ML20206F165
| ML20206F165 | |
| Person / Time | |
|---|---|
| Issue date: | 04/29/1999 |
| From: | Jerome Murphy Committee To Review Generic Requirements |
| To: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20206F150 | List: |
| References | |
| NUDOCS 9905060015 | |
| Download: ML20206F165 (4) | |
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Apn!29.1999 MEMORANDUM TO.
William J. Travers Executive Director for Operations 7-FROM:
Joseph A. Murphy, Chairman
,Qf'/f' Committee to Review Generic Re ire ents
SUBJECT:
PROPOSED AMENDMENTS TO THE MAINTENANCE RULE -
10 CFR 50.65 The Committee to Review Genenc Requirements (CRGR) met on Tuesday, Apnl 27,1999, from 9:00 a.m. to 12:30 p.m. At this meeting, the staff presented for CRGR review and endorsement the draft final amendments to the Maintenance Rule (10 CFR 50.65). Pending issuance of the final meeting minutes, the purpose of this memorandum is to inform you of the issues raised by the Cornmittee.
While CRGR had several comments, we believe they can be resolved by the staff without change in the wording of the proposed amendments to the rule which we reviewed. However, the Regulatory Analysis does need to be modified before the proposed amendments to 10 CFR 50.65 are enacted. Although we had no objection to sending forward the version which the Committee had reviewed at the meeting, it is our understanding that the rule package may have been revised since then, and we have not seen the later draft. The Attachment contains details of the Committee's comments and recommendations on the version which we reviewed at the CRGR meeting.
As always, I am available to discuss this matter further,
Attachment:
As stated cc:
F. Miraglia M. Knapp J. Johnson, Ril B. Sheron M. Virgilio M. Federline J. Moore B. Boger ATTACHMENT 3 9905060015 990430 PDR COMMS NRCC CORRESPONDENCE PDR J
, y, CRGR Comments and Recommendations On Draft Final Amendments to 10 CFR 50.65 (CRGR Meeting No. 340. Apnl 27,1999) 1.
The staff did not seek CRGR endorsement of the revised draft Regulatory Guide (RG) 1.60. However, without reviewing this guide and the associated inspection guidance, the Committee remains concemed about understanding the impacts associated with implementation of this rule, and the potential for inconsistent decisions on the part of the licensees and NRC inspectors regarding unacceptable configurations.
Because the detailis in the guidance document, including the scope of the SSCs, CRGR requested the opportunity to review the revised RG 1.60 and the inspection guidance before final issuance.
2.
As presented, the staff has not provided a defensible rationale for a " substantial increase"in safety The Committee is especially concerned that the staff did not provide a quantitative safety case. Previous examples have shown that poor configuration control can have a dramatic effect on the instantaneous core damage frequency. The Committee recommends that the staff develop a quantitative cost benefit analysis supplemented by a qualitative analysis, if necessary. For the latter, the Committee recommends that the staff consider using one or more of the nine factors included in," Guidance on Application of the ' Substantial increase Standard'," of the CRGR Charter, Revision 6.
3.
The accompanying regulatory analysis needs to be better organized, especially the discussion related to voluntary actions implemented by the licensees. The Committee recommended that the staff should weigh merits and demerits of each alternative being considered, both with and without the voluntary actions, make arguments in favor of or against each alternative, and, on the bases of these arguments, justify the selection.
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4.
In the context of assessing the impact of Alternative 2 (Section 3.2.1 of the Regulatory Analysis, page 6, top sentence), the Committee cautioned the staff that sole reliance on plant's Technical Specifications (TS) must be discouraged. Using the TS information may be necessary, out it may not be sufficient for adequately assessing the impact of an SSC being out of service under particular circumstances; e.g., the station blackout emergency diesel generator, which may not be included in the TS, 5.
In the same Section of the Regulatory Analysis (page 7), the cost estimates included for pre-maintenance assessments, and also those for both using and maintaining the methodologies, need to be better explained. Furthermore, these analyses need to be clear with respect to what it would cost a licensee to develop and implement the risk management process. CRGR also stressed the importance of ensuring consistency of various' assumptions used in the pre-maintenance assessments with those used in other key analyses. The Committee further recommended that the staff should address the inherent uncertainties.
ATTACHMENT l
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The wording used in the last sentence of the thud paragraph of Section 3 2.2 of the Regulatory Analysis (page 8) suggests adequate protection However, the staff indicated that it was not the intent, The Committee recommends that this sentence should be truncated by deleting the latter part of the sentence as follows:
"It is this risk avoidance feature of this alternative (Alternative 2] that provides a significant safety benefit over Alternative 1. endpovtderthe-protechofHe the publio4teef th-endenfetydhaHheNRGerequtred to-ntaintain!
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