ML20211A085

Proposes That Ge/Nrc Conduct Workshop on Integrated Safety Analysis During Wk of 970929.Comments on Proposal & Suggested Agenda,Requested

ML20211A085
Person / Time
Site:	07001113
Issue date:	09/05/1997
From:	Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Reda R GENERAL ELECTRIC CO.
References
NUDOCS 9709240113
Download: ML20211A085 (5)

Text

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,T September 5,.1997 Dr. Ralph Reda Manager. Fuel and Facility Licenses General Electric Company

.P.O. Box 780. MC J26 Wilmington-NC 28402

SUBJECT:

INTEGRATED SAFETY ANALYSIS WORKSHOP

Dear Dr. Reda:

'As a followup to our conversations with Mr. Charles Vaughan of the General Electric Company (GE). I am proposing that we conduct the GE-Nuclear Regulatory Commission workshop on Integrated Safety Analysis (ISA) during the-week of September 29, 1997.

The idea for this workshop emerged in our May 1997-discussions 1.i p aration for renewing GE's fuel fabrication license in

-June 1997. As descr1 in the enclosed workshop proposal, the purpose of the workshop is to assess the methodology.'information. and results of an ISA for a portion of a fuel cycle facility and to identify how the ISAs can best be incorporated into NRC's regulatory process. The results of the workshop will

-be used by NRC in designing and implementing NRC's licensing program and in modifying the ongoing revisions to 10 CFR Part 70. as appropriate.

In addition consistent with Condition S-5 of GE's NRC-License No. SNM-1097. the

-workshop should substantially contribute to developing an acceptable outline for the ISA summary for GE's Dry Conversion Process.

To ensure maximum benefit-to-NRC and GE. I anticipate participating in the workshop along with six NRC technical specialists representing a range of interests, including radiation protection chemical safety. criticality safety, industrial safety. fire safety, risk analysis, and operations. With GE's agreement, we would plan to arrive at Wilmington in the early afternoon of September 29 and conduct the workshop-throughout the week. We would appreciate GE's comments on the proposal and suggested agenda for the workshop.

Please contact me at 301-415-7190 or Susan Chotoo at 301-415-8102 to discuss any questions or comments or plan the proposed workshop.

Sincerely.

Original si ned by:

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SF Division of Fuel Cycle Safety and Safeguards. NMSS DN-EW License LSNM-1097

Enclosure:

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September 5, 1997 Dr. Ralph Reda Manager, Fuel and Facility Licenses General Electric Company P.O. Box 780, MC J26 Wilmington, NC 28402

SUBJECT:

INTEGRATED SAFETY ANALYSIS WORKSHOP

Dear Dr. Reda:

As a followup to our conversations with Mr. Charles Vaughan of the General i

Electric Company (GE)

I am proposing that we conduct the GE-Nuclear Regulatory Commission workshop on Integrated Safety Analysis (ISA) during the week of September 29, 1997.

The idea for this workshop emerged in our May 1997 discussions in preparation for renewing GE's fuel fabrication license in June 1997. As described in the enclosed workshop proposal, the purpose of the workshop is to assess the methodology, information, and results of an ISA for a portion of a fuel cycle facility and to identify how the :SAs can best be

' incorporated into NRC's regulatory process.

The results of the workshop will be used by NRC in designing and implementing NRC's licensing program and in modifying the ongoing revisions to 10 CFR Part '0. as appropriate.

In addition, consistent with Condition S-5 of GE's NRC License SNM-1097, the workshop should substantially contribute to developing an acceptable outline for the ISA summary for GE's Dry Conversion Process.

To ensure maximum benefit to NRC and GE. I anticipate participating in the workshop along with six NRC technical specialists representing a range of interests, including radiation protection, chemical safety, criticality safety, industrial safety, fire safety, risk analysis, and operations. With GE's agreement, we would plan to arrive at Wilmington in the early afternoon-of September 29 and conduct the workshop throughout the week. We would appreciate GE's comments on the proposal and suggested agenda for the workshop.

Please contact me at 301-415-7190 or Susan Chotoo at 301-415-8102 to discuss any questions or comments or plan the proposed workshop.

Sincerely,

'S],'A k f W Hichael F. Weber. Chief Licensir.g Branch Division of Fuel Cycle Safety l

and Safeguards, NMSS Docket 70-1113 License SNM-1097

Enclosure:

As stated l

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t ISA Workshop Proposal August 28,1997 Purpose To assess the methodology, information, and results of an Integrated Safety Analysis (ISA) for a portion of a fuel cycle facility and identify how the performsnce and maintenance of an ISA and the ISA results can best be incorporated into the regulatory process.

13ackground in the early 1990s, NRC identified the need for fuel facilities to perform systeinatic safety analyses to provide a more objective, comprehensive, and robust basis for continued safe operation. These Integrated Safety Analyses (IS A) are the comerstone of revisions to NRC requirements in 10 CFR Part 70, as proposed by both the NRC staff and the nuclear industry. Since NRC's first proposals that nuclear fuel fabric stion facilities prepare IS As in 1995, most facilities have committed to prepare and document ISAs in some form for portions of their facilities. Early feedback from the licensees who have progressed with their ISAs is that the ISA process and results have been helpful not only in enhancing the safety of their operations, but also in improving the efliciency and economy of fuel fabrication and ancillary operations.

Although NRC and the industry have invested a considerable amount of effort in identifying the contents and suitable methodologies for ISAs, questions remain about how the performance and maintenance of an ISA and the IS A results can best be incorporated into NRC's licensing process under existing or potential future regulations. For example, NRC staff review of General Electric's ISA Summary for its Dry Conversion Process and Transitional facility identified deficiencies in the level of detail ofinformation included in the ISA summary. This spawned a series of questions such as hcw much information needs to be submitted to NRC as part of the license docket, what will NRC do with this information, and how should licensee commitments based on the ISA be included in the license.

In May 1997, GE representatives discussed these questions with the NRC staffin an open meeting and identified complications and challenges associated with providing NRC more information about the IS As. They illustrated their concerns by showing the NRC staff a small sampling ofISA results and explored the difficulties they foresaw if NRC attempted to include commitments in the license based on the IS A for the Dry Conversion Process and Transitional Facility. GE and NRC agreed to work together to further refine the ISA process in the licensing context, with the objective to identify how the perfe mance and maintenance of an ISA and the ISA results can best be incorporated into the licensing process after renewal of GE's license.

Statement of Work In an attempt to fulfill this objective, an interdisciplinary team of NRC specialists will participate with GE staffin a four-day workshop at the GE-Wilmington facility during September 29-October 3,1997. The scope of the workshop will be limited to the ISA for 2 or 3 select

b i-2 subsystems or " nodes" of the Dy Conversion Process and Transitional Facility. The nodes should be selected to represent a range in terms of safety risks to illustrate the range of assurance and confidence required for systems, controls, and compenents that have different levels of safety signifance.

The workshop will consist of the following components:

A description by GE of the ISA process, capabilities of the IS A team, methodologies used for accident analysis, accident sequences analyzed, and key assumptions for the analysis.

This would also include a description of the analytical method used to define and communicate risk levels associated with specific postulated accident sequences.

Process line walk downs for select nodes under review to familiarize the NRC staff participants with the systems under review.

Summay by GE of the IS A results, identification of safety significant controls for select nodes, and description about how the identified risk levels are used to establish design criteria for equipment and management controls (QA, maintenance, requirements, training, configuration management, etc.) necessary to provide adequate assurance that the controls will be available to respond on demand.

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Discussion by NRC and GE staff about alternative approaches for incorporating the IS A results as part of the regulatory program. This discussion willinclude consideration of how the results could be incorporated into the license, what information needs to be included in the docket, how NRC plans to independently review the information, how could NRC best inspect adherence to licensee commitments based on the ISA, and problems and limitations with the alternative methods.

The workshop would be punctuated by periodic caucuses by the NRC staff alone and the GE staff alone. Observation, conclusions, and proposals made during the workshop would not be binding on either party, The meeting will not be open to public observation due to the need to candidly discuss proprietary information used by GE as part ofits IS A. NRC will, however, make a general summary of the workshop available to interested members of the public.

Product The product of the workshop tyruld be a brief point paper to be prepared by the NRC staff that will identify and assess the alternative approaches for incorporating IS A results in the regulatory process and recommendations, if appropriate, on how this could best be achieved. The approaches should address:

-(1)

Acceptance criteria for IS As (to be included in a Standard Review Plan),

(2)

Linkage between IS As and other safety assessments (radiation protection, nuclear

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- criticality safety, fire protection, industrial. safety, chemical and environmental protection),'._

(3)

Risk criteria (consequence and likelihood of occurrence), and (4);

Documentation of the ISA as part of the licensing file.

This point paper will be considered in designing and implemeating NRC's ongoing licensing program,'and modifying the ongoing revisions to 10 CFR Part 70, as appropriate. NRC st_aff will use the point paper as a starting point for discussion with the fuel fabrication industry on how ISA results can best be incorporated into the licensing process. In addition, NRC staff will use the point paper in modifying, as necessary, the acceptance criteria for ISAs in~ the revised Starulard

Review Planfor a License Applicationfor a Fuel Cycle Facility, NUREG-1520 (SRP).' NRC will also use the point paper in developing and modifying graded review criteria in other safety areas, such as radiation safety, criticality _ safety, chemical safety, and fire safety. NRC licensing l

staff will incorporate these' graded review criteria into the SRP. The SRP will be modified and prepared in conjunction with the Part 70 rulemaking.

The point paper will be completed within 30 days of the conclusion of the workshop and provided to the Director of FCSS. Although the point paper will be a public document, it will not contain any information deemed proprietary by GE.

Resources The NRC team will consist of 6 reviewers representing different interests, including radiation

' protection,- chemical safety, criticality safety, fire safety, risk analysis, and operations. The NRC

- team will have both licensing and inspection experience. It will be managed by the Chief of the Licensing Branch.-

NRC staff time involved in the workshop includes the following:

Planning and preparations = 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> (0.03 FTE)

Onsite workshop =

224 hours0.00259 days <br />0.0622 hours <br />3.703704e-4 weeks <br />8.5232e-5 months <br /> (0.17 FTE)

Report orenaration =

60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> (0.04 EIE)

Total =

324 hours0.00375 days <br />0.09 hours <br />5.357143e-4 weeks <br />1.23282e-4 months <br /> (0.24 FTE; about $40K)

Travel expenses for the workshop are as follows:

7 staffx $800/ person = $5600 -

- Because this effort is directed at generic development of NRC's regulatory program, none of the -

i staff hours or travel costs will be charged directly to GE for specific licensing work.

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