ML20217Q933
| ML20217Q933 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 04/16/1998 |
| From: | Gaskin C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Weber M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9805130031 | |
| Download: ML20217Q933 (5) | |
Text
76-//67 p#
4 UNITED STATES
{,
j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666-0001 49.....,o MEMORANDUM TO: Michael F. Weber, Chief Licensing Branch, Division of Fuel Cycle Safety and Safeguards THRU:
Mary T. Adams, Section Chief p6 Et/
Licensing Section 1 FROM:
Charles E. Gaskin 6( [
Licensing Project Manager Licensing Section 1
~
SUBJECT:
MEETING
SUMMARY
- WESTINGHOUSE MANAGEMENT MEETING-LICENSING AND TECHNICAL REVIEWS - January 9,1998 Members of U.S. Nuclear Regulatory Commission's (NRC's) Fuel Cycle Safety and Safeguards Division and Region ll Division of Nuclear Material Safety met with representatives of the l
Westinghouse Electric Company's (WEC) Columbia Fuel Fabrication Facility. Attendees at this meeting are listed in the attachment to this memorandum.
The following items were diccussed at the meeting and are listed along with discussion summaries for each item:
NRC request for additional information relating to CSA/CSE summary submittal (reference: NRC letter-November 25,1997).
Discussion summary - WEC pointed out that the November 25,1997, request for information (RAI) was asking for information beyond that anticipated when the WEC license was renewed in 1995. It was WEC's understanding that detailed information would be gathered during NRC staff site visits, thus precluding the necessity to provide detailed process descriptions in the Criticality Safety Evaluations and Criticality Safety Analyses (CSEs and CSAs). WEC also expressed concern that providing two sets of information, one proprietary and one non-proprietary, was also unnecessarily burdensome, and a non proprietary version would not be meaningful.
As a result of the discussion, NRC agreed that no licensee response to the November 25,1997, RAI was necessary at this time, and that NRC technical reviewers would visit the site late in January to review the available information and determine whether WEC would need to submit additional information. NRC committed to provide a letter to WEC advising them not to respond to the November 25,1997, RAI.
(Subsequent to the January 9,1998, meeting, NRC staff visited the site to review the CSEs and CSAs during the week of January 26,1998. In addition, NRC advised WEC b
k
!I51 4
c eon m a u a m eagy j
2 via letter dated January 28,1998, there was no need to respond to the November 25, 1997, RAI because the initial technical review would be conducted onsite during the week of January 26,1998.)
Following CFFF shutdown for a safety significant process upset, what are the conditions of compliance required before restart?
Discussion summary - WEC discussed their understanding of the safety upset and the associated assumptions. WEC stated that both administrative and equipment analysis must be completed before restart and that restart can be initiated once they (WEC) conclude that analysis. WEC perceived they had a different approach than that expected by the NRC. WEC also stated that the root cause analycis does not necessarily need to be completed before restart. WEC stated they believe the NRC requires a formal analysis while WEC considers the analysis to be in the nature of a performance procedure.
NRC staff related to WEC that the August 1997 process upset was outside the approved safety analysis and had be reviewed by NRC before restart. NRC stated that it was not acceptable for a licensee to proceed to operate the process knowing they are operating outside of the approved safety analysis and in violation with the license. Conformance with the license conditions is required. It was also pointed out that NRC could provide a confirmatory action letter (CAL) to address identified and justified compensatory and corrective actions. WEC proposed that if they established that there is no safety problem, but they were not fully in compliance with the license commitments, that restart could be initiated. NRC stated that WEC must remain in compliance or obtain other i
NRC approval. WEC asked about verbal agreements regarding compliance versus revising documentation. It was pointed out that pen and ink changes to procedures would be okay if reviewed and approved in accordance with licensee proc.1dures and followed up formally, it was also discussed that a confirmatory action letter could be generated quickly.
WEC stated they would review how their license deals with procen upsets, would assure the process for reviewing upset conditions and making temporary changes is stated in the license, and would submit a license amendment application if necessary.
CFFF and NRC have differing expectations for communications and notifications, including initiation of timing trigger points for notification.
Discussion summary - WEC stated that their understanding of the start time for i
notification to NRC after a safety event has occurred appeared to differ from NRC's expectations. They expressed concerns about the potential perception that WEC does not feel that notification of the NRC is important. WEC committed to reconsider its communication procedures to ensure their clarity and effectiveness.
3 Szfs op ration and safsty cignificance of procacs upsets relats, in part, to o*
defense in depth. CFFF and NRC seem to disagree on the defiriition of, and controls to accomplish, double contingency protection for nuclear criticality safety.
Discussion summary - WEC expressed concerns that double contingency protection was not defined clearly enough, and that they and NRC seemed to disagree on the definition and controls associated with double contingency protection. WEC was q
unclear if it was a notification problem related to NRC Bulletin 91-01 or a definition problem associated with double contingency. NRC pointed out that double contingency protection provides a high level of protection that requires analysis and identified measures and procedures. While NRC agreed that other controls for a particular process may be relied upon, controls must be identified, analyzed, and maintained if they are to be relied upon as a part of double contingency protection. The analysis needs to clearly define the safety envelope for the process.
WEC advised they would determine what additional controls they would like to identify, analyze them, and get back to NRC with any proposed changes.
Performance-based license and inspections were intended, but traditional prescriptive-based inspections continue.
WEC expressed a perception that although they had moved toward a performance-based license, a prescriptive-based inspection process was still being implemented by the NRC. NRC noted that full compliance with the safety and regulatory requirements was expected. The staff further noted that inspection activities are normally focused on the areas of highest or dominant safety risk at each facility. However, the inspection program will review selected areas to ensure that all program commitments have been effectively implemented under the existing NRC program. Additional inspection effort would also be provided in response to operating events to ensure that an adequate level of safety has been reestablished after events and adequate corrective actions taken to prevent recurrence. WEC acknowledged that they have seen risk-informed, performance-based NRC inspections in the MC&A area.
CFFF proposes to revise SNM-1107, Chapter 6, " Nuclear Criticality Safety," for improved consistency and needs participative NRC review and approval Discussion summary - WEC indicated they were going to propose revisions to Chapter 6 of the license to incorporate items currently under review. NRC advised that it would review the proposed revision as soon as NRC received the submittals. It was understood that the revised Chapter 6 would replace some submittals currently under review and that those items would be simultaneously withdrawn.
Attachment:
As stated Distribut:on %DCLN % - l 15 f NRC File Center PUBLIC FCSS R/F NMSS R/F FCLB R/F WSchwink. FCOB DCollins. Ril EMcAlpine, Ril CHughey, Ril GHurnphrey, Ril FWenslawski, wc Fo
(
RIVPHiland.Rlli CPederson,Rlli RScarano, RIV wtead,,a, W c.
[gTwecsum2.wpd] *See previous concurrence OFC FCLB FCLB FCLB FCOB FCSS j /
FCLB
_ f NAME CGaskin*
PShea' Madams
- PTrg*
EWBrach MWeber DATE 02/ /98 02/ /98 02/ /98 02/ /98 04/[d98 h/th 04h98 C = COVER E m COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY
l 9
3 Safe operation and safety significance of process upsets relate, in part, to defense in depth. CFFF and NRC seem to disagree on the definition of, and controls to accomplish, double contingency protection for nuclear criticality safety.
Discussion summary - WEC expressed concerns that double contingency protection was not defined clearly enough, and that they and NRC seemed to disagree on the definition and controls associated with doubi s contingency protection. WEC was unclear if it was a notification problem related to NRC Bulletin 91-01 or a definition problem associated with double contingency. NRC pointed out that double contingency protection provides a high level of protection that requires analysis and identified measures and procedures. While NRC agreed that other controls for a particular process inay be relied upon, controls must be identified, analyzed, and maintained if they are to be relied upon as a part of double contingency protection. The analysis needs to clearly define the safety envelope for the process.
WEC advised they would determine what additional controls they would like to identify, analyze them, and get back to NRC with any proposed changes, Performance-based license and inspections were intended, but traditional e
prescriptive-based inspections continue.
WEC expressed a perception that although they had moved toward a performance-based license, a prescriptive-based inspection process was still being implemented by the NRC. NRC noted that full compliance with the safety and regulatory requirements was expected. The staff further noted that inspection activities are normally focused on the areas of highest or dominant safety risk at each facility. However, the inspection program will review selected areas to ensure that all program commitments have been effectively implemented under the existing NRC program. Additional inspection effort would also be provided in response to operating events to ensure that an adequate level of safety has been reestablished after events and adequate corrective actions taken to prevent recurrence. WEC acknowledged that they have seen risk-informed, performance-based NRC inspections in the MC&A area.
CFFF proposes to revise SNM-1107, Chapter 6, " Nuclear Criticality Safety," for improved consistency and needs participative NRC review and approval Discussion summary - WEC indicated they were going to propose revisions to Chapter 6 of the license to incorporate items currently under review. NRC advised that it would review the proposed revision as soon as NRC received the submittals. It was understood that the revised Chapter 6 would replace some submittals currently under review and that those items would be simultaneously withdrawn.
Attachment:
As stated Docket 70-1151 License SNM-1107 cc: Mr. W. Goodwin, W
W=tinghou:o El:Ictric Comp ny Masting ATTENDANCE LIST January 9,1998 NAME,
ADDRESS TELEPHONE E-MAIL Robert A. Williams Westinghouse 803 776 2610x3393 Williara@ Westinghouse.com Wilbur L. Goodwin Westinghouse 803 776-2610x3282 Goodwiwl@ westinghouse.com Jack B. Allen Westinghouse 803 776-2610x3300 Allen 2jb@ Westinghouse.com Jim Fici Westinghouse 412 374-3000 Ficija@ Westinghouse.com Elizabeth Ten Eyck NRC 301 415-7212 Eqt@nrc. gov Bill Brach NRC 301 415-7213 Ewb@nrc. gov Douglas Collins NRC 301 415-4701 Dmc@nrc. gov Wm Troskoski NRC 301 415-8076 Wmt@nrc. gov Bob Pierson NRC 301 415-7192 Rep @nrc. gov Harry Felsher NRC 301 415-5521 Hdf@nrc. gov Craig Hrabal NRC 301 415-5424 Cahi@nrc. gov Charles Gaskin NRC 301 415-8116 Cegi@nrc. gov Walt Schwink NRC 301 415-7190 Wss@nrc. gov Melanie Galloway NRC 301 415-7266 Mam@nrc. gov Michael Weber NRC 301 415-7190 Mfw@nrc. gov Mary Adams NRC 301 415-7249 Mta@nrc. gov ATTACHMENT