ML031680621
| ML031680621 | |
| 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: ML031680621 (49) | |
Text
MV2 I I -(
ii IEIE1R$l June 10 and 11, 2003 Kansas City Following is a workshop agenda. The flow of the workshop is from Licensing submittal scheduling issues to quality to change processes. The workshop is meant to be panel discussion with one or more NRC and STARS person on the panel (as indicated by the topic). Each panelist will present an aspect or perspective of the topic. Once complete, the session will be open for questions with a member of RASIG taking turns as moderatorl facilitator. STARS panelists will either be a COE Lead (as indicated), IRAG member or IRAG backup member. Times have been scheduled based on breadth of the topic. One break is scheduled for each moming with two in the aftemoon. A discussion session has been scheduled for the second aftemoon. Since IRAG will begin their Quarterly meeting that aftemoon, the intent is to have a seasoned STARS Licensing person from each plant there as a facilitator. his is a session for the exchange of experience and discussion.
STARS I NRR Projects Licensing Workshop June 10 and 11, 2003, Kansas City Tuesday, June 10. 2003 MORNING SESSION 8:00 - 8:30 WELCOME and INTRODUCTION NRC - Herb Berkow STARS - Don Woodlan 8:30 - 10:00 LICENSING ACTIONS - SCHEDULING (Panel Discussion)
NRC Work Controls NRC - Steve Dembek
- Impact on submittals
- Improving efficiency (things licensees can do to improve work assignment, work flow)
- Revised Project Manager Responsibilities Potential Benefit:
ffthe licensee understands the recent changes to NRC's work controls program and the impact on workflow, there may be things that licensees can do to ensure efficiency.
Managing Schedules for LARs to NRC-Dave Jaffe Support Plant Activities STARS - Glenn Michael
- Scheduling and timing of submittals Potential Beneft:
Submittals associated to outage implementation are always of interest.
Additional plant evolutions (e.g., steam generator replacement, power uprates) would also fall in this category. Licensees depend on the license amendment to exit their outage. The NRC requires submittals of quality to ensure the schedule can be met. This discussion is intended to focus on the elements that ensure both NRC and Licensee are satisfied.
9:45- 10:00 Break 1
STARS / NRR Projects Licensing Workshop June 10 and 11, 2003, Kansas City Tuesday. June 10. 2003 MORNING SESSION (after break) 10:00 - 10:30 NRC Fees NRC - Steve Dembek STARS - Scott Head
- When is exemption from fees applicable?
- How do licensee apply for exemption of fees?
Potential Beneft:
This section would provide a forum to ask questions about the current process, the process mechanisms, and requirements. This would provide for appropriate and complete applications for fee exemption.
10:30 - 11:30 LICENSING ACTIONS - QUALITY (Panel Discussion)
Quality of Submittals Revisited NRC - All PMs STARS - Fred Madden
- Noted Improvements (trends)
- NRC perspective
- Licensee perspective
- Lapses in improvements (trends)
- NRC perspective
- Licensee perspective
- Relief Requests
- Addressing Correspondence- Avoiding Error Traps
- Address rules and policies (i.e., how it is decided who responses are addressed to; especially beyond the regs.) -NRC
- Results of incorrectly addressed submittals -
NRC
- How to avoid - Licensee practices and tools -
STARS Mgrs Potential Beneft:
This would be a quick review of areas discussed in earlier workshops to ensure progress continues and any back lapses are caught and corrected.
One ftem of discussion involves the addressing of correspondence to the NRC. Recent letters have had anomalies in address requests. A brief review and discussion will ensure licensees understand the system and ramifications. It will also provide a forum for tools licensee use to ensure correspondence is correct prior to mailing.
11:30 - 12:30 Lunch 2
STARS NRR Projects Licensing Workshop June 10 and 11, 2003, Kansas City Tuesday. June 10. 2003 AFTERNOON SESSION 12:30 - 4:30 QUALITY ISSUES CONTINUED (Panel Discussion)
(12:30 - 1:30) Quality and Role of SERs Today NRC - Robert Gramm IRAG - Dave Shafer
- Obligations and Responsibilities
- NRC perspective (enhancements - Technical Review Guidance)
- Licensee perspective (trends)
- Correcting or Clarifying Information
- NRC experience
- Licensee experience (trends)
Potential Beneft:
In recent years the role of SERs has been down played. However, they are still play a role n the regulatory process. This session would review that role and issues associated to the issuance and receipt of SERs. The intent of this session would be to identify issues that ensure a quality SER, ensure the SER is appropriately addressed upon receipt and identify mechanisms for changing SERs.
(1:30 - 1:45) Use of Task Interface Agreements NRC - Dylanne Duvigneaud (TIAs)
Potential Benefit:
Discussion of the use of TIAs will help Licensees understand their function.
1:45 -2:00 BREAK 3
STARS I NRR Projects Licensing Workshop June 10 and 11, 2003, Kansas City Tuesday. June 10. 2003 AFTERNOON SESSION (after break)
(2:00 -2:45) Bulletin 2002-01 RAI Lessons NRC - Jack Donohew Leamed STARS - Ken Peterson
- Ways to avoid another industry RAI.
- NRC perspective
- Licensee perspective (i.e., determining the balance between too much information and too little)
Potential Beneft:
This iteration of bulletin, response, RAl impacted resources both within the NRC and licensees. A discussion of the lessons leamed may prevent another similar situation.
(2:45 - 3:15) Safety Conscious Work Environment NRC - Mohan Thadani IRAG - Stan Ketelsen
- NRC perspective
- Licensee perspective Potential Benefit:
This is a topic of interest that increased understanding and awareness will improve especially in the area of communications (if we are all talking about the same thing and thinking the same thing, communications will certainly improve).
3:15-3:30 BREAK 3:30 - 4:30 Informal Communications (e.g., NRC - Jack Donohew email) STARS - Fred Madden
- Guidelines; when and how to use it
- What to expect
- Experiences Potential Benefit:
During the 2002 Licensing Information Forum the issue of emails was discussed. Since this communication mechanism is one that can be efficient but also embarrassing, a review of guidance and expectations and use will encourage effective use.
4:30 End of First Day 4
STARS NRR Projects Ucensing Workshop June 10 and 11, 2003, Kansas City Wednesday. June 11. 2003 MORNING SESSION 8:00 - 8:15 SECOND MORNING WELCOME 8:15- 10:45 CHANGE PROCESSES (8:15 - 9:00) Processing Submittals Associated to NRC - Dave Jaffe Security Issues STARS - Stan Ketelsen
- Guidance for deciding when to submit Safeguards information vs. Sensitive Information vs. Non-safeguards
- Improving efficiency Potential Benefit:
With the intensity of issues relating to security transmitting nformation that is safeguards or non-safeguards or sensitive information has become a topic of discussion. Ensuring licensees ssue the proper category of document necessary for the NRC purposes and not putting the NRC in a difficult space for publication would increase NRC effectiveness and efficiency.
(9:00 - 9:30) Making Changes to the Plant NRC - Bob Gramm Associated to Orders. Process IRAG - Rich Luckett Guidance Potential Benefit:
Since much of the change to security conditions has been done in response to an order, mechanisms to change those conditions are not clear.
Discussion on this topic will ensure the proper reviews and submittals are performed. Discussion should include the role of the NRC Project Manager.
9:30 - 9:45 BREAK 5
STARS I NRR Projects Licensing Workshop June 10 and 11, 2003, Kansas City Wednesday. June 11. 2003 MORNING SESSION (after break)
(9:45-10:15) Perry Decision NRC - Jack Donohew STARS - Don Woodlan
- Implications - How to stay out of the same situation
- Application continues?
Potential Benefit:
Although it was stated at the 2002 Licensing Information forum that the Perry Decision was a document with one time use, it continues to be an issue.
Licensees do not wish to find themselves in a siftuation where there is question as to the limits of the license. Discussion on this point and insight from both the industry and regulator will improve communications.
(10:15-10:45) 50.59 Revised Rule Follow-up NRC - Mohan Thadani STARS - Jimmy Seawright
- Quality of the Annual Report
- NRC perspective on use and application
- Inspection Results (sharing)
- Other rule language - new emphasis and results (e.g.,
trends in submittals)
Potential Benefi:
This section would provide an opportunity to benchmark on how the industry is doing in the area of 50.59 and look for improvements.
10:45-11:15 Open Session NRC-All STARS - Don Woodlan
STARS I NRR Projects Licensing Workshop June 10 and 11, 2003, Kansas City Wednesday. June 11. 2003 MORNING SESSION (wran-up) 11:15 - 12:00 WORKSHOP WRAP-UP NRC - Herb Berkow STARS - Diane Hooper This session should be a joint effort between the NRC and the STARS attendees. The topics below should be brainstormed and condensed into a list of discreet items. A summary of take away items should also be developed. The list should include improvement items and may be fashioned after the STARS delta/plus model.
- Effectiveness
- Challenges
- Measurable
- Future Activities a What was most
- Types of Success
- Follow-up beneficial? challenges?
- P ideas?
- Improvements
- What was most
- Barriers?
- Other?
- Communication effective?
12:00 Adjourn / Lunch Wednesday. June 11. 2003 AFTERNOON (Post Workshop Session) 1:00-3:00 Licensee Closed Session STARS -
This is an impromptu session for sharing experience and discussing workshop questions. The session should be facilitated by an experienced licensing person from each STARS plant.
7
I STARS Presentations
WELCOME AND INTRODUCTION STARS*NRR Projects Lcensing WoTkshop, June 10, 2003 Don Woodlan Welcome
- Strategic Teaming Ind Resource Sharing
- AnerenUE, TXU Electric, Pacific Gas and Electric, STPNOC, Arizona Public Service Co. and Wolf Creek NOC
- NRR Projects representatives
- Members of the Public vel, 2 FM -, i....-
Introductions
- Please introduce yourself with brief bio
- Currentjob
- Work history
- Years in licensing/projects or related work
- Area of expertise
- Other info of interest Gnolo 3 1
Purpose and Objectives
- Meet your STARS regulatory affairs counterparts
- Meet your NRR projects people
- Open discussion on several key topics bnbw 4 Workshop Structure
- Discussion Topics Identified
- 1/3 of time for STARS presentation
- 1/3 of time for NRR presentation
- 1/3 of time for open discussion
- Ask questions as they occur - may hold off discussion until open discussion period UIe S t
Housekeeping
- Meals
- Breaks
- Restrooms
- Attendance List
- Other 4lvm 2
Managing Licensing Action Request (LAR) Schedules to Support Plant Activities Glenn Michael Palo Verde Nuclear Generating Station June 10, 2003 t
Types of LARs that may be Needed to Support Plant
- Relief Requests
- ISI/IST
- NRC Orders
- Tech Spec Changes
- Core Reloads (e.g., DNBR)
- New Methods
- Exemptions Challenges
- LAR Scheduling must Consider:
- Licensing resources
- Preparation time
- Peer quality-review time
- Cross organization reviews
- On- and Off-site Safety Committee Reviews
- NRC review
- Implementation time
- LARs to support the plant require early, complete planning I
Licensing Document Change Request (LDCR) Process
- LARs may be identified by anyone on site by using the LDCR process.
- Licensing must determine where the LDCR fits in with the other LARS being prepared.
- Licensing manages the LARs by using the Licensing priority List (LPL).
Licensing Priority List (LPL)
- List of "Top Ten" LARs.
- Actively being prepared
- SubmittnaVapproval schedule identified
- List of "Honorable Mention" LARs.
- List of LARs currently with the NRC.
- Approval schedule identified.
- List of LARs approved by the NRC.
Licensing Priority List (LPL)
- Licensing works to the LPL.
- Input meetings with individual stakeholders to identify potential LPL items and restraints.
- Work with responsible groups to address any restraints.
- Licensing meets monthly with Nuclear Fuels to ensure needed LARs are identified.
2
Licensing Priority List (LPL)
- Management stakeholders meet semi-annually to review LPL and verify that plant needs are being met.
- Lcensing
- Opations
- Engineering
- Outage Management
- PRA
- Nuclear Fuels Licensing Priority List (LPL)
- LPL Performance Indicators
- Input to monthly departmental report
- Number of LARs submitted
- Average age of LARs
- NRC review time
- NRC review fees Licensing Priority List (LPL)
- Emergent needs may push LARs down the list:
- NRC Order relief requests
- Emergent ISI relief request 3
Licensing Priority List (LPL)
- Challenges that affect LPL schedule projections:
- Not resource loaded (outage volunteering, vacations, training, etc.)
- Unexpected emergent work sometimes significant (NRC Orders, etc.)
so LAR "Need" Dates
- The "need" date requested in the LAR letter may be based on plant preparation need, which may be months prior to startup need.
- Intent is to have confidence that LAR will be approved as-requested so that design work can be done.
- NRC often needs to know startup date for their work management
- Should standard submittal format specify both dates? Is Notification of LAR Implementation?
There is no standard guidance for the need and the format to notify the NRC when an approved LAR is implemented.
12 4
Licensing Priority List (LPL)
Chanaes to be actively worked Description of Change Restraints NRA RE Submittal Sponsoring Date LDCR STARS?
Schedule Org Started No.
Working 1 TSTF-283 for EDG surveillance None J Proctor Second Qtr 2003 PRA 6/4/02 03-TOOl Y limitations (TS 3.8.1 and 3.8.4) _
2 MSSV TS changes (TS 3.7.1) None G Michael Third Qtr 2003 NFM 11/14/01 01-TOOl N 3 Request NRC approval for higher None J Proctor Third Qtr 2003 NFM 11/15/02 02-F047 N fuel pin pressure for ZIRLO fuel 4 Movement of recently" irradiated None R Wilferd Third Qtr 2003 ENG 3/20/03 Not yet Y fuel (TSTF-51) assigned 5 Relaxation of RX Vessel Head Need Hoop R Rogalski Third Qtr 2003 ISI TBD NA N Order for UT testing to the Stress Obotom of the nozzle for Units I reports for and 2. Units I and 2 6 EDG AOT increase to 14 days None J Proctor Third Qtr 2003 PRA 5/20/03 99-T002 N (TS 3.8.1) 7 Relaxation of specific ISI R Rogalski TBD ISI TBD NA N requirements in License Order Need by Spring Sections IV.C (1)and IV.C (2) 2004 outage requiring volumetric examination of the RPV head vent nozzle 8 Administrative changes: delete None D Gregoire TBD Licensing 11/1/01 01-TOIO N reporting license condition, 02-TO01 remove round cell batteries, add note to SR 3.8.1.2, and correct MSIV/MFIV applicability (TS 3.7.2 and 3.7.3).
9 Revise TS 3.1.5 condition B for None TBD TBD OPS TBD 99-TO05 N one CEA position indicator channel operable to state that there is only one CEA position indicator channel OPERABLE for one or more CEA per CEA group.
05/27/03 I
Licensing Priority List (LPL)
Chan-es to be actively worked Description of Change Restraints NRA RE Submittal Sponsoring Date LDCR STARS?
Schedule Org Started No.
Working 10 Relaxation of LCO 3.0.4 (TSTF- None R Wilferd TBD Licensing TBD Not yet Y 359) CLIIP issued in 68 FR assigned 16579, April 4, 2003. Also see letter from NEI to NRC dated April 28, 2003, containing revised TSTF-359.
05/27/03 2
Licensing Priority List (LPL) Honorable Mention Description of Change Restraints Notes and Comments LDCR No. STARS
. CIV AOT increase to 7 days (TSTF-373) PRA Unapproved TSTF; approved topical N 2 CS AOT increase to 7 days (TSTF-409) PRA Unapproved TSTF; approved topical 98-T006 N 3 Revise TS 5.5.6 Containment Tendon Need LDCR and Needed for Spring 2004 TBD Y Surveillance Test Program (TSTF-343 rev 1). input from Civil Design Engineering 4 Revise the test frequency for the Containment Need LDCR and South Texas recently submitted TBD Y Spray Nozzle Air test (SR 3.6.6.6) so that it is input from similar change.
only required after maintenance that could Maintenance affect performance. Engineering 5 Delete Appendix B, Environmental Protection None ?
Plan, from the PVNGS operating licenses 6 Define woperations involving positive None Several STARS plants have 01-T009 Y reactivity" (TSTF-286) received this.
7 Rewrite DC sources specification (TSTF-360) Engineering needs to TSTF is approved. Y review 8 Revise QA Program to be able to use ISO- NAD to develop May be ready to pursue by mid- Y 9000 certified vendors 2003 9 Delete Appendix C antitrust conditions from None Per Ken Manne, we committed to N the PVNGS operating licenses SRP that we would do this 10 New 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AOT for breach of CR boundary None NRA has done some preliminary 00-TO17 N (TSTF-287) work on this.
11 Consistent completion times for reaching None Y Mode 4 (PSV/LTOP - TS 3.4.11 and 3.4.13)
(TSTF-352) 12 Steam generator generic licensing package NEI 97-06 Lead plant (Catawba) to submit an Y (TSTF-449) amendment request in early 2003.
13 Relaxation of end state per CEOG topical None Topical approved, but TSTF has not Y (TSTF-422) been submited. Potential CLIIP.
05/27/03 3
Licensing Priority List (LPL) Honorable Mention Description of Change Restraints Notes and Comments LDCR No. STARS 14 Add note to EC specification (TSTF-351) None N 15 Delete TS hydrogen recombiner requirements NRC is working on TSTF to be developed after Rule Y 10 CFR 50.44 Rule change, which Is planned for early change 2003.
16 ISI relief request to use Code Case N597 for Need ISI justification N localized thinning analyses 17 ISI Code Case 532 (TSTF-412) Per M. Melton, this request should N not be needed because the Code Case is expected in the next RG 1.147 revision 18 Revise pressure-temp limits per 3/4.4.8 to Need Engineering 97-001 N Incorporate revised instrument uncertainties. Input (LDCR).
PTLR - This TS change would remove the RCS pressure and Temperature Limits from various TS's and relocate them to a Licensee Controlled document.
19 ISI relief request for use of Code Case N651- Need ISI justification N 2 to allow for ASME pipe overlay repairs for one cycle - outage benefe.
20 Risk-informed ISI Need PRA and ISI Y input 21 Revise the NRC reporting requirement InTS ?
Tables 5.5.9-2 and 5.5.9-3 (SG inspections) to be consistent with the revised 10 CFR 50.72 reporting criteria. .
05/27/03 4
Submittals Currently with NRC Description of Change NRA RE LDCR Submitted Requested Date Category STARS?
to NRC 1 Power uprate R Bemier 01-T004 12/21/01 12/31/02 I N (102-04641) 2 ISI relief request to use embedded flaw R Rogalski 3/15/02 9/27/02 II N techniques for CEDM nozzle repairs - ISI (102-04668)
Relief Request Nos. 20 and 21. ( - )
3 ISI Relief Request for proposed altemative R Rogalski 5/22/02 "to support the 11 N repair method for reactor vessel head (102-04705) VHP inspections penetrations - ISI Relief Request No.18 scheduled during (temperbead) the upcoming refueling outages for Units I and 3" 4 License recovery time from low power testing R Wilferd 02-T002 8/28/02 8/31/03 III N 5 CPC upgrade: DNBR, TS 3.2.4; RPS D Gregoire 01-T003 11/7/02 7/1/03 I N Instrumentation - Operating, TS 3.3.1; (102-04864)
CEACs, TS 3.3.3.
6 IST relief request for Unit 1 HPSI pump 1A for D Gregoire 1/21/03 7/1/03 I N high vibration dunng full flow - IST Pump (102-04881)
Relief Request No. 13.
7 E-Plan change to reduce number of STAs R Roehler 2/14/03 9/1/03 III N (102-04890) 8 Admin TS changes to reflect reorg (Chemistry R Rogalski 02-T004 4/15/03 None specfied Ill N and WEI) (Sholly'ed 5/27/03) 02-T006 (102-04926) 9 Qualification of licensed operators - TS 5.3.1 R Rogalski 01-T014 4/25/03 April 2004 III N (RIS 01-01) (102-04930) 10 ISI Relief Request 23 - Altemative Repair R Rogalski 5/15/03 9/15/03 I N Request for Pressurizer Heater Sleeves (102-04941)
(temperbead)
Category : A Category I submittal isneeded to be approved by the NRC for a specific plant evolution or startup after a plant refueling outage. It would be of prime Importance for the NRC to meet the requested approval date for this category of submittal and there is very little flexibility available for having the submittal approved beyond the date requested. Delay would Impact power production.
05/27/03 5
Submiffals Currently with NRC A
Category II: A Category 11submittal is needed to be approved by the NRC for general purposes, but not a plant specific evolution or outage. at a category 11submittal is desired to be approved by the requested approval date, but there is some flexibility for having the submittal approved later date than requested. The amount of flexibility can only be determined on a case by case basis. Delay may Impact power production.
relying on Category I: A Category Ill submittal is needed to be approved by the NRC, but there is no time dependent situation or evolution that isof submittal is approved. Typically this type the approval of this submittal. There is a great amount of flexibility for when this category of submittal the is purely administrative or a submittal to correct an error in the TS where administrative controls already have been implemented to ensure error in the TS does not have an Impact. Delay would not Impact power production.
05/27/03 6
Submittals Anoroved bY NRC in 2003 Description TAC Nos. Date Date NRC Review STARS? Date Submitted Approved Tlme Implemented (Months) 1 ISI Relief Request for altemative repair method MB6439, 9/25/02 1/27/03 4 N 1/27/03 to use electrical discharge machining (EDM) for MB6440, reactor vessel head penetrations - SI Relief MB6441 Request No. 22 2 Relaxation of the requirements of License Order MB7855 2/28/03 4/25/03 1.9 N 4/25/03 Sections IV.C(1)(b)(i) and IV.C.(2)(b)(i) for the CEDM nozzles .
3 Request for Relaxation of Order EA-03-009 MB7855 4/4/03 4/25/03 1.7 N 4/25/03 Requirement IV.C(2)
Average Review Time:
2.5 Months 05/27/03 7
riF i--l- -
LICENSING ACTIONS QUALITY OF SUBMITTALS STARS/NRR Projects Licensing Workshop, June 10, 2003 Fred Madden - TXU Energy 6n a Panel Members
- Jack Donohew - Project Manager for Callaway, Wolf Creek and Palo Verde
- David Jaffee - Project Manager for Comanche Peak and Diablo Canyon
- Mohan Thadani - Project Manager for South Texas Project
&a 2 LICENSING ACTIONS QUALITY OF SUBMI1TALS A. Improvements trends)
- Industry (NET) Templates for Licensing Actions (LARs) & Code Relief Requests (RRs). Are they working? Do they elicit the appropriate information to minimize RAls?
- NRC Project Manager insights....
.... ~~~~~~~~~~~~~~~
1
LICENSING ACTIONS QUALITY OF SUBMITTALS A. LaDses (trends)
- Code Reief Request (RR) content omissions
- RAls resulting from adaptadon of generic, industry topical reporS (Licensee omission of required pbnt specific information; NRC SER specificity)
- WordPerfect vice Word software. Why are some licensees constrained to use of WordPerfect?
- NRC Project Manager insights...
zae a LICENSING ACTIONS QUALITY OF SUBMITTALS A. Addressine Correspondence - Avoidine Error Tras
- Address Ruks aed Policies - NRC PM Guidance
- Crespondence Addeses br Ordas, Securhy Orders, Bulletins, Generic Lenem. et
- Consequans of bncormt Addessed Comepondence - NRC PM Guidance
- Lices Pactices and Tools:
I UseofSundaid Teqisie Cbekaand ProfRdu I OsDs.
6'l000 2
STARS / NRR Projects Ucensing Workshop June 10 & 11, 2003 Quality and Roles of SERs Today Dave Shafer Callaway Role of SER Provides the Basis for NRC Approval Level Details Varies Based on:
- SubJect rmatter
- Point hIfire when SER was tssued NRC Approvals Generally Fall In 3 Cateaories
- Conformance to an Applicable Standard
- Plant Specfic Review of a Deviation to an Applicable Standard
- Plant Specfk Review Where there Is no Standard
-None Exist
-Pre-dates Standard 1
Callaway SER Review Practices k*tnnomIReview Not Procedurd zed
- Pr-Approva I PoetAproval
- Some PMs have provided final draftnd afew days b conment Somehave provkdedSER's fte Restf FOov,-Up have Varied
- TYPos Editorials re som mes oded I NRC
. Factual sue we provided b NRC
. COffecti Lee Revised SER
- Potenealy Signcart Issues ae ot CosasktenAdiressed Future Plans
- Callaway wit Fornalize Process for Review
- Nonnaly Complete Review Prior to nplementation
- Use te Corrective Acton Program to Address Issues Significant Issue Examples
- NRC Approval of Origmal Lcerse Condion on SGTR
- Secondary side isolafon valves not considered CVs
- Feedwater Reg I Bypass valves not hi Tech Specs 2
NRC Aooroval of SGTR Caltaway analyzed 2 cases
-Stuck Open ASD
-Failed open flow control valve (SG Overlili?)
- Callaway concluded:
-No SG overfl (dose. but .
-Stuck open ASD was bounding case and added to FSAR NRC requested Caflaway lorce overflir
-Callaway analysis sil showed it was bounded by ASD case
-Calaway considered 'orced overflir as beyond licensing -
basis NRC Approval of SGTR Conrd NRC SER reected Calaay rontendon that overfill did not ocur
- Approved LC based on:
Forced overifi analysis Idependent NRC dose calcutations RCS activity Ttnis InTIS Distance to exclusion area and LPZ boundartes Caiaway raintained overlil was not a Licensing Basis but did not address SER approval basis
- Caliway Issubmlfttng updated analysis this month Secondary Side Isolaton Valves not Considered ClVs :
. Amendert IO larilled IS perlrdng b MSNi a M
-Renoved lotaJon trnes rn TS T.3.fl.1
-Aed spe forMFrvs (slnar to USV)
NRC rsareed on bases for spprvd
-Calaway jusled charge based vaes nl being CNs
-NRC accepted based other TS existe snd no eltecive cwie hiresponse line
- NRC Specrfed hI SER tiu TS eases Wange be renovd
-This aevoied the issue InTSB FSAR bases Is sail tithey re nol CNs 3
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Your Feedback Fr SGTR eprval What uld we have dae?
For Secondary Side ation Vavs not Considered Civ What ahouldwe have doe?
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For Feed Reg Vles What shouLdwe he done?
What shotld we do nlow?
7
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Bulletin 2002-01 Request for Additional Information (RAI)
Lessons Learned STA1WNRR Projects Ucensing Workshop, June 10, 2003 Ken Petersen Industry Concerns
- Significant NRC and Licensee resources expended to address RAls
- Can we minimize utility RAIs?
- Can we avoid another industry RAI?
- Bulletin 2002-01 MoWm 2 Issues
- What techniques can be used to minimize the likelihood of RAls?
- How do we know when "enough" information is being supplied?
- How do we know when "too much" information is being supplied?
view 2 I
Techniques to Minimize RAIs
- Clearly define the NRC question or request.
- Conduct a critical review of response.
Define the NRC Question or Request
- Break down complex questions into parts.
- Bulletin 2002-01 RAI - 69 parts
- What if you can not define NRC question or request?
- Check with peers or call the NRC Critical Review of Response
- Response must completely addresses the question or request.
- Ensure ALL parts of a conplex question are addressed.
- Statements of fact must withstand the "future review" test.
2
Critical Review of Response
- Consider industry events.
- What if the response to one part appears redundant to another part's response?
- May not be interpreting the question cofectly.
Gnaw 3
Safety Conscious Work Environment Mohan Thadani Stan Ketelsen
Background
- The following background will be addressed by Mohan Thadani
- Commission's Statement of Policy
- SCWE vs. Safety Culte
- Discrimination Task Group
- Staff Requirements Memorandum (3/26/03)
NEI Recommendations
- Three areas addressed:
- Office of Investigation (01) Tecniques
- Development of Altemative Dispute Resolution (ADR) Process
- Development of SCWE Best Practices" 1
Assessment of 01 Techniques Should be performed by an independent agency Focus on effectiveness of using criminal investigative techniques for employment related dispute Seek insights from other stakeholders (DOL, industry representatives, allegers, etc.)
Development of ADR Process
- Would address weaknesses of 01 approach
- Initiated early in the process, could provide an alternative to enforcement action
- Outside involvement promotes confidence
- Minimize negative impact on environment
- Promotes quicker resolution of allegations Development of "Best Practices"
- Voluntary industry activities:
- Identify core attributes ofsuccessful ECP
- Updatelexpand industry's "tool box"
- Develop guidance for management training on SCWE-related issues
- Recommend NRC defer internal efforts pending completion of ongoing industry activities 2
INFORMAL COMMUNICATIONS STARS/NRR Projects Licensing Workshop, June 10,2003 Jack Donohew - NRC Project Manager Fred Madden - TXU Energy INFORMAL COMMUNICATIONS A. Informal Communication - What is it? Typically e-mail and melephone discussions and conference calls.
B Guidelines-
- When nd how to use
- Project Mauger diretion andpespecLivc.
C. Wat to Exee
- What are die pitls?
Wben and why does e-mail becoue dockeled/
Project ManSer perspective....
Mnom 2 INFORMAL COMMUNICATIONS Experiences
- 1. Comancbe Pcak provides to Project Manager e-mail copy of correspondence
- 2. Comanche Peak provides drafi responses oRAls via e-mail to ensure completeness of proposed responses
- 3. Regular (several imes pet week) communications between Prmdect manger and licensing kad
- 4. Appreciate efforts of Project Manager to explicidy define technical issues
- 5. Other experiences....
ve 1
I NRC Orders Orders .... Once you implement them, what is the mechanism for changing a condition in them?
NRC Orders
§2.202 Orders.
(a) The Commission may institute a proceeding to modify, suspend, or revoke a license or to take such other action as may be proper by serving on the licensee or other person subject to the jurisdiction of the Commission an order that will:
I
NRC Orders
()MAepu teeewimii aolnorOtaews e uled Is the CrOW AdS 0ee,W VW*Oon vec4:
te , nd W WgUd IVUVPuepond SC h.
MreCI oath or a-nahon dyt203oide dae. r aud We m pw be apedied Intu eder.
(21 llwi loeno at st epalsn adnlsy feleddby aetptrid hleor htrr wneestVy %20dps of ftdale oftheoeder w such other Inteia y ed in On r. deman a o on i orpW d 101 eder aip=lSta CM eWew atee oor pesn hee Wieed hIng tU (4)SpKey ft hl_ Ir 1h : Vd (5)St t feltcowdated On olde CPuCom¶naLei findema ft s*lk 13*5. let.0or blesPsatfleliaor#thavl e de rcoodlc mpg the I' ad. Pu oder myt poAde.tarPae teasonuVWP ellllt P papoled eden be Ineiwda er .0w pe-nd gw older NRC Orders (2)PThe cense, or te r ponw b hor e b hn Coneuslon s sued Unituiedlalely eltclve rdeXrwy. h addOon b demandeina heaing.
at Pu thhe Pu anuwer Is filed oxrsor move Pu preskle d6cer Of b metskdki th dabe efoles_s adne erdor wnPu grotad 11wl ft orde. berng Pu need lor benedate eness. notbased on rdequilte evidencebutenrtierePupio. tu ed algatos. or atar. The motn mnust ae wit plarty Pu reasom why Pu order Is naI based en eate evidence oidniwi be aco naeby afiavits o,rotter edeee rehedon The NRC shell resond wh I5) days of Pu rmcept of P ttn The moron must 6ed officer epeditbous:DurrPg of reftulon defcwess df Pu orer.n ar enIts own ttdn or upon mtlon of be hcertsee or other peorL The presiding officer w upheld Pu liedae effetkeness of t ardor fit inds tt Ithere Isadequae Aidece t upport trrtedate effectveress. An order uphld ng brenedlate eneetveness cconsitte te W ency acton on tmlredae efecivbeness. An orr Pettg asie it"tuttni e ff fertebe reteee y Pu l mi andwi notbe efetv edigti re a uCmison.
NRC Orders (d) An answer rnay consent to the entry df an order in eutstasiait thlefoirproposed h the order with respect b tt or some d the actions proposed hnthe order The oonsent, h the answeer or other wrtten docunentd the, censee or herperson towhorn the order has been Issued tO the enty d an order ahall tconstitute a waiver by the kcensee or other person df a heating.
ftdings df tact and conctuskons d iow, and d et rtsJht to seek Commnisso and judical review or to contest the validity od the orderany hrunw as to those matters which have been onsented to or agree tooron which a heatin has not been requested. An orer that has been consented to shaHhave the sare orre and effect a an order moadeaner hearing by a presidnofdficer or the Connlslon and shaHbe affective s irovided h the order C.)In the order tnvdsves the modificetion df a Pert 50 icense and ts a butit the requirements od550.10t d this chapter shatt be follwed, unless the, Icenisees has consented to the adon required.
2
NRC Orders Lets Talk Process .....
How does a Licensee change a condition of an order?
For example an order requires the Installation of a certain feature to enhance station security. However after a period of time the licensee Identifies an Improved feature that would work better.
How Is a change to the order initiated, so the licensee can utilize the improved feature?
NRC Orders Lets Talk Process .....
What can the licensee do?
-Write a letter to the NRC asking for permission to provide a substitute feature that meets the substantial Intent of the order.
- Initiate a License Amendment Request.
- Wait for rule making to obviate the order.
NRC Orders
§50.54 Conditions of licenses (h) The license shall be subject to the provisions of the Act now or hereafter In effect and to all rules, regulations, and orders of the Commission. The terms and conditions of the license shall be subject to amendment, revision, or modification, by reason of amendments of the Act or by reason of rules, regulations, and orders issued In accordance with the terms of the act.
3
NRC Orders
§50M Coann f iken 4p.Xl)Iw -We aid pn at n shgu.dn r ahn ptUe,.m vacbr8o whm pb CCdwpn3 d ti chpbr i dg 11l WCfld b rIhaR.pfh l blker otby dI CU uCho m n lo onlo e p ; mgency no lan nge ich WOr.d Sc t thrt .t:re d a nY e4r waningmd QaAbn Pln; B_, Ibyrklr~~~~sing uad mIngac npln ppd paum IC WO.aldlC rPr rJ d dUar, -
73 anlcti. wiheedprbr p.o~8C CUennunlmn. Ai.. denurt tIC m md
- r*lig nn 11bi 81.n.iin trmr gfini I th ken... ken. px,a ICf5JK.
42)118tw. ma makecre IoUe pan iClenen pW8OPX Iptlo' ChiC tfftn,. _lEn Inc.rCnsron 8duf IfCUd.aees rb'C e rnase C aiuda aflcfr.nmu dI CUplan.Thkn.. a 11 manUanrecede d chrJ . IhsirPls m.dre phiZwb Coennean q~nl lor.4 addd bliv. hew,hen Cde CIs Wirr. mid aih sutin.. Ss.pcIldh .4
- mcon Oannog *rncifen d Charge haha keGseethe Us rnp.. udmePilac bCCUs NueSn angency p181 tha p he aleX CU en. dil h:n NRC Orders
§50.90 Application for amendment of llcense or construction permit.
Whenever a holder of a license or construction permit desires to amend the license or permit, application for an amendment must be filed with the Commisslon, as specified in §50.4, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
NRC Orders 550.4 Wrltten conununiatiol.
(4) Secrityplan and relatedsubmtals. Wrtten carOnscaorls.
as defined I paragraphs (bX4XI) trough (lv)of ttis section muet be submitted as lofws: The sned original and three copies to the NLucear Ftegutatory Cofmmssion. Document Contol Desk.
WasNrgtorn. DC 20555. an two copies lo the appropriate Regonal Ofice; (M)Change to sectuty plan, guard training and qualtficaton plan.
or safeguards corAngency plan rade without prior Camnission apprval pursuant to 50.54(p)
(v) Application or anmendment d phyical securlty plan, guard rning and qualiication plan, or safeguards contingency plan pursuant to 150.90.
4
PERRY DECISION STARS/JRR Projects Licensing Workshop, Jume 11.2003 Don Woodan
- 011, 1
Origin
- Memorandum and Order, CLI 96-13
- Issued by Commission 12/16/1996
- Reversed ASLB Order
- License amendment was not required to change vessel specimen removal details as long as I OCFR50 Appendix H continued to be met W1I 2 Regulatory Point
- What is threshold needing a License Amendment for making changes which need "prior NRC approval"
- Goes back to meaning of Section 189a of Atomic Energy Act re hearing rights and public involvement
- Does the change create "greater operating authority" wII8 I 1
Industry Concerns
- NRC referred to Perry Decision to require that several changes needed License Amendment to adopt
- Examples:
- Fire protection alternate rule
- BWR Integrated Surveillance Program
- NEls Steam Generator Program
,m NRC Approval without License Amendments
- Exemptions
- QA Program changes
- E Plan changes
- Code relief
- Fire Protection Plan changes
- Some Security Program changes IlI m3 s Issues
- How is the relocation of info from TS to Licensing Basis Documents affected?
- When does NRC prior approval require a License Amendment?
- Will requirements be added to Technical Specifications just to force License Amendments prior to change?
wiM 6~~~~~~~~~~~~~~~~~~
2
Regulatory Activity
- NEI letter opposing the recent NRC use of the decision
- NRC position presented at 2002 NEI Licensing Forum Mnim Potential Position
- Changes which actually change license need LAR
- Changes need LAR if required by IOCFR50.59 Evaluation
- Changes in regulations which require prior NRC approval do not require LAR unless so stated
- Other changes should require an LAR if a 10 CFR 50.59 Evaluation would have required one (e.g.,
topical reviews)
Muo a 3
50.59 Revised Rule
- Follow-up i; Fow!<e i t -
-Uazt*--
YFI-11,11cs USA 50.59 Task Team Benefits and Challenges Evaluations Performed Since Rule Implementation No. of PLANT Evaluations Callaway 3 Comanche Peak S Diablo Canyon 22 Palo Verde 43 South Texas 13 Wolf Creek 4 1
Regulatory Reporting Requirement "The licensee shall submit, as specified in Sec.
50.4, a report containing a brief description of any changes, tests, and experiments, including a summary of the evaluation of each. A report must be submitted at intervals not to exceed 24 months."
4 .,y, X, .... ,, .. , vr.s s NEI 96-07 Reporting Guidance
'A summary of 10 CFR 50.69 evaluations for activities implemented under 10 CFR 60.69 must be provided to NRC. Activities that were screened out, canceled or implemented via license amendment need not be Included in this report The 10 CFR 60.69 reporting requirement (every 24 months) is identical to that for UFSAR updates such that licensees may provide these reports to NRC on the same schedule."
Resource Manual Reporting Guidance A summary of 10 CFR 50.59 evaluatons for activities implemented under 10 CFR 50.59 must be provided to NRC. Activities that were screened out, canceled or Implemented via lcense amendmnent need not be Included In this report."
2
-22g {-- .,
Resource Manual Reporting Guidance (cometoed)
'Each evaluation will Include an Activity description and a Summary of Evaluation. These sectins will become e basis fbr preparing the 10 CFR 50.59 Summary Reporl The activity descriptlon and suiwnary sections for each evaluatlon should address the Important attributes of the activity as well as the significant results and conclusions of the evaluation In as brief and concise a manner as practical In order to keep the report brief and concise."
3
OPEN SESSION STARS&NR Projects Licensing Workshop, June 11,2003 Don Woodan MJ I Other Topics as Time Allows
Work Shop Wrap-Up STARS/NRR Projects licensing Workshop, JUne 10, 2003 Diane Hooper/HeTb BeTkow
- Effectivass *Challages *Mcuing Success*Future Ativities Most *Typs -1 Idea Flow-up beleicia? Bris *m
-Mot Commwdcatio G,
1