ML031680606
| ML031680606 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde, Wolf Creek, Diablo Canyon, Callaway, South Texas, Comanche Peak  |
| Issue date: | 07/17/2003 |
| From: | Donohew J NRC/NRR/DLPM/LPD4 |
| To: | |
| Donohew J N, NRR/DLPM,415-1307 | |
| Shared Package | |
| ml031980030 | List: |
| References | |
| Download: ML031680606 (103) | |
Text
NRC PRESENTATIONS STARS/NRC LICENSING WORKSHOP June 10 and 11, 2003 Kansas City, Kansas
NRC Work Controls Stephen iek Section Chie Tuesday, June 10.
June 10, 200 2 Overview o TNesentation
- 'What is CWP?
- Desired outcomes
- Critical information
- What's different for the PM?
- What can licensees do to help?
- Implementation plan
June 10, 200 - 3 What is NR t Centralized Work Planning>o ss?
- Tool to help organize, understand manage the workload of the office
- Optimizes the matchup of resource deman resource availability
- Works from an office perspective rather than a project perspective
- Integrates work of the office
June 10, 2003 4 Desired comes
- More efficient and effective use of resources
- Better predictability
- Better quality control
- Continuous improvement
June 10, 2003 5 Critical Inforation Needed
- Skill demand:
- Which skills and how many hours of each nee
- Skill availability =
- Total skill pool minus current loading Current loading = previous skill demands minus hours alrea expended
- Dependencies
- Whose work depends upon who
- Relative priority of work
- Office decision independent of skills
June 10, 200 6 What's D i for the PM?
- See Handout
June 10, 2003 7 What can licen%ees do to help?
- Nothing surprising here:
- Submit high quality documents
- Make it easy for NRC to determine wh review branches/sections are needed
- Give target date and basis
- Give previous examples, if action has been done before
- Quickly respond to RAI requests
June 10, 200 8 Im ementation F 'Ian
- FY03
- Define and communicate responsibili to staff
- Pilot standardized characterization process
- Pilot standards development process
- Standardize process steps for another product
- FY04
- Apply characterization and standards development pro two more products
- Standardize process steps for another product (or two)
- Update skills database and prioritization scheme
- Develop and pilot performance monitoring scheme
June 10, 2003 9 Implemientation Plan (co ntinued
- FY05
- Repeat cycle of standards development an ."SS definition as needed
- Develop scheduling and planning optimization
- Implement performance monitoring scheme
- FY06
- Start cycle of systematic process review and improvement
- Pilot centralized scheduling
Centralized Work Planning Stephen )ek Section Clea1 Tuesday, June 10
John Harrison 10/30102 The Role of the DLPM Project Manager Before and After the Centralized Work Planning Pilot Program Before Pilot After Pilot 1 PM receives license amendment application Same 2 PM requests TAC for a license amendment Same 3 PM prepares Federal Register notice Same 4 PM initiates Work Request Form WPC initiates the new Work Form upon TAC request 5 PM determines which sections are involved PM lists which sections may be involved, DPR makes determination 6 PM may prepare multiple Work Request Forms for one TAC PM fills in information on the new Work Form one time 7 PM performs precedent search and provides resulting *PM provides precedents referenced or used by the licensee precedents .Technical review section provides precedents that they have done and which are still appropriate to use
.WPC performs precedent search if requested 8 PM negotiates" completion date with each involved section SC provides completion date based on PM's required completion date 9 PM negofiates? hours with each involved section STR provides hours along with basis for hours 10 PM coordinates review dependencies, and who compiles the Technical Branch DPRs coordinate review dependencies, and who inputs, with each section compiles the Inputs, with each section 11 PM checks each returned Work Request Form for appropriate PM checks each retumed Work Form for appropriate hours and dates, hours and dates review dependencies, and who compiles the inputs 12 PM forecasts his estimated completion date PM forecasts his estimated start date, completion date, and level of effort 13 PM resolves or coordinates resolution of technical issues Same 14 PM periodically checks if review Ison schedule Technical Branch DPRs periodically check if review Is on schedule, and reports back to PM. Special attention is paid to urgent/outage related X . amendments 15 PM issues final product (FR Notice, SE, Amendment, and Same Transmittal letter)
DPR - DMsion Planning Representative SC - Technical Branch Section Chief WPC - Work Planning Center PM - DLPM Project Manager STR - Senior Technical Reviewer C:WPCVMaeteis\PM job change.wpd
Managing Schedules
- 4L for LARs to Support Plant Activities Davilr Jaffe Senior Project A NRC Comanche Peak Steam .ation Tuesday, June 10,
Routine omm un ications (No>SLWprises)
- Occasionally Remind Us of Planned Outages
- Inform Us Promptly of Emergent Situations
- Occasionally Contact Section Chief (Important for Emergent Situations) 2
The BlGPcure
- Only Submit LARs that you can su rt (Assume you can Answer a Reasonab o 15 Question RAI in 60 days)*
- No Licensing Actions at the NRC for more One Year (Subdivide Review into Parts)
- Schedule as a Prominent Part of Submittal (Key to Specific Event and Defensible)
- 10 CFR 2.108 Allows the NRC to Deny an Application for Failure to Respond to an RAI 3
SCh ole for Routine LAR Moderate mopIexity (No Generic Pb ems)
ItDay Submit LAR 1st Month Reviewers Assigned Noticed in Federal Register _
3 rd Month RAI to Licensee 5 th Month Response to RAI 7 th Month Issue License Amendment
- High Quality Submittal
- Plenty of Support 4
Emergency/Exigency
- Emergency (10 CFR 50.91(a)
- Requires an Explanation of Why thcti .on Could NOT be Handled in a Routine (Act in 0 to 7 Days)
- Exigency (10 CFR 50.91(a)(6))
- Required when Licensee and NRC Must Act "Quickly" (Act in 1 to 3 Weeks)
.gtpl~
Managing Schedules
-IIm for LARs to
- - * ,E*
eF Support Plant Activities Davil Jaffe Senior Project M - NRC Comanche Peak Steam' itation Tuesday, June 10,
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Waivers Stephen bek Section Chie Tuesday, June 10
2 eq uireme for Fee
- Required by law to assess fees to r2 ver most of our budget
- FY2002 annual fee for power reactors licenl operate is $2,849,000 and the hourly rate for is $156
- FY2003 numbers should be available before the ei the month
- Fees are sent to treasury, are not retained by the '
NRC, and do not directly affect amount of funds available to NRC
June 10, 2003_3 Fees for Lic sing Actions
- Regarding licensing actions, ssesses fees for:
- Pre-application consultations
- New applications, amendments, & renewa
- Standard technical specifications
- Other licensing tasks requiring NRC approva
June 10, 2003 4 Billable Doc lated Activity
- Billable P? -t Manager activities incl
- Docket specific such as:
- Work licensing actil
- Discussions with NR(
on plant specific issi
. Site visits I. -i
. Responding to licensee questions r, .I I I i '. , ,
,1, : , 11 1,
- Attendance at this meeting
June 10, 2003 5 Billable on-Docket Related A vities
- Non-docket specific activities, suc
- Training
- Performing administrative tasks
- Scheduling, planning, coordinating work with te staff
- Staff meetings
- If a Project Manager has more than on docket, th non-docket specific activities are prorated equally to all assigned dockets
June 10, 2003 6 Non-BillabeiActivities
- Can not bill licensees for the f ing Project Manager activities:
- Leave, rulemaking, voluntary (unpaid) overtime, preparation of generic guidance documents, Freedom of Information Act requests, union activities, Combined Federal Campaigns
June 10, 2003 7 Fee Ex7 mptions
- NRC grants fee exemptions as ows (s ,ee 10 CFR 170.1 1):
- 1) Nonprofit educational institutions
- 2) Performance assessments or evaluation which the licensee volunteers at NRC's reqi and that are selected by the NRC
June 10, 20 8 Fee xemp on continued)
- 3) Requests or reports submitte he NRC:
- Response to a GL or Bulletin (except ting an amendment)
- Response to an NRC request (Associate Offi or above, e.g., Brian Sheron or Bill Borchardt to resolve an identified safety, safeguards, or environmental issue, or to assist NRC in developi rule, regulatory guide, policy statement, generic let or bulletin; or
- Means of exchanging information between industry organizations and the NRC to support NRC' s genenc regulatory improvements or efforts.
June 10, 20 9 Fee Exemp ons (continued)
- Regarding requests or reports submitted to the NRC:
- This fee exemption applies only when:
- 1) Report/request has been submitted to the NRC to supp C's development of generic guidance and regulations (e.g., reg guides, and policy statements; and
- 2) The NRC, at the time the document is submitted, plans to use one of the purposes stated in the above paragraph
- If you believe you meet the criteria for a fee exemption, request it with the application
- The decision on the fee exemption should be made prior to significant work being performed on your request
- Examples (See Handout)
OCFO WAIVERS UNDER 10 CFR 170.11 DATE OF LICENSEE NAME SUBJECT DECISION BASIS LETTER 04/15/2002 GE Nuclear Energy GE disputes the $1,377,000 of deferred costs Denied Licensee was aware of deferred costs, delayed billing does not relieve GE assessed under Part 170 for the review of the of its legal obligation to pay the fess associated with the services that the General Electric Standard Safety Analysis Report NRC provided in response to GE's request for a standardized design review.
(GESSAR). Reviews were ended in 1985 and 1986.
costs were deferred under the fee rule.
02/14/2002 Electric Power Research Inst. Request waiver of fess for review of EPRI's Topical Denied TR-102323, Rev. 2 was not submitted for the purpose of supporting NRC Report TR-102323, Rev 2, 'Guidelines for generic regulatory improvements or efforts, and NRC has no plans to revise Electromagnetic Interfernece (EMI) Testing in RG 1.180 to endorse TR-102323, Rev 2.
Power Plant Equipment.
02/05/2002 Nuclear Energy Insitute Request waiver of fees to review EPRI Technical Granted Revisions F and Gwere submitted for the purpose of supporting NRC's Report entitled, Guidelines for Addressing Fatigue generic regulatory improvements related to the treatment of fatigue Environmental Effects in a License Renewal environmental effects.
Application" 12/20/2001 Dairyland Power Cooperative Exemption from assessment of new Part 171 Denied OBRA-90 is consistent with the intent of the statute to collect 100 percent Deconissioning and Spent Fuel Pool annual fee. of the NRC's budget authority as it applies to all licensee in the class, Request based on old, and small. thereby establishng a fair and equitable basis for assessing annual fees for those licensees in decommission and/or have spent fuel pools.
12/05/2001 SouthernNuclearOp.Co. Partialexemptionto 10CFR 170feesforLicense Granted As the first BWR, a part of the safety review contributed to the Renewal development of generic regulatory documents.
10/23/2001 CEOG CE NPSD-994, -995, and -996, "Joint Application Granted - PartialThe review effort from Jan. 3, 1996 the February 28, 1997, was used to Reports for Safety Injection Tank (SIT), Low support generic regulatory improvements.
Pressure Safety Injection (LPSI), and Emergency Diesel Generator, (EDG) Allowed Outage Time (AOT) Extensions" 09/17/2001 CEOG CE NPSD-1 186 - TECHNICAL JUSTIFICATION DENIED SUBMITrAL OF REPORT DOES NOT MEET THE THE FEE WAIVER FOR RISK INFORMED MODIFICATION TO CRITERIA OF FOOTNOTE 4 TO 10 CFR 170.21.
SELECTED REQUIRED ACTION END STATES FOR CEOG PWRs 09/13/2001 .YLAND POWER COOPERAFULL OR PARTIAL EXEMPTION FROM THE DENIED EXAMINED BUDGETED COSTS ALLOCATED TO THE LACBWR SPENT FUEL STORAGE/REACTOR AND HAVE DTERMINED THAT THERE ISNO SIGNIFICANT DECOMMISSIONING ANNUAL FEE DIFFERENCE BETWEEN THE NRC'S REGULATORY COSTS FOR THE LACBWR AND THOSE FOR OTHER LICENSEES IN THE SPENT FUEL STORAGE/REACTOR DECOMMISSIONING CLASS.
Page 1 of6 Thursday, May 29, 2003 29, 2003 Page of 6
DATE OF LICENSEE NAME SUBJECT k'DECISION BASIS LETTER I .-;rv~~~~
06/13/2001 EPRI REVISED RISK-INFORMED INSERVICE GRANTED FOOTNOTE 4 -
INSPECTION EVALUATION PROCEDURE INFORMATION TO BE USED TO StJPPORT NRCS GENERIC REGULATORY IMPROVEMENTS, SPECIFICALLY RE: RI-ISI 03/02/2001 TVA RI-ISI AS AN ALTERNATIVE FOR ASME ANTED - PART PART 170.11 (bX 1) - PARTIAL WAIVER IS APPROPRIATE FOR THAT SECTION Xi CODE CLASS PIPING AND PORTION OF THE BFN'S UNIT 3 SUBMITTAL THAT STAFF AUSTENITIC STAINLESS STEEI, PIPING FOR DETERMINED HAD GENERIC APPLICABILITY.
BROWNS FERRY UNITS 2 AND 3 02/27/2001 VEPCO REQUEST FEE WAIVER FOR SURRY GRANTED PART 170.11 (b I) - PARTIAL WAIVER FOR PORTION OF THIS INDEPENDENT SPENT FUEL STORAGE FIRST-OF-A-KIND REVIEW EFFORT THAT SUPPORTS INSTALLATION LICENSE RENEWAL DEVELOPMENT OF THE GENERIC PART 72 LICENSE RENEWAL PROCESS.
01/18/2001 CON EDISON CO. ACCIDENT SOURCE TERMS FOR LIGHT- GRANTED PART 170.1 I(bXI1) - STAFF USED EXPERIENCE TO ASSIST IN WATER NUCLEAR POWER PLANTS PREPARATION OF THE REGULATORY GUIDANCE, STANDARD REVIEW PLAN AND RULEMAKING.
01/16/2001 VEPCO ALTERNATIVE RADIOLOGICAL SOURCE GRANTED PART 170.1 I(bX1) - STAFF USED EXPERIENCE TO ASSIST IN TERMS FOR EVALUATION DESIGN BASIS PREPARATION OF THE REGULATORY GUIDANCE, STANDARD ACCIDENTS AT NUCLEAR POWER RXs REVIEW PLAN AND RULEMAKING.
01/16/2001 GRAND GULF NGS ALTERNATIVE SOURCE TERM PILOT PLANT GRANTED FOOTNOTE 4-PROGRAM PARTICIPATION OF GGNS AS PILOT PLANT AND MEMBER OF NEW TASK FORCE SUPPORTED THE DEVELOPMENT OF THE RULE AND ASSOCIATED RG.
07/31/2000 TXU ELECTRIC CO. CONTROL OF HAZARD BARRIERS GRANTED PART 170.1 I(bXI) - INFORMATION PROVIDED IN TIHE TOPICAL REPORT LED TO THE CONCLUSION THAT THE RESOLUTION OF THIS ISSUE IS GENERIC IN NATIURE AND NOT PLANT SPECIFIC 02/08/2000 TXU ELECTRIC FIRST-OF-A-KIND RISK-INFORMED GRANTED PART 170.1I(bXI1) - TXU ELECTRIC PARTICIPATION IN THE RI-IST INSERVICE TESTING PROGRAM TO PILOT EFFORT PROVIDED NRC WITH A PERMANENT APPROACH DETERMINE INSERVICE TEST FREQUENCIES TO RI-IST. EXPERIENCE GAINED THROUGH THE PILOT FOR CERTAIN VALVES AND PUMPS THAT APPLICATION IN THE PROPOSED RULEMAKING PROCESS TO ARE CATEGORIZED AS LOW SAFETY MODIFY 50.55a TO EXPLICITLY ENDORSE Rl-IST METHODOLOGY.
SIGNIFICANT 01/06/2000 MOAB MILL SITE COURT APPOINTED GRANTED PART 170.1 (bX 1) - ALL FUNDS AVAILABLE TO PWC FROM THE PRICEWATERHOUSECOOPERS LLP (PWC), TRUST SHOULD BE USED TO OPTIMIZE SITE REMEDIATION.
TRUSTEE FOR ATLAS MOAB MILL ATLAS DECLARED BANKRUPTCY AND PURSUANT TO THE TERMS OF SETTLEMENT COURT-APPROVED REOGRANIZATION NOT REQUIRED TO COMPLETE THE REMEDIATION. EXEMPTION GIVEN TO PWC (TRUSTEE) IN THE PUBLIC INTEREST.
Page 2 of 6 Thursday, May 29,2003 Thursdaty, 29, 2003 Page 2 of 6
DATE OF LICENSEE NAME SUBJECT DECISION BASIS LETTER 10/29/1999 ARIZONA PUBLIC SERV. RISK-INFORMED INSERVICE TESTING GRANTED PART 170.1 1(b)( I) - APS WAS ASKED TO PARTICIPATE IN PILOT PROGRAM PILOT PLANT REVIEW PROGRAM AND NRC ACCEPTED THEIR SUBMITTAL, UTILIZED THE EXPERIENCE GAINED THROUGH THE REVIEW TO MODIFY 50.S5a TO EXPLICITLY ENDORSE RI-IST METHODOLOGY.
10/21/1999 PA POWER& LIGHT CO PART 50 EXEMPTION REQUEST RE: THE GRANTED PART 170.1 1(bX 1) - PA P&L WAS REQUIRED TO REQUEST CONDUCT OF A FULL PARTICIPATION EXEMPTION FROM PART 50 REQUIREMENT DUE TO FEMA AND EXERCISE OF THE ONSITE AND OFFSITE NRC REGION I'S NEED TO RESCHEDULE EMERGENCY EXERCISE EMERGENCY PLANS AT THEIR SITE - SHOULD NOT HAVE TO INCUR COSTS FOR REVIEW OF PART 50 EXEMPTION.
07/27/1999 VARIOUS NRR'S PILOT INSPECTION PROGRAM - GRANTED PART 170.1 I(bXI) - FEE IS WAIVED FOR CERTAIN INSPECTION REGULATORY OVERSIGHT PROGRAM - 13 EFFORT RELATED TO NRR'S NEW REGULATORY OVERSIGHT PLANT INSPECTIONS PROCESS THAT AFFECTS ALL NUCLEAR POWER PLANTS. FULL IMPLEMENTATION WILL COMMENCE PENDING SUCCESSFUL COMPLETION OF PILOT PROGRAM.
04/30/1999 IN UNIV.MEDICAL CTR IUMC AND ROUDEBUSH VETERANS ADMIN. GRANTED PART 170.1 1(b)( I) - SEPARATE LICENSES ARE MAINTAINED, MEDICAL CTR (VAMC) EXPLORING FACULTY MEMBERS HAVE JOINT APPOINTMENTS BETWEEN POSSIBILITY OF INCINERATING IUMC AND VAMC. IUMC IS CURRENTLY LICENSED BY NRC TO RADIOACTIVE WASTE GENERATED BY PROCESS/INCINERATE ITS OWN RADIOACTIVE AND VAMC. HAZARDOUS WASTES. AS PART OF SHARE PROGRAM IUMC WILL INCINERATE VAMCs WASTE WITHOUT A PROFIT MARGIN BUILT INTO THE COST FOR TIME AND MATERIALS. PUBLIC INTEREST.
04/21/1999 ALPHA-IDAHO, LLC APPLICATION FOR A NEW LICENSE FOR GRANTED PART 170.11 (bX I) - NO NEED TO AMEND YOUR LICENSE TO CALIBRATION USING SMALL QUANTITIES INCLUDE FEE CATEGORIES IC AND 2C BECAUSE OF THE SMALL OF VARIOUS NUCLEAR MATERIALS FEE QUANTITY OF SPECIAL NUCLEAR MATERIALS COULD BE CATEGORY 3P. LCENSEE THEN WANTED TO GENERALLY LICENSED. WAIVE APPLICATION FEE IC AND 2C ADD TO LICENSE CATEGORIES IC AND 2C. AS WELL AS AMENDMENT FEE.
03/24/1999 BG&E COMPANY CALVERT CLIFFS NPP - APPLICATION FOR GRANTED PART 170.11 (b)( I) - APPLICATION REPRESENTS FIRST-OF-A-KIND LICENSE RENEWAL EFFORT FOR BOTH NRC AND INDUSTRY. STAFF INTENDS TO UTILIZE EXPERIENCE GAINED TO DEVELOP GENERIC IMPLEMENTATION GUIDANCE FOR LICENSE RENEWAL PROCESS FOR WHOLE INDUSTRY. (PARTIAL) 03/24/1999 DUKE ENERGY CORP. OCONEE NPP - APPLICATION FOR LICENSE GRANTED PART 170.1 1(bX I) - APPLICATION REPRESENTS FIRST-OF-A-KIND RENEWAL EFFORT FOR BOTH NRC AND INDUSTRY. STAFF INTENDS TO UTILIZE EXPERIENCE GAINED TO DEVELOP GENERIC IMPLEMENTATION GUIDANCE FOR LICENSE RENEWAL PROCESS FOR WHOLE INDUSTRY. (PARTIAL)
Page 3 of 6 May 29,2003 Thursday, May 29, 2003 Page 3of 6
DATE OF LICENSEE NAME SUBJECT DECISION BASIS LETTER 03/11/1999 CENTERIOR PERRY - LEAD PILOT PLANT APPLICATION GRANTED PART 170.11(bX))- FIRST-OF-A-KIND APPLICATION FOR THE FOR THE USE OF THE REVISED ACCIDENT REVIEW OF REVISED ACCIDENT SOURCE TERM - STAFF USED SOURCE TERM METHODOLGY EXPERIENCE IN PREPARATION OF REGULATORY GUIDANCE, STANDARD REVIEW PLAN AND ASSOCIATED RULEMAKING.
09/04/1998 SUPERIOR WELL SERV. WITHDRAWAL OF AMENDMENT TO ADD A GRANTED PART 170.11 (bX 1) - LICENSEE OBTAINED THE GENERALLY-CESIUM 137 SEALED SOURCE TO THEIR LICENSED DEVICES FROM THE MANUFACTURER AND LICENSE WITHDREW THE APPLICATION FOR A SPECIFIC LICENSE. NRC REVIEWER DIED AND WORK ASSIGNED TO OTHER STAFF WHO DIDN'F KNOW ABOUT THE WITHDRAWAL OF THE SPECIFIC LICENSE APPLICATION. COSTS REFUNDED 09/0111998 VT YANKEE NUCLEAR VT YANKEE PILOT PLANT - RISK- GRANTED PART 170.11 (b(1) - PROVIDES THE PERMANENT APPROACH TO INFORMED INSERVICE INSPECTION RI-ISI - STAFF INTENDS TO UTILIZE EXPERIENCE GAINED THROUGH THE PILOT APPLICATIONS IN PROPOSED RULEMAKING PROCESS TO MODIFY 10 CFR 50.55a & RELATED GUIDANCE DOCUMENTS.
08/18/1998 ENTERGY ANO PILOT PLANT - RISK-INFORMED GRANTED PART 170.1 1(bX1) - PROVIDES THE PERMANENT APPROACH TO INSERVICE INSPECTION RI-ISI - STAFF INTENDS TO UTILIZE EXPERIENCE GAINED THROUGH THE PILOT APPLICATIONS IN PROPOSED RULEMAKING PROCESS TO MODIFY 10 CFR 50.55a 06/16/1998 VARIOUS NMSS REQUEST - EXEMPTION FROM FEE GRANTED PART 170.1 I(bXI ) - THERE IS NO TECHNICAL REVIEW REQUIREMENTS FOR LICENSE AMENDMENT ASSOCIATED WITH THE ISSUANCE OF AMENDMENTS; FILED BY AND ISSUED TO FIXED GUAGE ISSUANCE OF AMENDMENTS IS AN ADMIN. MATTER; AND SELF-SHIELDED IRRADIATOR MAINTAINING LISTING OF CURRENT RSO IS FOR THE LICENSEES TO CHANGE THE RADIATION CONVENIENCE OF THE AGENCY SAFETY OFFICER (RSO) 06/12/1998 VEPCO SURRY PILOT PLANT SUBMITTAL - RISK- GRANTED PART 170.1 I(bXI) - PROVIDES THE PERMANENT APPROACH TO INFORMED INSERVICE INSPECTION - RI-ISI - STAFF INTENDS TO UTILIZE EXPERIENCE GAINED THROUGH THE PILOT APPLICATIONS IN PROPOSED RULEMAKING PROCESS TO MODIFY 10 CFR 50.55a 02/26/1998 INTERSTATE NUC. SERV. LICENSEE CONDUCTED SOME SITE GRANTED PART 170.11(bXl) - ONE-TIME ACTIVITY WILL FACILITATE REMEDIATION WORK IN VOLUNTARY DECONTAMINATION OF THE NUCLEAR LAUNDRY FACILITY COOPERATION WITH NRC REGION I STAFF THAT IS IN THE POSSESSION OF A NON-LICENSEE. NO FEE AT A FORMER NUCLEAR LUNDRY FACILITY. CHARGED FOR AMENDMENT TO INS LICENSE TO TEMPORARILY RECEIVE AND STORE RADIOACTIVE WASTE.
Page 4 of6 Thursday, May ThursdRy, 2003 29, 2003 May 29, Page 4of 6
DATE OF LICENSEE NAME SUBJECT DECISION BASIS LETTER 11/12/1997 ATLAS CORP. FEE FOR MODELING AND DETERMINATION GRANTED PART 170.1 1(b)( I) - NRC AGREED TO FUND ONE TASK IN ORDER OF SEEPAGE FROM THE TAILINGS INTO THE TO ISSUE THE FINAL ENVIRONMENTAL IMPACT STATEMENT GROUNDWATER OVER THE 100 -YEAR (FEIS) SO THAT ATLAS COULD PROCEED TO RECALIM THE 10.5 DESIGN LIFE OF THE RECLAMATION MILLION TONS OF URANIUM MILL TAILINGS AT THE SITE.
TASK IS VIEWED AS A CONFIRMATORY ANALYSIS OF ANALYSIS ALREADY PERFORMED BY NRC AND ORNL FOR WHICH ATLAS WAS BILLED IN THE PAST.
10/03/1997 Arizona Public Service CO. Request fee exemption inder the provision of Part Granted NRC agrees that the submittal meets the criteria for the fee waiver provided 170.21, footnote 4, item 3 for NRC review of the in 170.21, Footnote 4, item 3. The National Technologu and Advancement NIST National Voluntary Lab. Accreditation Act of 1995 requires agencies to use consensus technical standards unles Program (NVLAP) to determine if it contains they are not appropriate to agency needs. NRR confirmed that clarification controls sufficient to allow NRC licensees and 10 of the audit requirements of NVLAP accredited laboratorieis is a matter of CFR 50 Appendix B auidet calibration service generic interest to all nuclear plant licensees.
providers to not have to audit NVLAP accredited laboratories.
09/08/1997 ST. LOUIS UNIV. REQUEST EARLY IMPLEMENTATION OF GRANTED PART 170.1 I(bXI) - LICENSE WAS AMENDED TO GRANT REVISED 10 CFR 35.75 DUE TO A PATIENTS HOSPITAL AUTHORITY TO IMPLEMENT THE PROVISION OF 10 MEDTCAL CONDITION AND UNIQUE CFR 35.75 EARLY, SO AS NOT TO UNNECESSARILY DELAY PERSONAL CIRCUMSTANCES MEDICAL TREATMENT TO PATIENT. ALL ELEMENTS WERE IN PLACE FOR ADMINISTERING THE FINAL RULE, NO TECHNICAL REVIEW WAS REQUIRED TO GRANT REQUEST. HOSPITAL WOULD HAVE TO PASS ON COSTS FOR AMENDMENT, IT WAS DEEMED UNFAIR TO BURDEN PATIENT WITH AMENDMENT FEE DUE TO UNFORTUNATE TIMING OF MEDICAL CONDITION. (2 WEEKS PRIOR TO NEW RULE) 06/23/1997 KINNCO/KINNSCAN OGC REQUESTING THAT NRC NOT ASSESS GRANTED PART 170.1 I(bXI) - IN PUBLIC INTEREST TO TRANSFER LICENSE AN AMENDMENT FEE TO KINNCO OR BACK TO KINNCO, HAVE SETTLEMENT AGREEMENT SIGNED, KINNSCAN FOR NAME CHANGE TO COLLECT THE UNPAID ANNUAL FEES AND CIVIL PENALTIES TRANSFER THE TITLE OF ITS MATERIALS AND CLOSE THE CASE.
LICENSE FROM K[NNSCAN TO KINNCO.
04/21/1997 VARIOUS NRR'S PILOT INSPECTIONS - FIRE GRANTED PART 170.11 (bX I) - PRIMARY PURPOSE OF THE PILOT PROTECTION FUNCTIONAL INSPECTION INSPECTIONS IS TO TEST THE DRAFT FPFI PROCEDURE AND (FPFI) PROGRAM IDENTIFY NEED FOR ANY REVISIONS BEFORE PROCEDURE IS INCORPORATED INTO THE REACTOR INSP PROG.
01/24/1997 DR. DALE E. EDLIN MORE THAN ONE LICENSEE HAVING THE GRANTED PART 170.1 1(bX 1)- AMENDMENT REQUEST FILED BY DR. EDLIN SAME PLACE OF USE ON THEIR LICENSE TO REMOVE THE DUPLICATE LOCATION FROM HIS LICENSE TO CAUSES CONFLICTS IN AUTHORITY AND CONFORM WITH AGENCY POLICY SHOULD BE EXEMPT FROM RESPONSIBILITY OVER THE RADIATION FEES SAFETY Page 5 of 6
- Thursday, Thursday, May 2993 29, 2003 May 29, Page 5 of 6
DATE OF LICENSEE NAME SUBJECT DECISION BASIS LETTER 11/29/1996 NEI Risk-infonned Inservice Inspection Evaluation Granted The non-proprietary version is not subject to fees in accordance with Procedure, EPRI Report TR-106706. This is the criterion three of Footnote 4 of 10 CFR Part 170.21.
non-proprietary version of TR- 106218.
09/18/1996 VARIOUS NMSS REQUEST- EXEMPTION FROM GRANTED PART 170.1 l(b)(1) - THERE IS NO TECHNICAL REVIEW REQUIREMENTS FOR LICENSE AMENDMENT ASSOCIATED WITH THE ISSUANCE OF AMENDMENTS; FEES FILED BY AND ISSUED TO PORTABLE ISSUANCE OF AMENDMENTS IS AN ADMIN. MATTER; GAUGE LICENSEES TO CHANGE THE MAINTAINING CURRENT RSO IS FOR CONVENIENCE OF THE RADIATION SAFETY OFFICER (RSO) COMMISSION.
05/30/1996 BG&E and Duke Power Co. Partial waiver fo Part 170 fees for the review of Granted-Partial The part of the NRC review that supports the development of the standard generic license renewal technical reports for one review plan, regulatory guide, and inspection guidance meets criteria 2 of licensee from each owners group. footnote 4 of 170.21. NRR established both a generic and a site specific TAC in order to separately keep track of the time being expended for each review and to provide a record upon which to bill Part 170 fees for the plant specific reviews.
06/02/1994 CEOG CEN-607 - REACTOR VESSEL HEAD GRANTED PART 170.1 1(bXI) - REPORTS PROVIDE INFORMATION THAT IS PENETRATION CRACKING BEING USED TO DETERMINE WHAT, IF ANY, GENERIC REGULATORY ACTIONS ARE NEEDED TO ADDRESS A GENERIC SAFETY CONCERN.
06/02/1994 B&WOG BAW-10190P - REACTOR VESSEL HEAD GRANTED PART 170.1 1(bXI) - REPORTS PROVIDE INFORMATION THAT IS PENETRATION CRACKING BEING USED TO DETERMINE WHAT, IF ANY, GENERIC REGULATORY ACTIONS ARE NEEDED TO ADDRESS A GENERIC SAFETY CONCERN.
05/27/1994 SQUG GENERIC IMPLEMENTATION PROCEDURE GRANTED REPORT WAS EXEMPT FROM 170 FEES - SUBMITTED IN (GIP) SEISMIC QUALIFICATION UTILITY RESPONSE TO GENERIC LETTER$& DID NOT RESULT IN THE GROUP GENERIC BASIS FOR UTILITIES TO REVIEW OF AN ALTERNATE METHOD OR REANALYSIS TO MEET ADDRESS ISSUES IN GL 87-02 THE REQUIREMENTS OF GL-87-02 (BEFORE FOOTNOTE) 05/20/1994 NEI EPRI-102470 - ANALYSIS OF HIGH- GRANTED BEST INTEREST OF COMMISSION NOT TO ASSESS FEES UNDER FREQUENCY SEISMIC EFFECTS PART 170.21 - INFORMATION SUPPORTS POTENTIAL GENERIC REGULATORY IMPROVEMENTS. (BEFORE FOOTNOTE) 04/14/1994 NEI SAFETY RELATED MOTOR OPERATED GRANTED PART 170.11 (bX1) USE OF METHODOLOGY WILL PROMOTE VALVE TESTING AND SURVEILLANCE - GL UNIFORMITY IN THE DETERMINATION OF VALVE SWITCH 89-10 EPRI FINAL TOPICAL REPORT SEITINGS & UTILITY RESPONSES TO GL 89-10 Page 6 of 6 Thursday, 29, 2003 May 29, Thursday, May 2003 Page 6of 6
Quality of Submittals Revisited I : 4 ack Donohew Senioi Pr Manager, NRC Call away Station Palo Verdc 0%. Nucl Station, Wolf Creel kNuclear Lon Tuesday, June
June 11, 2003 2 Gula ce
- LIC-101, Amendments
- LIC-102, Relief Request Reviews
- LIC- 103, Requests For Exemption From The Regulations
- NEL White Paper Dated August 2001 II
June 11, 2003 3 Goals of Lice es and NRC
- Licensee sends all the informa need for NRC's regulatory decision
- NRC requests only what is needed for regulatory decision in one RAI
June 11, 2003 4 RC Perspective of V.
rovements
\0 I.
1.
t S ded
- Provide date licensing action needed the basis
- Provide time to implement amendment
- Provide precedents
- Provide electronic copy of submittal and clean copy of TS pages
June 11, 2003 5 IOOF .(a)
- Signed original of written corre dence to DCD, Washington, DC 20555
- List NRC-specified addresses on submi as receiving copy
June 11, 2003 6 Incorrect Addr ed Submittal
Quality of Submittals Revisited t.
. ****IK ..,
4 Jack Donohew Senior Prl IManager, NRC Callaway 1' XStation Palo Verde Nuclear ,gStation Wolf Creek Nuclear ( ton Tuesday, June
.0) 1.0
-9 0
Quality and Role of SERs Today Robert A Section Chie Tuesday, June 10
June 10, 2003- 2 ROLE OF ETY EVALUATI ONS
- LIC- 0 1 and LIC- 102 provide outlines content
- Introduction
- Regulatory Evaluation
- Technical Evaluation
- Commitments
- Conclusion
- SEs provide regulatory basis for NRC decisions ox licensing actions
June 10, 20 3 ROLE 3F SAFETY EVALUATIONSontinued
- SEs cite pertinent regulations and re criteria
- SEs describe staff rationale for why chang is/is not acceptable
June 10, 200 4 RLi F SAFETY EVALUATIONS continued
- Licensees provide licensing bases information aof application
- Staff works with licensee to capture important informa the licensing basis
- License condition
- TSs
- Other licensee controlled document (FSAR, TRM, QA program..
- Commitment
- SEs describe licensee commitments relied upon to make licensing decision
- SEs are generally not directly enforceable
Junl 10 2003!A , n UT E ATIONS continuiu
- Unique Cases where SEs may contain new licensin is information
- ASME code relief under IST 50.55a(f)(6)(i) and Inservice n 50.55a(g)(6)(i)
- For relief sought when code requirements are impractical, "Th commission may grant relief and may impose alternative require
- SEs provide insights for licensee consideration on what informat include in FSAR updates per 50.7 1(e) and NEI 98-03
- NRC insights on relative importance of analysis performed by licensee with respect to NRC approval of the change
- If SE contains a factual error of importance/safety significance -
contact PM to discuss need to issue a correction _
June 10, 2003 6 QUALI F SEs
- Expectation is that staff products are accurate an(
fully support licensing decisions
June 10, 2003 7 QUALITY OF SEs - continued
- Technical reviewer self-checks
- Technical staff peer reviewer (optional/documented)
- Technical SC (documented)
- LA for integrated SE
- DLPM SC for integrated SE (documented)
June 10, 2003 8 QUALITY OF - continued
- Results evaluated and trended? NRR Office level basis
- Office Instruction to be prepared folloN' pilot
- Quality Initiative to expand to include othe NRR work products
Quality and Role of SERs Today Robert A.
Section C Tuesday, June 10
PROCESS STANDARD: Assessing Safety Evaluation Quality - For Integrated SE Package TASK: Prepare safety evaluation input for licensing actions satisfying the attributes listed below (i.e., A through F)
ITERATION PC 1 2 3 4 (circle)
Plant & TAC Number(s):
Prepared By: Date Submitted:
Peer Consultation (PC) By: Date Reviewed: _
Peer consult is highly recommended; however, it is optional. It should be used to determine if the attributes described below have been successfully incorporated into the safety evaluation input prior to concurrence.
Section Chief Review: Date Reviewed:
ATTRIBUTE Y N COMMENT A The introduction section briefly describes the amendment request (LIC-101, 4.5.1).
B The regulatory evaluation section provides the regulatory framework for the licensee's action, including a summary of design features, licensing bases, and relevant regulatory standards/acceptance criteria (LIC-101, 4.5.2).
C The evaluation section includes an independent analysis of the proposal in terms of the regulatory requirements, established staff positions, industry standards, or other relevant criteria; document covers the full scope of important issues. Each evaluation subsection specifically identifies the basis for approving or disapproving the amendment request (LIC-101, 4.5.3).
ATRIBUTE Y N COMMENT D All information used in the SE to make a regulatory decision is formally submitted to. the NRC and properly references the date, author, and subject (or is reasonably inferred from general knowledge, regulatory requirenents, or standard industry practice). Where appropriate, the SE identifies the regulatory commitments made by the licensee.
E Evaluation Conclusion - Document includes a sunmary or conclusion that restates the findings of the evaluation.
F Clear Writing - Concise sentences, active voice, subject-verb agreement, clear logic, unambiguous, clear pronouns. No typographical or punctuation errors (Provide type of errors). Grade typographical or grammatical errors as Low or High. Errors are low if they are few and manageable such that they are easily corrected, and high if errors are numerous or a consistent pattern of mistakes appear. Return to TB/author if SE contains a high number of errors.
DLPM Licensing Assistant (LA) (or optional secretary) Typographical Grammatical review includes Attributes D and F from the template errors detected errors detected above. (See Attribute F (See Attribute F for instructions) for instructions)
Date LA Review: Reviewed:
Additional Comments:
Use of Task Interface Agreements DyLanne neaud Intern,t.
Tuesday, June 101
June 10 2 What isaask Interface Agreeme>T IA)
- A request for technical assistance from a region or another NRC office that contains questions on subjects within the scope of NRR's mission and responsilbilities
June 10, 2003 3 ReasonMor TIAs
- Responses to:
- A generic issue
- A policy issue
- A specific plant event
- An inspection finding
- An issue identified by a licensee
June 10, 2003 4 Seeking ation on:
- Specific plant licensing bases
- Regulatory requirements
- NRR technical positions
- The safety or risk significance of particular plant configurations or operating practices
June 10, 2003 5 TIA Pa el
- TIA SES Process Owner
- A management representative of at least t Branch Chief level from the requesting office
June 10, 2003 6 P S
- Issue is discussed by telephone
- Submittal mutually agreed p I upon within a week of initial request
June 10, 2003 7 AT KS iot needed in the fol lowi.cases:
- The staff has previously expressed a pos
- The inspection findings involve the performak significance evaluation that can be done within th
- Inspection finding was determined to be GREEN
- A more efficient means of answering a question would n compromise the NRC's regulatory function
June 10, 2003 8 TIA not nee ed (continued):
/ Do not concern policy
- Mutually agreed to have very lo significance and can be answered b lephone or e-mail
June 10, 2003 9 Priori aTIA
- Safety and risk significance
- Operational impact
- Regulatory impact
10 Involvement
- Interaction with licensee encou?, d to obtain clear and accurate informatil
- A written submittal from a licensee may requested
- Adverse impact on the licensee
da; Use of Task InterFace Agreements DyLanne 1 teaud Inte,Je 1 Tuesday, June 14
Bulletin 2002-01 RAI Lessons Learned k Donohew Senior Pro NRC Callaway i Ftation Palo Verde Nuclear Wolf Creek Nuclear Tuesday, June
June 10, 2003 2 B in2002-01 RAI Lesson trned
- Bulletin 2002-01 not explicit on w NRC wants to know
- what components were inspected
- how inspections were performed
- how discrepancies were dispositioned
- In RAI, staff acknowledged that it was not clea bulletin
- NRC generic communication process does not len itself to being specific
- evolving knowledge of problem
- political realities
- timeliness demanded for generic communication being issued vs. being specific information will be exchanged following the generic communication is this not what is to be expected
June 10, 2003 3 Bulletin 2002-Al rA""O Lessons Learned
- NRC and industry have different audiences
- Licensees need to convey there is no severe problem and it is contr n within existing licensing basis
- NRC needs to convey there is problem (why else the generic communica controlling the problem
- Effect of deregulation
- Can we develop means of industry/NRC interaction in the public domain
- NRC needs information from industry, but the interaction must be in the public dc
- Perhaps similar situations just can not be avoided
- Bulletin 2002-01 reflected NRR need to quickly request information
Bulletin 2002-01 RAI Lessons Learned w.~~~~~~~!* Ae ik Donohew Senior Pro A r, NRC Callaway1 Palo Verde Nuclearl Wolf Creek Nuclear Tuesday, June
r E.It Safety Conscious w /Work Environment
. '+
Moha. Thadani Senior Project I NRC Cooper Nuce South Texas Pi Tuesday, June 10,
~S-afety Conscious Work Pvironment l Commission's Statement of
- Safety Conscious Work Environment/Si Culture
- In a Staff Requirements Memorandum (SRM)
Dated March 26, 2003, the Commission Disapproved the Proposed Rulemaking and Approved the Discrimination Task Group (DTG)
Recommendations (Revised by Senior Management Review Team (SMRT))
June 10, 2003 2
Safe Conscious Work Eninen
- The Staff's Responses . _-
to March 26, 2003 SRM
- The SRM Outlines the Commission' s Recommendations June 10, 2003
r>o Safety Conscious i 1Work Environment Moha?&. Thadani Senior Project I NRC Cooper Nud,e South Texas P Tuesday, June 10,
Informal Communications (e.g., email draft information)
.1 1RDonohew inninr
%OI.. A . .I I r, NRC Callaway 1 ition Palo Verde Nuclear Wolf Creek Nuclear Tuesday, June
2 ommunications email)
- Emails and Letters which do not go through th Document Control Desk (DCD) quickly provides copies to P submittals going to DOD provides informal or draft does not go through licensees' QC/QA checks
- COM-203, "Informal Interfacing and Exchange of Inforn with Licensees and Applicants'
- covers conference calls where summaries are written in record book
- allows for informal communications between NRC/Licensees per 2.102
- Information used to make a regulatory decision must be docketed
June 10, 2003 3 Infor mmunica tons
>maiI)
- Informal Communications help improve efficie
- Quickly helps determine if what NRC needs on the is being provided
- Avoids multiple letter exchanges between NRC/License
- Information used to make a regulatory decision must be docketed
- Substantial information (letter needed) vs. Clarification (
call from licensee)
- PM judgment
June 10, 2003 4 I nfor nommunications (e. a al
- RAls can be docketed several ways
- letter issued by staff and responded to by license
- letter submitted by licensee referencing emails/calls
- Docketing informal communications in ADAMS
- memo to docket file describing call and/or describing/attaching em
- emails may have statements that information provided is confidential
- Informal communications should not include infor I I that would be withheld from public
- proprietary information
- safeguards information
Informal Communications (e.g., email, draft information) i .
k Donohew Senior Pro NRC Palo Verde Nuclear - tion Wolf Creek Nuclear Tuesday, June
Processing Submittals Associated with Security Issues Davilmmtl Jaffe Senior Projett NRC Comanche Peak Steam llation Wednesday, June 1
June 11, 2003 2 Protecting S fguards Information Withholding Sensitive Information
- Regulatory Issues Summary 200
- Fall 2003 NEI Licensing Issues Forum.,. .
June 11,2003 3 Doc enfts 1 Withheld frm Public Disclosure Classified Information
- National Security Information (NSI): information classifie Executive Order, whose compromise would case some degre to the national security.
- Restricted Data (RD): information classified by the Atomic Energ whose compromise would assist in the design, manufacture, or utili:
of nuclear weapons
June 11, 2003 me Wi4 Gveuments VVithheld from Pubi Disclosure Classified Information
- Information concerns physical protection vulne may be classified information.
- Clearance and "need-to-know" required for access
5 J%Documents VVithheld fro1/2ŽubIicDisclosure Safeguards Information (SGI)
Sensitive unclassified information authorized by t Energy Act
- SGI concerns the physical protection of operating powe reactors, spent fuel shipments, strategic special nuclear material, or other radioactive material.
June 11,2003 nts Withheld from 6 Publs3isclosure Other Sensitive Unclassified Information
- Should be withheld from Public Disclosure but does not me criteria
- 10 CFR 2.790(d)(1) states:
(d)The following information shall be deemed to be commerca inancial information within the meaning of subsection 9.17(a)(4 chapter.
(1) Correspondence and reports to or from the NRC which contain intormation or records concerning a licensee's or applicant's physic protection, classified matter protection, or material control and accou program for special nuclear material not otherwise designated as Safeguards Information or classified as NSI or RD
v Documents Withheld from Ric Disclosure Other Sensitive Unclassified I ation
- The NRC expects that licensees will continue St withholding of some information using this provis
- The NRC believes that the volume of material reque s to be withheld from public disclosure according to 10 CFR 2.790(d)(1) may increase.
- The NRC staff will interact with licensees on a case-by-case basis regarding the use of the provisions of 10 CFR 2.790(d)(1).
June 11,2003 8 Submit s Addressing Securit> sjes
- Change'olving Physical S
- FSAR Updates
- Miscellaneous Issue Under 10 CFR 2.790
Processing Submittals Associated with Security Issues Davi= Jaffe Senior Project A NRC Comanche Peak Steam ation Wednesday, June 1
Making Changes to the Plant Associated to Orders -
Process Guidance Robert A.
Section Chie Wednesday, June 1
June 10, 2003 _2 rd rs
- NRC may modify, suspend revoke a license with an order
- License modification orders: change in nt, procedures, personnel, or management co
- Suspension orders: remove threat to public he and safety, licensee interference with inspection/investigation
- Revocation orders: for conditions which would warrant refusal of a license on an original application
June 10, 2003 3 Order ntinued
- Cease and desist orders: stop an ithorized activity
- 1 CFR 2.202
- NRC Enforcement Manual Section 5.8, "Orde Modifying, Suspending, or Revoking License"
- Staff Handbooks
Ordrs - continued
. r Fhe Order will
- Identify hazardous condition or facts j action
- Specify action to be carried out
- Require a licensee response in 20 days (or ot time as specified in order) under oath and affirmation
- Require a demand for hearing within 20 days (or other time as specified in order)
June 10, 2003 5 Order continued
- -11...
- Response may consent to order whI waives right to hearing
- Response may present facts supporting posi for not consenting to the order and reasons w the order should not have been issued
- Response can demand a hearing to move Commission to set aside immediate effectiveness of the order
June 10, 2003 6 MODIFYINGJ\N ORDER
- Provisions of an order can be o by:
- Issuance of a follow-on order
- Issuance of a license amendment
- Following the self-contained change control pr the order
- Can be immediately effective if circumstances warrant
- If no hearing, becomes effective on day following deadline to request a hearing
June 10, 2003 7 MODIFY AN ORDER-contin
- If a hearing, becomes effective as (I; b,
determined in the N.
p I
hearing vz,: P-
,<O t I
- Requests for extension I fI of time to request a I I1 hearing can be made P.-, E111 to OE (or as described in the Order)
June 10, 2003 8 EXAMPLESMOF ORDERS EA 03-009 Interim Inspection Requirements for PWR R eads
- Order effective immediately until superceded by 50.55a cha swer or request for hearing does not stay immediate effectiveness
- ... all PWR Licenses identified in the Attachment to this Order sha modified to include the inspection requirements for RPV heads and a penetration nozzles identified in Section IV of this Order."
- "The Director, Office of Nuclear Reactor Regulation, may, in writing, rel rescind any of the above conditions...."
- Requests for relaxation associated with specific penetration nozzles will be evaluated by the NRC staff using its procedure for evaluating alternatives to the ASME code in accordance with 10 C.F.R. 50.55a(a)(3)." Section chiefs can sign out the relief
June 10, 2003 9 EXAMPLE&OF ORDERS-co ntiŽd EA 03-038: Cornpensatory Measures for Fitness-for-Dut ancements for Security Force Personnel ~_
- Order effective immediately, answer or request for hearing do immediate effectiveness
- "All Licensees shall.. .comply with the requirements described in At 2 to this Order except to the Licensee's security plans." il
- Licensees given 35 days to inform Commission if unable to comply, if compliance is unnecessary, or if implementation would violate regulations license
- Licensees to submit an implementation schedule in 35 days and report when full compliance achieved
- "The Director, Office of Nuclear Reactor Regulation may, by letter, relax or rescind any of the above conditions upon demonstration by the Licensee of good cause."
Making Changes to the Plant Associated to Orders -
- - *
- A Process Guidance Robert A mm Section Chied Wednesday, June
Perry Decision ack Donohew Senior I Pr~Manager, NRC Callaway Station Palo Verde Nuclear l ll JSaion Wolf Creek Nuclear Tuesday, June
June 11,2003 2 X < w w ~~ Perry
__~~~~~~~~~~~~ 0 S l \u~~~ecision
- Perry Decision: ASLB decision that a change to the Pel schedule for RPV material specimens per Part 50 Appen licensing amendment.
- Commission reversed decision: Only agency approvals grant "exceed existing licensing authority" are license amendments.
- withdrawal schedule change conforming to ASTM standard not a license amendment
- a change not conforming to ASTM standard is a license amendment.
June 11,2003 3 Perry lucision
- 10 CFR Parts 2 and 50 allows a few s for the staff to approve a license change:
- Exemption per 50.12
- Relief request per 50.55a
- Order per 2.202
- Amendment and Security program change per 50.90
- QA and EP program change per 50.54
- NRC approval must be by one of the above methods
- Orders can include the method for changing the requirements in the order (i.e., the RPV head inspection order).
June 11, 2003 4 Perry sion
- Examples
- Comanche Peak RTT change in corn and method of verification in TS RT de
- Diablo Canyon probability of detection in Note 2 stating upper voltage repair limit calculated by GL 95-05
Perry Decision
- 1. .
ack Donohew Senior I Rr^LManager, NRC Callaway 1' ;Station Palo Verde Nuclear I lIl HgStation glon.
li 'l Wolf Creek Nuclear Tuesday, June
--- X 50.59 Revised Rule Follow-up L** 19L Moh C:. Thadani Senior Proj ect I Ic ' , NRC Cooper Nuclei South Texas I Wednesday, June 1
50a Rievse Rule Fiw-up
- Revised Rule effective March 0 I1
- Inspection Procedure 71111.02 June 10, 2003 2
59 Revised Rule Folow-up I
- Experience
- NRC staff has questions about the approp Ss of the licensees implementation
- NEI believes that the NRC is inconsistent in judg a applicability of 10 CFR 50.59
- Future Action
- Industry Meeting - Need for Further Guidance?
June 10, 2003
50.59 Revised Rule 11 Follow-up Moha . Thadani Senior Projec er, NRC Cooper Nuclec South Texas P'1 Wednesday, June 1