ML20203E734
| ML20203E734 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1999 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20203E725 | List: |
| References | |
| SECY-99-001-C, SECY-99-1-C, NUDOCS 9902170299 | |
| Download: ML20203E734 (3) | |
Text
- .-
NOTATION VOTE RESPONSE SHEET 1
I TO:
John C. Hoyle, Secretary FROM:
CHAIRMAN JACKSON
SUBJECT:
SEC 001 - PROPOSED GUIDANCE FOR UPDATED FINAL SAFETY ANALYSIS REPORTS IN ACCGRDANCE l
WITH 10 CFR 50.71(e) w/ comment Approved X
Disapproved Abstain Not Participating COMMENTS:
SEE ATTACHED COMMENTS j
SIGINATUl4E January 29, 1999 DATE Entered on "AS" Yes XX No E82'?8:M7J8!
CORRESPONDENCE PDR 4902/7027f
_ _ ~. _ _ _ _ _ _ _ _ _. _ _ _ -
. _..~.-...._ _._ _
l
+
l Chairman Jackson's Comments on SECY-99-001 1.
I approve issuance of DG-1083, " Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e)." The staff and ind;stry should be commended on the i
progress they have made in this controversial area.
2.
in applying NEl 98-03, the definition of "UFSAR description" should be as fol!ows:
i i
UFSAR description includes text, table, diagrams, etc., that provide L
an understanding of the facility, design bases, safety analyses and l
l facility operation tmder during all conditions offumel plant
!~
operation including normal shutdown operations, anticipated operational occurrences, design basis accidents, extemal events,
)
and natural phenomena for which the plant is designed to function.
Use of this definition is necessary to be consistent with 50.34(b) and the proposed revision to the Maintenance Rule.
1 3.
I have long been an advocate of risk-informing our regulations. Recent staff and industry initiatives have begun to lay the foundation for risk-informing our licensing, inspection, l
assessment, and enforcement programs. I commend the staff for identifying in SECY 001 the potential issue associated with retention of information, in the Updated Final Safety l
Analysis Report (UFSAR), associated with risk-significant structures, systems, and components (SSCs). The staff indicates that the industry's voluntary guidance in NEl 98-03 could be interpreted to allow the removal of all information that is not specifically required to be incorporated into a UFSAR, regardless of whether that information is associated with risk-significant SSCs. The staff has attempted to limit this potential adverse impact through incorporation of the following language in NEl 98-03:
[
lt is the intent of this guideline to help licensees remove unimportant l
information from UFSARs such as excessive detail, obsolete, or redundant information. This guideline is not intended to be used to remove information from UFSARs regarding SSCs that insights from operating experience or probabilistic risk assessments would indicate are risk significant.
However, the staff notes in'SECY-99-001 that this limitation is voluntary; i.e., a licensee that chooses to take out this information regarding risk-significant SSCs would be free to do so, absent an order or other legally binding requirement (e.g., a rule) by the Commission to the licensee directing the licensee not to remove the information. The staff states that such an order or other legally binding requirement would have to be based on a finding that removal
- of such information (and by implicahon the SSCs described) would bear on reasonable
. assurance of adequate protection. I believe that this constitutes too high a threshold to bc L
of much practical utility in ensuring risk-information is not removed from the Updated FSAR.
L
. Allowing the potential for removal of risk-significant information from the Updated FSAR l-(and by implication the SSCs described) is not consistent with our vision for properly risk-L informing our regulations and programs. Therefore, the staff should carefully monitor the implementation of this voluntary commitment and consider the need to codify criteria in
. 50.71(e) for retention of such risk-significant information.
r L
l I
The staff has indicated that this issue can be resolved prior to publication of the final regulatory guide. The staff should consider providing specific examples in the regulatory guide of: (1) information that could be deleted from the UFSAR with due consideration of the original FSAR requirement (50.34(b)) to provide information "that describes the facility" and (2) information that should not be deleted from the UFSAR based on its importance to risk.
i j
l l
4.
Section 6.1.1 of NEl 98-03 discusses updating of the FSAR to reflect changes to the facility resulting from new or amended requirements, including plant-specific orders. The staff should provide additional guidance in the Regulatory Guide on the disposition of plant-specific orders that require changes in facility administrative controls (e.g., Millstone Orders on the ICAVP and independent oversight of the SCWE/ECP), but do not require specific facility changes or changes to the safety analysis. For example, could these plant-specific orders be interpreted as a modification to the
- Managerial and administrative controls to be used to assure safe operations" as discussed in 50.34(b)(6) and, as such, require updating of the final safety ana;ysis report?
5.
Sections 6.1.2 and 6.1.3 of NEl 98-03 discusses updating of the FSAR to reflect changes to the facility or procedures, and analyses of new safety issues. The staff should provide additional guidance in the Regulatory Guide on the disposition of risk-significant changes to the facility and procedures that go *beyond the design basis" of the plant. For example, probabilistic risk considerations led licensees to modify their facilities and procedures in response to NRC Generic Letters, including:
- Generic Letter 89-16 " Installation of a Hardened Wetwell Vent": Licensees for Mark I containments installed hardened vents under the provisions of 50.59.
- Generic Letter 88-17 ' Loss of Decay Heat Removal": PWR licensees committed to procedural and plant enhancement to prevent and mitigate the consequences of core damage during mid-loop operations.
6.
Given the extent of public interactions that have occurred in the development of the proposed draft regulatory guide and the apparent lack of significant remaining issues, the staff should consider limiting the public comment period to 45 days. This would allow issuance of the final regulatory guide by September 1999, after due consideration of public comments. In addition, the staff should inform the Commission on the resolution of public comments received prior to issuance of the final regulatory guide.
1 l
l
\\
{