ML20210R673
| ML20210R673 | |
| Person / Time | |
|---|---|
| Issue date: | 08/13/1999 |
| From: | Stewart Magruder NRC (Affiliation Not Assigned) |
| To: | Carpenter C NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9908170185 | |
| Download: ML20210R673 (9) | |
Text
-
l
(
e rugk UNITED STATES g
- g j
NUCLEAR REGULATORY COMMISSION.
t WASHINGTON, D.C. 20086-0001
{
...s August 13, 1999 MEMORANDUM 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 J M A.r Generic issues, Environmental, Financial and Rulemaking Branch' Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JULY 28,1999, MEETING WITH THE PUBLIC TO DISCUSS EFFORTS TO RISK-INFORM 10 CFR PART 50 (RIP 50)
On July 28,1999, the staff held a public meeting at the NRC's offices in Rockville, Maryland. At the beginning of the meeting, the staff notified attendees that the meeting would be an open l
forum on the subject of risk-informed Part 50, and that participation was encouraged from all present. Attachment 1 provides a list of attendees at the meeting.
.The staff opened by stating that the goal of the meeting was to discuss issues related to risk-l informing the scope of structures, systems, and components (SSCs) subject to special treatment under Part 50 (Option 2 from SECY-98-300.) Specifically, the staff stated that they were l
interested in learning more about the status of the industry pilot plants, risk-informing 10 CFR l
~
50.59, and selective implementation of prop? sed changes to Part 50.
' Representatives of the Nuclear Energy Institute (NEI) began their discussion by noting that they planned to discuss their draft guidance document and to cover the topics mentioned by the staff.
They also noted that the industry was very interested in what the staff was thinking about the treatment of SSCs that are not currently within regulatory scope but that would be under i
proposed changes. The NEl representatives also reminded the staff that the industry is working on a phased approach to risk-informing Part 50. The first phase is the oversight process and the second phase involves the scope of SSCs.
The industry representatives next asked the staff whether the South Texas pilot submittal had been helpful. The staff replied that it was useful in determining what rules might need
- exemptions and that the staff was trying to design the first phase of the proposed rule changes so that they could be implemented without exemptions.
The group next discussed the treatment of SSCs that would no longer be within the scope of regulatory control under the proposed changes, it was agreed that current industry practices for
'(\\ \\
9908170185 990813 PDR ORC NRRA JJ PDR M
hh Il em e
se
W C. Carpenter August 13, 1999 treatment of commercial grade SSCs would be applied to them. The staff noted that this equipment would fall into two categories; those that the industry would need to maintain for commercial reasons, and those that they wouldn't. The NEl representatives committed to research this issue and to make a presentation on it at the next public meeting. Also, the staff committed to provide at the next meeting a more complete discussion of the treatment of non-safety related SSCs that would become in scope due to their safety-significance.
10 CFR 50.59 The group discussed what effect risk-informing the scope of SSCs under Part 50 would have on 50.59. The staff suggested that the scope of SSCs subject to 50.59 may not have to be changed, even if some SSCs are reclassified as not risk-significant, since the purpose of 50.59 is to preserve the licensing basis. The group next discussed whether reclassifying SSCs should require a license amendment or whether it could be done under 50.59. NEl committed to review this with the task force and report back during the next public meeting.
Pilot Plants in response to a question from the staff, the industry stated that they expect that the pilots will be more developmentalin nature than tests of the new rule language. The industry expects that the pilot plants will explore what rules need to be changed and that all four plants will probably request exemptions. The group agreed that the goal of the pilot process should be to ensure that the process is applicable to all plants and that all the pilot plants follow the same guidelines.
The staff asked the representatives of the three pilot plants that have not yet submitted exemption requests to provide a status summary. The representative from Fermi stated that they were planning to request an exemption from the maintenance rule and were in the process of cost-benefit analyses to determine whether other rules would b6 Mduded in their request.
The representative from San Onofre stated that, as of now, they were only planning to request an exemption to the maintenance rule. The representative from Arkansas Nuclear One stated that tney were not sure yet what their request would include.
Selective Implementation The NEl representatives stated that their guidance will suggest that each licensee should implement each risk-informed rule fully. That is, all SSCs will be treated appropriately and ne systems will be excluded.
Other issues in response to questions from the staff, the NEl representatives stated that they were not prepared to discuss the impact of risk-informing the m6intenance rule on license renewal. They also stateo that they believe that the definition of " basic component" in 10 CFR 21 may have to be changed to be consistent with the changes in Part 50.
l C. Carpenter August 13, 1999 l
NEl Presentation The NEl representatives presented a preliminary overview of their guidance document. The NEl handouts are included as Attachment 2. The presentation began with a discussion of a draft definition of " safety significant SSCs" that could replace the definition of safety-related in Part 50.
The NEl representatives noted that further clarification of the meaning of some of the terms such
)
as " minimal contribution" and " events" would still be required but that their guidance would make it clear that beyond des lgn basis events should be evaluated. They also noted that the draft definition would allow for qualitative evaluations and that the guidance was modeled on Regulatory Guide 1.174. The group discussed all the slides and agreed that the "high" and " low" ranking on the last slide should be changed to " safety significant" and "non-safety significant."
The staff concluded the meeting by noting that a workshop to solicit input from the industry on more significant changes to Part 50 (Option 3) will be held in Rockville, Maryland on September 15,1999. The group also agreed to schedule another meeting on Option 2 issues in 3-4 weeks.
Attachments: As stated
- ).cc w/atts: See next page h
e
C. Carpenter August 13, 1999 NEl Presentation The NEl representatives presented a preliminary overview of their guidance document. The NEl handouts are included as Attachment 2. The presentation began with a discussion of a draft definition of " safety significant SSCs" that could replace the definition of safety-related in Part 50.
The NEl representatives noted that further clarification of the meaning of some of the terms such as " minimal contribution" and " events" would still be required but that their guidance would make it clear that beyond design basis events should be evaluated. They also noted that the draft definition would allow for qualitative evaluations and that the guidance was modeled on Regulatory Guide 1.174. The group discussed all the slides and agreed that the "high" and " low" ranking on the last slide should be changed to " safety significa'nt" and "non-safety significant."
The staff concluded the meeting by noting that a workshop to solicit input from the industry on 1
more significant changes to Part 50 (Option 3) will be held in Rockville, Maryland on I
September 15,1999. The group also agreed to schedule another meeting on Option 2 issues in 3-4 weeks.
Attachments: As stated
/cc w/atts: See next page DISTRIBUTION:
Hard Copv
/PUBLIC RGEB R/F OGC ACRS SMagruder TBergman EMail SCollins/RZimmerman BSheron WKane GHolahan TCollins JStrosnider RWessman GTracy, EDO DMatthews SNewberry CCarpenter FAkstulewicz MMarkley, ACRS DFischer JWilliams Treed CGrimes AMarkley RYoung GParry MCheok KHeck PBalmain MRubin RPalla JKnox RAuluck GBagchi MShuaibi EWeiss NGilles GMizuno, OGC TKing, RES MDrouin, RES TWolf, RES PKadambi, RES RWoods, RES SMays, RES HHamzehee, RES G:\\RGEB\\simi\\msum0728.wpd OFFICE RGEB RGEB SC:RGEB NAME SMagruderd$iNv TBe $
FAkstulewik DATE 08/ G/99 08/(3 /99 08/ ni39 OFFICIAL RECORD COPY
i RIP 50 PUBLIC MEETING July 28,1999 List of Attendees NAME ORGANIZ?TlON Adrian Heymer NEl Biff Bradley NEl Lynne Neal NEl Jim Meyer Scientech i
Jim Chapman Scientech Bill Burchill Commonwealth Edison Linda Bugoci Detroit Edison Richard Harris Entergy Parviz Moleni Southern California Edison Bob Christie Performance Technology Glen S7 South Texas Project Joe Williams NRC/NRR Tim Reed NRC/NRR Tom Bergman NRC/NRR Chris Grimes NRC/NRR Anthony Markley NRC/NRR Ronald Young NRC/NRR Gareth Parry NRC/NRR Mike Cheok NRC/NRR Ken Heck NRC/NRR Peter Balmain NRC/NRR Mark Rubin NRC/NRR John Knox NRC/NRR Bob Palla NRC/NRR Raj Auluck NRC/NRR Goutam Bagchi NRC/NRR Nanette Gilles NRC/NRR Gary Holahan NRC/NRR Dick Wessman NRC/NRR Stu Magruder NRC/NRR Frank Akstulewicz NRC/NP,R Eileen McKenna NRC/NRR Eric Weiss NRC/NRR Cindi Carpenter NRC/NRR Tom King NRC/RES Mary Drouin NRC/RES Tom Wolf NRC/RES Prasad Kadambi NRC/RES Roy Woods NRC/RES I
Steven Mays NRC/RES Hossein Hamzehee NRC/RES Mike Markley NRC/ACRS 1
Rosemary Reeves NUS-IS Yue Guan ASTM, Inc.
i l
1 4
]
DRAFT Safety-Significant Definition Safety Sigmyicant structures, systems and components (SSCs) are those SSCs whose performance has more than a minimal contribution to the overall probability and consequences of events that impact public health and safety I
'1F' ATTACHMENT 2 i
)
Draft Overall Approach for Categorizing Safety-Significant SSCs Safety Related & ITS SSCs V
Identify Safety-Significant SSC!
IN Safety Related & ITS SCOPE y
Identify / Justify at gorhation of OUT OF +
- " Y~ " "'"
SCOPE Other SSC Category V
i Identify Nonsafety-Related SSCs as safety-Significant SSCs
> IN SCOPE P-
Draft improved Safety-Focused SSC Scope Nonsafety-ITS Related SSCs
\\
' g g xxxxx Other SSCs lllllllllllllllllll3 Safety-Related SSCs kh % \\NN Safety-Significant SSCs l
Draft Preliminary Approach to Safety Significant Categorization Component System Risk Role Evaluation If if Operating CLB Experience Structured
{
Review if Periodic Overall Feedback Ranking A
If If High Low t
Cumulative Risk Check lf Implementation QEI