ML20207G458
| ML20207G458 | |
| Person / Time | |
|---|---|
| Issue date: | 06/07/1999 |
| From: | Stewart Magruder NRC (Affiliation Not Assigned) |
| To: | Carpenter C NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9906110167 | |
| Download: ML20207G458 (8) | |
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j NUCLEAR REGULATORY COMMISSION WASHINGT*)N, D.C. 20665-0001 g
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June 7, 1999 MEMORANDUG TO: Cynthia A. Carpenter, Chief Generic issues, Environmental, Financial and Rulemaking Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation FROM:
Stewart L. Magruder, Project Manager EAM Generic issues, Environmental, Financial V
and Rulemaking Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF MAY 24,1999, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING GUIDANCE FOR UPDATING FINAL SAFETY ANALYSIS REPORTS AND DESIGN BASIS INFORMATION On May 24,1999, representatives of the Nuclear Energy Institute (NEI) and the industry design bases task force met with representatives of the Nuclear Regulatory Commission (NRC) at NRC's offices in Rockville, MD. The purposes of the meeting were to discuss (1) proposed changes to industry guidance on updating final safety analysis reports (FSARs) and (2) staff and industry views on guidance to promote a clearer understanding of design basis information as defined in 10 CFR 50.2. Attachment 1 provides a list of meeting attendees.
During the first part of the meeting the discussion focused on the FSAR update guidance as proposed by the industry in NEl 98-03. The staff noted that public comments had been received on the draft guide through which the staff proposed to endorse NEl 98-03. A summary of a public meeting held on May 11.1999, during which the comments were discussed, was published on May 19,1999. This summary contains proposed char.ges to NEl 98-03 and the staff's position on the changes. It was agreed during the May 24,1999, meeting that the changes agreed to by the staff would be incorporated into Revision 1 to NEl 98-03 and that i
Revision 1 will be submitted in June 1999. The staff also 1ounced that the regulatory guide (RG) endorsing NEl 98-03 wou.:d be RG 1.181. The NEl representatives next brief!y discussed their concern that the current enforcement guidance regarding FSAR updates (EGM 98-007) does not allow for prioritization schemes other than that used to rank structures, systems, and components (SSCs) for the maintenance rule. NEl noted that EGM 98-007 requires licensees to have complete and accurate UFSARs by March 2000 for those SSCs that are determined to be ' risk significant. The staff responded that by March 2000, enforcement discr., tion with respect to UFSAR content will have been in place for tnree-and -a-half years and that appears l
to be sufficient time to identify and correct important UFSAR discrepancies.
Y CONTACT: Stewart Magruder 301-415-3139 i
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l C. Carpenter June 7, 1999 i
The focus of the rest of the meeting was the definition of design bases. Since the last meeting on April 16,1999, the staff and NEl have exchanged letters. NEl sent a letter dated May 7,1999, summarizing their proposed guidance and the staff sent one dated May 14, l
1999, forwarding the final draft staff position and some specific examples.
The staff began by explaining how the examples were developed for the May 14,1999, letter.
A single handout was provided and is induded as Attachment 2. The handout prompted discussion of the scope and level of detail of design basis information. NEl emphasized that design basis information should be just the functions and bounding values ar.d not a description of how the functions are performed.
The following is a summary of the discussion regarding guidance on design basis information:
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NEl proposal in 5/7/99 letter " Functional requirements or controlling parameters for design established by regulations, technical specifications, license conditions, or orders."
Staff position in 5/14/99 letter- "all functions described in UFSAR, that are relied on to satisfy NRC regulatory requirements."
Agreement that there can be functions without associated value Main points of disagreement are treatment of non-safety systems and the importance of functions reviewed by the staff that are not tied directly to a requirement Level of detail Agreement that " function" includes condition or environment under which SSC must perform Agreement that detailed description of how functions will be performee is not part of design basis Disagreement on what level of detail is required
- discussion of functional design requirement vs. licensing basis requirement
- dccussion of when components are included - general agreement that they should be when necessary to show system meets regulatory requirement
- worked through staff examples from 5/14 letter and agreed on about half - generally followed guidance - NEl believes functions should be directly tied to regulatory requirement Disagreement on whether design bases changed for different generation plants (i.e., do
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early plants have less than later plants?)- NEl contendr 'at functions and bounding values don't change for a requirement and that the adder' 'aformation in later FSARs is supporting information and not design bases.
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C. Carpenter June 7,1999 Agreement that the level of detail is difficult to describe through guidance - examples are needed Implementation issues
- 50.71(e) updates - discussion of level of detail required and whether it should be the same for all plants
- 50.59 criterion viii-NEl emphasized that a small, well-defined scope of design basis information makes implementation easier
- design inspections - agreement that clear definition is important to inspectors and licensees when evaluating inspection findings l
Project No. 689 i
Attachments: As stated cc w/att: See next page 8
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i NRC/NEl MEETING ON DESIGN BASIS LIST OF ATTENDEES i
May 24,1999 NAME ORGANIZATION Tony Pietrangelo NEl Russ Bell NEl Ben George Southern Nuclear Ken Hutko PSE&G Mark Dooley NMPC George Wrobel RG&E Jack Smith VA Power Scott Newberry NRC/NRR Gary Holahan NRC/NRR David Fischer NRC/NRR Tom Scarbrough NRC/NRR Christopher Jackson NRC/NRR Gene Imbro NRC/NRR Dick Wessman NRC/NRR David Terao NRC/NRR James Tatum NRC/DR Joe Birmingham NRC/NRR l
Bill Reckley NRC/NRR
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Frank Akstulewicz NRC/NRR i
Eileen McKenna NRC/NRR Tom Bergman NRC/NRR Stewart Magruder NRC/NRR Susan Uttal NRC/OGC Mark Satorius NRC/OEDO Don Palmrose NUS-IS Jenny Weil McGraw-Hill l
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C. Carpenter June 7, 1999 Agreement that the level of detail is difficult to describe through guidance - examples are needed implementation issues
- 50.71(e) updates - discussion of level of detail required and whether it should be the same for all p! ants
- 50.59 criterion viii-NEl emphasized that a small, well-defined scope of design basis information makes implementation easier
- design inspections - agreement that clear definition is important to inspectors and licensees when evaluating inspection findings Project No. 689 Attachments: As stated ec w/att: See next page i
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DISTRIBUTION: See attached page l
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I Document Name: a:\\SLM1\\rnsum0524.wpd A i
j OFFICE PM:RGEB SC:RGEEj d )
NAME SMagrudef FAksthb
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DATE h7/99 h7/99 1
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1 Nuclear Energy Institute Project No. 689 cc:
Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute i
Nuclear Energy institute -
Suite 400 Suite 400 1776 I Street, NW 1776 l Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy lnstitute ABB-Combustion Engineering, Inc.
1 Suite 400 12300 Twinbrook Parkway, Suite 330 1776 i Street, NW Rockville, Maryland 20852 Washington, DC 20006-3708 i
Mr. David Modeen, Director Enginer. ring Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 i
Mr. Anthony Pietrangelo, Director Licensing Nuclear Energy Institute Suite 400 1776 I Street, NW l
Washington, DC 20006-3708 Mr. Nicholas J. Liparuto, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 o
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Distribution: Mtg. Summary w/ NEl Re Design Basis Dated g,mo 7, 1000 i
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