ML003682966
| ML003682966 | |
| Person / Time | |
|---|---|
| Issue date: | 02/11/2000 |
| From: | Sheron B NRC/NRR/ADPT |
| To: | Ralph Beedle Nuclear Energy Institute |
| References | |
| TAC MA5312 | |
| Download: ML003682966 (9) | |
Text
February 11, 2000 Mr. Ralph Beedle Nuclear Energy Institute 1776 I Street, N. W.
Washington, D. C. 20006-24996
SUBJECT:
TELEPHONE CONVERSATION REGARDING NEIs POSITION ON DEVELOPING GUIDELINES FOR CREDITING VOLUNTARY INDUSTRY INITIATIVES IN LIEU OF REGULATORY ACTIONS
Dear Mr. Beedle:
On February 6, 2000, Mr. Jack Strosnider and I had a telephone conversation with you regarding the Nuclear Energy Institute's (NEIs) position on the staffs proposal to develop guidelines for crediting voluntary industry initiatives (VIIs) in lieu of regulatory action. The purpose of this letter is to document that telephone conversation and our understanding that you would provide a letter stating NEIs position on this subject at a meeting scheduled for February 17, 2000, at the US Nuclear Regulatory Commissions (NRCs) Headquarters in Rockville, Maryland.
During this telephone conversation, we discussed the history of our interactions on this subject, which is summarized in the enclosure. As the enclosure indicates, the staff has actively pursued involvement of external stakeholders, including NEI and the industry, as part of this initiative. The NRC staff has had discussions on this subject at several public meetings with NEI and other interested stakeholders, as described in the attachment. These discussions focused mainly on the intent and usage of VIIs, without significant input from the various stakeholders on specifics to be included in the proposed guidelines.
On December 13, 1999, the NRC issued a Federal Register notice (64 FR 238) ... soliciting additional stakeholder comments from interested parties on both the technical and regulatory aspects related to the development of guidelines to allow the drafting of a regulatory framework that supports the implementation of [VIIs], from interested stakeholders, by January 15, 2000.
Mr. Strosnider expanded upon this solicitation during the December 21, 1999, meeting with your staff, stating that this included any comments, up to and including proposed guidelines in toto.
The response date was chosen in order to allow the staff time to incorporate any comments received into the proposed guidelines. No response to the FR notice was received from NEI or any other stakeholders. Given the general nature of the discussions at the public meetings, it is our understanding that the industry has comments and concerns on the proposed guidelines.
However, we cannot address those concerns until the industry provides them to us.
Mr. Ralph Beedle Given this history, I requested in our February 6, 2000, telephone conversation, that you provide more specifics regarding NEIs position on the VII proposal and your plans for providing any additional industry input. At your request, we have scheduled a public meeting on this subject for 1:00 p.m. on February 17, 2000, to be held in room O-4B-6 at the NRC Headquarters. Per our telephone conversation, I understand that, at this meeting, you will provide a written statement detailing NEIs position and plans regarding the development of guidelines for crediting voluntary industry initiatives in lieu of regulatory actions, and that we will discuss future plans in this area.
As indicated in the enclosure, the milestone for providing the proposed VII guidelines to the Commission is May 24, 2000. If NEI does not intend to provide any additional, detailed input, the staff will proceed to develop guidelines based on the general discussions and comments received during the several meetings on VIIs held to date, and provide these proposed guidelines to the Commission on the requested schedule. Alternatively, if NEI, or other interested stakeholders, want to provide more detailed comments and input, it may be possible to provide additional time to factor that input into development of these guidelines. However, we would need to know this no later than February 17, 2000, in order to pursue Commission approval for a revised schedule.
The staff continues to believe that voluntary industry initiatives can play a major role in achieving our regulatory goals of maintaining safety; reducing unnecessary regulatory burden; improving efficiency, effectiveness, and realism; and improving public confidence. I appreciate your cooperation on this subject and look forward to our discussions on February 17, 2000.
Sincerely,
/RA by/
Brian W. Sheron, Associate Director for Project Licensing and Technical Analysis Office of Nuclear Reactor Regulation
Enclosure:
As stated cc: Alex Marion, NEI David Modeen, NEI Owners Groups Chairs PWR MRP Chair BWRVIP Chair Mr. Ray Shadis Mr. David Kraft, NEIS
Mr. Ralph Beedle Given this history, I requested in our February 6, 2000, telephone conversation, that you provide more specifics regarding NEIs position on the VII proposal and your plans for providing any additional industry input. At your request, we have scheduled a public meeting on this subject for 1:00 p.m. on February 17, 2000, to be held in room O-4B-6 at the NRC Headquarters. Per our telephone conversation, I understand that, at this meeting, you will provide a written statement detailing NEIs position and plans regarding the development of guidelines for crediting voluntary industry initiatives in lieu of regulatory actions, and that we will discuss future plans in this area.
As indicated in the enclosure, the milestone for providing the proposed VII guidelines to the Commission is May 24, 2000. If NEI does not intend to provide any additional, detailed input, the staff will proceed to develop guidelines based on the general discussions and comments received during the several meetings on VIIs held to date, and provide these proposed guidelines to the Commission on the requested schedule. Alternatively, if NEI, or other interested stakeholders, want to provide more detailed comments and input, it may be possible to provide additional time to factor that input into development of these guidelines. However, we would need to know this no later than February 17, 2000, in order to pursue Commission approval for a revised schedule.
The staff continues to believe that voluntary industry initiatives can play a major role in achieving our regulatory goals of maintaining safety; reducing unnecessary regulatory burden; improving efficiency, effectiveness, realism; and improving public confidence. I appreciate your cooperation on this subject and look forward to our discussions on February 17, 2000.
Sincerely, Brian W. Sheron, Associate Director for Project Licensing and Technical Analysis Office of Nuclear Reactor Regulation
Enclosure:
As stated cc: Alex Marion, NEI David Modeen, NEI Owners Groups Chairs PWR MRP Chair BWRVIP Chair Mr. Ray Shadis Mr. David Kraft, NEIS Distribution:
Document Name: G:\EMCB\vol-init 99-063\Beedle Letter.wpd Sam Collins Roy Zimmerman Robert Hermann Bill Bateman Richard Wessman Bill Bateman C. E. Carpenter To receive a copy of this document, indicate in the box C=Copy w/o attachment/enclosure E=Copy with attachment/enclosure N = No copy OFFICE D:DE ADPT:NRR NAME JRStrosnider:JRS BWSheron:BWS DATE 02/09/2000 02/11/2000
ENCLOSURE The initiative to develop guidelines for crediting industry voluntary initiatives in lieu of regulatory action is an outgrowth of the Commissions Direction Setting Initiative (DSI) 13 entitled "The Role of Industry and Use of Industry Initiatives" (SECY 97-303), dated December 31, 1997 and the associated staff requirements memorandum (SRM) issued on April 16, 1998. In accordance with the Commissions SRM, a public stakeholders meeting on DSI-13 was held in Rosemont, Illinois, on September 1, 1998. On March 2, 1999, the staff forwarded SECY 99-063 to the Commission proposing to develop guidelines for crediting voluntary industry initiatives in lieu of regulatory action providing an outline of the areas proposed to be addressed in the guidelines. On May 27, 1999, the Commission issued an SRM approving the staff's recommendations in SECY 99-063. The SRM directed the staff to move forward, working with the industry and other stakeholders, in the development of the process and guidelines for use of industry initiatives in the regulatory process. The Commission set a due date of May 24, 2000 for providing the proposed guidelines to the Commission for review prior to implementation.
A second public meeting with interested stakeholders, including NEI and Owners Groups management representatives, was held on October 27, 1999, in Rosemont, Illinois, which is summarized in a meeting summary dated November 18, 1999. At the request of the Nuclear Energy Institute (NEI), a third stakeholders meeting was held at the NRC Headquarters on December 21, 1999. Both of these meetings were noticed and discussed in advance with NEI and other stakeholders. Although the attendance at the October meeting was relatively small (seven external stakeholders), the panel at the meeting included management representatives from NRC, NEI, and two nuclear utilities. Other participants represented a vendor and industry consultants. A representative from the Nuclear Energy Information Services (NEIS) who had planned to attend was unfortunately unable to be at the meeting. Seven external stakeholders also participated in the December 21, 1999 meeting. Participants in this meeting included management from NEI, NRC and EPRI, as well as representatives from utilities and vendors.
Discussions at both of these meetings focused largely on the general concept and philosophy of crediting industry voluntary initiatives in lieu of regulatory action, and was less focused on the specific details to be included in the guidelines. During the December 21, 1999, meeting, the NEI representatives provided a one page flow chart outlining a proposed process for crediting industry initiatives. The NRC staff indicated it would review the flow chart and provide comments, which were provided to NEI by letter dated February 9, 2000. These meetings were transcribed, and the NRC staff intends to use the comments and suggestions made at these meetings in its development of the guidelines.
During both the October 27, and the December 21, 1999, meetings, the NRC staff requested that stakeholders respond to the Federal Register notice (64 FR 238, dated December 13, 1999), soliciting comments from ...interested parties on both the technical and regulatory aspects related to the development of guidelines to allow the drafting of a regulatory framework that supports the implementation of [VIIs] by January 15, 2000. During both of these meetings, the NRC management suggested that NEI consider proposing a set of guidelines in response to the FR notice, up to and including proposed guidelines in toto. The staff noted that it could propose a revised schedule to the Commission if the industry needed more time to develop such guidelines. Notwithstanding the above, the NRC did not receive any comments in response to the FR notice from NEI or any other party.
On February 2, 2000, Messers. Strosnider, Bateman and Carpenter of my staff had a telephone conversation with Mr. Marion and Mr. Modeen of your staff. During that conversation, Mr.
Strosnider asked if NEI planned to provide any further comments or input to the proposed guidelines. Mr. Marion indicated that some initial guiding principals would be provided by NEI to the staff in February 2000, and additional comments would be provided by early March 2000.
He also requested that NRC provide any comments on the flow chart that NEI had provided to the NRC during the December 21, 1999, public meeting; these were provided in a letter dated February 9, 2000.
ENCLOSURE
cc:
Mr. Alex Marion, Director Mr. W. Glenn Warren Programs BWR Owners Group Chairman Nuclear Energy Institute Southern Nuclear Company Suite 400 42 Inverness Parkway 1776 I Street, NW PO Box 1295 Washington, DC 20006-3708 Birmingham, AL 35201 Mr. David Modeen, Director Mr. James M. Kenny Engineering BWR Owners Group Vice Chairman Nuclear Energy Institute PP&L, Inc.
Suite 400 Mail Code GENA6-1 1776 I Street, NW Allentown, PA 18101-1179 Washington, DC 20006-3708 Mr. Thomas J. Rausch Mr. Anthony Pietrangelo, Director RRG Chairman Licensing Commonwealth Edison Company Nuclear Energy Institute Nuclear Fuel Services Suite 400 1400 Opus Place, 4th Floor 1776 I Street, NW Downers Grove, IL 60515-5701 Washington, DC 20006-3708 Mr. Drew B. Fetters Mr. Jim Davis, Director PECO Energy Operations Nuclear Group Headquarters Nuclear Energy Institute MC 61A-3 Suite 400 965 Chesterbrook Blvd.
1776 I Street, NW Wayne, PA 19087-5691 Washington, DC 20006-3708 Mr. H. Lewis Sumner Ms. Lynnette Hendricks, Director Southern Nuclear Company Plant Support 40 Inverness Parkway Nuclear Energy Institute PO Box 1295 Suite 400 Birmingham, GA 35201 1776 I Street, NW Washington, DC 20006-3708 Mr. Carl D. Terry Vice President, Nuclear Engineering Mr. Charles B. Brinkman, Director Niagara Mohawk Power Corporation Washington Operations Nine Mile Point - Station ABB-Combustion Engineering, Inc. OPS Bldg/2nd Floor 12300 Twinbrook Parkway, Suite 330 PO Box 63 Rockville, Maryland 20852 Lycoming, NY 13093 Mr. H. A. Sepp, Manager Mr. George T. Jones Regulatory and Licensing Engineering PP& L, Inc.
Westinghouse Electric Company MC GENA6-1 P.O. Box 355 Two North Ninth Street Pittsburgh, Pennsylvania 15230-0355 Allentown, PA 18101
Mr. John Kelly Mr. H. A. Sepp, Manager New York Power Authority Regulatory and Licensing Engineering 14th Floor Mail Stop 14K Westinghouse Electric Corporation Centroplex Building P.O. Box 355 123 Main Street Pittsburgh, PA 15230-0355 White Plains, NY 10601 Mr. Andrew Drake, Project Manager Mr. Thomas G. Hurst Westinghouse Owners Group GE Nuclear Energy Westinghouse Electric Corporation M/C 182 Mail Stop ECE 5-16 175 Curtner Avenue P.O. Box 355 San Jose, CA 95125 Pittsburgh, PA 15230-0355 Mr. Thomas A. Green Mr. Jack Bastin, Director GE Nuclear Energy Regulatory Affairs M/C 182 Westinghouse Electric Corporation 175 Curtner Avenue 11921 Rockville Pike San Jose, CA 95125 Suite 107 Rockville, MD 20852 Mr. Gordon C. Bischoff, Project Director CE Owners Group Randy Hutchinson, Chairman ABB Combustion Engineering Nuclear B&WOG Executive Committee Power Vice President Operations M.S. 9615-1932 Arkansas Nuclear One 2000 Day Hill Road Entergy Operations, Inc.
Post Office Box 500 1448 S.R. 333 Windsor, CT 06095 Russellville, AK 72801-0967 Mr. Ralph Phelps, Chairman Mr. W. W. Foster, Chairman CE Owners Group B&WOG Steering Committee Omaha Public Power District Director of Safety Assurance P.O. Box 399 Duke Power Company Ft. Calhoun, NE 68023-0399 Oconee Nuclear Station P.O. Box 1439 Mr. Ian C. Rickard, Director Seneca, SC 29679 Nuclear Licensing ABB Combustion Engineering Nuclear Mr. J. J. Kelly, Manager Power B&W Owners Group Services 2000 Day Hill Road Framatome Technologies, Inc.
Post Office Box 500 P.O. Box 10935 Windsor, CT 06095 Lynchburg, VA 24506-0935 Mr. Charles B. Brinkman, Manager Mr. F. McPhatter, Manager Washington Operations Framatome Cogema Fuels ABB Combustion Engineering Nuclear 3315 Old Forest Road Power P.O. Box 10935 12300 Twinbrook Parkway, Suite 330 Lynchburg, VA 24506-0935 Rockville, MD 20852
Mr. R. Schomaker, Manager James P. Pelletier, BWRVIP Liaison Framatome Cogema Fuels to EPRI Nuclear Power Council 3315 Old Forest Road Nebraska Public Power District P.O. Box 10935 1200 Prospect Avenue Lynchburg, VA 24506-0935 PO Box 98 Brownville, NE 68321-0098 Mr. Michael Schoppman Licensing Manager Robert Carter, EPRI BWRVIP Framatome Technologies, Inc. Assessment Manager 1700 Rockville Pike, Suite 525 Greg Selby, EPRI BWRVIP Rockville, MD 20852-1631 Inspection Manager EPRI NDE Center Mr. Gary L. Vine P. O. Box 217097 Senior Washington Representative 1300 W. T. Harris Blvd.
Electric Power Research Institute Charlotte, NC 28221 2000 L Street, N.W., Suite 805 Washington, DC 20036 Joe Hagan, BWRVIP Vice Chairman PEPCO Energy Co.
Mr. James F. Lang MC 62C-3 Electric Power Research Institute 965 Chesterbrook Blvd Post Office Box 217097 Wayne, PA 19807-5691 1300 W.T. Harris Boulevard Charlotte, NC 28262 Steve Lewis, Technical Chairman BWRVIP Assessment Task Mr. Bindi Chexal Entergy Electric Power Research Institute P. O. Box 756 Post Office Box 10412 Waterloo Road Palo Alto, CA 94303 Port Gibson, MS 39150 Mr. Raymond C. Torok Carl Larsen, Technical Chairman Project Manager, Nuclear Power Group BWRVIP Inspection Task Electric Power Research Institute P.O. Box 157 Post Office Box 10412 Vernon, VT 05354 Palo Alto, CA 94303 John Wilson, Technical Chairman Bill Eaton, Executive Chair BWRVIP Mitigation Task BWRVIP Inspection Committee Clinton Power Station, M/C T-31C Entergy Operations, Inc. P.O. Box 678 PO Box 756, Waterloo Rd Clinton, IL 61727 Port Gibson, MS 39150-0756 Vaughn Wagoner, Technical Chairman Harry P. Salmon, Executive Chairman BWRVIP Integration Task BWRVIP Integration Task Carolina Power & Light Company New York Power Authority One Hannover Square 9C1 123 Main St., M/S 11 D P.O. Box 1551 White Plains, NY 10601-3104 Raleigh, NC 27612
Bruce McLeod, Technical Chairman BWRVIP Repair Task Southern Nuclear Operating Co.
Post Office Box 1295 40 Inverness Center Parkway Birmingham, AL 35201 Tom Mulford, EPRI BWRVIP Integration Manager Raj Pathania, EPRI BWRVIP Mitigation Manager Ken Wolfe, EPRI BWRVIP Repair Manager Electric Power Research Institute P. O. Box 10412 3412 Hillview Ave.
Palo Alto, CA 94303 Mr. Ray Shadis, Staff New England Coalition on Nuclear Pollution P. O. Box 76 Edgecomb, Maine 04556 Mr. David Kraft Nuclear Energy Information Services P. O. Box 1637 Evanston, IL 60204