ML003766430
| ML003766430 | |
| Person / Time | |
|---|---|
| Site: | Boiling Water Reactor Owners Group |
| Issue date: | 11/03/2000 |
| From: | Richards S NRC/NRR/DLPM |
| To: | Kenny J BWR Owners Group |
| Pulsifer R M, NRR/DLPM, 415-3016 | |
| References | |
| Download: ML003766430 (4) | |
Text
November 3, 2000 Mr. James M. Kenny, Chairman BWR Owners Group PPL, Inc.
2 North Ninth Street M/C A6-1 Allentown, PA 18101
SUBJECT:
RISK-INFORMED PART 50 PILOT PROGRAM
Dear Mr. Kenny:
We have reviewed your letter dated October 9, 2000, in which you outlined the BWR Owners Groups (BWROG) plans for the Risk-Informed Part 50 (RIP 50) Option 2 pilot program. Based on this review, we offer the following comments.
The NRCs initial thoughts regarding the RIP 50 Option 2 pilot program were described in an October 19, 1999, letter from Samuel Collins to Ralph Beedle of the Nuclear Energy Institute (NEI). In this letter, we noted that the pilot plant program is an essential component of the RIP 50 Option 2 rulemaking process, addressing the viability of the proposed requirements and implementation guidance. Therefore, we are pleased that the BWROG has taken the initiative to participate in this important activity.
The NRC is currently reviewing guidance documents that NEI proposes be used for implementation of RIP 50 Option 2. These documents include NEI 00-02, "Probabilistic Risk Assessment Peer Review Process Guideline," and the draft of "Risk-Informed Categorization of Structures, Systems, and Components." The NRCs initial observations regarding these guidelines are given in letters from David Matthews to Ralph Beedle dated September 19 and September 26, 2000.
It is our understanding that the BWROG plans to use the NEI guidelines in your RIP 50 Option 2 pilot program, and that NEI will function as the focal point for our interaction with industry efforts. Since we plan to incorporate these guidelines into our rulemaking effort as an acceptable means to implement the RIP 50 Option 2 regulations, it is essential that pilot activities thoroughly exercise these guidelines, and that all parties understand lessons learned from this effort. We believe industry efforts coordinated through a single point of contact is the most effective way to accomplish this goal.
In our October 19, 1999, letter, we stated that the risk-informed categorization of plant equipment should be applied to a variety of plant systems, including mechanical, fluid, and electrical systems. We also stated our belief that the pilot program participants should identify candidate rules for exemptions. We noted that the scope of the RIP 50 Option 2 alternative rules could be affected by the scope of systems evaluated by the pilot program if we are unable to assess the impact of specific rule changes. Your proposal describes your intent to evaluate the low pressure core spray, standby gas treatment, and feedwater/condensate systems, but does not address the scope of affected special treatment rules. We will need to understand how the scope of systems and rules you propose will provide adequate information for the RIP 50 Option 2 rulemaking effort.
Mr. James M. Kenny November 3, 2000 We plan to schedule a public meeting in the near future to discuss these specific issues and other pilot program topics. We plan to coordinate this meeting through NEI, and will seek the participation of the BWROG and other owners groups. As pilot program efforts proceed, we expect to have additional interactions, including site visits, with pilot program participants.
You should be aware of one significant concern we have regarding the BWROG pilot program proposal. Your letter discusses plans to request "generic exemptions" for all boiling water reactors in Phase 3 of your pilot program. It is not our intent to process such generic exemption requests. This issue was addressed in SECY-98-300, "Options for Risk-informed Revisions to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities," which stated:
The grant of limited exemptions to a limited number of plants for purposes of pilot testing does not pose any special problems but the repeated issuance of a large number of exemptions which, considered together, represent a fundamental alteration of the conceptual nature of the licensing basis, to more than a limited number of plants essentially constitutes a generic change to the regulatory requirements in Part 50. Such generic changes should be adopted through rulemaking, rather than the case-by-case approach inherent in the regulatory approach embodied in the issuance of exemptions.
More recently, we addressed the prospect of generic exemptions In SECY-00-0194, "Risk-Informing Special Treatment Requirements," stating "...that a generic exemption may not be consistent with agency policy because broadly applicable exemptions can preempt rulemaking."
Therefore, we request that the BWROG reconsider its plans to request generic exemptions as part of its RIP 50 Option 2 pilot program.
Questions or comments regarding these issues can be directed to Joe Williams, who is the NRC Project Manager for the RIP 50 Option 2 pilot program. Mr. Williams may be reached at (301) 415-1470, or via email at jfw1@nrc.gov.
Sincerely,
/RA Stephen Dembek for/
Stuart A. Richards, Director Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation Project No. 691 cc: See next page
Mr. James M. Kenny November 3, 2000 We plan to schedule a public meeting in the near future to discuss these specific issues and other pilot program topics. We plan to coordinate this meeting through NEI, and will seek the participation of the BWROG and other owners groups. As pilot program efforts proceed, we expect to have additional interactions, including site visits, with pilot program participants.
You should be aware of one significant concern we have regarding the BWROG pilot program proposal. Your letter discusses plans to request "generic exemptions" for all boiling water reactors in Phase 3 of your pilot program. It is not our intent to process such generic exemption requests. This issue was addressed in SECY-98-300, "Options for Risk-informed Revisions to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities," which stated:
The grant of limited exemptions to a limited number of plants for purposes of pilot testing does not pose any special problems but the repeated issuance of a large number of exemptions which, considered together, represent a fundamental alteration of the conceptual nature of the licensing basis, to more than a limited number of plants essentially constitutes a generic change to the regulatory requirements in Part 50. Such generic changes should be adopted through rulemaking, rather than the case-by-case approach inherent in the regulatory approach embodied in the issuance of exemptions.
More recently, we addressed the prospect of generic exemptions In SECY-00-0194, "Risk-Informing Special Treatment Requirements," stating "...that a generic exemption may not be consistent with agency policy because broadly applicable exemptions can preempt rulemaking."
Therefore, we request that the BWROG reconsider its plans to request generic exemptions as part of its RIP 50 Option 2 pilot program.
Questions or comments regarding these issues can be directed to Joe Williams, who is the NRC Project Manager for the RIP 50 Option 2 pilot program. Mr. Williams may be reached at (301) 415-1470, or via email at jfw1@nrc.gov.
Sincerely,
/RA Stephen Dembek for/
Stuart A. Richards, Director Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation DISTRIBUTION:
Project No. 691 PUBLIC RidsOgcMailCenter PDIV-2 Reading RidsAcrsAcnwMailCenter cc: See next page SRichards (RidsNrrDlpmLpdiv)
SWest RidsNrrLAEPeyton RidsNrrPMRPulsifer RidsNrrPMJWilliams CCarpenter (RidsNrrDripRgeb)
Accession No. ML003766430 OFFICE PDI-2/PM PDIV-2/LA PDIV/PM RGEB RGEB PDIV-2/SC NAME RPulsifer EPeyton JWilliams CCarpenter SWest SDembek DATE 11/02/00 11/01/00 11/02/00 11/02/00 11/02/00 11/03/00 OFFICE PDIV&D NAME SDembek for SRichards DATE 11/03/00 OFFICIAL RECORD COPY
BWR Owners Group Project No. 691 cc:
Mr. H. Lewis Sumner Southern Nuclear Company 40 Inverness Center Parkway PO Box 1295 Birmingham, AL 35242 Mr. Carl D. Terry Vice President, Nuclear Engineering Niagara Mohawk Power Corporation Nine Mile Point - Station OPS Bldg/2nd Floor PO Box 63 Lycoming, NY 13093 Mr. George T. Jones PP& L, Inc.
MC A6-1 Two North Ninth Street Allentown, PA 18101 Mr. John Kelly New York Power Authority 14th Floor Mail Stop 14K Centroplex Building 123 Main Street White Plains, NY 10601 Mr. Thomas G. Hurst GE Nuclear Energy M/C 782 175 Curtner Avenue San Jose, CA 95125 Mr. Thomas A. Green GE Nuclear Energy M/C 782 175 Curtner Avenue San Jose, CA 95125 Mr. William H. Bolke COMED 1400 Opus Place, Suite 400 Downers Grove, IL 60515 Mr. J. A. Gray, Jr., Vice Chairman BWR Owners Group New York Power Authority 123 Main Street White Plains, NY 10601 Mr. James W. Langenbach PECO Energy 965 Chesterbrook Blvd MC 62C-3 Wayne, PA 19087 Mr. James F. Klapproth GE Nuclear Energy M/C 706 175 Curtner Avenue San Jose, CA 95125 Mr. Ralph Beedle Nuclear Energy Institute 1776 I Street, N.W.
Suite 400 Washington, DC 20006-3708 Mr. Stephen D. Floyd Nuclear Energy Institute 1776 I Street, N.W.
Suite 400 Washington, DC 20006-3708 Mr. Biff Bradley Nuclear Energy Institute 1776 I Street, N.W.
Suite 400 Washington, DC 20006-3708