ML20235A936
| ML20235A936 | |
| Person / Time | |
|---|---|
| Issue date: | 11/04/1988 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Bernero R, Goldberg J, Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| Shared Package | |
| ML20235A909 | List: |
| References | |
| NUDOCS 8811160179 | |
| Download: ML20235A936 (4) | |
Text
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MEMORANDUM FOR: Robert M. Bernero, NMSS Jack R. Goldberg, OGC Carl J. Paperiello, RIII Denwood F. Ross, RES James H. Sniezek, NRR FROM: Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
CRGR MEETING N0. 150 The Committee to Review Generic Requirements (CRGR) will meet in the afternoon on Wednesday, November 9, 1988 in WF 16B-11 from 1-3 p.m. The agenda is as follows:
1-2 p.m. W. Morris (RES) will present for CRGR review a proposed rule entitled, " Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites." This package was included in the agenda for Meeting No. 146. Additional material was provided to you separately by RES.
2-3 p.m. L. Shao (NRR) will brief the Committee on a draft SER of B&W Topical Report BAW-10167 and Supplement 1, " Justification for Increasing the Reactor Trip System On-Line Test Intervals." (The submittal package is enclosed.) A copy of the topical report can be provided to you on request.
If a CRGR member cannot attend the meeting, it is his responsibility to assure that an alternate, who is approved by the CRGR Chairman, attends the meeting.
Persons making presentations to the CRGR are responsible for (1) assuring that the information required for CRGR review is provided to the Committee (CRGR Charter - IV.B), (2) coordinating and presenting views of other offices, (3) as appropriate, assuring that other offices are represented during the presentation, and (4) assuring that agenda modifications are coordinated with the CRGR contact (C. Sakenas, X24148) and others involved with the presentation.
Division Directors or higher management should attend meetings addressing agenda items under their purview.
In accordance with the ED0's March 29, 1984 memorandum to the Commission concerning " Forwarding of CRGR Documents to the Public Document Room (POR),' l the review packages for items scheduled at this meeting, which contain g I ll/[
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Driginal Signd Byl ;
E! D Jordan j Edward L. Jordan, Chairman :
Committee to Review Generic Requirements
Enclosure:
As stated cc w/ enclosure:
SECY V. Stello l
Dist'ribution:
E. Jordan J. Heltemes da Conran z C. Sakenas l R. Fraley B. Morris (w/o enc.)
L. Shao (w/o enc.)
l E.'Rossi-(w/o enc.) !
l C. Berlinger (w/o enc. )
P. Kadambi (w/o enc.)
CRGR SF I S. Treby (w/o enc.)
J. Blaha (w/o enc.)
M. Taylor, OEDO '
PDR (NRC/CRGR) (w/o enc.)
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1 0FFICIAL RECORD COPY
r August 14, 1987 MEMORANDUM FOR: Victor Stello, Jr.
Executive Director for Operations FROM: Edward L. Jordan, Chairman ,
Committee to Review Generic Requirements '
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 1_lfL The Committee to Review Generic Requirements (CRGR) met on Wednesday, July 8, 1987, from 1-3 p.m. A list of attendees for this meeting is enclosed (Enclosure 1). The following item was addressed at the meeting:
The Committee reviewed proposed changes to the Technical Specifications for BWR relay reactor protection systems (RPS) that would lengthen the intervals for RPS functional testing. The Committee recommended in favor of issuing the proposed changes, subject to minor wording revisions to be coordinated with the CRGR staff. The Committee also recommended that the EDO direct the staff to consider improved means of monitoring the long-term reliability of plant equipment subject to such Tech Spec relaxations. The discussion of these matters is documented in Enclosure 2.
In accordance with the ED0's July 18, 1983 directive concerning " Feedback and Closure on CRGR Reviews," a written response is required from the cognizant office to report agreement or disagreement with CRGR recommendations in these minutes. The response, which is required within five working days after receipt of these meeting minutes, is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the E00 for decisionmaking.
Questions concerning these meeting minutes should be referred to Jim Conran (492-9855).
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- t. u borden Edward L. Jordan, Chairman Committee to Review Generic l Requirements
Enclosures:
As stated Distribution: w/o encl.
Central File i cc: Commission (5) PDR (NRC/CRGR)
, SECY R. Hernan l'
Office Directors S. Treby Regional Administrators W. Little CRGR Members M. Lessar
- W. Parler J. Zerbe i
A. Thadani J. Johnson (w/ enc.)
l T. Collins J. Conran (w/ enc.)
, j CRGR SF (w/ enc.)
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Enclosure 2 to the Minutes of CRGR Meetir; No.118 Proposea Technical Specification Imorcsement for BWR Relay Reactoi"Trotection System July 8, 1987 TOPIC Proposed Technical Specification Modification for BWR Relay Reactor Protection ;
Systems (RPS).
l l
BACKGROUND A. Thadani and T. Collins, NRR, presented for review by the Committee proposed l Tech Spec revisions that would increase the existing functional test interval for BWR relay RPS. The proposed changes are based on the staff's review of GE Topical Reports NEDC-30844, dated January 1985, "BWR Owners' Group Response to Generic Letter 83-28," and NEDC-30851P, dated May 1985, " Technical Specifica-tion Improvement for BWR Reactor Protection System." ine proposed Tech Spec changes represent a relaxation of current staff positions, i.e., (a) an exten-sion from monthly to quarterly of the surveillance interval for relay RPS channel functional testing, and (b) an extension from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and from 2 nours to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, of certain allowable out of-service times (A0Ts) for that RPS instrumentation. The proposed changes are permissive type chan the Tech Specs (i.e. , they are not imposed by the staff on any licensee)ges, andto so do not constitute a backfit. Licensees may adopt the changes voluntarily, i if they choose to do so. This change is similar to RPS Tech Spec changes made for Westinghouse PWR RPS several years ago. Copies of the briefing slides used by the staff to guide the presentations and discussions at this meeting are attached to this Enclosure.
l The package submitted for review by CRGR in this matter was transmitted by memorandum dated May 27, 1987, T. E. Murley to E. Jordan; that package included the following review documents as attachments:
- 1. Attachment 1 - Draf t letter to T. A. Pickens, Chairman of the BWR Owners' Group (BWROG), regarding acceptance of Topical Reports NEDC-30844 and NEDC-30851P, and enciosures:
- a. Enclosure 1 - NRC Staff Safety Evaluation of Topical Reports NEDC-30844 and NEDC-30851P
- b. Enclosure 2 - Proposed Changes to Relay RPS Technical Specifications
- 2. Attachment 2 - Response to Requirements for Content of Package Submitted for CRGR Review.
DISCUSSION The major comments and questions raised by CRGR at this meeting regsrding the proposed changes to the Tech Specs for BWR relay RPS functional test intervals were as follows:
F 1. The Committee questioned the staff regarding details of NRC contractor verification of the completeness and applicability of the RPS system reliability data used or cited by GE in support of the proposal to lengthen RP$ channel functional test interval. The staff indicated that this verification involved a literature search by the contractor, and comparisons of values used by GE with standard data bases (e.g.,
NUREG/CR-2815 and EPRI data), as well as comparisons / correlations with performance reliability results gleaned from LER surveys and previous ATWS analyses and conclusions. This led to the question of how the staff proposed to assure that the topical report analyses and conclusions remain valid. The need for close monitoring of RPS (and other reactor plant systems) availability at the train level was identified by the Committee in the course of these discussions as an issue of increasing importance, because this tweaking of RPS Tech Specs is just the first in what is expected to be a series of such Tech Spec changes that are anticipated in connection with implementation of NRC's Tech Spec Improvement Program (TSIP). It was noted that available LER data can only indicate system-level reliabilities; and, to the present at least, utility support and participation in NPRDS has been spotty, with the result that train level reliability figures that might be derived from it currently cannot be regarded as truly representative. After thorough discussion of these l questions, the consensus Committee view was that a recommendation should be made to the the ED0 to direct the appropriate NRC offices (probably AE00 and NRR) to jointly develop proposals for effective means to track ;
train-level reliabilities for nuclear plant systems. It was emphasized, !
l however, in these discussions that such a recommendation should not be misconstrued as in any way relieving licensees of the primary obligation l
I to assure that component or train level reliability levels (or failure rates) used in the topical report analysis are accurate and applicable to their individual facilities, if they choose to amend their Tech Specs to I
decrease RPS functional test intervals. Improved NRC capability in this regard is important, however, as an independent check of the reliability (or failure rate) values used in licensee / vendor analyses, as well as in the performance indicator context.
- 2. The Committee questioned the staf f's conclusion that staggered testing of RPS channels need not be required in conjunction with this relaxation of l BWR RPS functional test frequencies, as was done earlier with respect to Westinghouse PWR RPS testing. The staff felt confident that their con-clusion in this regard was defensible; they cited the greater diversity of )
inputs to BWR scram channels, and the alternate ATWS scram feature for BWRs, as the fundamental considerations underlying that conclusion. They !
also noted that no credit had been assumed for staggered testing in GE's l analyses in support of this proposal; and, although NRC's contractor did not check those analyses in detail, GE's conclusions seemed consistent with the staff's knowledge and experience regarding the general character- l istics and expected behavior of systems of high diversity. Specific ;
examples were discussed in which common mode failures were produced by l maintenance personnel misadjusting a number of similar sensor inputs to the scram channels in the same way. In each case it was concluded that the scram function was not likely to be defeated, because the sheer number l of different types (i.e. , the diversity) of inputs was great enough that '
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