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 Section Chie Tuesday, June 10.
iek
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 Desired comes
- More efficient and effective use of resources
- Better predictability
- Better quality control
- Continuous improvement 4
June 10, 2003 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 5
June 10, 200 6
What's D i for the PM?
- See Handout
June 10, 2003 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 7
June 10, 200 Im ementation F
- FY03 Define and communicate responsibili to staff Pilot standardized characterization process Pilot standards development process Standardize process steps for another product 8
'Ian
- 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 Implemientation Plan (co ntinued
- FY05 Repeat cycle of standards development an definition as needed Develop scheduling and planning optimization Implement performance monitoring scheme
- FY06 Start cycle of systematic process review and improvement Pilot centralized scheduling
."SS 9
Centralized Work Planning Stephen Section Clea 1
Tuesday, June 10
)ek
The Role of the DLPM Project Manager Before and After the Centralized Work Planning Pilot Program John Harrison 10/30102 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 Is on 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 PM - DLPM Project Manager SC - Technical Branch Section Chief STR - Senior Technical Reviewer WPC - Work Planning Center C:WPCVMaeteis\\PM job change.wpd
4 L Managing Schedules 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)
I tDay Submit LAR 1st Month Reviewers Assigned Noticed in Federal Register 3rd Month RAI to Licensee 5th Month Response to RAI 7th 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 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)
.on
Managing Schedules
.gtpl~
-IIm for LARs to Support Plant Activities Davil Jaffe Senior Project M
- NRC Comanche Peak Steam' itation Tuesday, June 10,
,E*
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NRCFees and F ee Waivers Stephen bek Section Chie Tuesday, June 10 Iyo w
f IIt B
AW Ke
$N i** JH -
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eq uireme for Fee
- Required by law to assess fees to r2 our budget ver most of 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 2
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 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
- Attendance at this meeting 4
r,.I I I
i '., ,
,1, : , 11 1,
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 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 6
June 10, 2003 Fee Ex7 mptions
- NRC grants fee exemptions as ows (s 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
,ee 7
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 02/14/2002 Electric Power Research Inst.
02/05/2002 Nuclear Energy Insitute GE disputes the $1,377,000 of deferred costs assessed under Part 170 for the review of the General Electric Standard Safety Analysis Report (GESSAR). Reviews were ended in 1985 and 1986.
costs were deferred under the fee rule.
Request waiver of fess for review of EPRI's Topical Report TR-102323, Rev 2, 'Guidelines for Electromagnetic Interfernece (EMI) Testing in Power Plant Equipment.
Request waiver of fees to review EPRI Technical Report entitled, Guidelines for Addressing Fatigue Environmental Effects in a License Renewal Application" Denied Licensee was aware of deferred costs, delayed billing does not relieve GE of its legal obligation to pay the fess associated with the services that the NRC provided in response to GE's request for a standardized design review.
Denied TR-102323, Rev. 2 was not submitted for the purpose of supporting NRC generic regulatory improvements or efforts, and NRC has no plans to revise RG 1.180 to endorse TR-102323, Rev 2.
Granted Revisions F and G were submitted for the purpose of supporting NRC's generic regulatory improvements related to the treatment of fatigue environmental effects.
12/20/2001 Dairyland Power Cooperative Exemption from assessment of new Part 171 Deconissioning and Spent Fuel Pool annual fee.
Request based on old, and small.
12/05/2001 SouthernNuclearOp.Co.
Partialexemptionto 10CFR 170feesforLicense Renewal 10/23/2001 CEOG Denied OBRA-90 is consistent with the intent of the statute to collect 100 percent of the NRC's budget authority as it applies to all licensee in the class, thereby establishng a fair and equitable basis for assessing annual fees for those licensees in decommission and/or have spent fuel pools.
Granted As the first BWR, a part of the safety review contributed to the development of generic regulatory documents.
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" CEOG CE NPSD-1 186 - TECHNICAL JUSTIFICATION FOR RISK INFORMED MODIFICATION TO SELECTED REQUIRED ACTION END STATES FOR CEOG PWRs 09/13/2001
.YLAND POWER COOPERAFULL OR PARTIAL EXEMPTION FROM THE SPENT FUEL STORAGE/REACTOR DECOMMISSIONING ANNUAL FEE DENIED SUBMITrAL OF REPORT DOES NOT MEET THE THE FEE WAIVER CRITERIA OF FOOTNOTE 4 TO 10 CFR 170.21.
DENIED EXAMINED BUDGETED COSTS ALLOCATED TO THE LACBWR AND HAVE DTERMINED THAT THERE IS NO SIGNIFICANT DIFFERENCE BETWEEN THE NRC'S REGULATORY COSTS FOR THE LACBWR AND THOSE FOR OTHER LICENSEES IN THE SPENT FUEL STORAGE/REACTOR DECOMMISSIONING CLASS.
Thursday, May 29, 2003 Page 1 of6 09/17/2001 Thursday, May 29, 2003 Page of 6
LICENSEE NAME SUBJECT k'DECISION I
.-;rv~~~~
VEPCO GRAND GULF NGS 07/31/2000 TXU ELECTRIC CO.
02/08/2000 TXU ELECTRIC 01/06/2000 MOAB MILL SITE REVISED RISK-INFORMED INSERVICE INSPECTION EVALUATION PROCEDURE RI-ISI AS AN ALTERNATIVE FOR ASME SECTION Xi CODE CLASS PIPING AND AUSTENITIC STAINLESS STEEI, PIPING FOR BROWNS FERRY UNITS 2 AND 3 REQUEST FEE WAIVER FOR SURRY INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE RENEWAL ACCIDENT SOURCE TERMS FOR LIGHT-WATER NUCLEAR POWER PLANTS ALTERNATIVE RADIOLOGICAL SOURCE TERMS FOR EVALUATION DESIGN BASIS ACCIDENTS AT NUCLEAR POWER RXs ALTERNATIVE SOURCE TERM PILOT PLANT PROGRAM CONTROL OF HAZARD BARRIERS FIRST-OF-A-KIND RISK-INFORMED INSERVICE TESTING PROGRAM TO DETERMINE INSERVICE TEST FREQUENCIES FOR CERTAIN VALVES AND PUMPS THAT ARE CATEGORIZED AS LOW SAFETY SIGNIFICANT COURT APPOINTED PRICEWATERHOUSECOOPERS LLP (PWC),
TRUSTEE FOR ATLAS MOAB MILL GRANTED FOOTNOTE 4 -
INFORMATION TO BE USED TO StJPPORT NRCS GENERIC REGULATORY IMPROVEMENTS, SPECIFICALLY RE: RI-ISI ANTED - PART PART 170.11 (bX 1) - PARTIAL WAIVER IS APPROPRIATE FOR THAT PORTION OF THE BFN'S UNIT 3 SUBMITTAL THAT STAFF DETERMINED HAD GENERIC APPLICABILITY.
GRANTED PART 170.11 (b I) - PARTIAL WAIVER FOR PORTION OF THIS FIRST-OF-A-KIND REVIEW EFFORT THAT SUPPORTS DEVELOPMENT OF THE GENERIC PART 72 LICENSE RENEWAL PROCESS.
GRANTED PART 170.1 I(bXI1) - STAFF USED EXPERIENCE TO ASSIST IN PREPARATION OF THE REGULATORY GUIDANCE, STANDARD REVIEW PLAN AND RULEMAKING.
GRANTED PART 170.1 I(bX1) - STAFF USED EXPERIENCE TO ASSIST IN PREPARATION OF THE REGULATORY GUIDANCE, STANDARD REVIEW PLAN AND RULEMAKING.
GRANTED FOOTNOTE 4-PARTICIPATION OF GGNS AS PILOT PLANT AND MEMBER OF NEW TASK FORCE SUPPORTED THE DEVELOPMENT OF THE RULE AND ASSOCIATED RG.
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 GRANTED PART 170.1 I(bXI1) - TXU ELECTRIC PARTICIPATION IN THE RI-IST PILOT EFFORT PROVIDED NRC WITH A PERMANENT APPROACH TO RI-IST. EXPERIENCE GAINED THROUGH THE PILOT APPLICATION IN THE PROPOSED RULEMAKING PROCESS TO MODIFY 50.55a TO EXPLICITLY ENDORSE Rl-IST METHODOLOGY.
GRANTED PART 170.1 (bX 1) - ALL FUNDS AVAILABLE TO PWC FROM THE TRUST SHOULD BE USED TO OPTIMIZE SITE REMEDIATION.
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.
Thursday, May 29,2003 Page 2 of 6 DATE OF LETTER BASIS 06/13/2001 03/02/2001 02/27/2001 01/18/2001 01/16/2001 01/16/2001 Thursdaty, May 29, 2003 Page 2 of 6
LICENSEE NAME 10/29/1999 ARIZONA PUBLIC SERV.
10/21/1999 PA POWER& LIGHT CO RISK-INFORMED INSERVICE TESTING PROGRAM PILOT PLANT REVIEW PART 50 EXEMPTION REQUEST RE: THE CONDUCT OF A FULL PARTICIPATION EXERCISE OF THE ONSITE AND OFFSITE EMERGENCY PLANS GRANTED PART 170.1 1 (b)( I) - APS WAS ASKED TO PARTICIPATE IN PILOT PROGRAM AND NRC ACCEPTED THEIR SUBMITTAL, UTILIZED THE EXPERIENCE GAINED THROUGH THE REVIEW TO MODIFY 50.S5a TO EXPLICITLY ENDORSE RI-IST METHODOLOGY.
GRANTED PART 170.1 1 (bX 1) - PA P&L WAS REQUIRED TO REQUEST EXEMPTION FROM PART 50 REQUIREMENT DUE TO FEMA AND NRC REGION I'S NEED TO RESCHEDULE EMERGENCY EXERCISE AT THEIR SITE - SHOULD NOT HAVE TO INCUR COSTS FOR REVIEW OF PART 50 EXEMPTION.
NRR'S PILOT INSPECTION PROGRAM -
REGULATORY OVERSIGHT PROGRAM - 13 PLANT INSPECTIONS GRANTED PART 170.1 I(bXI) - FEE IS WAIVED FOR CERTAIN INSPECTION EFFORT RELATED TO NRR'S NEW REGULATORY OVERSIGHT PROCESS THAT AFFECTS ALL NUCLEAR POWER PLANTS. FULL IMPLEMENTATION WILL COMMENCE PENDING SUCCESSFUL COMPLETION OF PILOT PROGRAM.
04/30/1999 IN UNIV.MEDICAL CTR 04/21/1999 ALPHA-IDAHO, LLC 03/24/1999 BG&E COMPANY 03/24/1999 DUKE ENERGY CORP.
IUMC AND ROUDEBUSH VETERANS ADMIN.
GRANTED MEDICAL CTR (VAMC) EXPLORING POSSIBILITY OF INCINERATING RADIOACTIVE WASTE GENERATED BY VAMC.
APPLICATION FOR A NEW LICENSE FOR GRANTED CALIBRATION USING SMALL QUANTITIES OF VARIOUS NUCLEAR MATERIALS FEE CATEGORY 3P. LCENSEE THEN WANTED TO ADD TO LICENSE CATEGORIES IC AND 2C.
CALVERT CLIFFS NPP - APPLICATION FOR GRANTED LICENSE RENEWAL OCONEE NPP - APPLICATION FOR LICENSE GRANTED RENEWAL PART 170.1 1 (b)( I) - SEPARATE LICENSES ARE MAINTAINED, FACULTY MEMBERS HAVE JOINT APPOINTMENTS BETWEEN IUMC AND VAMC. IUMC IS CURRENTLY LICENSED BY NRC TO PROCESS/INCINERATE ITS OWN RADIOACTIVE AND 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.
PART 170.11 (bX I) - NO NEED TO AMEND YOUR LICENSE TO INCLUDE FEE CATEGORIES IC AND 2C BECAUSE OF THE SMALL QUANTITY OF SPECIAL NUCLEAR MATERIALS COULD BE GENERALLY LICENSED. WAIVE APPLICATION FEE IC AND 2C AS WELL AS AMENDMENT FEE.
PART 170.11 (b)( I) - APPLICATION REPRESENTS FIRST-OF-A-KIND 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)
PART 170.1 1 (bX I) - APPLICATION REPRESENTS FIRST-OF-A-KIND 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)
Thursday, May 29,2003 Page 3 of 6 DATE OF LETTER SUBJECT DECISION BASIS 07/27/1999 VARIOUS Thursday, May 29, 2003 Page 3of 6
LICENSEE NAME 03/11/1999 CENTERIOR 09/04/1998 SUPERIOR WELL SERV.
09/0111998 VT YANKEE NUCLEAR PERRY - LEAD PILOT PLANT APPLICATION FOR THE USE OF THE REVISED ACCIDENT SOURCE TERM METHODOLGY WITHDRAWAL OF AMENDMENT TO ADD A CESIUM 137 SEALED SOURCE TO THEIR LICENSE VT YANKEE PILOT PLANT - RISK-INFORMED INSERVICE INSPECTION GRANTED PART 170.11(bX))- FIRST-OF-A-KIND APPLICATION FOR THE REVIEW OF REVISED ACCIDENT SOURCE TERM - STAFF USED EXPERIENCE IN PREPARATION OF REGULATORY GUIDANCE, STANDARD REVIEW PLAN AND ASSOCIATED RULEMAKING.
GRANTED PART 170.11 (bX 1) - LICENSEE OBTAINED THE GENERALLY-LICENSED DEVICES FROM THE MANUFACTURER AND 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 GRANTED PART 170.11 (b(1) - PROVIDES THE PERMANENT APPROACH TO 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.
ANO PILOT PLANT - RISK-INFORMED INSERVICE INSPECTION NMSS REQUEST - EXEMPTION FROM FEE REQUIREMENTS FOR LICENSE AMENDMENT FILED BY AND ISSUED TO FIXED GUAGE AND SELF-SHIELDED IRRADIATOR LICENSEES TO CHANGE THE RADIATION SAFETY OFFICER (RSO)
SURRY PILOT PLANT SUBMITTAL - RISK-INFORMED INSERVICE INSPECTION -
GRANTED PART 170.1 1(bX1) - PROVIDES THE PERMANENT APPROACH TO RI-ISI - STAFF INTENDS TO UTILIZE EXPERIENCE GAINED THROUGH THE PILOT APPLICATIONS IN PROPOSED RULEMAKING PROCESS TO MODIFY 10 CFR 50.55a GRANTED PART 170.1 I(bXI ) - THERE IS NO TECHNICAL REVIEW ASSOCIATED WITH THE ISSUANCE OF AMENDMENTS; ISSUANCE OF AMENDMENTS IS AN ADMIN. MATTER; MAINTAINING LISTING OF CURRENT RSO IS FOR THE CONVENIENCE OF THE AGENCY GRANTED PART 170.1 I(bXI) - PROVIDES THE PERMANENT APPROACH TO 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 REMEDIATION WORK IN VOLUNTARY COOPERATION WITH NRC REGION I STAFF AT A FORMER NUCLEAR LUNDRY FACILITY.
GRANTED PART 170.11(bXl) - ONE-TIME ACTIVITY WILL FACILITATE DECONTAMINATION OF THE NUCLEAR LAUNDRY FACILITY THAT IS IN THE POSSESSION OF A NON-LICENSEE. NO FEE CHARGED FOR AMENDMENT TO INS LICENSE TO TEMPORARILY RECEIVE AND STORE RADIOACTIVE WASTE.
Thursday, May 29, 2003 Page 4 of6 DATE OF LETTER SUBJECT DECISION BASIS 08/18/1998 06/16/1998 06/12/1998 ENTERGY VARIOUS VEPCO ThursdRy, May 29, 2003 Page 4of 6
LICENSEE NAME 11/12/1997 ATLAS CORP.
10/03/1997 Arizona Public Service CO.
09/08/1997 ST. LOUIS UNIV.
06/23/1997 KINNCO/KINNSCAN 04/21/1997 VARIOUS 01/24/1997 DR. DALE E. EDLIN FEE FOR MODELING AND DETERMINATION GRANTED OF SEEPAGE FROM THE TAILINGS INTO THE GROUNDWATER OVER THE 100 -YEAR DESIGN LIFE OF THE RECLAMATION Request fee exemption inder the provision of Part Granted 170.21, footnote 4, item 3 for NRC review of the NIST National Voluntary Lab. Accreditation Program (NVLAP) to determine if it contains controls sufficient to allow NRC licensees and 10 CFR 50 Appendix B auidet calibration service providers to not have to audit NVLAP accredited laboratories.
REQUEST EARLY IMPLEMENTATION OF GRANTED REVISED 10 CFR 35.75 DUE TO A PATIENTS MEDTCAL CONDITION AND UNIQUE PERSONAL CIRCUMSTANCES OGC REQUESTING THAT NRC NOT ASSESS GRANTED AN AMENDMENT FEE TO KINNCO OR KINNSCAN FOR NAME CHANGE TO TRANSFER THE TITLE OF ITS MATERIALS LICENSE FROM K[NNSCAN TO KINNCO.
NRR'S PILOT INSPECTIONS - FIRE GRANTED PROTECTION FUNCTIONAL INSPECTION (FPFI) PROGRAM MORE THAN ONE LICENSEE HAVING THE GRANTED SAME PLACE OF USE ON THEIR LICENSE CAUSES CONFLICTS IN AUTHORITY AND RESPONSIBILITY OVER THE RADIATION SAFETY PART 170.1 1 (b)( I) - NRC AGREED TO FUND ONE TASK IN ORDER TO ISSUE THE FINAL ENVIRONMENTAL IMPACT STATEMENT (FEIS) SO THAT ATLAS COULD PROCEED TO RECALIM THE 10.5 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.
NRC agrees that the submittal meets the criteria for the fee waiver provided in 170.21, Footnote 4, item 3. The National Technologu and Advancement Act of 1995 requires agencies to use consensus technical standards unles they are not appropriate to agency needs. NRR confirmed that clarification of the audit requirements of NVLAP accredited laboratorieis is a matter of generic interest to all nuclear plant licensees.
PART 170.1 I(bXI) - LICENSE WAS AMENDED TO GRANT HOSPITAL AUTHORITY TO IMPLEMENT THE PROVISION OF 10 CFR 35.75 EARLY, SO AS NOT TO UNNECESSARILY DELAY 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)
PART 170.1 I(bXI) - IN PUBLIC INTEREST TO TRANSFER LICENSE BACK TO KINNCO, HAVE SETTLEMENT AGREEMENT SIGNED, COLLECT THE UNPAID ANNUAL FEES AND CIVIL PENALTIES AND CLOSE THE CASE.
PART 170.11 (bX I) - PRIMARY PURPOSE OF THE PILOT INSPECTIONS IS TO TEST THE DRAFT FPFI PROCEDURE AND IDENTIFY NEED FOR ANY REVISIONS BEFORE PROCEDURE IS INCORPORATED INTO THE REACTOR INSP PROG.
PART 170.1 1 (bX 1) - AMENDMENT REQUEST FILED BY DR. EDLIN TO REMOVE THE DUPLICATE LOCATION FROM HIS LICENSE TO CONFORM WITH AGENCY POLICY SHOULD BE EXEMPT FROM FEES Thursday, May 29, 2993 Page 5 of 6 DATE OF LETTER SUBJECT DECISION BASIS Thursday, May 29, 2003 Page 5 of 6
LICENSEE NAME SUBJECT DECISION 1 1/29/1996 NEI Risk-infonned Inservice Inspection Evaluation Procedure, EPRI Report TR-106706. This is the non-proprietary version of TR-106218.
09/18/1996 VARIOUS NMSS REQUEST-EXEMPTION FROM REQUIREMENTS FOR LICENSE AMENDMENT FEES FILED BY AND ISSUED TO PORTABLE GAUGE LICENSEES TO CHANGE THE RADIATION SAFETY OFFICER (RSO) 05/30/1996 BG&E and Duke Power Co. Partial waiver fo Part 170 fees for the review of generic license renewal technical reports for one licensee from each owners group.
06/02/1994 CEOG CEN-607 - REACTOR VESSEL HEAD PENETRATION CRACKING 06/02/1994 B&WOG BAW-10190P - REACTOR VESSEL HEAD PENETRATION CRACKING 05/27/1994 SQUG GENERIC IMPLEMENTATION PROCEDURE (GIP) SEISMIC QUALIFICATION UTILITY GROUP GENERIC BASIS FOR UTILITIES TO ADDRESS ISSUES IN GL 87-02 05/20/1994 NEI EPRI-102470 - ANALYSIS OF HIGH-FREQUENCY SEISMIC EFFECTS 04/14/1994 NEI SAFETY RELATED MOTOR OPERATED VALVE TESTING AND SURVEILLANCE - GL 89-10 EPRI FINAL TOPICAL REPORT Granted The non-proprietary version is not subject to fees in accordance with criterion three of Footnote 4 of 10 CFR Part 170.21.
GRANTED PART 170.1 l(b)(1) - THERE IS NO TECHNICAL REVIEW ASSOCIATED WITH THE ISSUANCE OF AMENDMENTS; ISSUANCE OF AMENDMENTS IS AN ADMIN. MATTER; MAINTAINING CURRENT RSO IS FOR CONVENIENCE OF THE COMMISSION.
Granted-Partial The part of the NRC review that supports the development of the standard review plan, regulatory guide, and inspection guidance meets criteria 2 of 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.
GRANTED PART 170.1 1(bXI) - REPORTS PROVIDE INFORMATION THAT IS BEING USED TO DETERMINE WHAT, IF ANY, GENERIC REGULATORY ACTIONS ARE NEEDED TO ADDRESS A GENERIC SAFETY CONCERN.
GRANTED PART 170.1 1(bXI) - REPORTS PROVIDE INFORMATION THAT IS BEING USED TO DETERMINE WHAT, IF ANY, GENERIC REGULATORY ACTIONS ARE NEEDED TO ADDRESS A GENERIC SAFETY CONCERN.
GRANTED REPORT WAS EXEMPT FROM 170 FEES - SUBMITTED IN RESPONSE TO GENERIC LETTER$& DID NOT RESULT IN THE REVIEW OF AN ALTERNATE METHOD OR REANALYSIS TO MEET THE REQUIREMENTS OF GL-87-02 (BEFORE FOOTNOTE)
GRANTED BEST INTEREST OF COMMISSION NOT TO ASSESS FEES UNDER PART 170.21 - INFORMATION SUPPORTS POTENTIAL GENERIC REGULATORY IMPROVEMENTS. (BEFORE FOOTNOTE)
GRANTED PART 170.11 (bX1) USE OF METHODOLOGY WILL PROMOTE UNIFORMITY IN THE DETERMINATION OF VALVE SWITCH SEITINGS & UTILITY RESPONSES TO GL 89-10 Thursday, May 29, 2003 Page 6 of 6 DATE OF LETTER BASIS Thursday, May 29, 2003 Page 6of 6
Senioi Call Palo Verdc Wolf Creel Quality of Submittals Revisited ack Donohew Pr Manager, NRC away Station 0%. Nucl
- Station, k Nuclear Lon Tuesday, June I : 4
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 Goals of Lice es
- Licensee sends all the informa and NRC need for NRC's regulatory decision
- NRC requests only what is needed for regulatory decision in one RAI 3
June 11, 2003 V.I.1.
RC Perspective of rovements
\\0 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 4
t
June 11, 2003 IOOF
.(a)
- Signed original of written corre to DCD, Washington, DC 20555
- List NRC-specified addresses on submi as receiving copy dence 5
June 11, 2003 Incorrect Addr ed Submittal Lg, PM pon r mi sends cop original, if po DCD lo 6
Quality of Submittals Revisited Jack Donohew Senior Prl Callaway 1' I Manager, NRC X Station Palo Verde Nuclear
,g Station Wolf Creek Nuclear (
Tuesday, June
.ton t.
. ****IK..,
4
Quality and Role of SERs Today Robert A Section Chie Tuesday, June 10
.0) 1.0
-9 0
June 10, 2003-ROLE OF ETY EVALUATI
- 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 n
10 2003!A 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 QUALI F
- Expectation is that staff products are accurate an(
fully support licensing decisions LIC-101, 6
June 10, 2003 QUALITY OF SEs - continued NRR Pilot Initiative on SE Quality for License dments Quality Attributes for SE extracted from LIC-101 (See t)
SE Quality Checks performed at various stages of SE Deve Technical reviewer self-checks Technical staff peer reviewer (optional/documented)
Technical SC (documented)
PM for SE inputs LA for integrated SE DLPM SC for integrated SE (documented) 7
June 10, 2003 QUALITY OF
- Results evaluated and trended?
- continued NRR Office level basis
- Office Instruction to be prepared folloN' pilot
- Quality Initiative to expand to include othe NRR work products 8
Quality and Role of SERs Today Robert A.
Section C Tuesday, June 1 0
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 Intern, t.
neaud Tuesday, June 101
June 10 2
What isaask I nterface 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 ReasonMor TIAs
- Responses to:
- A generic issue
- A policy issue
- A specific plant event
- An inspection finding
- An issue identified by a licensee 3
June 10, 2003 Seeking ation on:
- Specific plant licensing bases
- Regulatory requirements
- NRR technical positions
- The safety or risk significance of particular plant configurations or operating practices 4
June 10, 2003 TIA Pa el
- TIA SES Process Owner
- A management representative of at least t Branch Chief level from the requesting office 5
June 10, 2003 P
S
- Issue is discussed by telephone Submittal mutually agreed upon within a week of initial request
I 6
4
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
8 June 10, 2003 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 Priori aTIA
- Safety and risk significance
- Operational impact
- Regulatory impact 9
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
d a; Use of Task InterFace Agreements DyLanne 1
Inte, Je 1
Tuesday, June 14 teaud
Bulletin 2002-01 RAI Lessons Learned k Donohew Senior Pro Callaway i
Palo Verde Nuclear Wolf Creek Nuclear Tuesday, June NRC Ftation
June 10, 2003 B
in 2002-01 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 2
June 10, 2003 Bulletin 2002-Al Lessons Learned NRC and industry have different audiences Licensees need to convey there is no severe problem and it is contr 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 3
n within rA""O
Bulletin 2002-01 RAI Lessons Learned ik Donohew Senior Pro A
Callaway1 Palo Verde Nuclearl Wolf Creek Nuclear Tuesday, June r, NRC w.~~~~~~~ !* Ae
r Safety Conscious E.It 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) 1R Donohew A
%OI..
.I I
Callaway 1
Palo Verde Nuclear Wolf Creek Nuclear Tuesday, June r, NRC ition
.1 inninr
ommunications email)
Emails and Letters which do not go through th Control Desk (DCD) quickly provides copies to P submittals going to DOD provides informal or draft does not go through licensees' QC/QA checks Document 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 2
mmunica tons
>maiI)
I nfor Informal Communications help improve efficie Quickly helps determine if what NRC needs on the provided Avoids multiple letter exchanges between NRC/License Information used to make a regulatory decision must be docketed is being Substantial information (letter needed) vs. Clarification (
call from licensee)
PM judgment June 10, 2003 3
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 that would be withheld from public proprietary information safeguards information I I June 10, 2003 4
Informal Communications (e.g., email, draft information) k Donohew Senior Pro Palo Verde Nuclear -
Wolf Creek Nuclear Tuesday, June NRC tion i
Processing Submittals Associated with Security Issues Jaffe Senior Comanche Peak Steam Wednesday, June 1 NRC llation D avi lmmtl Projet t
June 11, 2003 Protecting S fguards Information Withholding Sensitive Information
- Regulatory Issues Summary 200
- Fall 2003 NEI Licensing Issues Forum.,..
2
3 June 11,2003 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 fro1/2ŽubIic Disclosure 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 Jaffe Senior Comanche Peak Steam Wednesday, June 1 NRC ation Davi=
Project A
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 Order ntinued
- Cease and desist orders:
activity stop an ithorized
- 1 CFR 2.202
- NRC Enforcement Manual Section 5.8, "Orde Modifying, Suspending, or Revoking License"
- Staff Handbooks 3
Ordrs - con tinued 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) r
June 10, 2003 Order continued
--11...
- Response may consent to order whI to hearing waives right
- 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 5
June 10, 2003 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 6
June 10, 2003 MODIFY contin
- If a hearing, becomes effective as determined in the hearing AN ORDER-
- Requests for extension of time to request a I
hearing can be made to OE (or as described in the Order)
(I; Ip t
I fI I1 7
b, N.
vz,: P-
,< O I
P.-,
E111
June 10, 2003 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 8
June 10, 2003 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."
9
Making Changes to the Plant Associated to Orders -
Process Guidance Robert A mm Section Chied Wednesday, June A
Perry Decision ack Donohew Pr~Manager, NRC Callaway Palo Verde Nuclear Wolf Creek Nuclear Station l ll JSaion Tuesday, June Senior I
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 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 4
Perry Decision Senior I ack Donohew Rr^LManager, NRC Callaway 1' Palo Verde Nuclear Wolf Creek Nuclear Tuesday, June
- Station I lIl HgStation g li 'l lon.
1.
.
50.59 Revised Rule Follow-up Moh C:. Thadani Senior Proj ect I Ic
, NRC Cooper Nuclei South Texas Wednesday, June 1 X
L** 19L I
50a Rievse Rule Fiw-up
- Revised Rule effective March 0
- Inspection Procedure 71111.02 June 10, 2003 2
I1
59 Revised Rule Folow-up
- 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 I
50.59 Revised Rule Follow-up Moha Senior Projec
. Thadani er, NRC Cooper Nuclec South Texas Wednesday, June 1 11 P'1