should be implemented.
- b. If the Division Director determines that the position, if imposed, would not constitute a backfit, no further action under this instruction is necessary. The determinatica should be noted in the BIF and BIF filed,
- c. If the Division Director determines that the position if i imposed, would constitute a backfit, but that imposition on the licensee would not provide substantial additional safety pro-tection or is otherwise not necessary, then no further action on the issue should be taken beyond documentation of this detennination on the BIF and of the BIF should be filed.
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Enclosure 3 4/11/85
- 3. Regulatory Analysis
[THE REGULATORY ANALYSIS PROVISIONS ARE MANDATORY. WHO PREPARES THE RA IS OPTIONAL.]
- a. If the originating staff's Division Director detennines that the potential backfit constitutes backfitting, and it appears that imposition will provide substantial additional safety protection, then a RA will be performed. Preparation of the RA will be the responsibility of the Section Chief whose staff identified the backfit issue, t The regulatory anal.vsis shall generally conform to the directives and guidance of NUREG 0058 and NUREG CR 3568, which are the NRC's governing documents concerning the preparation of regulatory analyses. In preparing regulatory analyses, the complexity and comprehensiveness of an analysis should be limited to that necessary to provide an adequate base for decision-making among the alternatives available. NUREG 0058, Section !!I.A.2, Scope of the Analysis indicttes that "The emphasis in (doing the analysis) should be simplicity, flexibility, and convnon sense, both in tenns of the type of i information supplied and in the level of detail provided."
r However, as a minimum, the following infonnation shall be i
included in the regulatory analysis:
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- Enclosure 3 4/11/85 (1) A succinct statement of the backfit to be imposed, and how it will provide a substantial increase in overall protection.
(2) A statement describing how the backfit meets the definition of "plant-specific backfit and is therefore subject to the provisions of this Regional Office Instruction.
(3) A benefit versus cost analysis that includes consideration of at least the following listed factors. Infdnnation should be used to the extent that it is reasonably available, and a qualitative assessment of benefits may be made in lieu of a quantitative analysis where it would provide more meaningful insights, or is the only analysis practicable. Qualitative factors to be considered may include operational trends, plant events, management issues, SALP results, etc.
(a) The net effect on public risk from the accidental off-site release of radioactive material. The relationship of the proposed backfit to other current proposed and existing positions should be considered.
(b) The rier, effect on radiological exposure of facility employees due both to installation of procedural or
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Enclosure 3 4/11/85 hardware changes and to the effects of.the changes for the remaining lifetime of the plant.
(c) The installation and continuing costs related to the backfit changes, including the replacement power costs of facility downtime or construction delay.
(d) The estimateo resource burden on the NRC arsociated with the proposed backfit and the availability of such resources.
(4) The staff position concerning whether the proposed backfit is interim or final, and if interim, the justification for imposing the proposed backfit on an interim basis.
(5) A statement affirming appropriate inter-office coordination related to the proposed backfit and plan for implementation.
(6) The basis for requiring or pemitting implementation on a particular schedule, including sufficient information to demonstrate that the schedules are realistic and provide sufficient time for in-depth engineering, evaluation, design, procurement, installation, testing, development of
,c Enclosure 3 4/11/85 operating procedures, and training of operators and other plant personnel, as appropriate.
(7) Schedule for staff actions involved in implementatior. and verification of implementation of the backfit, as appropriate.
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- c. The completed RA and updated BIF will be forwarded for review by the cognizant Division Director, and if favorable, will be
, transmitted to the Regional Administrator for approval. If the Division Director determines further staff action is not warranted the BIF and RA shall be filed.
- 4. Approval of Backfit Requirement
- a. The Division Director whose staff has initiated the backfit issue will forward the RA and BIF to the Regional Administrator for approval. At the same time, the completed RA will be forwarded to the Division Director of the appropriate head-quarters office having program responsibility for the backfit issue (see Appendix C). The Program Office will in this manner be formally kept apprised of any backfit issues and will be given the opportunity to coment on the issue prior to its imposition on the licensee. Three workdays should normally be sufficient.
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'g Enclosure 3 4/11/85
- b. (APPROVAL AUTHORITY MAY NOT BE REDELEGATED.]
The Regional Administrator, or the Deputy Regional Administrator will either approve or reject the backfit. If approved, the BIF information will be provided to the Information Management Section for entry into the Backfit Data Base. If not approved, the BIF and RA will be filed,
- c. If approved for issuance, the bs afit position and RA will be forwarded by the Project Division Director to the licensee. The transmittal should clearly identify the position as a backfit.
- 5. Immediate Imposition Procedure i
- a. If the Division Director whose staff has originated the backfit position believes that insnediate imposition of the position is ,
necessary to protect the public health and safety or the com:n l de'ense and security, then the backfit may be processed without performance of the RA.
- b. [ STRUCTURE OF DECISION PROCESS IS OPTIONAL, HOWEVER, PROGRAM I
OFFICEREPRESENTATIONISMANDATORY.]
In this instance a backfit panel will convene, chaired by the Regional Administrator or Deputy Regional Adninistrator, l
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Enclosure 3 4/11/85 .
attended by the Projects Division Director or Deputy Director, and the Division Director and Branch Chief whose staff initiated the backfit, A representative f rom the headquarters office having program responsibility for the backfit requirement should attend the backfit panel meeting or participate via telecon.
The head-quarters representative will be designated by the Office Director. The cognizant Section Chief will be responsible for presenting the issue including the rationale for innediate imposition.
- c. [ PROVISION FOR OFFICE DIRECTOR ACTION OR DECISION NOT TO TAKE IMiEDIATE ACTION IS MANDATORY.]
If the backfit panel agrees with the need fer imediate imposition, the backfit will be forwarded, by the Regional Administrator, to the Office Director of the headquarter. office having program responsibility for the backfit issue. The Office Director will be expected to act on immediate issuance of the backfit position within two working days from receipt of the request.
- d. If approval for innedia te issuance is given by the Office Director, then the backfit will be issued to the licensee in accordance with Section D.4.c above and the EDO infonned of such action by the Regional Administrator. Additionally, the
4,
- e Enclosure 3 4/11/85 transmittal letter to the licensee should clearly indicate that because of the need for innediate impo31 tion, a RA was not performed.
- e. If approval for innediate issuance is not given by the Office Director, then the backfit will be processed in accordance with Sections D.3 and D.4 above. ,
- f. In either case d or e above, the BDB will be updated by the originating Section Chief by the forwarding of s completed BIF to the IMS.
- 6. Appeal Process
[0PTIONAL ARRANGEMENTS ARE PERMITTED; HOWEVER, THE FIRST APPEAL l
MEETING MUST BE CHAIRED BY A DIV. DIR./DEP. DIV. DIR. AND THE SECOND APPEAL MEETING MUST BE CHAIRED BY THE REG. ADM./DEP. REG.
i ADM.] i
! A licensee may appeal an action taken by the staff which, though not :
1 identified by the staff to be a backfit, the licensee considers to be a backfit. The appeal may be to petition for withdrawal or nodification of a backfit position or to consider a staff action as a backfit.
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Enclosure 3 4/11/85 I
- a. For positions imposed by the Regicnal staff, licensees will nonna11y address appeals to the Regional Administrator and will send a copy. of the appeal to the Director, Regional Operations and Generic Requirements staff.
- b. When an appeal is . received in the Regional Office, it will normally be forwarded to the Projects Division along with other ;
docket related mail.
i
- c. When the Projects Division Technical staff recognizes that.an appeal has been initiated by a licensee, the applicable Projects Division Section Chief will ensure that a copy of the appeal l documentation has be 'n forwarded by the licensee to the :
Director, ROGRS, and will forward the appeal through the Project Division Director to the Division Director whose staff initiated i
the backfit requirement or staff action. The initiating i i
(CONDUCT OF RA AND BDB UPDATE IS MANDATORY.] !
I Division Director will return the appeal to the initiating c Section Chief for action. If it is determined that the position is a backfit, a RA will be performed pursuant to Section D.3 above. The initiating Section Chief will submit to IMS a BIF reflecting that the staff position has been appealed, or that a previously unidentified staff action has been identified by the licensee as a potential backfit requirernent.
,' e Enclosure 3 4/11/85
- d. The initiating Section Chief will arrange and. issue appropriate documentation for a first level appeals meeting with the appealing licensee in order to attempt to resolve the issue.
This meeth J will be chaired by the cognizant Division Director and be attended by the applicable Projects Division Section Chief, and the Branch Chief and Section Chief whose staff initiated the appealed backfit position or staff action. A copy of the RA (if appropriate) will also be provided to the licensee, by the initiating Section Chief, in preparation for the appeals meeting. The first level meeting should normally occur within 2 weeks of receipt of the appeal.
- e. The initiating Section Chief will draft a memorandum by which the Regional Administrator will inform the EDO of the planned disposition of the appeal. A copy of this memorandum will be forwarded to the headquarters office having program respcnsi-bility for the backfit requirement or staff action and the BDB updated accordingly. This action should normally be completed i
within 3-working days.
- f. A sumary of the appeals meeting will be prepared by the initiating Section Chief and forwarded to the licensee with copies to the EDO and PDR. The result of the meeting with the licensee should take the fom of one of the following: , ,
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. , e-Enclosure 3 4/11/85 (1) The licensee agrees with the NRC staff that the backfit requirement should be implemented as imposed, or that a staff action, initially considered by the licensee to be a backfit requirement is, in fact, not a backfit requirement.
In each of these instances, the appeal process in effect will be terminated pursuant to this instruction.
~
s:t (2) The NRC agrees with the licensee that a backfit requirement should be withdrawn or modified or that a staff action, initially considered by the staff to not be a backfit requirement is, in fact, a backfit requirement. If the backfit requirement is to be modified, then the backfit requirement should be reissued in accordance with Section D.4.c above. If the staff action is now considered to be a backfit requirement, ; hen either the procedure for imposition of a backfit requirement may be perfonred in accordance with Section D.7 of this Instruction, or the Division Director whose staff originated the staff action may determine not to pursue the issue as a backfit (i.e.,
withdrawthestaffaction).
h (3) No agreement will be reached. i
- g. If no agreement was reached at the meeting in Section 4.d above, !
then the applicable initiating Section Chief will arrange for
- - _ _ - , _ __,_.,~n-r.-r-._------m y 7 m-- ,
e
,f' Enclosure 3 4/11/85 and issue appropriate documentation for a second level meeting with the appealing licensee in order to reattempt to resolve the issue. Normully, it should be attempted to hold this meeting on the same day as the initial meeting. This second meeting will be attended by the applicable Projects Division Section Chief, the Division Director and Section Chief whose staff initiated the appealed backfit requirement or staff action and the Projects Division Director or Deputy Director. The meeting will be chaired by the Regional Administrator or Deputy Regional Administrator.
- h. A summary of this second appeals meeting will be prepared by the initiating Section Chief and forwarded to the licensee with copies ~o the EDO and PDR. The results of this second meeting with the licensee should take one of the forms specified in step O.4.f above and the BDB will be updated accordingly, f
- 1. If no agreement was reached at the meeting in Section h above, l then the initiating Section Chief will arrange for and issue l
appropriate documentation for a third meeting with the appealing ;
licensee in order to again attempt to resolve the issue. This third meeting will be held in headquarters and coordinated with i
[li IS MANDATORY THAT THE OFFICE DIRECTOC/DEP. DIR.
CHAIRTHETHIRDLEVELMEETING.) ,
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Enclosure 3 4/11/85 '
the offi:e having program responsibility for the backfit requirecent or staff action. This third meeting will be attended by the applicable Program Office Director or Deputy i Director, the Regional Administrator or Deputy Regional Adminir trator, and other appropriate managers, whose staff initiated the appealed backfit position or staff action. The meeting will be chaired by the cognizant Program Office Director or Deputy Directcr. The cognizant program offices are identified in Appendix C. The third level meeting should nomally be conducted within 2 weeks of the second level meeting.
J. A sumary of this third appeals meeting will be prepared by the initiating Section Chief and forwarded to the licensee with I
- k. At the conclusion of this third meeting, v.he appeals process will be considered concluded, regardless of whether the position of the 1Icensee or NRC staff was modified. All information j regarding the appeals process will be updated in a timely manner f
and the results of appeals process updated in the BDB by the [
initiating Section Chief using revised BIFs.
- 7. Backfit imposition
'- /
9
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Enclosure 3 4/11/85 Following approval of the backfit position by the Regional Administrator, and issuance to the licensee, the licenses wilI either implement the requirement or appeal it. It should be noted that Orders must be implemented by the licensee, notwithstanding the appeal process. After an appeal and subsequent final decision by the NRC, the licensee may elect to implement a position resulting from the decision. If the licensee does not elect to implement the requirement, the position may be imposed ';y Order of the appropriate Program Office Director.
Implementation of plant-specific backfit positions will be accomplished on a schedule negotiated between the licensee and the Projects Division Director. Scheduling criteria should include the priority of the requirement relative to other safety-related activities underway or the plant construction or maintenance planned for the facility, and schedules and reasonable constraints thereon to maintain high quality construction and operations. For plants that have integrated schedules, the integrated scheduling process can be used for this purpose.
A staff-proposed position may be imposed prior to completing any of the procedures set forth in this Regional Office Instruction, provided the appropriate headquarters Office Director detennines that prompt imposition is necessary to protect the health and safety or the corinon defense and security. In this instance, either the
,J Enclosure 3 4/11/85 procedures of Sections D.S and D.6 above will be followed, or the Division Director whose staff initiated the backfit requirement will prepare a memorandum for the Regional Administrator's signature requesting that the appropriate headquarters Office Director impose a backfit position upon a licensee prior to completion of an appeals process. In such cases, the EDO shall be notified promptly of the action.
If prompt imposition is not necessary, staff proposed positions shall not be imposed, and plant operation shall not be interrupted during the staff's initial evaluation and transmittal process, or a subse-quent appeal process, until a final action is completed by either the licensee or by the NRC staff.
E. Data and Recording Requirements: The data identified in the Backfit Identification Form shall be entered into the Backfit Data Base within 3 working days after any action which requires updating of the BIF. The
[0RGANIZATIONRESPONSBILITYMAYVARY.]
cognizant Section Chief is responsible for providing the updated BIF to the IMS for BDB entry.
F.
Contact:
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Enclosure 3 4/11/85 ,
Questions or coments should be directed to the Chief, Technical Support Staff.
G. Effective Date:
This Regional Office Instruction is effective upon issuance.
Regional Administrator
Enclosure:
Backfit Identifftation Form 1
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,e APPENDIX A - Guidance for Backfit Determinations General In this section selected regulatory activities or (ocuments are discussed in order to enable regional staff to better understand the conditions under which a planty pecific backfit may be recognized. It is important to understand that the ,essity for making backfit determinations should not inhibit the normal informal dialogue between the inspector and the licensee. The intent of this process is to manage backfit imposition, not to quell it. The discussion in this Appendix is intended to aid in identifying backfits in accordance with the principles that should be implemented by all staff members. This Appendix is not intended to be an exhaustive, comprehensive workbook in which can be found a parallel example for each situation that may arise. There will be some judgment necessary tv determine whether a staff position would cause a licensee to change the design, construction or operation of a facility. In making this !
j determination, the fundamental question is whether the staff's action is directing, telling, or coercing, or is merely suggesting or asking the licensee !
tc consider a staff proposed action.
1 Actions proposed by the licensee are not backfits when the actions result from nonnal discussions between staff and licensee concerning an issue, even though !
the charge or additions may meet the definitions of Section C of this ;
instrv. tion.
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-2 Standard Review Plan (SRF)
The SRP delineates the scope and depth of staff review of licensee subinittals associated with various review activities. It is a definitive NRC staff ;
interpretation of measures which, if taken, will satisfy the requirements of l the more generally stated, legally binding body of regulations, primarily found in title 10 CFR. Since October 1981, changes to the SRP are to have been 4
reviewed and approved through a generic review process involving the Connittee to Review Generic Requirements (CRGR), and the extent to which the changes apply to classes of plants is defined. Consequently, application of a current !
SRP in a specific operating license (OL) review generally is not a plant-specific backfit, if the SRP was effective 6 months prior to the start of the OL review. Asking an applicant for an operating license questions to clarify staff understanding of proposed actions in order to determine whether the -
actions will meet the intent of the SRP is not considered a backfit, L
On the other hand, using acceptance criteria more stringent than those ,
contained in the SRP or proposing licensee actions more stringent than or in i addition to those specified in the SRP, whether in writing or orally, are plant-specific backfits. During meeting with the licensee, staff discussion or I t
corsnents regarding issues and licensee actions volunteered which are in excess '
of the critaria in the SRP generally do not constitute plant-specific backfitsi l however, if the staff imolies or suggests that a specific action in excess of already appliceble staff positions is the only way for the staff to be '
satisfied, the action is considered a plant-specific backfit whether or not the l i
3
. ~ . _ , _ ,
,W licensee agrees to take su:h action. However, the staff should recognize that a verbally implied or suggested action should not be accented by a licensee as an NRC position of any kind, backfit or noti only written and authoritatively approved statements should be taken as NRC positions.
Application rf an SRP to an operating plant after the license is granted ,
generally is considered a backfit unless the SRP was approved specifically for operating plant implementation and is applicable to such operating plant.
Reculatory Guides As part of the generic review process pursuant to the CRGR Charter, it is decided which plants or groups of plants should be affected by new or rnodified Regulatory Guide provisions. Such implementation is therefore not governed by the plant-specific backfit procedures. However, any staf f proposed plant-specific implewntation of a Regulatory Guide provision, whether orally or in writing, for a plant not encompassed by the generic frrplementation determin-ation is considered a plant-specific backfit. A staff action with respect to a specific licensee that expands on, adds to, or sedifies a generically approved regulatory guide, such that the position taken is more demanding than intended in the generic positions, is a plant-specific backfit.
Plant-Specific Orders
,f An order ' issued to cause a licensee to take actions which are not otherwise applicable regulatory staff positions is a plant-specific backfit. An order effecting prompt imposition of a backfit may be issued prior to completing any of the procedures 'et forth in this instruction provided that the appropriate Headquarters Office Director determines that prompt imposition is necessary.
An order issued to confim a licensee comitment to take specific action even if that action is in excess of previously applicable staff positions, is not a plant-specific backfit provided the commitment was not solicited by the staff with the expressed or implied emphasis that such a comitment is necessary to gain acceptance in the staff review process. Discussion or coments by the NRC staff identifying deficiencies observed, whether in meetings or written reports, do not constitute backfits.
Definitive statements to the licensee directing a specific action to satisfy staff positions are backfits unless the action is an explicit already applicable regulatory staff positions.
Inspections NRC inspection procedures are to govern the scope and depth of staff inspections associated with licensee activities such as design, construction and operation. As such, they define those itens the staff is to consider in its detemination of whethe' thi licensee is conducting tts activities in a safe tr6r,r.cr. The conduct of inspection establishes no new staff rositions for the licensee and is not a plant-specific backfit.
,j 2
Staff suggestions to the licensee that the contents of an NRC inspection procedures are positions that must be met by the licensee constitute a plant-specific bat,kfit unless the item is an applicable regulatory staff position. Discussion or coment by the NRC staff regarding deficiencies ;
observed in the licensee conduct of activities, whether in meetings or in written inspect ha reports, do _not constitute backfits, unless the staff :
suggests that specific corrective actions different from current applicable
^
positions are the only way to satisfy the staff. In the nomal course of inspecting to detemine whether the licensee's activities are being conducted safely, inspectors may examine and make findings in specific technical areas '
- wherein prior i
- RC positions and licensee comitments do not exist. Examination of such areas and making findings is not ,onsidered a backfit. Likewise, ,
discussion of findings with the licensee is not considered a backfit. If curing such discussions, the licensee agrees that it is appropriate to take action in response to the 11spector's findings, such action is not a backfit :
a provided the inspector does not indicate that the specific actions are the only way to satisfy the staff. On the other hand, if the inspector ino,' cates that a
~
specific action must be taken, such action is a backfit unless it constitutes j an applicable regulatory staff position.
.l l
For example, if the licensee comits to ANSI-N18.7 in the SAR and the inspector finds the licensee's implementing procedures do not contain all the elements required by ANSI-N18.7, telling the licensee he must take action to include ill i l the elements in its implementing procedures is _not a backfit. Likewise, if the !
inspector finds the licensee has included all the required elements of i
[
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, a*
ANSI-N18,'/, but has not included certain of the optional elements in its implementing procedures, insncetor discussion with the licensee regarding the merits of including the op'ional elements is not a backfit. On the other hand, if the inspector tells the licensee that the implementing pacedures must include any or all of the optional elements in order to satisfy the staff. ;
inclusion of such elements is a backfit, whether or not agreed to by the j licensee.
f 3
Notice of Violations (NOV)
! i e
A NOV requesting description of a licensee's proposed corrective action is not a backfit. The licensee's connitments in the description of corrective action are not backfits. A request by the staff for the licensee to consider some !
specific action in response to on NOV is not a backfit. However, if the staff ;
i is not satisfied with the licensee's proposed corrective actions and reques*s that the licensee take additiv.) actions, those additional actions (whether i i
i requested orally or in writing) are a backfit unless they are an applicable ~
i l
j regulatory staff position, f I
i l
r 4
l Otscussions during enforcement conferences and responses to the licensees requests for advice regarding corrective actions are not backfits; however, ;
I definitive statements to the licensee di tetiry a specific action to satisfy (
Staff potitions are backfits, unless the action is an explicit applicable regulatory staff position. [
f 4 ;
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[
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, g-Bulletins IE Eulletins and resultant actions requested of licensees undergo the generic etview process pursuant to the CRGR r.harter. Therefore, in general, it is not necessary to apply the plant-specific backfit process to the actions requested in a Bulletin. However, if the staff expsnds the action requested by a Bulletit uring d its application to a specific licensee, such expansion is considered a plant-specific backfit.
_ Reanalysis of Issues N
Throughout plant lifetime, many inspectors have an opportunity to review the requirements and comitments incumbent upon a licensee. Undoubtedly, there will be occasic,ns when an inspector concludes the previously NRC approved licensee's program in a specific area does not satisfy a regulation, license condition or commitment. In the case where the staff previourly accepted the
'icensee's i program as adequate, any staff specified change in the program would be classified as a backfit.
For example, in the case of an NTOL, once the SER is issued signifying staff acceptance of the program contained in the SAR, the licensee shoulo be able to conclude that his comitments in the SAR satisfy the NRC requirunents for a particular area. If the staff was to subsequently require tnt the licensee coer.it to additional action other than that specified ,in the SAR for the particular area, such action would constitute a backfit. If there was tacit
l
,O 8-acceptance by staff, by being silent on the issue for an extendsd period of tire, then staff action to force change would be a backfit.
v t
Appendix B BACKFIT IDENTIFICATION FORM Licensee / Facility:
l Substance of Backfit Issue: -
\
s-i i
I Cognizant NRC Organization: Region / Division /Section Issue Identified by: Region Licensee l
Document that Transmitted Staff Backfit Position to Licensee:
Licensee Document that Identified Issue as Backfit: I i
Cognizant HQ Program Office: NRR IE NMSS __
{
Pending/ Completed Action: (AsAppropriate) !
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a 2
- 1. Dates of Backfit Detemination: Scheduled Completed
- 2. Basis for Backfit Detemination:
- 3. Regulatory Analysis Approval: Official Date 4 Dates and Results of Appeal Regional Level: First -
Second -
Headquarters Level:
4 '
ke.
6
- 5. Close Out Action: Brief Description, Documentation, Date
f
,i r Appendix C COGN!ZANT HEADQUARTERS PROGRAM OFFICES Inspection Related Backfit Positions - Office of Inspection and Enforcement Enforcement Related Backfit Positions - Office of Inspection and Enforcement Licensing Related Backfit Positions - Office of Nuclear Reactor Regulation, except for:
o Safeguards !ssues - NMSS o QA Issues - IE o EP Issues - IE h
i
e 1
(g-f*"
Enclosura 2 BACKGROUND INFORMATION FOR CRGR REVIEW OF REGULATORY GUIDE 1.99, REVISION 2 The following information is provided in the format required by the CRGR charter. ,
- 1. The proposed generic action is issuancis of Revision 2 of R6gulatory Guide 1.99 "Radiation Damage to Reac',or Vessel Materials," for public comment. It is Enclosure 1 to this '4emorandum. The proposed implementa-tion schedule is Section 0 of the Guide.
- 2. A staff paper giving the technical basis for the procedures for calculating the extent of radiation damage given in the Guide is Enclosure 3. Copies of the referr.nces in Enclosure 3 and in the Guide are available.
- 3. A brief description of each of the steps anticipeted that licensees must carry out in order to comply with the recommendations of the Guide is as follows.
3.1 Are there separate short-ters and long-tere requirements?
When Revision 2 becomes effective, it will be used in our review of all submittals of P-T limit updates by owners of operating reactors and appli-cants for OLs. Revision 2 will also be used in analyses of transients that threaten the integrity of the reactor vessel beltline and in the evaluation of flaws found in the reactor vessel beltline. Licensees may continue with schedulesfor review of the P-T limits presently given in their Technical Specifications, for a maximum of three years. Within that period, those for whom the allowable operating period has been reduced or has expired when judged by the criteria of Revision 2, should revise their operating procedures and submit the appropriate revision to their Technical Specifications.
05/22/85 1 CRGR BACK INFO RG 1.99 REV 2
3.2 Is it the definitive, cumprehensive position on the subject or is it the first of a series of requirements to be issued in the future?
Revision 2 is an update of the Revision 1 procedures for calculating the adjustment of the reference temperature caused by radiation damage.
Another revision will be required to update the procedures for calculating the decrease in u;.,$er-shelf energy when the technical basis for that because available in t year or two. That change will not effect plant l'-T limits. The technology for prediction of radiation damage is in such v state that further revision of the calculative procedures probably will be necessary in a few years time.
3.3 How does this requirement affeet other requirements? Does this requirement ;
mean that other itees or systems or prior analyses need to te reassessed?
{
Paragraph 5.3.2 of the Standard Review Plan should be changed to refer to !
Revision 2 of Regulatory Guide 1.99. As an example of the editorial changes, !
the references to "copper and phosphorus" should be changed to "copper and nickel." The changes of most significance involve the use of mean values !
and the separate calculation of margin described in Revision 2. The pro-f posed amendments to the Standard Review Plan are given in Enclosure 4. 1 Issuance of Revision 2 and the associated changes in the Standard Review Plan will eventually affect the Tech Spec P-T limits for most plants and I near-tern QLs.
hsuance of Revision 2 for public comment will not affect the procedure for calculating RT ET relative to the screening criteria given in the proposed
,l final rule on pressurized thensal shock, SECY 85-60, February 20, 1985. j!
That procedure is associated with screening criteria (270'F for base metal ,
and axial welds, 300'F for circumferential welds), which were justified by a probabilistic analysis that considered all identifiable uncertainties !{
including those in the calculation of RT@T. Only if a licensee expects l a screening criterion to be exceeded 3 years hence will Revision 2 (or the {
then-current revision) be applied in the reanalysis of susceptibility to l
1 I 05/22/85 2 CRGR BACK INF0 RG 1.99 REV 2 l - - . - _ . - - - - - - -
e pressurized thermal shock for that particular reactor vessel. Note, how-ever, the action recommended in paragraph 4.b.1 of Enclosure 5.
3.4 Is it only computation? Or, does it require or may it antall engineering design of a new system or modification of any existing systee?
It entails the computation of new P-T limits, processing a Tech Spec change, and making the resulting changes in operating procedures during heatup and cooldown. Such changes occur every few years anyway. It will also be used in the analysis of transients that affect the reactor vessel beltline and the evaluation of flaws found in inservice inspection of the l beltline.
3.5 There are no plant hardware changes involved in issuance of Revision 2.
- 4. Revision 2 will apply to all owners of operating reactors and to all f applicants for an operating license, i
- 5. In the regulatory analysis (Enclosure 5), Table 1 gives a breakdown of the benefits and impacts to operating reactors and applicants for OLs, and to PWRs and RWRs.
5.1. Risk reduction assessments and cost assessments given in Enclosure 5 are l
based on a value/ impact analysis made by Pacific Northwest Laboratories I (Enclosure 6) and a review of the costs by the NRC's Cost Analysis Group (Enclos"res 7 and 8). .
5.2. The basis for requiring implementation as described in Section D of the Guide is given in the Regulatory Analysis (Enclosure 5), Sections 5 and 6.
Section D states in effect that Revision 2 will be used in evaluating all predictions of radiation damage submitted after Revision 2 becomes effective.
However, as given in 5 3.1, the implementation schedule will require that every utility review its pressure-temperature limits by 3 years af ter i Revision 2 becomes effective. The reasons for doing so are discussed in the Regulatory Analysis, Enclosure 5.
05/22/85 3 CRGR BACK INFO RG 1.99 REV 2
e.
5.3 The schedule for staff actions to get Revision 2 published in final fore !
will involve: ACRS review, final editing, a 2-month public comment period, I resolution of connents and redrafting of the final version, resubmittal to -
CRGR, and publication in final form. ;
5.4 Implementation of Revision 2 will crowd the normal calendar for review of <
P-T limits somewhat, especially toward the end of the 3-year period described in l 3.1, but the NRC staff schedule will not be impacted severely. !
- 6. Each proposed requirement implements existing regulations, namely General Design Criterion 31 and Appendices G and H 10 CFR Part 50. j
- 7. Section D of Revision 2 describes the implementation. To ensure a proper
(
and timely response, copies of the Guide when issued in final form will
{
be sent to each licensee and applicant for an operating license as part l of the distributien of Revision 2. The concurrence of DELD and DL was ,
obtained when the completed package was sent for Office concurrence to ;
transmit to CRGR.
I
- 8. The Ops clear:nce package when required under the Paperwork Reduction
(
Act, and the Regulatory Flexiblitty Statement are not required. l Regulatory Guide 1.99 does not impose reporting requirements. It !
describes acceptable procedures for fulfilling certain requirements of Appendices G and H.10 CFR Part 50 for which 0M8 clearance has been obtained and for which the Commission has certified that it will not have a significant impact on a substantial number of small entities (Federal (t Register Vol. 44, Number 104, May 27,,1983, p. 24008). !(
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_. _ _ ___ __O
Gh
. Enclosure 2 p
SUMMARY
OF PROPOSED GENERIC REQUIREMENTS FOR CRGR R,E,VI,EW OFFICEOFNUCLEARREGULATORYRESEARQi DATE. June 3, 1985 RES TASK NO.: MS 402-1 RES TASK LEADER: John A. O'Brien TELEPHONE: 301-443-7854 Title of Proposed Action:
Broad Scope Modification of General Design Criterion 4 Requirements for Pro-ta: tion Against Dynamic Effects of Postulated Pipe Ruptures.
, Type e of Action:
Proposed Rule C_ategory:
Tnts paper covers a major policy issue. Resource estimates, Category I, preliminary.
Statement of the Problem:
Advances in technology have led to the acceptance by NRC staff of procedures that estimate the likelihood of ruptures in nuclear reactor piping. However, General Design Criterien 4 (CDC 4) does not allow use of this new technical approach except by exemption granted pursuant to 10 CFR 50.12. Rulemaking is therefore needed to accommodate this engineering advance.
Prior to the last few years, there was no sound technical basis for excluding certain pipe ruptures from the design buis. Now it is clear that it is possi-ble to defend the exclusion of pressurized water reactor primary loop dou-ble-ended guillotine pipe ruptures, and that the scope may be extended to other piping, including piping in boiling water reactors. Rulemaking action will promote investigations to detennine which other situations will permit the re-moval of pipe whip restraints and jet impingenent barriers. Acceptance crite-ria for generally applying these results pertaining to leak-before 'reaku have been published by the NRC staff in "Report of the U.S. Nuclear Regulatory Com-mission Piping Review Committee" NUREG-1061 Volume 3, and are being proposed by the American Nuclear Society in ANS-58.2 entitled "Design Basis for Pro-tection of Light Water Nuclear Power Plants Against Effects of Postulated Pipe Rupture."
. M
I In suwery, the requirements of GDC 4 have led to a situation where protective devices have been added to nuclear power plants to forestall events which are now regarded as extremely unlikely. These protective devices reduce safety and increase worker radiation exposures. A need exists to allow exclusion other than oy exemption from compliance with General Design Criterion 4 requirements when supported by acceptable analyses.
Objectives:
To obtain Comission approval to publish a notice of proposed rulemaking which would expand the scope of affected piping in a recent interim modification to GDC 4 (See SECY 85-108) to include all high energy piping systees in all light water reactors. This arendment to R 4 would persit a potentially mTcli more extensive removal of pipe whip restraints and jet impingement shields originally designed to ottigate the dynamic effects of postulated instantaneous pipe ruptures.
Alternatives and Decision Rationale:
Three alternative to the proposed rule were evaluated as indicated below:
- 1. Maintain the status quo This effectively would continue to require the placement of pipe whip restraints and jet impingement barriers on all piping except the primary main loops of PWRs. This alternative is rejected because analysis have shown that substantial cost savings can be realind when these protective devices are removed. Additionally, total man-rem exposures will be reduced significsntly.
Finally, safety would actually be enhanceti since sisalignment or not l maintaining tolerances when installing or reinstalling pipe whip restraints actually Inc.reases the probability of pipe ruptures.
- i. Reinterpret the existing text of GDC 4
)
For more than fifteen years the staf f has interpreted GDC 4 to require the l placement of pipe whip restraints and jet impingement barriers near nuclear reactor piping. Rulemaking is necessary to justify the departure from long standing past practices.
- 3. Use Exemptions to Acceeplish the Removal of Pipe Whip Restraints and l
Jet Impingement Barriers l
j While rulemaking has recently been implemented for the primary loops of PWRs, the use of plant specific exemptions to the regulations on a The system unique basis entails significant allocation of NRC resources.
4 u
o .
use of repeated GDC 4 exemptions amounts to an amendment to a fundamental NRC rule in the absence of rulemaking procedures, leading to potential legal difficulties. For these reasons, this alternative is also rejected.
Based on this evaluation, the staff reconnends thet the NRC proceed with the proposed rulemaking because:
- 1. It finnly secures the legal basis for staff actions.
- 2. It removes impediments to the application of new technology in the licensing arena, thereby allowing the realization of improved safety, lower costs and reduced worker exposures.
Consequences:
i Although the rule change itself will, in principle, be applicable to all piping systems, the detailed value-irpact assessment has been limited to the main re-actor coolant loop (RCL) piping in PWR plants and to recirculation piping in
- BWR plants. The results of this assessment are annarized below:
i Value(r.an-rem) Impact ($)
I PWR Reactor Coolant loops Best Estimate 3.4E+4 -186+6 j High Estimate 1.lE+5 -277E+6 Low Estimate 8.6E+3 -87E+6 i
j _BWR Recirculation loops i
Best Estimate 8.6E+3 -30E+6 High Estimate 1.0E+4 -65E+6
-15E+6 l i Low Estimate 5.9E+E
\ -
l In this table, "value" represents reduction in occupational radiation exposure. l The nominal estimates of cost and radiation dose indicate that substantial re- t ductions in both would result from implementation of the proposed action. l Implementation: i j
SECY-85-108 dated March 26, 1985, covered the primary circuits of PWRs and al-lowed schedular exemptions for operating plants, plants under construction and ,
future plant designs. General Electric in a April 26, 1985 letter to the Di-l rector. Division of Licensing submitted a draf t emendment supporting l leak-before-break for GESSAR II. Subject to the establisheent of an acceptable
basis, leak before-bretk technology will be applied to piping in BWRs and to other piping in PWRs besides the primary loop piping. Implementation is further described in the accompanying table.
t 4
o I
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4 9
IMPLE_M,E,NJATION Approximate No. Plant Status Regulatory Basis Proposed Mechanism of Plants For Implementation 53 Operating PWRs Modified GOC-4 Licensing amendment under 10 CFR 50.59 ,;
32 PWRs Under Modified GDC.4 Amendment to appli-Construction cation in accordance '
to 10 CFR 50.35(c) 24 Operating BWRs Modified GDC 4 Licensing amendment :
under 10 CFR 50.59 14 BWRs Under Modified GDC-4 Amendment to appli-Construction cation in accordance to10CFR50.35(c) i i
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. lf oL REGULATORY ANALYSIS REGULATORY GUIDE 1.99, REVISION 2 RADIATION DAMAGE TO REACTOR VESSEL MATERIALS
- 1. STATEMENT OF THE PROBLEM One ob>ious constraint on the operation of a reactor is prevention of fracture of the vessel. This is accomplished, in part, by warming it before pressurization, following the pressure-temperature (P-T) limits given in the Technical Specifications (Tech Specs). Neutron radiacion damage to the reactor vessel is compensated for by shifting the P-T linits up the temperature scale every few years by an amount corresponding to the shift in the Charpy test transition temperature produced by the accumulated neutron fluence. The NRC regulates this process on the basis of Appendices G and H,10 CFR Part 50.
Paragraph V.A of Appendix G requires: "The effects of neutron radiation...are to be predicted from the results of pertinent radistion effects studies...."
Since Revision 1 of Regulatory Guide 1.99 was published eight years ago, there has been a significant accumulation of power reactor surveillance data, which constitutes a much more pertinent basis for the Guide than was available when Revision I was written. Revision 2 is based entirely on the surveillance data, and its issuance will provide a basis for licensing decisions that con-stitutes the most pertinent results available, in conformance with the regulation.
It may be asked why the Guide is needed if plants now have surveillance data of their own. Of course, for the newer plants such data are not yet avail-able. For many older plants, unfortunately, the materials in the surveillance capsules are not the controlling materials for that reactor according to our present day understanding. Thus, instead of using the plants' own surveillance T-lY 08/22/85 i REG ANAL RG 1.99 REV 2
r.. - . .
results directly, the staff must rely on calculated values based on the chemi-cal composition of the vessel materials and the neutron fluence.
Regulatory Guide 1.99 Revision 2 upgrades and expands the calculative procedures that are acceptable to the NRC, and it describes acceptable proce-dures for using plant-specific surveillance data when they become available.
The Guide is used in any regulatory action that requires knowledge of the fracture toughness of reactor vessel beltline materials. Three examples of such actions are: (1) setting pressure - temperature (P-T) limits for heatup and cooldown, (2) evaluating transients that threaten the integrity of the reactor vessel, such as low temperature overpressurization and pressurized ther% t shock events, (3) evaluating flaws found during inspection. In any of these analyses, a key input to' the calculation is the fracture toughness of the material as a function of temperature. The ASME Code gives reference values of toughness as a function of temperature relative to RTNDT, the "reference temperature nil-ductility transition" of the material. The Code also describes how to measure the initial RT ET for the unirradiated material. This Guide gives calculative procedures for ARTET, the adjustment of RTNDT caused by neutron tadiation.
The Guide also describes how to combine the initial and the "delta" with a suit-able margin to obtain a value of RT NOT that covers the uncertainties in both.
From analysis of the new data base, and from experience in applying the Guide, the need for certain changes became clear.
. Nickel has been found to increase the Charpy shif t in the presence of
- copper, and should be a factor in the calculations. Thus, some reactor vessels with high nickel welds, which were made when nickel was added in the welding process, have more susceptibility to radiation than previously thought. Conversely, some early reactor vessels that were made with no deliberate alloying additions of nickel have lower sensitivity to radia-tion. Implementation of Revision 2 will remedy these situations.
08/22/85 2 REG ANAL RG 1.99 REV 2
- The effects of copper and nickel content on the sensitivity of welds to radiation damage are dif ferent than they are for base metal--so dif ferent as to require separate t.-eatment of welds and base metal in this Guide.
- The fluence funccion needs revision, i
- The calculative procedure needs to be amended to prescribe mean values instead of upper bound values and to
- tate the margin separately, f
- Procedures for calculating the attenuation of radiation damage tcirough the ,
vessel wall need to be stated specifically.
Improved knowledge of scatter in the surveillance data base made it .secessary to rewrite the criteria for use of plant-specific surveillance data in setting P-T limits for that reactor.
- 2. OBJECTIVE, 2.a General Objective of Regulatory Guide 1.99 The objective of the guide is best described by reference to the schematic pressure-temperature (P-T) diagram Figure 1. The following discussion ',
mainly applicable to PWRs. (See parkgraph 4.a.1.6) The upper-lef t boundary of the operating zone, the P-T limit, appears in the Technical Specifications for all plants together with ce.'*.ain limits on heatup/cooldown rates. The P-T limits are based on Apper. dix G, 7.') CFR 50, which incorporates Appendix G and parts of Section III of the ASME boiler and Pressure Vesol Code. And, the P-T limits are affected by Regulatory Guide 1.99 as described in the previous Section.
In the upper-lef t corner of Figure 1 is a region labelled "hazardous to vessel integrity" which is bounded by a set of curves (instead of one curve) to indicate that higher cooldown rates increase the hazards. This boundary moves upscale in temperature as radiation damage accumulates during the operating Ilfe of the vessel. The objective of the margins added in calculating P-T limits is to place the operating zone for heatup/cooldown far enough from the hazardous 3 REG ANAL RG 1.99 REV 2 08/22/85
~
region to provide the operator time to diagnose and correct system transients such as low temperature overpressurizations (LTOPS) and rapid cooldown events that could threaten vessel integrity.
2.a.1 Sources of M rain in P-T Limit Calculations A discussion of the sources of margin that are present in the calculative proce. dure for P-T limits given in the ASME Code and NRC Regulations is in order.
First, the postulated flaw is a semiellipse 0.25T deep by 1.5T long (2.2 in. A 13 in. , typically, for a PWR). From the flaw size distribution used in the VISA code, the probability of such a flaw in the critical beltline weld of a reactor vessel is about one in 60,000. The probability may be debatable, but clearly there is margin in the 0.25T flaw assumption. Nevertheless, the use of a 0.25T flaw is an accepted feature of the Code procedure for calcula-tion of P-T limits, which we endorse. This is partly because the efficacy of the flaw detection and sizing in non-destructive examination is still debatable, and partly because some flaws are the result of metallurgical conditions that also degrade the toughness of the aajacent material.
Second, there is a safety factor of two on the stresn intensity factor due to primary membrane stress (in the beltline, pressure stress) and a f actor of one on that due to thermal stress. These factors were chosen by the Code writing bodies with the help of the basic document, WRC BJ11etin 175,* but the rationale for the factor of 2 on pressuee is not explicitly stated therein.
1 A third source of margin is the requirement that thu toughness-temperature function used in these calculations should be the "K g , carve" for crack arrest, called the "K IR curve" in Appendix G, rather than the "Pyg curve" for static crack initiation. (See Figure 4 of the Regulatory Analysis). The KIR curve is the lower bound of dynamic and crack arrest toughness values for specimens some -
of which were full thickness. Its adoption for Appendix G of the ASME Code
- PVRC AdHoc Task Group on Toughness Requirements," PINC Recommendations on .
Toughness Requirements for Ferritic Materials," Welding Research Council Bulletin No.175, August,1972.
08/22/85 4 REG ANAL RG 1.99 REV 2
derived from a philosophy that was subscribed to by many, especially the researchers from the Naval Research Laboratory, that many service failures were the result of dynamic loading. In a reactor vessel beltline, the pressure and thermal stresses are not applied dynamically in the sense intended here, not even in a thermal shock situation. However, one can postulate a case for rapid loading by postulating a small defect that is surrounded by a nugget of brittle
! metal that carries stress up to some critical level, then cracks open suddenly, presenting the sound metal with a running crack. Thus, the requirement to use the crack arrest toughness curve instead of the crack initiation curve is not entirely a matter of adding margin - in some unknown percentage of cases, it is the realistic thing to do. Whether based on this scenario or on simple conservatism, the calculations required t'y the ASME Code for P-T limits are to be based on the K curve. For evaluation of accident conditions, however, IR Section XI uses the Kg , curve. The temperature difference between the Kgg curve and the K), curve is about 65'F in the region of interest.
The fourth source of margin in 'he calculation of P-T limits is the use of lower bound toughness curves. In the VISA code, however, toughness is simulated from the mean K yg curve with a distribution about the mean of i 10 per cent (1 sigma). 'he use of a lower bound curve is consistent with Code philosophy in setting allowables, and was believed justified at the time it was drawn, because the data base was for only one heat of plate material. The temperature margin between the K), curve in the Code and the best-estimate curve used in the VISA code is about 40*F in the region of interest. (See Figure 5.)
The fifth source of margin is that required by Revision 2, paragraph C.I.a.(3). Toughness values Kg , and Kg, are given in terms of (T- ATNOT)*
The margin added to RTNDT covers uncertainty in the initial RTNOT for unitra-diated material as well as the uncertainty in ARTNOT' *hICh I' 'P'CIII'd I" Revision 2 to be 56'F for welds and 34'F for base metal. These values resulted f rom the regression analyses of the data and represent two-sigma upper bounds.
They are considored to cover the uncertainty caused by scatter of the data abaut the mean and uncertainties in the copper, nickel, and fluence. These variables are entereo in the calculative procedure as best-estimate or mean values. The margin also is assumed to cover uncertainty arising from possible differences between the copper and nickel contents cf the weld and base metal samples and 5 REG ANAL RG 1.99 REV 2 03/22/85
those of the actual vessel materials at the location of interest in a fracture analysis.
In conclusion, it should be pointed out that the efforts to provide margin in the five areas described above are quite consistent with the requirements of General Design Criterion 31. It states in part "The design shall ref'oct consideration of ...the uncertainties in determining (1) material properties, (2) the effects of irradiation on material properties, (3) residual, steady state and transient stresses, and (4) size of flaws."
Constraints on the amount of margin that can prudently be provided derive from the need for an operating zone of reasonable width for efficiency in heatup/
cooldown operations and the presence of a lower limit on pressure at a given ,
temperature based on avoidance of pump cavitation or thermal hydraulic problems caused by an approach to saturation conditions.
2.b Sum ary An attempt has been made to describe the objectives of Regulatory Guide 1.99 by placing it in context with the other documents that provide the basis for procedures to assure prevention of fracture of the reactor vessel and by describing the sources of margin provided in those procedures. The scope of the Guide is restricted to one part of the procedures.. to provide an acceptable basis to account for the effects of neutron radiation on the fracture toughness of reactor vessel materials. This is ne sded in the calculation of P-T limits, in ana'ysis of transients that threate'. vessel integrity and in the analysis of beltline f1ms.
r The objective of Revision 2 is to upgrade the calculative procedures in ,
Regulatory Guide 1.99 by basing them on the most pertinent radiation data and the best available understanding of radiation damage in reactor vessel mate-rials in accordance with 10 CFR 50, Appendix G. The specific changes made in preparing Revision 2 are iteeized in Section 1, above.
08/22/85 6 REG ANAL RG 1.99 REV 2
- 3. ALTERNATIVES The alternatives to issuance of Revision 2 are to leave Revision 1 in place or to eliminate the Guide altogether. The latter can be disposed of ,
quickly: the staff reviews several P-T limits per year, plus an c:'asional transient and flaw indication and clearly needs a published basis for its '
reviews. There is at present nothing equivalent to Regulatory Guide 1.99 in the ASME Code. ASTM Standard Guide E-900-83 corcains an equation relating the Charpy shif t to capper content and fluence., but, it is out of date, and the Standard does not contain guidance on the use of plant-specific surveillance data. The alternative of continuing to use Revision I has a safety impact on g many plants and penalizes other plants; a detailed analysis of these conse-quonces is given in the following section. -
,t
- 4. CONSEQUENCES I
4.a. Costs and Eenefits of Alternatives t l'
4.a.1. Application to P-T Limit Calculations !
In this Section, it >
4.a.1.1 Effects on P-T limits for All Plants.
will be shown that taplementation of Revision 2 will mean that for about one-half of the operating reactors the P-T Itatts should be moved upscale to higher l temperatures by amounts that depend on fluence level and copper and nickel content of the beltline materials. ,
Referring again to Figure 1, this means that the region labelled "hazardous to vessel integrity" extends farther upscale in temperature than would be pre- j-I dicted if Revisto.n 1 were continued to be used; hence the P-T limit should be moved also, to maintain the margin.
t:
About one sixth of the plants will be able to operate with their present P-T limits for a longer period than previously determined based on Revision 1. ,
- i The remaining third will De essentially unaffected. l' To determine the consequences of changing from Revision 1 to Revision 2 in i
our review of P-T limits, the first step was to calculate what differences would 7 REG ANAL RG 1.99 REV 2 08/22/85
result if all plants should review their P-T limits this year first according to Revision 1 and then according to Revision 2. The fluence value used for each plant was chosen, assuming that the goal was to have P-T limits that would be good for 4 or 5 years in the case of PWRs and somewhat longer for BWRs.
The importance of fluence level is shown in Figure 2 which illustrates for one materia'l how the "trend curve" from Revision 1 compares to correspond-ing curves from Revision 2. The trend curve from Revision 1 is an upper bound curve, hence for comparison, the Revision 2 values are mean plus-margin, cal-culated as described in the Guide. Note how the two curves from Revision 2 cross that for Revision 1 at fluences of about 3 x lots n/c : for base metal and somewhat higher for welds, indicating that plants having 0.35 Cu and 0.6 Ni and low fluences will be ratcheted whereas those having higher fluences will get some benefits. Figure 2 is drawn for 0.35 parcent copper and 0.6 percont nickel. For other compesitions, the general appearance of the figure would be similar, with the crossovers occurring at different fluences.
In Figures 3 and 4, the numerical differences between shif t values calev-lated for Revision 1 and those for Revision 2 (mean plus margin) are tabulated for eight copper levels, three nickel levels, and seven fluence levels. In the figures, the boundaries between conditions for which a plant would be ratcheted (the positive values in the Table), and those under which plants would benefit (the negative values) are indicated.
Having Figurcs 3 and 4, the effect on each plant of a change from Revi-sion 1 to Revision 2 as a basis for the P-T limits was readily estimated on the basis of the copper and nickel content of its critical material and the fluence value described above. For the eight plants ratcheted 50-100*F, actual shift calculations were made following Revisions 1 and 2.
t Our information on the limiting material and its copper and nickel content was quite good for PWR operating reactors, f airly complete for operating BWRs, but for many plants under construction it was limited to knowing whether or not the reactor vessel was bought to a low-copper specification. However, inspec-tion of Figures 3 and 4 shows that the numbers do not vary radically from box l
08/22/85 8 REG ANAL RG 1.99 REV 2
to box in most cases, and we believe the results are sufficiently accurate for ,.
discussion purposes. ,
Table 1 presents a summary of the changes in P-T limits that would result from a change from Revision 1 to Revision 2. For example, the Table shows that, ;
of the 81 operating light-water reactors (including three that are licensed [
only for low power testing), about 30 would fine little difference (120*F) in the use of Revision 2 or Revision 1. Eight plants (four PWRs and four BWRs) ,
l would find that the use of Revision 2 would raise their P-T limits somewhere betwen 50'F and 100*F. The features that made this happen were: high nickel welds in three cases, and low fluences in five cases. Some 33 plants would be ratcheted 20-50'F. A total of 10 plants would bg benefitted a significant amount. Most of these have low-nickel material (A302 8 plate and selds with only residual nickel content). ;
l Most owners of plants undergoing licensing would find the use of Revision 2 i raises their P-T limits 20-50'F, but the impact of this is small because flux reduction programs, the use of low-copper materials, and better information j
l about initial RT NDT will cause the expected end-of-life reference temperature to be less than 200'F even when calculated using Revision 2.
It is important to note that the fluences used in the calculations on which 4
~
j Table I is based correspond to about one-fourth of plant life on the average.
I l Inspection of Figures 3 and 4 reveals that for fluences characteristic of later life, which range from 1 to 7 x 10" n/cm8 for PWRs, and for copper levels that produce high-shif t values, the ratchet efforts of Revision 2 (as calculated for l j
Table I) disappear and become benefits during the latter half of the lifetime. '
j 4.a.1.2 Risk Avoided by usino Revision 2. One source of risk of f continued operation with P-T limits based on Revision 1 when RTNOT is really l
~l higher (as given by Revision 2) depends upon the increased probability that
,f a given transient will threaten the vessel. To illustrate this situation in Figure 1, consider that the hazardous region is expanded to the right, closer f to the P-T limit, because its extent really depends on a value of RTNDT b: sed l i
on Revision 2. Thus the operator will be misled by erroneous P-T limits as to !
9 REG ANAL RG 1.99 REV 2 08/22/85 i
the potential severity of the transient and will have less time to take corree-tive action to avoid the hazardous region.
To quantify the risk that would be avoided if the P-T limits wer7 noved upscale to conform to Revision 2, several factors must be evaluated:
- a. Expected frequency of transients that may violate P-T limits.
- b. Expected severity of transients in terms of pressure and temperature as functions of time,
- c. Reduction in severity caused by having proper P-T limits and therefore more concern on the part of the operator and more time to take corrective action.
This factor must be evaluated as a f' unction of the difference in P-T limits based on Revisions 1 and 2.
A quantitative evaluation of these factors was not undertaken, because it appeared that uncertainties, particularly in ites c, would be so large that the result might not be defensible.
Another source of risk is incvered by a heatup-cooldown operation following P-T limits that are lower than they should be. Consider, for example, one of the plants for which the P-T limits based on Revision 1 are 100'F below those based on Revision 2. If a plant in that situation continued to operate with a P-T limit based on Revision 1 and if the operator followed the limits closely in a heatup - cooldown sequence, there would be greater probability of fracture of the vessel. A contract was given to Pacific Northwest Laboratories (PNL) to evaluate the increased risk, calculete tha public exposure to radiation as a consequence of vessel failure, and calculate the costs resulting from a change to Revision 2 as the basis for P T limits. The PNL report is Enclosure 6. ,.
The change in the probability of fracture (Revision 1 - Revision 2) was ,
calculated using a Monte Carlo technique and the VISA code, which originated at the NRC and is being further developed at PNL. In this analysis, initial RT NOT, toughness, copper content, fluence, and flaw size were treated proba-bilistically. Actually, in most runs, the flaw tize had to be treated as 08/22/85 10 REG ANAL RG 1.99 REV 2
~
j fixed at a large value (a 2 in, deep continuous flaw, probability of one) to i
" get the Monte Carlo procedure to produce f ailures f requently enough to keep the '
, required total runs to a reasonable number. Then the probability was reduced l e
by a factoe of 3500 to account for the more realistic flaw size distribution norskily used, as explained in the PNL report.
i The conclusion reached by PNL, based on the probabilistic frar.turc l mechanics analysis, was that ths best estimate of the increase in probability '!
of vessel failure resulting from following P-T Itaits that were 100'F too low f was 2.5 E-7 per hettup/cooldc~n cycle. In the subsequent risk analysis, this 'l t'
1 f
result was used for plants ratcheted 50-100*F and half that amount for plants i 3
- ratcheted 20-50*F. Using the techniques described in Enclosure 6. PNL completed If the calculation of increased public risk resulting from these vessel failure I
l probabilities. For.the ' lifetime of the present population of plants, the total a man-res avoided was 1.1 E+4 man-ree. !
1 '
J i
l 4.a.1.3 Costs to Industry--PNL Value/ impact Analysis. The cost af adopt- l ing Revision 2 derives mainly from the cost of purchased power during delays in If 1
startup caused by the more restrictive operating Itaits. In the PNL analysis. l i Enclosure 6, the extra time involved was estimated to be 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the worst
- l case of a 100*F ratchet, based on the opinions of their contacts among inspec- t l
i ters and utilities. When the P-T limit is moved upscale, the effect is to i increase time spent at low pressure during heatup/cooldown, and the time was ff ^
The calculated by dividing 100'F by 50'F/hr, a typical heatup rau Itatt. '[
J $
l j PML estimate of industry operating cost is based on an average power cost of (
S300,000 per EFP0 for all plants. Thus, for the 8 plants that are expected to be ratcheted 50-100*F an estimated delay of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per heatup, and 6 beatup/ 5l cooldown cycles per year, the cost will be $150,000 per year per plant for the i next 25 years. The 77 plants, including those undergoing licensing, %et are expected to be ratcheted 20-50'F per year are assumed to incur half that amount. ji
}
! The best estimate present value of these industry operating costs was given by f PNL as $101,000,000 and the not cost to the industry was $63,000,000. The l bottom line, best estimate, cost oer san-rem saved reported by PNL is "in the
$3,500-85.600 range." ,
i
- l i
1 11 REG ANAL RG 1.99 REV 2 I 08/22/85 i
?
1
! l
- 1 4.a.1.4 Costs to Industry - NRC Cogt Analysis Group. The NRC's Cost t Analysis Group (CAG) made a number of substantive comments about the September. l 1984 draf t of the PNL report and also did a complete recalculation of the indus- i try operating cost. (See Enclosures 7 and 8). In this work CAG used their own !
plant specific power costs as well as plant specific values of the extra heatup ;
time required as calculated by MEBR from the actual difference in P-T limits l' per Revision 2 relative to those per Revision 1. Their industry operating cost figure was $71,000,000. If this figure is substituted for the PNL figure of $101,000,000 in the PNL cost estimate, the not cost to industry (See Sec- ;
tion 4 of Enclosure 6) of $33,000,000 instead of the PNL figure of $63,000,000. ;
(Further reduction of this cost figure may be justified as discussed in para- l graph 4.a.1.6.) This use of the CAG cost estimate reduces the bottom line to j
$1,800-82,900 per san-ree-saved.
There is also a paper work cost to the industry when a Tech. Spec, chango ;
is prepared and submitted to the NRC. PNL's best estimate of this is $2270 per !
I plant--too small to enter into the cost benefit analysis, j i
4.a.1.5 Costs to Industry--Corrections Based on Comments Received ;
Durina Concurrence. The PNL estimate of 6 startup/ shutdowns per plant year j was questioned by the staff. It had been based on reactor scran data available I
to PNL. However, af ter a scram, The plant does not necessailly go to cald shut- i i
down. In the plant operating data given in NUREG-0020, shutdowns greater than [
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are tabulated for each month. Af ter correcting for the refueling shut- l down, which extends r ver several months, the average over a three year period, ;
1982-4 was 4.3 shutdowns greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per reactor year. Free an ORNL l analysis of plant operation for 1982, there were approximately 2.0 shutdowns ;
I per reactor year greater than 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />. Sased on these data, and assuming l that some of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> shutdowns wa' not cold shutdowns, it seems reasonable l to assume that there are no more *, o tr.: 2e startup/ shutdown operations per I
reactor year instead of six as asnr.Y b PNL. This correctior, redxes the bottom line to $900-1400 per san-ren haved.
Consideration has also been given to the estimate of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> extra heatup time, caused by the P-T lialts being moved upscale by 100'F. The PNL estimate j was based on staple division, assuming a heatup rate of 50'F per hour. The i 08/22/85 12 REG ANAL RG 1.99 REV 2 l
l rationale was that any restriction to the operating zone (see Figure 1) would require more care in heatup/cooldown and therefore take more time. From data located by R. R. Riggs, SPEB, in EPRI NP-1139, Vol. 2 for PWRs, the average i startup time from cold shutdown to hot standby conditions is 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. The )
average shutdown time, hot to cold, is 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. If it tntas 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> for an (
average startup/ shutdown operation (from cold shutdown to het standby and back) li it appears that 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is almost "lost in the noise." 'l i
There must be a number of operational factors that determine the critical 'l psth, and it la c'oubtful that the restriction in the operating zone is normally l
+ critical path itos considering the number of testing and operational proce- [
dures involved in a startup from cold shutdown. Moreover, the ratchet effect l of Revision 2 is at a maximum early in plant life when the operating zone has f Its g n atest breadth. In effect, adoption of Revition 2 will simply mean that i anticipated restrictions in the operating zone All occur Aconer than expected. [
Consequently, among the list of uncertainties to be itemized later, there is [
l the judgment that the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> figure, and the correpponding cost to industry of
$25,000 per startup/ shutdown, is probably an upper bound, and the lower bou A ,
is nearly zero. !;
5 Conservatism in the PNL analysis *, hat affects both cost and risk is the ,1 assumption that the ratchets shown in Table I are constant for the remainder I!
l of plant life. For the majority of those ratcheted 50-100'.*, this may be true, but for some plants the 'atchet steadily decreases and becomes a benefit as l early as mid-life of the plant. However, the risk re&ctions also diminish. }
lt has been assumed *. hat their ratio, the dollars per wan-ree "bottom line" l remains constant. Clearly, there is uncertainty in the assumption that the risks and the present value of the ists are thw same function of the ratchet.
l but it has been made for want of better infonnation. 'i fl 4.a.1.6 Boilina Water Reactors -- Special Contderations. Boiling I lLc
- t water reactors, four of which would be ratcheted 50-100'F according to Table 1 should probably be cattted from the calculation of both cost anc risk assor.iated I(
with heatup/cooldown operations, because saturation conditions govern the pres- l
. tre at any temperature even during transients if the vessel is not water solid. if This consideration would reduce the O3.000,000 industry cost estimate to abou*, f
$21,000,000, or about one-third of the original PNL cost estimate, f r
13 REG ANAL RG 1.99 REV 2 08/22/85 !
It is during hydrotests and leak tests that BWRs may be affected by Regula-tory Guide 1.99. The margins required for hydrotest are given by the ASHE Code ,
and Aprendix G, 10 CFR 50 just as they are for normal operation, except the factor of safety on pressure is 1.5 for hydrotest instead of 2.0. A number of BWHs are now at the level of radiation damage where the required metal tempera-ture at the hydrotest pressure is nearing 200*F. This causes two problems, according to verbal reports from some BWR owners representatives. Heatup with pump power apparently is slow in BWRs, compared to PWRs. Also, prolonged opera-tion of the pumps at '.ow pressure causes extra wear of the pump seals. In any case, it takes longer to get to the higher temperature.
I The other problem arises from a requirement in the Technical Specifications that the containment drywell be closed when water temperature approaches 212*F.
Inerting is not required for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more, so entry can be made for leak test inspections, but the time required is increased. Yet, the hydrotest temperature for PWRs exceeds 200'F in many cases: hence, the problem of inspect-ing for leaks must be manageable. These delays occur after refueling, normally about once every 18 months. Data from R. Riggs (EPRI NP 1136, Vol. 1) show the ;
mean time to conduct a hydrotest of a BWR 1s 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />, + ith a standard deviation of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Thus the impact (time / cost) on BWRs likely falls within the stand-ard deviation of the hydrotest time interval.
Risks incurred dteirg hydrotest are probably small. It is debatable whether or not the margin of 1.5 on pressure required by the Code, compared to a margin of 2.0 for normal operation, properly weighs the relative risks. However, any change in thase values involves an amendment to Appendix G,10 CFR 50 and is It is concluded that the BWR hydro-beyond the scope of negulatory Guide 3.99.
test situ 1 tion represents little change in the direction of cost per man-rem-saved ($900-$1400, as discussed in 4.a.1.5). The effect is undoubtedly plant specific because the conclusion depends on operational details involved in conducting hydrotests and leak tests.
After a number of Icw temperature 4.a.1.7 Effects on LTOP Limits.
overpressurizations occurred in the 1970's a requirement was placed on PWRs to provide automatic pressure relief at low temperatures that would prevent viola-tion of the pressure-temperature limits. Some plants accomplish this by enabling 14 REG ANAL RG 1.99 REV 7 08/22/85
l a low setpoint setting on the pressure operated relief valves (PORVs) when at I low temperatures. Others use the relief valves in the residual heat removal system (RHR) to provide this function.
For PWRs that would have the P-T limits moved up the temperature scale if the limits were based on Revision 2, the allowable pressure at the cold shut-down temperature, say 140*F for example, would be slightly reduced. The aosunt is small, because the P-7 limit curve in flet at --' temperatures, especially for vessels with a large radiation shif t. Unfu _..ately, the system constraints are tight. The reactor coolant pumps (RCP) used in Wettinghouse plants require ,
(
a pressure of about 325 psig minimum for proper function of the seals. ,
Typical settings of the PORV for LTOP prote'clion are 400-500 psig for temperatures up to about 350*F. This restriction on the operating zone probably accounts for most of the impact on startup time.
I f -
In his memorandum to B. D. Liaw, February 27, 1985 comenting on Revision 2,
- 8. J. Elliot wrote:
Thus, to begin heatup with these limitations, the reac-tor vessel is pressurized to approximately 350 psig us- ,
ing RHR and CVCS pumps prict to initiating flow through tne RCPs. The RCPs are the main source of heat prior to care critical operations. At temperaturos below 350'F, the reactor coolant pressure (RCP) %st be maintained below the LTOP pressure set-point of 400 psig, since .
actuation of the LTOP valves would depressurize the '
system and heatup would have to begin again. The LTOP set points for pressure and temperature are derived from the pressure-temperatura liuits. Henc<a, a charege tre the pressure-temperature lir.it requires an adjustment it, the LTOP set-points. The narrowing of the operating *'
band that results from RCP minimum pressurite and tho j LTOP set point, as plants age, has been rucognized as a problem by the staff and NSSS vendors,. NSSS vendors are reevalua*.ing critical component ifmitations and
' operating procedures to deters.ine whetherThe thestaff, low tem- in parature operating band may be widened.
a letter from B. W. Sheron to k. Minners dated August 1, [
l (
1984, has requested t. hat the LTOP criteria for operat-ing plants be prioritized as a new generic issue. l The last sentence in the quotation refers to another aspect of the LTOP !
issue. At Maine Yankee, the requirements for LTOP protection have been 15 REG ANAL RG 1.99 REV 2 08/22/85 i
I
broadened to mean there should be automatic protection for the P-T limits at high temperatures as well as low. Until recently, this was provided by the nonnal high setpoint on the PORVs, because the temperature at which the RHR system was isolated was higher than the P-T limit temperature at 2250 psig.
(See AEOD Engineering Evaluation Report No. E426, October 24, 1984, by E. V. Imbro).
Actually, Maine Yankee is not affected by Revisinn 2, because there are sufficient credible surveillance data. They show relatively large shift, however, and the P-T limits have been moved upscale so far that the operators elected to add a PORY setpoint at an intermediate pressure.
~
At present, the NRC does not require automatic protection of the P-T I limits at the higher temperatures. If dat becomes a requi.ement, Revision 2 may have some impact on this new aspect of LTOP requirements as well.
4.a.1.8 Costs to NRC. The immediate impact of proposed changes on NRC staff review time will be minimal, because we plan to implement Revision 2 for P-T limit calculations at the regularly scheduled times, as described in Section 6. However, the 3 year limit on implementation will crowd the calendar for review of P-1 limits somewhat.
4.a.1.9 gmaary of Uncertainties and Conclusions re: Application of, Revision 2 to P-T Limits. The conclusion reached by PNL - that the costs pe:-
man-rem were in the range $3500-5600 has been corrected based on more detailed power cost analysis by CAG (paragraph 4.a.1.4) Lad on data collected by the staff with regard to the number of cold shutdown por reactor year to yield a value of $900-1400 per man-rem. The following uncertainties have been identi-fled in this result the net effect of which is believed to reduce it signifi-cantly, but it has not been possible to further quantify the number.
The most important uncertainty is in the risk term. In paragraph 4.a.1.2 and Figure 1, it was shown that the principal safety function of P-T limits is to separate the operating zone far enough from the zone that is hazardous to vessel integrity to give time for corrective action to mitigate a transient.
16 REG ANAL RG 1.99 REV 2 08/22/85
4 Regulatory' Guide 1.99, being part of the bases for calculating P-T limits, affects the margin provided. For reasons given previously, it was not possible to quantify the risk avoided by a given correction to,the P-T Ifnits, but it is
- believed to be a larger source of risk than the one PNL was asked to evaluate. ,
The second most important uncertainty is in the cost ters. The principal l i
cost to industry is the cost of power not generated because of delays in startup/ shutdown operations caused by restrictions in the operating zone'if -
the P-T limits are moved upscale. The PNL estimate of two hours per startup
+
1 is believed to be high for most plants, as discussed in paragraph 4.a.1.5. ,
, e The narrowing of the operating zone resulting from adoption of Revision 2 in certain plants is not significant early in life when the operating zone is f broad. Moreover, it is no more severe than was expected to occur late in life.
I Finally, at higher fluences the "ratchet" disappear,s, because of differe'nces in the fluence functions given in Revisions 1 and 2. All of these uncertainties a
are in the direction of significantly reducing the PNL cost estimate.
4.a.2 Other Applications of Regulatory Guide 1.99 L:
must be calculated as part of Regulatory Guide 1.99 is used whenever RTNDT ,
F
' an analysis of a transient that has actually occurred. The analysis provides the basis for deciding if the possibility that the vessel has been damaged is ] '
sufficiently high to warrant an inspectiun before returning it to service.
j Such in6pections are tisia consussis,g and cost'y in terms of power replacement. i
+ k f
Another application of Regu~tatory Guide 1.99 is in t5e analysis of flaws
,r
., A recent example n found by irservice inspection nf the reactor vessel beltline. li occurred at Indian Point 2. First, the draft Revision 2 was used to calculate f'
l RT at the inside surface, based on the fluence and the weld end plate NOT chemistry. Second, because the flaw was near the uutside surface, the formula through the vessel wall, (a feature of Revision 2), f for attenuation of ARTNOT at the tip of the flaw. The evaluation is the ,f l vas Used to calculate ARTET basis for deciding if the vessel must be repaired before being put back in l service. ,I
, 'l
'! F II 17 REG ANAL RG 1.99 REV 2 ,l 08/22/85 't j l
~ . _ _ _ _ _ _ _
In evaluations of transients and flaws there may be significant safety questions the cost impact may be high, and contention over the decisions may surface. Clearly, it is important to have a basis for the calculation of radiation damage effects that has had public review and resolution of out-standing issues.
4.b. Impact On Other Requirements
- 4. b.1 Impact on the Pressurized Thermal Shock Rule i
o In the PTS rule FEDERAL REGISTER, July 23, 1985 there is a formula for I
calculating RTNDT (called RTPTS to distinguish that method from others), which :
is based on an early version of the formulas that are the basis for Revision 2.
There are several differences. For the calculation of RT PTS. (1) weld and base metal data were analyzed as one data base yleiding one correlation function, (2) the fluence function was of simpler form, and (3) there was a second equa-tion which gave bounding values.
It is not intended to change the proposed PTS Rule to incorporate the latest formula for RT NDT. (H te, however, the action recommended below.) The calcultatien of RT required by the PTS rule is associated with screening cri-NOT teria (270*F for base metal e.nd axial welds, 300'F for circaferential welds),
which were just.ified by r. probabilistic analysis that considered all identiff- ,
able uncertainties including those in the calculation of RTNDT. At tne time f the Rule was drafted, it was recognized that there would be an evolution in the l; calculative proceduros, but there could be too many actions taken by the utili- !! r s
'~
ties in the area of flux reduction programs and other measuras to permit fre-quent chtnges in the position of every plant relative to tre screening criteria.
However, when it appears that the screening criteria vill be exceeded at a .i specific plant, tte PTS Rule requires an evaluation of all aspects of the PTS analysis as they apply to that plant. That re-evaluation must include the l fracture toughness of the beltline material and thus RTNOT s411 be re-evaluated too. By that time, a number of plants will have credible surveillance data of their own. If not, and if Revision 2 of Regulatory Guide 1.99 were used, RTNOT i values would be higher for a few vessels having high-nickel welds but most would
! he slightly lower.
18 REG ANAL RG 1.99 REV 2 08/22/65
{ _ _
4 M the calculative procedures of Revision 2 were substituted for those of the PTS Rule, and H the present information about copper, nickel, and fluence i values is confirmed by the submittals required by paragraph (b) of Section 50.61 of the PTS Rule, it appears that eight plants would reach the screening cri-terion before EOL. Of the eight plants, four would reach the screening cri-terion in the years 1993 to 1996 and four in the year 2000 or later. Based on '
these findings, it is recommended that the copies of proposed Revision 2 sent to utilities and others be accompanied by a letter containing the following f
statement of the relationship of the proposed Guide to the PTS rule, The calculative procedures given in paragraph C.I.a of this draft Guide are not the same as those given in the Pressurized Thermal Shock rule
- for calculating RTPTS, the reference temperature that is to be compared to the screening criterion given in the rule. Issuance of Regulatory Guide 1.99, Revision 2 for public comment in no way affects the recently promulgated PTS ruiv. Licensees and the technical community are requested to comment on the technical merits of this proposal, including its offact on their plants for non - PTS purposes, chiefly as the basis for calcula-tion of pressure-temperature limits as required by Appendix G,10 CFR Part 50. Licensees may also consider and comment on the proposed change's effect on tr.a calcu'ated PTS risk at their plant, assuming the Revision 2 correlation, if juttified, would at some future time replace the RT .73 p c rreintion in the PTS rule. Following resolution of connents, and once general agreement is reached regarding the best way to calculate RTNOT' then it will be appropriate to re-evaluate the overall conservatism of the PTS rule.
4.b.2 Impact on Material Selection f
For plants in the very early construction phase before the reactor vessel '
materials have been ordered, for which the provisions of Position C.3 of the say have some Guide are applicable, the new procedure for calculating RTHDT ,
effect on the limit specified for copper content. (Position C.3 itself is
""Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events," Federal Reaf ster, July 23, 1985, pp. 29937-29945.
19 REG ANAL RG 1.99 REV 2 08/22/85
unchanged from Revision 1). However, sample calculations indicate that there should not be many instances of a negative effect, because they are made for I end-of-life fluences.
For plants for which the surveillance materials have not been selected, the changes from Revision 1 to Revision 2 may affect the decision as to which '
beltline materials will be controlling and therefore which weld and base metal should be represented in the surveillance capsules. However, because we are '
not changing this requirement, there should not be any extra cost involved.
4.c. Constraints We have r:ot identified any constraints such as scheduling or enforceabil-ity that affect the implementation of Revision 2.
- 5. DECISION RATIONALE Based on the foregoing analyses of the safety issues, system impacts and costs, it is recommended that Revision 2 be issued for public comment. The analysis has shown that the Guide is needed, because it providos part of the basis for ensuring safe operation of reactors during startup and shutdown and for the evaluation of transients and flaws found ir, service. Periodic updating of the Guide is consistent with the requirements of Appendix G,10 CFR Part 50.
Adoption of Revision 2 will rair,e the P-T limits for about half of the opr. rating reactors that new use Revir.fon 1 as the basis for these limits. In preparing the value/ impact analysir,, based on contract work by PNL, one source of avoided risk by going to Revision 2 was quantified. After making corrections based on staf f comments, the cost-benefit ratio was in the range $900-1400 per man-rem evolded. However, there is another, more significant source of risk which was not quantifiable. As discussed '1 Section 4.a.1.2, the principal safety impact of operating with lower P-T limits (i.e., continuing to use limits based on Revision 1) will occur during a transient, because the operator (a) will t
not have accurate information of the potential hazard to */essel ir<tegrity, and In paragraphs 4.a.1.4 and (b) will have less time to take corrective action.
4.a.1.5, reasons have been given to believe that the amount of replacement power, 20 REG ANAL RG L 99 REV 2 ,
08/22/85
, _ _ _ + - - - _ , , _ . - __, - - .
which is the principal cost impact of implementing Revision 2, will be lower for In summary, most plants than the values determined in the PNL cost estimates.
it is believed that the cost benefit ratio is in the range of a few hundred dollars per man-rom avoided. Because there is a significant safety benefit, and because it is cost effective, the implementation of Revision 2 is ',ecommended.
i-Finally, we believe that industry will be receptive to the proposed "trend curves," as they are commonly called. Based on industry response to presenta-1 tions to ASTM Committee E-10, the Metal Properties Council, and ASME Boiler Code Section XI working groups concerned with this subject, there appears to be general agreement on the need for new curves. At this time we know of no I'
serious objection to the calculative procedures g,iven in Revision 2. There may f be disagreerrents about the chemistry factor or fluence factor near the edges of the data base, where extrapolation is required, and about the margin to be added. We intend to push for adoption in ASTM Standard Guid: E900 as well as in Section XI of the ASME Boiler Code, but this will take at least a year or f longer. If implementation of Revision 2 is delayed, there will most likely be more negative ballots by those who expect to be impacted by the new trend curves.
There will continue to be a need for Regulatory Guide 1.99 to provide acceptable traatunt of the question of margin, the treatment of plant specific surveil-i lance data, and the calculation of attenuation of damage through the vessel waii. i ,
i In Revision 2, Further revision of Regulatory Guide 1.99 is to be expected.
Fosition C.1.b. and Figure 2, which presents a "trend curve" for the percent decrease in upper t,helf energy as a function of fluence and copper content, That needs to be upgraded whin tbs basis becomes ava#la'>1e in a year cr so.
l effort will not affect P-T limits and it will affect only relatively few Further Mjustrent of !'
plants--those having low upper shelt energy initially.
the calculative procedure for reference temperature may be indicated in a few l' years when more surveillance data have accumulated or when our understanding l'
of embrittlement mechanisms and the role of copper, nickel and other elements f l improves.
I I
21 REG ANAL RG 1.99 REV 2 08/22/85
- 6. IMPLEMENTATION Paragraph D.1. of the Implementation Section of Revision 2 reads much as it did for Revision 1, the key sentence being: "...the methods described in regulatory position C.1 and C.2 will be used in evaluating all predictions of radiation dar. age needed to implement General Design Criterion 31 or as called for in Appendices G and H to 10 CFR Part 50 submitted after the effective date of publication of the Guide." This means that plants will be allowed to con-tinue to follow the present schedule for updating their P-T limits, but only within a 3 year period. Paragraph D.2. requires all operating plants to review the limits within a 3 year period af ter the Guide becomes effective and to revise them if necessary. The decision to forego prompt implementation across the board is based on the existence of significant margins, as discussed in Section 2.a.1 and elsewhere in this analysis. In the staff's judgment, the risk of allowing some plants to operate three more years with present P-T limits ,
was justified by the reduced impact on the industry and the NRC achieved by i; not requiring a complete review of all P-T limits in a 6-12 month period. No l:
staff actions will be required to implement the Guide other than making sure I-that each facility gets a copy.
l'
- 7. OTHER JMPACTS l.
There are no other actions, systems or prior analyses known to need ,
reassessment as a result of publication of Revision 2.
This Guide does not add to the reporting or information collection require- I ments of licensees, nor does it affect small entities as defined in the Regula-tory Flexibility Act. .
f I
l 08/22/85 22 REG ANAL RG 1.99 REV 2
TABLE 1.
SUMMARY
OF THE CHANGES IN PRESSURE-TEMPERATURE LIMITS EXPECTE0 TO RESULT FROM A CHANGE FROM REVISION 1 TO REVISION 2 0F REGULATORY GUIDE 1.99
~~
Effect of Change Operating Reactors Plants Undergoing Licensina from Rev. I to Rev_. 2 PWR BWR Total PWR BWR Total Ratchet 50-100* 4* 4 8 Ratchet 20-50' 16 17 33 32 12 44
. No Change (120') 23 7 30 3 0 3 Benefit 20-50' 7 1 8 Benefit 50-100' 1 0 1 Benefit 100-150* 1 0 1 Totals 52 29 81 35 12 47
-
- Values in the table are number of plants.
i 9
08/22/85 23 REG ANAL RG 1.99 REV 2
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SUMMARY
OF PROPOSED REGULATORY GUIDE FOR CRGR REVIEW 0FFICE OF NUCLEAR REGULATORY RESEARCH DATE: AUGUST 27, 1985 RES TCF NO.: EE 405-4 RES PROGRAM MANAGER:
S. X. AGGARWAL Telephone: 44-37668 TITLE of Proposed Action:
Proposed Regulatory Guide 1.63, Revision 3, "Electric Penetration Assemblies in Containment Structures for Nuclear Power Plants" STATEMENT of the Pr@jy:
, Regulatory Guide 1.63 Rev. 2 endorses IEEE 317-1976, subject to seven exceptions. Since then the staff has worked with IEEE in the development of IEEE Std. 317=1983. By this action, the staff has evaluated the latest version of national standard in terms of its suitability for endorsement by regulatory guide.
Objective: The objective is to endorse a national consensus standard, and thereby provide licensees cod applicants with the NRC staff's positicq with regard to its use.
Consequences: Ti.is action is consistent with NRC policy of evaluating the latest versions of national standards 'in tenns of their suitability for endorsement by regulatory guides.
Decision Rationale:
The guide should '4e issued to inform licensees and applicart of the current staff position on IEf.E 317-1983 and to reduce staff effort during the licensing review r>rocess.
Implementation:
s The guide will apply to future nuclear power plants, ard to replacement equiopment in operating nuclear power plants.
h T-lC
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