ML20206S367
| ML20206S367 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1998 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-3116, SECY-97-205-C, NUDOCS 9905210105 | |
| Download: ML20206S367 (6) | |
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b ADVISORY COMMITTEE OS REACTOR SAFEGUARDS MEETING OF THE SUBCOMMITTEE ON PLANT OPERATIONS j
MEETING MINUTES - JUNE 19,1998 I
ROCKVILLE, MARYLAND INTRODUCTION j
The ACRS Subcommittee on Plant Operations met on June 19,1998, at 11545 Rockville Pike, Rockville, MD, in Room T-2B3. The purpose of this meeting was to discuss proposed changes to 10 CFR 50.59 (Changes, Tests and Experiments), status 4
of resolution of issues identified in the March 24,1998 Staff Requirements Memorandum related to SECY-97-205," Integration and Evaluation of Results from Recent Lessons-Learned Reviews," and related matters.
The entire meeting was open to public attendance. Mr. Michael T. Markley was the cognizant ACRS staff engineer for this meeting. The meeting was convened at 8:30 a.m. and adjoumed at 12:07 p.m.
ATTENDEES ACRS Members J. Barton, Chairman D. Powers, Member G. Apostolakis, Member R. Seale, Member M. Fontana, Member R. Uhrig, Member D. Miller, Member M. Markley, ACRS Staff Princioal NRC Seeakers E. McKenna, NRR*
T. Bergman, NRR T. Essig, NRR S. Magruder, NRR D
PrincioalIndustrv Seeakers g
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T. Pietrangelo, NEl*
oa m ' q R. Bell, NEl f4 D NRR Office of Nuclear Reactor Regulation NEl Nuclear Energy Institute There were approximately 3 members of the public in attendance at this meeting. A complete list of attendees is in the ACRS Office File, and will be made available upon request. The presentation slides and handouts used during the meeting are attached to the office copy of these minutes.
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6/19/98 Minutes OPENING REMARKS BY THE SUBCOMMITTEE CHAIRMAN Mr. Barton convened the meeting at 8:30 a.m. He stated that the purpose of this meeting was to discuss proposed changes to 10 CFR 50.59 (Changes, Tests and Experiments), status of resolution of issues identified in the March 24,1998 Staff Requirements Memorandum (SRM) related to SECY-97-205," integration and Evaluation of Results from Recent Lessons-Leamed Reviews," and related matters.
He staied that the Committee was disappointed with the staff's response to the SRM and suggested that some Members were frustrated with the staff resolution of what appeared not to be a major industry problem. Mr. Bar:on offered the Subcommittee's l
assistance in coming to closure on these matters.
1 Mr. Barton stated that the Subcommittee had received no wntten comments or requests l
for time to make oral statements from members of the public.
DISCUSSION OF AGENDA ITEMS NRC Staff Presentation l
Ms. Eileen McKenna, NRR, led the discussion for the NRC staff. Messrs. Thomas l
Essig, Thomas Bergman, and Stu Magruder, NRR, provided supporting discussion.
The staff discussed the history of rule for 10 CFR 50.59 and associated guidance, the decisionmaking process, and key issues related to proposed improvements. Significant l
points made during the discussion include:
The 10 CFR 50.59 decisionmaking process leads to the determination of the need for NRC review of proposed changes to the facility.
Key issues include:
Definition of change to the facility as described in the Final Safety i
i Analysis Report (FSAR) including possible changes to the design-basis and safety analyses.
L Guidance on the definition of " minimal" with respect to possible increases in probability and consequences.
Consideration of safety margins including the bases for any Technical Specification and associated definitions of margins.
Definition, formatting, and possible deletion of the term Unreviewed Safety Question (USQ).
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6/19/98 Minute,s -
Reporting and record keeping requirements including language in 10 CFR 50.71(e) regarding the " effects of" and " cumulative effects."
Backfit analysis and information collection requirements.
Options for evaluating the definition of " minimal" include:
Use of examples to demonstrate allowable increases in probability.
Options for consideration of increases in consequences including a fixed value approach (either percent or dose) and a graduated approach.
Industry Presentation Messrs. Tony Pietrangelo and Russell Bell of the Nuclear Energy institute (NEI)
. provided a brief discussion of industry views regarding proposed changes to 10 CFR 50.59. Significant points made during the discussion include:
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The NRC should expedite the rulemaking to clarify USQ criteria.
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1 The NRC should reassess the use of acceptance limits to provide long-term I
l stability to the rule. NEl supports the use of 10 CFR Part 100 as a safety l
threshold for increases in consequences or acceptance limits. NEl expressed concem regarding how the staff might define " minimal" with respect to l
consequences. The staff and Commissioners expressed concem over this l
approach as being too high a threshold.
l The NRC should consider changing the scope of the rule. NEl would propose to decouple the linkage between the FSAR and 10 CFR 50.59, define the scope directly in the rule, and focus on the safety analysis as the appropriate change.
i Potential benefits of a revised 10 CFR 50.5g process include: fewer evaluations l
with little or no safety /reguistory value, improved consistency between the rule and implementation, and resolution of concems over small versus big FSARs.
i SUBCOMMITTEE COMMENTS. CONCERNS. AND RECOMMENDATIONS Dr. Apostolakis questioned which part of the rule had not been applied properly. The staff stated that the main problem area was related to USQs as applied to increases in probability and consequences.
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6/19/98 Minutes Dr. Seale questioned why the staff had not come to closure on endorsing industry guidance (NSAC-125 or NEl 96-07). The staff stated that they had exchanged several letters with NEl regarding the subject documents but had not met to discuss these matters since January 1998.- The staff added that, in some cases, implementation of the industry guidance would lead to unacceptable solutions (e.g., increases in consequences). The staff stated that the Regulatory Guide was not yet available for ACRS review.
Drs. Seale and Uhrig questioned the resources involved in performing 10 CFR 50.59 safety evaluations. The staff stated that, on average, licensees expend 27 hours3.125e-4 days <br />0.0075 hours <br />4.464286e-5 weeks <br />1.02735e-5 months <br /> per safety evaluation. Dr. Seale questioned whether the changes proposed by the staff would result in additional review time for what appears to be a limited safety benefit.
The staff stated that licensees realize resource benefits from not performing license amendments.
Dr. Apostolakis questioned the stafs comments about the quality of licensee PRAs. '
Ho expressed the view that this matter was addressci during the ACRS' review of Regulatory Guide 1.174 and Standard Review Plan (SRP) Chapter 19 (General Guidance). He stated that the current 10 CFR 50.59 process requires a lot of judgement and that PRA adds structure to the judgement process. He expressed concem over the staff's apparent decision not to consider PRA in the decisionmaking process. The staff stated that a risk-informed approach was considered in the Commission paper SECY-97-205. Dr. Seale stated that most changes made under 10 CFR 50.59 do not contribute significantly to risk and are not reflected in PRAs.
Dr. Apostolakis questioned what the major issue was related to Final Safety Analysis Reports (FSARs). NEl representatives stated that it was the scope of what is conta:ned in FSARs. They added that there is a lot of variation from site to site and suggested that the FSAR may not be the best way to define the screening criteria for 10 CFR 50.59.
Dr. Apostolakis questioned the staff's views of minimal increases in risk and safety margins. He also questioned how cumulative effects would be tracked, if not quantified.
The staff stated they were not prepared to discuss safety margins and noted that their view on allowing minimal increases in risk was provided in the May 27,1998 memorandum, to the Commission. The staff stated that the numbers could be applied but suggested that examples would be better. Dr. Apostolakis stated that it would not be worthwhile to spend a lot of time fighting over small definitions of risk and suggested that the Individual Plant Examinations (IPEs) be used to perform qualitative assessments using the minimal cut sets.
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Plant Operations Subcommittee 5
6/19/98 Minutes At the conclusion of the meeting, Mr. Barton stated that this matter would be discussed during the July 8-10,1998 meeting. He stated that the Committee expects to prepare a report to the Commission and requested the staff to discuss its response to the SRM and its plans for developing a regulatory guide which endorses industry guidance with appropriate exceptions and clarifications.
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STAFF AND INDUSTRY COMMITMENTS None.
l SUBCOMMITTEE DECISIONS j
None.
FOLLOW-UP ACTIONS None.
BACKGROUND MATERIALS PROVIDED TO THE SUBCOMMITTEE PRIOR TO THIS MEETING i
1.
Subcommittee agenda.
2.
Subcommittee status report.
3.
Staff Requirements Memorandum dated March 24,1998, regarding SECY 205.
4.
Letter dated April 16,1998, from Ralph E. Beedle, Nuclear Energy Institute, to Shirley Ann Jackson, Chairman, NRC,
Subject:
10 CFR 50.59 Safety l
Evaluations and 50.71(e) FSAR Updates.
5.
Letter dated May 12,1998, from Samuel J. Collins, Director, NRR, to Ralph E.
Beedle, Nuclear Energy institute,
Subject:
10 CFR 50.59 Safety Evaluations and 50.71(e) Final Safety Analysis Report Updates.
6.
Letter dated January 9,1998, Samuel J. Collins, Director, NRR, to Ralph E.
Beedle, Nuclear Energy Institute,
Subject:
NEl 96-07 Guidelines for 10 CFR 50.59 Safety Evaluations.
7.
Report dated December 12,1998, from R.E. Seale, Chairman, ACRS, to Shirley Ann Jackson, Chairman, NRC,
Subject:
Proposed Revisions to 10 CFR 50.59 (Changes, Tests and Experiments).
8.
Report dated October 9,1998, from R.E. Seale, Chairman, ACRS, to Shirley Ann Jackson, Chairman, NRC,
Subject:
Proposed Changes to 10 CFR 50.59 and Proposed Revision to Generic Letter 91-18.
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6/19/98 Minute,s i
9.
Report dated April 8,1997, from R.E. Seale, Chairman, ACRS, to Shirley Ann Jackson, Chairman, NRC,
Subject:
Proposed Regulatory Guidance Related to l
Implementation of 10 CFR 50.59 (Changes, Tests and Experiments).
L 10.
Memorandum dated May 27,1998, from L. Joseph Callan, EDO, NRC, to the Commissioners,
Subject:
Evaluation of Rulemaking Language Proposals Concerning 10 CFR 50.59 (Changes, Tests and Experiments).
l 11.
Memorandum dated May 21,1998, from David C. Matthews, NRR, to John T.
Larkins, ACRS,
Subject:
Proposed Rulemaking on 10 CFR 50.59.
12.
Transcript for June 4,1998 Commission briefing, on UFSARs and 10 CFR 50.59.
Naia: Additional details of this meeting can be obtained from a transcript of this meeting available in the NRC Public Document Room,2120 L Street, N.W.
Washington, D.C. 20006, (202) 634-3274, or can be purchased from Ann Riley &
Associates, Ltd., (Court Reporters and Transcribers) 1250 i Street, NW, Suite 300, Washington, D.C. Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 842-0034.
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