ML20211L468
| ML20211L468 | |
| Person / Time | |
|---|---|
| Issue date: | 09/03/1999 |
| From: | Mckenna E NRC (Affiliation Not Assigned) |
| To: | Carpenter C NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9909080249 | |
| Download: ML20211L468 (8) | |
Text
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,j NUCLEAR REGULATORY COMMISSION C
WASHINGTON, D.C. 20555-0001
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September 3, 1999 i
MEMORANDUM TO: Cynthia A. Carpenter, Chief Generic issues, Environmental, Financial and Rulemaking Branch i
Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation FROM:
Eileen M. McKenna, Senior Reactor Engineer Akk Generic issues, Environmental, Financial N
and Rulemaking Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF SEPTEMBER 2,1999, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) RELATED STRAWMAN DRAFT REVISION TO NEl 96-07 ON IMPLEMENTATION OF 10 CFR 50.59 On September 2,1999, a public meeting was held at the NEl offices in Washington DC, between members of the Nuclear Energy Institute (NEI) and Nuclear Regulatory Commission (NRC) staff. Attachment 1 lists attendees at the meeting.
On August 19,1999, NEl submitted a preliminary draft of NEl 96-07, Revision 1, in order to obtain early feedback on the proposed document before it was circulated more broadly within the industry and within NRC for formal agency review and comment. The guidance document i
would be used by the industry to implement the revised requirements of 10 CFR 50.59.
The staff noted that the document as submitted by NEl was comprehensive, with clear examples, and reflected well on the efforts of the task force who put together a quality product.
The staff cautioned that the document had not been sent to all those within NRC who will need to review the document; thus, silence at this stage on particular parts of the guidance should not be construed as endorsement. Some specific questions and areas of discussion were k
identified and discussed during the meeting (see attachment 2).
I For many of the items, NEl and the task force members stated that they planned to make 40 clarifications to NEl 96-07 Revision 1. NEl also noted that there were a few items that were still
" fluid" and which therefore may result in revisions when the draft revision is submitted in September, in a few areas, NRC noted that further discussion would be needed to address possible concerns, such as the example for a methodology approved by NRC for one plant being usec es the basis for another licensee using that methodology under 50.59.
The group also discussed plans for guidance for implementation of section 72.48 (this section has rule language comparable to section 50.59, applicable to spent fuel storage cask licensees and certificate holders). While there was agreement that the general guidance and concepts in NEl 96-07 would be applicable for section 72.48, it was also agreed that some adjustments, or other examples, would make it more useful to those users. The staff outlined its plans for NN hk[N 1
RC pwa c
C., Carpenter September 3, 1999 developing a regulatory guidance for 72.48 (see attachment 3). There was some discussion as to whether the guidance document, and/or the RG should be totally separate from those for 50.59, but no decision was reached. Also discussed was possible plans for a workshop for Part 72 licensees and certificate holders, whether part of a currently planned NEl workshop on 50.59, or as a separate activity. NEl indicated that they planned to prepare some examples for Part 72 in time for the January workshop.
The group also discussed a number of topics related to implementation of the revision to 50.59. For instance, NEl stated that there was interest in discussing possible gradations of the licensee review processes that are applied to 650.59 evaluations, such that not every 50.59 evaluation would necessarily need to be reviewed by the plant onsite review committee.
Depending upon the plant requirements, this would be a revision to the quality assurance clan or to TS. The staff stated that NRC was amenable to discussing proposals that might be offered that would apply the review process commensurate with significance. Anothe topic concerned past NRC documents that might contain varying interpretations or positions on 650.59, and whether NRC planned to go back to those documents and review their continued applicability. The staff stated that it planned instead to rely on the (to be revised) inspection guidance, contained in Part 9900 of the inspection manual, as being the governing source of information. The staff further noted that this guidance would be finalized in parallel with the regulatory guide, such that to the extent possible, the inspection guidance could refer to the RG (or industry guidance document).
The topics of training, and the transition from the existing rule to the revised rule were also discussed. The staff noted its plans to provide training to its staff, following preparation of the RG and inspection guidance. The possibility of cross-fertilization between NRC and licensees during such training activities was discussed. For instance, NEl suggested that certain training or discussion materials might be used in common. The issues on " transition" relate to how a licensee moves from the existing requirements to the revised requirements on the effective date of the rule. The staff noted that since in almost all respects the existing rule requirements are more restrictive, a licensee using its procedures based upon existing requirements would reach conservative decisions (relative to the revised rule requirements) on the need for NRC review.
Both the staff and the industry agreed that this was a topic that needed further discussion.
Finally, the group discussed plans for a future meeting following submittal of the revised NEl 96-07. The next draft will be circulated within NRC (and through the industry) for review. A meeting in the first half of October would provide the opportunity for the staff to discuss any concerns with the document and for the document preparers to explain their proposals.
Attachments: As stated cc w/atts: See next page
0 C., Carpenter September 3, 1999 developing a regulatory guidance for 972.48 (see attachment 3). There was some discussion as to whether the guidance document, and/or the RG should be totally separate from those for 50.59, but no decision was reached. Also discussed was possible plans for a workshop for Part 72 licensees and certificate holders, whether part of a currently planned NEl workshop on
$50.59, or as a separate activity. NEl indicated that they planned to prepare some examples for Part 72 in time for the January workshop.
The group also discussed a number of topics related to implementation of the revision to 50.59. For instance, NEl stated that there was interest in discussing possible gradations of the licensee review processes that are applied to 50.59 evaluations, such that not every
@50.59 evaluation would necessarily need to be reviewed by the plant onsite review committee.
Depending upon the plant requirements, this would be a revision to the quality assurance plan or to TS. The staff stated that NRC was amenable to discussing proposals that might be offered that would apply the review process commensurate with significance. Another topic concerned past NRC documents that might contain varying interpretations or positions on
$50.59, and whether NRC planned to go back to those documents and review their continued aaplicability. The staff stated that it planned instead to rely on the (to be revised) inspection geidance, contained in Part 9900 of the inspection manual, as being the governing source of information. The staff further noted that this guidance would be finalized in parallel with the regulatory guide, such that to the extent possible, the inspection guidance could refer to the RG (or industry guidance document).
The topics of training, and the transition from the existing rule to the revised rule were a!so discussed. The staff noted its plans to provide training to its staff, following preparation of the RG and inspection guidance. The possibility of cross-fertilization between NRC and licensees during such training activities was discussed. For instance, NEl suggested that certain training or discussion materials might be used in common. The issues on " transition" relate to how a licensee moves from the existing requirements to the revised requirements on the effective date of the rule. The staff noted that since in almost all respects the existing rule requirements are more restrictive, a licensee using its procedures based upon existing requirements would reach conservative decisions (relative to the revised rule requirements) on the need for NRC review.
Both the staff and the industry agreed that this was a topic that needed further discussion.
Finally, the group discussed plans for a future meeting following submittal of the revised NEl 96-07. The next draft will be circulated within NRC (and through the industry) for review. A meeting in the first half of October would provide the opportunity for the staff to discuss any concerns with the document and for the document preparers to explain their proposals.
Attachments: As stated cc w/atts: See next page DISTRIBUTION: See attached page Document Name: g:\\rgebiemm\\msum0900.wpd OFFICE PM:PjhEp;DftlP SQ:Rkm NAME EMcKin$$[s\\
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DATE 9/8/99 9/ h/99 OFFICIAL OFFICE COPY
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NRC/NEl MEETING ON DRAFT REVISION TO NEl 96-07 LIST OF ATTENDEES September 2,1999 NAME ORGANIZATION Eileen McKenna NRR/ DRIP /RGEB Frank Akstulewicz NRR/ DRIP /RGEB Patricia Eng NMSS/SFPO Phil Brochman NMSS/SFPO Tony Pietrangelo NEl Russell Bell NEl Alan Nelson NEl Everett Whitaker TVA Scott Bauer APS Pete LeBlond LeBlond and Associates Ted Schiffley Comed Kenneth Hutko PSE&G Donald Ferraro Winston and Strawn Jenny Weil McGraw Hill Nancy Chapman SERCH/Bechtel Joe Hegner Virginia Power Bob Newkirk Detoit Edison Jim Kilpatrick Baltimore Gas & Electric Rosemary Reeves NUS-IS
e COMMENTS AND DISCUSSION ITEMS (e'ditorial comments noted if identified, however, a comprehensive review was not conducted).
Section 1.2 Commitment Management - endorsement is a projection Section 1.4 Part 72.48 - clarify intentions with respect to guidance / examples Section 3.2 Accidents - external events. See discussion in section 4.3.1 ebout malfunctions - is there a need for further discussion about the relationship between accidents and malfunctions for such items as external hazards?
Section 3.3 (Discussion), and elsewhere - what is meant by " intended safety function" as compared to " intended function"? (intended design function in section 3.12).
Section 3.2 Temporary modifications " connected to installed equipment"- what about in the vicinity of?
Section 3.12 - pending rulemaking on 50.67may add to the list (may be something to revise later)
Section 3.12 circa p.26 " minor corrections"- may want to provide additional examples of what fits and what doesn't - should provide explanation of both " minor" and " corrections" Section 3.12 same place " corrections ; hat preceded receipt of license" and Note - discuss intent and how this would be used Section 4.2 p. 26 Test or experiment - second half of definition?
)
Section 4.3.1 footnote - needs correction (either change "110" or " increase")
Section 4.3.2 Malfunction "at system level"- see also following sentence and 4.3.6 - need to clarify the guidance about FMEA and at what level it needs to be applied Section 4.3.2 malfunction factor of 2 - staff needs to consider further Section 4.3.3 " increase above the licensing limit" - what is the meaning here?
Section 4.3.8 not a departure "do not change fundamental assumptions..."- should also confirm through some means that the change does not have a " noticeable" effect on results (see also 3.4 "not important with respect to demonstrations...")
Section 4.3.8 Example 4 - plant specific approval - staff needs to consider further Appendix A - when FR notice is out, confirm that rule text is consistent (e.g. 50.59(e))
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Project No. 689 cc:
Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President?
Plant Support and Chief Nuclear Officer.
Nuclear Energy institute Nuclear Energy institute Suite 400-Suite 400 -
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Distribution: Mtg. Summary w/ NEl Re Strawman Revision to NEl 96-07 Dated Sept. 3,1999 ard Coov Docket File
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