ML20216E021
| ML20216E021 | |
| Person / Time | |
|---|---|
| Issue date: | 07/28/1999 |
| From: | Stewart Magruder NRC (Affiliation Not Assigned) |
| To: | Carpenter C NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9908020026 | |
| Download: ML20216E021 (10) | |
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% UNITED STATES
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2 NUCLEAR REGUI.ATORY COMMISSION WASHINGTON P 20566-0001
% s ,o So. 28, 1999 MEMORANDUM TO: Cynthia A. Carpenter, Chief l Generic issues, Environmental, Financial and Rulemaking Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation FROM: Stewart L. Magruder, Project Manager M A-Generic issues, Environmental, Financial and Rulemaking Branch Division of Regulatory improvement Programs :
Office of Nuclear Reactor Regulation !
SUBJECT:
SUMMARY
OF JULY 22,1999, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING GUIDANCE FOR 10 CFR i 50.59 RULE AND FOR DESIGN BASIS INFORMATION On July 22,1999, representatives of the Nuclear Energy Institute (NEI) met with the staff of the Nuclear Regulatory Commission (NRC) at the NRC's offices in Rockville, Maryland. Attachment i
1 provides a list of attendees. i The meeting was held to discuss two topics. First was the schedule and proposed content for a revision to NEl 96-07, guidance for implementation of 10 CFR 50.59. The staff provided a schedule of milestones from now through completion of the final regulatory guide (Attachment 2). Dates for submittal of draft and final versions of the NEl guidance, as reflected
. in the schedule, had been provided by NEl to the staff so that the consolidated schedule could be included. NEl then distributed an outline of the proposed revision to NEl 96-07 (Attachment 3). The staff distributed a list of topics for consideration for inclusion (or for enhancement of existing guidance), as shown in Attachment 4. The staff noted that the schedule reflects guidance for Part 50 facilities, and that further discussion is needed concerning guidance for Part 72 facilities.
Following this discussion, the group then discussed the topic of design ' basis information, and in particular, the staff comments presented in a July 19,1999, letter to NEl, concerning their June 25,1999, submittal of a draft revision to Appendix B of NEl 97-04. }
Much of the discussion focused upon the general criteria as provided by NEl and the alternative .
formulation offered by NRC in its May 14,1999, letter (also reflected in the 7/19 letter). The
. group discussed the intended meaning of " established by regulations, license conditions and Ob orders", and " relied upon to satisfy NRC regulatory requirements." The NRC was trying to determine how specifically or directly the functional requirement must be for this criterion to apply, and the industry representatives were concerned that " relied upon" was too vague.
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C. Carpenter July 28,1999 The group also discussed other issues, for instance, that normal operations can be a condition from which design bases functions or values arise, as for instance, for fuel meeting specified acceptable design limits under normal operations (GDC 10). The staff further noted that some regulations specify that particular SSC be designed to permit inspection and/or testing, and that these would be design bases functions. NEl stated that they agreed with inspectability and testability but did not agree that quality standards (and fabrication or construction standards) were design bases.
In summary, NEl agreed to make certain changes to their draft document, reflecting discussions at the meeting, and to provide the document to the staff in mid-August. The areas they are pursuing include clarification of the two general criteria referring to functions and values respectively, and the wording about how they should be determined; addition of " normal operations" to the set of conditions under which design bases functions must be performed; and inclusion as " design bases" of inspectability and testability requirements from the regulations (e.g., GDC.)
NEl agreed to provide to NRC examples of the most "significant" SSC that does not have a "50.2 design bases" under their proposed criteria. The NRC agreed that not all functions in the UFSAR are design bases functions and that it needs to better define its threshold of " functions relied upon to meet requirements." The consensus of the group was that another meeting should be set up for late August or early September and that the overall schedule should be revised to allow for additional discussions before a draft regulatory guide is published by the staff.
Project No. 689 Attachments: As stated cc w/att: See next page
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C. Carpenter -2 July 28,1999 The group also discussed other issues, for instance, that normal operations can be a condition from which design bases functions or values arise, as for instance, for fuel meeting specified acceptable design limits under normal operations (GDC 10). The staff further noted that some regulations specify that particular SSC be designed to permit inspection and/or testing, and that these would be design bases functions. NEl stated that they agreed with inspectability and testability but did not agree that quality standards (and fabrication or construction standards) were design bases.
In summary, NEl agreed to make certain changes to their draft document, reflecting
' discussions at the meeting, ar'd to provide the document to the staff in mid-August. The areas they are pursuing include clarification of the two general criteria referring to functions and values respectively, and the wording about how they should be determined; addition of " normal operations" to the set of conditions under which design bases functions must be performed; and inclusion as " design bases" of inspectability and testability requirements from the regulations (e.g., GDC.)
i NEl agreed to provide to NRC examples of the most "significant" SSC that does not have a "50.2 design bases" under their proposed criteria. The NRC agreed that not all functions in the !
UFSAR are design bases functions and that it needs to better define its threshold of " functions relied upon to meet requirements." The consensus of the group was that another meeting should be set up for late August or early September and that the overall schedule should be revised to allow for additional discussions before a draft regulatory guide is published by the Staff.
Project No. 689 Attachments: As stated cc w/att: See next page DISTRIBUTION: See attached page -
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OFFICE RGEB RGEB SC:Rhh NAME SMagruder:s@ EMcKenna
- FAkhic"z DATE 07/31/99- 07/ 71/99 07/Af/99 l
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NEl/NRC 50.59 AND DESIGN BASIS INFORMATION GUIDANCE MEETING i July 22,1999 List of Attendees NAME ORGANIZATION Tony Pietrangelo NEl Russ Bell NEl Gary Holahan NRC/NRR Dick Wessman NRC/NRR Stu Magruder NRC/NRR Frank Akstulewicz NRC/NRR Eileen McKenna NRC/NRR Gene Imbro NRC/NRR Dave Fischer NRC/NRR Eric Weiss NRC/NRR Bill Reckley NRC/NRR Cindi Carpenter NRC/NRR
, Mike Markley NRC/ACRS Phil Brochman NRC/SFPO John Laffrey Niagara Mohawk Ken Hutko PSE&G Ben George Southern Nuclear Nancy Chapman SERCH/Bechtel Roger Huston Licensing Support Services Rosemary Reeves NUS-IS George Wrobel RG&E Jack Smith Dominion Generation i
Attachment 1 Y . .
REGULATORY GUIDANCE CONSOLIDATED SCHEDULE 7/14/99 (10 CFR 50.59 Revisions)
, Meeting with NEl to discuss NEl 96-07 schedule and content ' July 22,1999 NEl provides preliminary draft NEl 96-07 to NRC August 19,1999 Meeting with NRC to discuss comments September 2,1999 Draft Rev.1 of NEl 96-07 submitted for staff review September 17,1999 (review includes OGC, regions, NRR, SFPO)
NRC conducts of NEl 96-07; meeting to discuss . October [ ] 1999 open issues NEl submits revised NEl 96-07 for NRC endorsement November 17,1999 NRC performs review of guidance for acceptability November 1999 Meeting to discuss any remaining issues on NEl 96-07 December (6] 1999 (if needed) 4
. Final draft of NEl 96-07 submitted (if needed) December {20] 1999 Publish draft RG for public comment (60 days) January (10] 2000 End of comment period March [9] 2000 NEl submits final version of NEl 96-07 April [3] 2000
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Prepare final RG, send to review committees April [20] 2000 !
I Complete CRGR and ACRS review May [16] 2000 Forward final RG to Commission for approval May 30,2000 Commission approves final RG June 30,2000 Licensee implementation (effective date is 90 days after RG) September 30,2000 DISCUSSION POINTS:
Possible workshop for licensees and NRC - best timing?
Guidance for other than power reactors.
. Posting on web of information (per SRM)
Attachment 2
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Outline for Revision 1 of NEI 96-07, Guidelines for 10 CFR 50.59 Evaluations Global considerations l
. Eliminate references to USQ & safety evaluation
. New Section 4 to include guidance from existing Sections 3 and 4; 1 (updated as needed). New Section 3 to focus on definitions. I
. Liberal use of examples to illustrate common changes and special cases
. Consider NRC comments of Jan. 9,1998
- i. Foreword (New) identifying intent of 1999 rule changes l
ii. Contents 1.0 Introduction 2.0 Defense-in-Depth Philosophy 3.0 Definitions 3.1.10 CFR 50.59 Evaluation 3.8. Input parameters 3.2. Accident Previously Evaluated 3.9. Malfunction of an SSC ITS 3.3. Change 3.10. Method of evaluation 3.4. Departure from a method 3.11. Procedures as described 3.5. Design Bases 3.12. Safety Analyses 3.6. Facility as described 3.13. Screening 3.7. FSAR (as updated) 3.14. Test or Experiments not described 4.0 Implementation Guidance
-4.1 Applicability 4.2 Screening 4.2.1 Screening Process 4.2.2 Screening Documentation 4.2.3 Screening of tests and experiments 4.2.4 Screening of changes to facility and procedures 4.2.5 Screening of changes to methods of evaluation Attachment 3
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l 4.3 Evaluation Process 4.3.1 Frequency of accidents 4.3.5 Accidents of a different type 4.3.2 Likelihood of malfunctions 4.3.6 Malfunctions with different result 4.3.3 Consequences of accidents 4.3.7 Integrity of fission product barriers 4.3.4 Consequences of 4.3.8 Methods of Evaluation malfunctions -
5.0 Documertation and Reporting l l
l Ap~pendix A - Revised rule language l
Appendix B - History rf 10 CFR 50.59 '
Appendix C - Relationship Of Engineering, Quality Assurance And 10 CFR 50.59 In The Design Change Process Attachment A - Worksheets
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GUIDANCE TOPIC AREAS OR ISSUES Screening of changes definitions of facility, procedure, tests determination as to whether CTE affects functions etc.
' Change j '
interdependent changes l relationship to maintenance rule l
equivalent components "de facto" changes l Minimal increase for accidents and malfunctions
! guidance and examples l
l Minimal increase in consequences l guidance re 10% of difference and SRP values
^ccidents previously evaluated - provide a (representative) list l
l Design _ basis limits for fission product barriers implementation process barriers / limits for other than operating power reactors Methods of evaluation distinction between inputs and methods
! elements of a method essentially the same generic approval understanding of design bases and safety analyses Supplemental guidance or specific examples '
Part 72 facilities Decommissioning facilities License renewal TLAA or aging management Attachment 4
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 Nuclear Energy Institute Suite 400 Suite 400 1776 l Street, NW
- 1776 i Street, NW _ ,
Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineedng, Inc.
Suite 400 12300 Twinbrook Parkway, Suite 330 >
1776 l Street, NW Rockville, Maryland 20852
' Washington, DC 20006-3708 Mr. David Modeen, Director Engineering .
Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Licensing Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Jim Davis, Director Operations Nuclear Energy institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 e
l l
Distribution: Mtg. Summary w/ NEl on Guidance for 10 CFR 50.59 and on Design Basis Information Dated July 28. 1999 Hard Coov v4'UBLIC RGEB R/F OGC ACRS SMagruder EMcKenna EMail SCollins/RZimmerman BSheron WKane GHolahan TCollins JStrosnider RWessman
' GTracy, EDO DMatthews SNewberry ,
CCarpenter I
FAkstulewicz MMarkley, ACRS '
- Phil Brochman, SFPO ,
DFischer WReckley EWeiss Elmbro JBirminghan PWen l
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