ML031920648
| ML031920648 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, Byron, Diablo Canyon, Callaway, Comanche Peak  |
| Issue date: | 06/10/2003 |
| From: | Donohew J NRC/NRR/DLPM/LPD4 |
| To: | |
| References | |
| Download: ML031920648 (160) | |
Text
NRC FORM 658 U.S. NUCLEAR REGULATORY COMMISSION (9-1999)
TRANSMITTAL OF MEETING HANDOUT MATERIALS FOR IMMEDIATE PLACEMENT IN THE PUBLIC DOMAIN This forn is to be filled out (typed or hand-printed) by the person who announced the meeting (i.e., the person who issued the meeting notice). The completed form, and the attached copy of meeting handout materials, will be sent to the Document Control Desk on the same day of the meeting; under no circumstances will this be done later than the working day after the meeting.
Do not Include proprietary materials.
DATE OF MEETING The attached document(s), which was/were handed out In this meeting, Is/are to be placed 06/10/2003 in the public domain as soon as possible. The minutes of the meeting will be issued in the near future. Following are administrative details regarding this meeting:
Docket Number(s) 50-275,50-323,50-455,50446,50482,50483, Plant/Facility Name Diablo Canyon, Comanche Peak, Wolf Creek, Callaway, TAC Number(s) (if available)
Not Applicable Reference Meeting Notice June 2,2003 (ML031530512)
Purpose of Meeting (copy from meeting notice)
The meetings on June 10 and 11, 2003, were a STARS-IRAG/NRC workshop to discuss selected topics listed in the agenda atached to the meeting notice.
NAME OF PERSON WHO ISSUED MEEiNG NOTICE TITLE Jack Donohew Senior Project Manager OFFICE Office of Nuclear Reactor Regulation DIVISION Division of iAcensing Project Management BRANCH Project Directorate IV Distribution of this form and attachments:
Docket File/Central File PUBLIC NRC FORMW W5 (91999)
PRINTED ON RECYCLED PPER This bn vs desrd using InFonnts
I 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 tums as moderator/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 afternoon, the intent is to have a seasoned STARS Licensing person from each plant there as a facilitator. This is a session for the exchange of experience and discussion.
STARS I NRR Projects Ucensing 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 Beneft:
If the 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 Support Plant Activities NRC-Dave Jaffe STARS - Glenn Michael Scheduling and timing of submittals Potential Benefit:
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. Lkensees 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 I
STARS I 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 e quick review of areas discussed in earlier workshops to ensure progress continues and any back lapses are caught and corrected.
One tem of discussion involves the addressing of correspondence to the NRC. Recent lefters have had anomalies in address requests. A brief review and discussion wSI ensure licensees understand the system and ramifications.
will also provide a forum for tools licensee use to ensure correspondence is correct prior to mailing.
11:30 - 12:30 Lunch 2
STARS I 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 Benefit:
In recent years the role of SERs has been down played. However, they are still play a role in 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 Learned 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 Benefit:
This iteration of bulletin, response, RAI 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 Beneft:
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 Licensing Workshop June 10 and 11, 2003, Kansas City Wednesday. June 11. 2003 MORNING SESSION 8:00 - 8:15 8:15-10:45 SECOND MORNING WELCOME CHANGE PROCESSES (8:15 - 9:00)
Processing Submittals Associated to Security Issues NRC - Dave Jaffe 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 transmiffing infornation that is safeguards or non-safeguards or senstive information has become a topic of discussion. Ensuring licensees issue 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 Associated to Orders. Process Guidance NRC - Bob Gramm IRAG - Rich Luckett 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 situation 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 Benefit:
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 NRR Projects involvement in level 3 SDPs 6
STARS I NRR Projects Licensing Workshop June 10 and 11, 2003, Kansas City Wednesday. June 1. 2003 MORNING SESSION (wrap-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 What was most beneficial?
What was most effective?
Challenges Types of challenges?
Barriers?
Measurable Success P ideas?
- Other?
Future Activities Follow-up Improvements Communication 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 STARSINRR Projects Licensing Workshop, June 10. 2003 Don Woodlan Welcome
- Strategic Teaming and 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
Introductions
- Please introduce yourself with brief bio
- Curent job
- Work history
- Years in licensing/projects or related work
- Aea of expertise
- Other info of interest I
Purpose and Objectives
- Meet your STARS regulatory affairs counterparts
- Meet your NRR projects people
- Open discussion on several key topics wi 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 Housekeeping
- Meals
- Breaks
- Restrooms
- Attendance List
- Other 2
Managing Licensing Action Request (LAR) Schedules to Support Plant Activities Glenn Michael Palo Verde Nuclear Generating Station June 10, 2003 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 1
Licensing Document Change Request (LDCR) Process
- LARs may be identified by anyone on site by using the LDCR process.
- Ucensing 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
- SubmittaVapproval 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.
- Licensing
- Operations
- Engineerin&
- Outage Management
- PRA
- Nuclear Fuels 7
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 S
Licensing Priority List (LPL)
- Emergent needs may push LARs down the list:
- NRC Order relief requests
- Emergent IS 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.)
I0 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?
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)
ChanQes to be actively worked Description of Change Restraints NRA RE Submittal Sponsoring Date LDCR STARS?
Schedule Org Started No.
W o rk in g
_ _ _ __Wr i
I TSTF-283 for EDG surveillance None J Proctor Second Qtr 2003 PRA 6/4/02 03-TOOI Y
limitations (TS 3.8.1 and 3.8.4) 1 2
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 "bottom of the nozzle" for Units I reports for and 2.
Units 1 and 2 6
EDG AOT Increase to 14 days None J Proctor Third Qtr 2003 PRA 5/20/03 99-T002 N
(TS3.8.1) 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-TO10 N
reporting license condition, 02-TOOI 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.
05127/03 I
Licensing Priority List (LPL)
Changes 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 n 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 I
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 "operations 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 certffied 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-T017 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 submitted. Potential CLIIP.
05/27/03 3
Licensing Priority List (LPL) Honorable Mention Description of Change Restraints Notes and Comments LDCR No.
STARS I
~~~~~~~~~~~~~~~~~~~~~~?
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 benefit.
20 Risk-informed ISI Need PRA and ISI Y
input 21 Revise the NRC reporting requirement In TS
?
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 I
Power uprate R Bemier 01-T004 12/21/01 12/31/02 l
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 Oto support the II 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 1 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-T03 11/7/02 7/1/03 l
N Instrumentation - Operating, TS 3.3.1; (102-04864)
CEACs, TS 3.3.3.
102-04864 6
IST relief request for Unit I HPSI pump 1A for D Gregoire 1/21/03 7/1/03 I
N high vibration during 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 Rogaiski 02-TO04 4/15/03 None specifled III 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
(102-04930) 10 ISI Relief Request 23 - Altemative Repair R Rogalski 5/15/03 9/15/03 l
N Request for Pressurizer Heater Sleeves (102-04941)
(temperbead)
Category 1: A Category I submittal is needed to be approved by the NRC for a specific plant evolutlon 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
Submittals Currently with NRC Category II: A Category 11 submittal Is needed to be approved by the NRC for general purposes, but not a plant specific evolution or outage. A category I submittal is desired to be approved by the requested approval date, but there Is some flexibility for having the submittal approved at a later date than requested. The amount of ftexibility can only be determined on a case by case basis. Delay may Impact power production.
Category I: A Category I submittal Is needed to be approved by the NRC, but there is no time dependent situation or evolution that is relying on the approval of this submittal. There is a great amount of flexibility for when this category of submittal Is approved. Typically this type of submittal is purely administrative or a submittal to correct an error In the TS where administrative controls already have been implemented to ensure the error in the TS does not have an impact. Delay would not Impact power production.
0527/03 6
Submittals ADroved by NRC In 2003 Description TAC Nos.
Date Date NRC Review STARS?
Date Submitted Approved Time 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 - ISI 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
LICENSING ACTIONS QUALITY OF SUBMITTALS STARS/NRR Projects Licensing Workshop, June 10.2003 Fred Madden - TXV Energy wu 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 LICENSING ACTIONS QUALITY OF SUBMITTALS A. Imrovemets (trends)
- Industry (NEI) Tempbates for Licensing Actions (LARs) & Code Relief Requests (RRs). Are they working? Do they elicit the appropriate infomiation to minimize RAls?
- NRC Project Manager insights....
I
LICENSING ACTIONS QUALITY OF SUBMITTALS A. Latses (trends)
- Code Relief Request (RR) content omissions
- RAls resuling fron adaptation of generic. ndustry topical reports (Licensee omission of required plant specific information; NRC SER specificity)
WordPerfect vice Word software. Why are some licensees constmined to use of WordPerfect?
NRC Project Manager insights...
LICENSING ACTIONS QUALITY OF SUBMI1TALS A.
Addressine Correspondence - Avoiding Error Tras Addrtss Rules and Policies - NRC PM Guidance Cmrespouience Addresses for Order. Secuiy Orders, Butins. Gnric Lente etc.
- Conaences odacoic* Addrsed Comesponder - NRC PM Guidamce
- Licesee Prtices od Toots:
@' Use of Sid Thlr I
Cbekmu dro PfeRs v I0m.,
2
STARS I NRR Projects Licensing Workshop June 10 & 11, 2003 Quality and Roles of SERs Today Dave Shafer Callaway Role of SFR Provides the Basis or NRC Approval Level Details Vanes Based on:
- Subject matter
- Point I ie when SER was issued NRC Approvals Generally Fall in 3 Cateaories Conformance to an Applicable Standard
- Plant Specific Review of a Devition to an Applicable Standard
- Plant Specific Review Where there is no Standard one East
-Pre-dates Standard 1
...~~I a Oit i
!'I 1 0 gfH
- SC1,
!o t11
~I I
t>.
NRC Approval of SGTR Calbway analyzed 2 cases
-Stuck Open ASD
-Failed open flow control vane (SG Overfill?)
- Caltway concluded:
-No SG overfl (close, but...
-Sluck open ASD was bounding case and added lo FSAR NRC requested Callaway lorce overfir
-Cetlaway analysis siN showed 11 was bounded by ASD case
-Calaway onsidered frced ovefflir as beyond kensing basis NRC Approval of SGTR Contd NRC SER rejected Calaway contenlion that overfli did not occur
- Approved LC based on:
Forced overlil analss Independent NRC dose calculations RCS activtty Inhs I T/S Distance to exduslon area and LPZ boundaries Calaway maintained overfill was not a Licensing Basis but did not address SER approval basis Calaway Is submting updated analysis this month Secondary Side Isolaton Valves not Considered CWVs A Arnden! Wda TS pefning b vemPFtVu
-Removed isol Mtes fkmn TS 1.3-1
-Added spec lr MFV tesMaw ID MV)
- NRC died on b for appvsd
-CaOlay usied change baed Valve ni beirg Cvs
-NRC ace based t TS ted end no elecve Chne in sponse rne
. NRC Specified In SER lt TS Bases aoge bervd This aided the ie hI TS8 F PSAR base Is SM St Vey we not Clvs 3
I UNITED STATES C, s.t t NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 18 TO OPERATING LICENSE NO. NPF-30 UNITON ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 INTRODUCTION By letter dated SeDtember 29, 1986, and suDplement thereto dated February
- 2fi, 1987, Union Electric Company (the licensee) submitted an amendment request for changes to the Technical Specifications for the Callaway Plant. The changes pertain to the main steam solation valves (MSIVs) and to the main feedwater isolation valves (MFIVs). The principal effect of the roposed changes would be to clarify the Technical Specifications pertaining to the MSIVs and to the NFIVs in Darticular.
We have reviewed the proposed changes and find them to be acceptable as discussed below.
DISCUSSION AND EVALUATION The licensee summarizes their amendment request by stating that the request provides clarification and restructures the Technical Secifications asso-ciated with the MSIVs and MFIVs. Further, no changes are being made to the valves or their response times, and therefore the original design bases are met.
For the Engineered Safety Features Response Times (Table 3.3-5), the licensee proposes to separate the response times for the MSIVs and the MFIVs into two parts. The response time for the sensor, associated electronics and actuation relays would be ndicated in Table 3.3-5, whereas the valve closure time, for the valve to be considered operable, would be given in a seDarate specification.
Thus, the MSIV and MFIV resDonse times in Table 3.3-5 would be changed from the present < 7 seconds to 2 seconds, with a footnote added that the response time does not include valve closure time. A separate secification would re-quire valve closure time within five seconds for the valve to be OPERABLE. As a result, there would be no effective change n the overall response times.
We therefore find this Droposed change to be acceDtable.
The Containment Isolation Valves (Table 3.6-1) include a list of the MSIVs and MFIVs under the table notation Other Automatic Valves.' The maxinum iso-lation time for these valves s Dresently indicated as 5 seconds. The licensee proposes to replace the 5 seconds with N.A. (not applicable). The 5 seconds requirement would then appear n other technical secifications as discussed previously.
J The licensee partially justifies the changes n Table 3.6-1 on the basis that the MSIVs and MFIVs are not containment solation valves because the valves are not required to meet containment isolation criteria since the containment I........I..
t
. I.
I.- -..............
I.
barrier integrity is maintained by the steam generator tubes, the shell of the secondary side of the steam generator, and the lines emanating from the steam generator secondary shells. We find that the licensee's contention that the MSIVs and MFIVs are not containment isolation valves conflicts with General Design Criterion 57 which states in part:
Each line that Penetrates primary reactor containment and is neither part of the reactor coolant pressure boundary nor connected directly to the containment atmosphere shall have at least one containment isolation valve which shall be either automatic,. or locked closed, or capable of remote manual operation.
Although we disagree with the licensee's contention that the MSIVs and MFIVs are not containment solation valves, we find the changes to Table 3.6-1 are acceptable because the soecifications for the MSIVs and MFIVs appear elsewhere in the Technical Specifications and there s no effective change n the over-all response time of the valve closures. Also the licensee states and the staff finds that the licensee's proposed change n Table 3.6-1 for the Callaway plant is similar to the existing Table 3.6-1 for the Wolf Creek plant.
A footnote pertaining to the MSIVs and MIVs would also be added stating:
- These valves are included only for table completeness. The require-ments of Specification 3.6.3 do not apply; instead, the requirements of Specification 3.7.1.5 and 3.7.1.6 apply to the Main Steam Isolation Valves and Main Feedwater Isolation Valves, respectively.
Specification 3.6.3 pertains to containment isolation valves other than the MSIVs and MFIVs and is applicable for Modes 1, 2, 3 and 4. Specifications 3.7.1.5 and 3.7.1.6 pertain to the MSIVs and MFIVs, respectively; apply to Modes 1, 2 and 3; and have different action statements than 3.6.3.
Thus, the effect of the licensee's proposed changed is to clarify the appropriate limiting conditions for oDeration and associated action statements for the MSIVs and MFIVs.
We find this clarification note acceptable and observe that a similar note appears in the Wolf Creek Technical Specifications.
The licensee proposes the addition of the following to the Bases section of the Technical Specifications:
3/4.7.1.6 Feedwater Isolation Valves The OPERABILITY of the feedwater isolation valves functions to: 1) provide a pressure boundary to permit auxiliary feedwater addition in the event of a main steam or feedwater line break inside contain-ment; and 2) ensure that no more than one steam generator will blow down in the event of a steam line rupture which a) minimizes the positive reactivity effects of the Reactor Coolant System cooldown associated wth the blowdown, and b) limits the pressure rise within containment. The MSIVs and FWIVs are not considered to be contain-ment isolation valves.
The containment boundary is the steam generator secondary side and tubes. The OPERABILITY of the feed-water isolation valves within the closure times of the Surveillance Requirements are consistent with the assumptions used in the safety analysis.
CALLAWAY - SP TABLE 3.2-3 (Sheet 2)
Regulatory Guide 1.29 Position Union Eleci
- a.
The reactor coolant pressure boundary.
- b.
The reactor core and reactor vessel intemals
- c.
Systems* or portions of systems that are required for (1) emergency core cooling, (2) post-accident containment heat removal, or (3) post-accident containment atmosphere cleanup (e.g., hydrogen removal system).
- d.
Systems* or portions of systems that are required for (1) reactor shutdown, (2) residual heat removal, or (3) cooling the spent fuel storage pool.
- e.
Those portions of the steam systems of boiling water reactors...
- f.
Those portions of the steam and feedwater systems of pressurized water reactors extending from and including the secondary side of steam generators up to and including the outermost containment isolation valves, and connected piping of 2-1/2 inches or larger nominal pipe size up to and including the first valve (including a safety or relief valve) that is either normally closed or capable of automatic closure during all modes of normal reactor operation.
- a.
Complies.
- b.
Complies.
c.
d.
Complies. See Item 2 below.
Complies. See Item 2 below.
- e.
Not applicable to the Callaway Plant.
f.
Complies with the exception that the words "or remote manual" are considered to be inserted after the word "automatic." This option is included to avoid an unnecessary complication (leading to decreased plant reliability) in the line which is not normally provided with automatic closing valves.
Note that valves in lines emanating from the steam generator are for secondary side isolation, not containment isolation.
Rev. OL-13 5/03
- 0'
CALLAWAY - SP considered. Sections 3.5, 3.6, and 9.5.1 provide the hazards analyses to assure that a safe shutdown, as outlined in Section 7.4, can be achieved and maintained.
SAFETY EVALUATION THREE - Section 3.2 delineates the quality group classification and seismic category applicable to the safety-related portion of this system and supporting systems. Figure 6.2.4-1 shows that the components meet the design and fabrication codes given in Section 3.2. All the power supplies and control functions necessary for the safe function of the containment isolation system are Class IE, as described in Chapters 7.0 and 8.0.
SAFETY EVALUATION FOUR - Figure 6.2.4-1 shows the arrangement for each line penetrating the containment and provides the design information that demonstrates that GDC-54 is met. Leak detection capabilities are discussed in Section 9.3.3 and in the system descriptions associated with the applicable penetrations. Tests and inspections for piping penetrations are discussed in Sections 6.2.4.4 and 6.2.6.
SAFETY EVALUATION FIVE - Figure 6.2.4-1 shows the arrangement and justifies compliance with the intent of GDC-55 for lines that are part of the reactor coolant pressure boundary and that penetrate the primary reactor containment. A list of penetrations subject to GDC-55 is provided in Table 6.2.4-1.
SAFETY EVALUATION SIX - Figure 6.2.4-1 shows the arrangement and justifies compliance with the intent of GDC-56 for lines that are connected directly to the containment atmosphere and penetrate the primary reactor containment. A list of penetrations subject to GDC-56 is provided in Table 6.2.4-1.
SAFETY EVALUATION SEVEN -As indicated in Table 6.2.4-1, there are no penetrations which are subject to GDC-57. Note that the containment penetrations associated with the steam generators are not subject to GDC-57, since the containment barrier integrity is not breached. The boundary or barrier against fission product leakage to the environment is the inside of the steam generator tubes, the outside of the steam generator shell, and the outside of the lines emanating from the steam generator shell side. Figure 6.2.4-2 shows the arrangement and justifies compliance with containment isolation.
As shown in Section 18.2.11.3, several portions of the main steam lines are considered essential and do not receive an automatic signal to close. These include the power-operated relief valves (PV-01, 02, 03, and 04) which receive no signal and the steam supply line isolation valves (HV-05 and 06) to the AFW pump turbines which open on AFAS.
SAFETY EVALUATION EIGHT - Sections 6.2.2, 6.5, and 9.4 and Chapter 15.0 provide an evaluation that demonstrates that the containment isolation system, in conjunction with other plant features, serves to minimize the release of fission products generated following a LOCA or fuel handling accident inside the containment.
6.2.4-6 Rev. OL-1 3 5/03
- 1..
.1
STEAM LINE BARRIER FEED LINE BLOWDOWN LINE CONTAINMENT BOUNDARY Rev. OL-0 6/86 CALLAWAY PLANT FIGURE 6.2.4-2 STEAM GENERATOR AND ASSOCIATED SYSTEMS AS A BARRIER TO THE RELEASE OF RADIOACTIVITY POST LOCA
/ X
SUMMARY
The licensee for the Callaway Plant has submitted proposed Technical Specifi-cation changes pertaining to the main steam isolation valves (MSIVs) and to the main feedwater isolation valves (MFIVs). The proposed changes restructure the Technical Specificatilons, primarily toward the objective of clarification.
No changes are being made to the valves or to their response times. We have reviewed the proDosed Technical Specification changes and find them to be acceptable, except for the changes proposed In the Bases section. In two places in the Bases section, the words "The OPERABILITY" appear.
We would suggest adding the words:
"of the main steam isolation valves and" after the word OPERABILITY in each Dlace.
Also the following statements should be removed from the Bases section.
'The MSIVs and FWTVs are not considered to be containment isolation valves.
The containment boundary is the steam generator secondary side and tubes."
ENVIRONMENTAL CONSIDERATION This amendment involves changes in the use of a facility comoonent located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously ublished a proposed finding that the amendment involves no significant hazards con-sideration and there has been no public comment on such finding.
Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR §51.22(c)(9).
Pursuant to 10 CFR §51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
CONCLUSION The Commission made a proposed determination that the amendment involves no significant hazards consideration which was published in the Federal Register (51 FR 45215) on December 17, 1986, and consulted with the state of Missouri.
No public comments were received, and the state of Missouri did not have any comments.
We have concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation n the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the ssuance of this amendment will not be nimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
Paul O'Connor, PWR#4/DPWR-A A. Toalston, EICSB/DPWR-A Date: March 10, 1987
FEEDWATER REG/BYPASS VALVES NOT IN TS
- Callaway MFIVs have dual actuators
- Feed Reg/Bypass valves are non-safety
- Callaway received NRC approval to revise MF Reg Valves logic in 1996 (Amendment 1 15)
- AmerenUE
- Callaway based it on dual actuators on MFIVs
- Feed Reg valves are not primary success path (1 OCFR 50.36, Crit 3)
- NRC
- did not agree that MF Reg Valves do not meet Crit 3
- that did not affect conclusion that proposed logic mod was acceptable
- Same Callaway rationale was provided to NRC during ITS amendment and no questions were received.
e,VU%Lt_.AH REGULATORY COIAMISSION WASHINGTON. D.C. =5-0OO*
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 115 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT. UNIT DOCKET NO. 50-483
1.0 INTRODUCTION
By letter dated May 29, 1996 Union Electric Company, the licensee, requested an amendment to Facility Operating License NPF-30 for the Callaway Plant.
The requested amendment involves an unreviewed safety question as defined in 10 CFR 50.59 Changes, tests and experiments." The unreviewed safety question involves a plant modification that will reduce the single failure trip potential for the main feedwater control and bypass valves (MFC&BVs). The purpose of the proposed modification is to reduce the number of inadvertent plant trips caused by inadvertent closure of the MFC&BVs due to a single failure. Reducing the single failure trip potential for these valves increases the probability that the valves will not perform their safety function (safety function is to close) and, thus, increases the probability of occurrence of a malfunction of equipment important to safety.
Therefore, pursuant to 10 CFR 50.59, staff approval of the modification is required prior to implementation.
Each of four steam generator (S/G) main feedwater lines contains a main feedwater isolation valve (MFIV) and a main feedwater control valve (MFCV) in series.
Each MFCV has a main feedwater bypass valve (MFBV) in parallel with it. The MFCVs are air-operated angle valves that control feedwater flow to the S/Gs between 20 percent and full power. The MFBVs are air-operated globe valves used to control flow to the S/Gs up to approximately 25 percent power.
The safety function of the FC&BVs credited in the accident analysis is to provide a backup to the MFIYs for the potential failure of the MFIV to close.
This safety function is accomplished on receipt of a feedwater solation signal (FWIS) via an emergency closure signal from the engineered safety feature actuation system (ESFAS).
For emergency closure, solenoid valves on each MFC&BV de-energize to release air pressure which results n valve closure.
The existing pneumatic valve control configuration for the MFC&BVs consists of two normally-closed ASCO three-way solenoid valves energized from separate Class E sources. A FWIS causes solid state protection system (SSPS) slave relays to energize and open normally-closed contacts. This interrupts power to the two normally-energized solenoid valves in the MFC&BV pneumatic control system. The solenoid valves are connected in series so that de-energizing J.
either valve (1 out of 2 logic) opens a vent path from the booster relay (for the MFCVs) or valve actuator (for the MFBVs) to atmosphere.
This results n depressurizing the associated reverse-acting actuator, which allows a spring to force the valve to a closed position. Valve closure time is less than or equal to 5 seconds.
The proposed modified pneumatic control configuration for the MFC&BVs will consist of two ASCO universal solenoid valves connected in parallel.
Either valve must be energized to align the air source to the booster relay or the valve actuator. De-energization of both solenoid valves (2 out of 2 logic) will be required to vent the booster relay or the valve actuator to atmosphere, which in turn will allow spring pressure to close the valve. This configuration will prevent a single solenoid or power supply failure from causing a plant trip due to loss of feedwater.
2.0 EVALUATION With the modified design, if one of the ASCO universal solenoid valves fails to operate when required, the respective MFCV or MFBV would not close as designed on a FWIS.
However, no other single failures would be postulated and the MFIVs would be assumed to operate as designed. Therefore, the safety function to isolate main feedwater flow to the S/Gs would still occur.
Each MFIV is a 14-inch gate valve with a dual redundant hydraulic actuator.
Two separate pneumatic/hydraulic power trains are provided for each FIY, each receiving a signal from a separate ESFAS channel. Either of the dual-redundant power trains is capable of closing the MFIV. The assumed single failure of one of the redundant MFIV actuation trains will not prevent the MFIV from closing.
Thus, there is-no single component failure, other than the valve itself (such as a stuck MFIV), that will prevent the MFIV from closing.
Therefore, there is also no single failure that could simultaneously affect the safety function of both a MFIV and a MFC&BV, and S/G feedwater isolation is assured given any single active failure.
While the proposed modification reduces the probability of a reactor trip, it slightly increases the probability that the feedwater isolation function will fail.
This is because the current design requires actuation of only one FWIS train to close the MFC&BVs, whereas the proposed design will require actuation of both trains.
However, this increased probability in loss of isolation function is minimized by the redundancy designed into the actuation system for the MFIVs. It is also minimized by the fact that the loss of power and loss
)f air failure modes still result in valve closure upon receipt of an FWIS.
%ny associated increase in risk caused by the increased probability that the
.eedwater isolation function will fail tends to be offset by a corresponding lecrease n risk associated with the reduction in inadvertent reactor trips.
n fact, the licensee stated that the requantified (requantflied to account or the new as modified failure rate) feed and steam line break event trees rom the Callaway Probabilistic Risk Analysis (PRA), showed no discernible ncrease n core damage frequency (CDF).
The safety related function of the main feedwater system is to provide containment isolation and S/G isolation. The containment isolation function is provided by the MFIV outside containment and a check valve inside containment. The proposed modification will not affect the containment isolation function. The design basis for the S/G isolation function is to isolate feedwater flow in 5 seconds upon receipt of a FWIS assuming any single active failure.
The proposed modification will continue to meet the single failure criterion for the feedwater isolation function and will not affect the ability of either the MFC&BVs or the MFIVs to close in < 5 seconds.
Therefore, the proposed modification will be in accordance with the original (and current) licensing design basis.
Based on its review as described above, the staff concludes that the proposed modification is in accordance with the original licensing design basis and will reduce the potential for loss of feedwater initiated reactor trips without a significant increase in risk as shown by the licensee's revised PRA.
The staff, therefore, concludes that the proposed modification is acceptable.
In its submittal, the licensee stated that because of the redundancy provided in the MFIV actuation system, the MFC&BVs are non-primary success path functions in the context of Criterion 3 of the NRC Policy Statement on Technical Specifications. Although the staff does not agree with the licensee's conclusion that the MFC&BVs do not meet Criterion 3 of the Policy Statement (Criterion 3 of 10 CFR 50.36) it does not affect the conclusion that the proposed modification is acceptable for the reasons described above.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Missouri State official was notified of the proposed issuance of the amendment. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (61 FR 34900).
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental mpact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
Your Feedback For SGTR Approval What should we have done?
For Secondary Side Isolation not Considered CIVs What should we have done?
What should we do now?
For Feed Reg Valves What should we have done?
What should we do now?
Valves ip
Bulletin 2002-01 Request for Additional Information (RAI)
Lessons Learned STARSNRR Projects Licensing Workshop. Jume 10.2003 Ken Petersen v"m I
Industry Concerns
- Significant NRC and Licensee resources expended to address RAls
- Can we minimize utility RAs?
- Can we avoid another industry RAI?
- Bulletin 2002-01 vlW 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?
I
Techniques to Minimize RATs
- Clearly define the NRC question or request.
- Conduct a critical eview of response.
Gnw 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 GnoD j
Critical Review of Response Response must completely addresses the question or request.
- Ensure ALL parts of a cornplex question are addressed.
- Statements of fact must withstand the "future review' tesL 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 coretly.
3
Safety Conscious Work Environment Mohan Thadani Stan Ketelsen
Background
- The following background will be addressed by Mohan Ibadani
- Commission's Statement of Policy SCWE vs. Safety Culture
- Discrmination Task Group
- Staff Requirements Memorandum (3/26/03)
NEI Recommendations
- Three areas addressed:
- Office of Investigation (01) Techniques
- 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 attnbutes of successful ECP
- Update/expand industy's tool boxe
- Develop guidance for management training on SCWE-related issues
- Recommend NRC defer internal efforts pending completion of ongoing industry activities 2
Sr
-. s.
INFORMAL COMMUNICATIONS STARS/NRR Projects Licensing Workshop. June 10 2003 Jack Donohew - NRC Project Manager Fred Madden - TXIU Energy 1n0w I
INFORMAL COMMUNICATIONS A.
Informal Communicution - What is it? Typically e-mail and telephone discussions and conference calls.
B.
uidelines -
v/ben and how o u Project Manager direction nd pespective....
C.
What to.Ehx c Whot ame s pilrails?
W n and why does e-mail become docketed/
Project Manger perspective....
INFORMAL COMMUNICATIONS Expenences
- 1. Comanche Peak provides to Project Manager e-mail copy of correspondence
- 2. Comanche Peak provides draft responses to RAls via e-mail to ensure conplemeness of proposed responses
- 3. Regular (several times per week) communications between Project manger and licensing lead
- 4. Appreciate efforts of Project Manager to explicitly define tedsnical issues S. Other experiences....
vom 3
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 C)
Em ve11 lm kl*
Of to UEE ad Cl :
Lonsliassl aftnul ily t hu.als orh Uw Or 1110 to l
n he 12 ie fie o eatiMmal UEUOlt da lteadaret Od tay SE 5st dlX IDI IE:de (3) 6lou EU EUIIe O ally 6,h1 pElE m dverely offE by VW Orde of Ndo o iinrrdt.usmy~da~ d a
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- BW 0s Ie_
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cWQ 02w U a.w dai dlt EUy El.e. It amCaruo dlde VW8 onPl W=be aEta eflEcdneP idO luftP ld NRC Orders
) tile keree. or Oter person b rer tbo Comnsr i Eonh sued an imnedlely efHechrve older lil0dI addition to de nding a heerhg at te trne I artwer dl tkd or soner. move Ile presidn oker D et aside le dnnediae tectiveneu of fte order on fte Wolald VWt toe order.lrg fila te need bor tdiate etec
.~ rinot bse on adqe vence bidt on mnere pcbon, taitonded atteatorts or error The motion muststat kwith p ytbe reasonswhfiteorder 11 not sed on ae ience n
by affits or other nce relied on. The NRC t sh1 resoond witr (5) dS of 11e receipt ot tie mobon. The Miobn rnu t be dedded by the predirntr othcr ept O ing n pericy d e moton or Itt ely otber le, to presidingp offcer may rot tay fie bad te tten 0t orter. Either on ts own inoln or rpon mootn el te icensee or other person. The residrg offi wU stIpeld the trlleite ffecterless of te S
H t ids td tiere Is adequate evidence tD spport lledilte ffectienss. An order rldng blalledste ectres wI constitute fe fil agency ctn on hrnediate fllciteness. An order se" aside iediate effectIven i
be reterred pr=arty ID ie Comnsbn Itset and in nmot be efecve pendrg ter of te Conti NRC Orders td) All answe rnsy aonsrl tO the *nitty df an order i siiistantss)ly thea brn proposed hl the order with resPect to all or Srne od the ans proposed in the oder. The corsert. h fe erwer or ther written docanent. d the kensee or other person ID wtom the order has been essued to the etry d an oder shat toristiLite a waiver by the iensee or thperson ds hea*ing.
fhdings d tat end Conctusirns d lw. and d alt rit to a"ek
=
.- Imesaon and jicial review or tO contest the vebdny d the order n ny fonim as to tose toners tich have been conSented to or reed Io or on wtiCh a heaing tas not been requested An order that has been consented to shal have fte earns tce and effect as en der made after teareng by a presiding officr or the Commission arid shalt be effective as provided h tha order.
(e) t the order Wolves the nofcation of a pan 50 icenise tnd s a tckft, the recuerments of S5W. 0 o tis Chtper shal be followed,tNless he Icersee has cosenta lo the action 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 beter.
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 perrnission to provide a substitute feature that meets the substantial Intent of the order.
- Initiate a License Amendment Request.
-Walt 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 Commisslon. 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 P0.611w mo s
s nacy dan Giftaai 1 ars r
9ac~wd an UmlA1 a
WS.gnC Sl loed 1iii 50.341d W ph 7310 In aar.er locaaS.
doat y
pir p.sr' am Ccmso *lia dasace m eacy s,n ra prlg Gu a.:14(ra eras lorn awdid tolls
.aaa Swineu prwan to elbeGtOr.5_0w Th s Swie.
hd mk change Ic m l land0 WbOr0f tD b
-s W:.,hCsA rmc C nmans acvos I 1 cs do da daesa m £a.59siUsrr efai,to ncll re.
Isna.
shsian am o1 chnes lS lan man.iaUpU Comsan acesu icr s d Sa
.a.shOle,, da 10m 01e. and salntor. a a Ie SIOA.
mte 1
aa.Ferlsgwrs esfwgety Dlan 1si p0sa GlaD.Ee 0)
NRC Orders 150.90 Application for amendment of license 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 Commission, as specified In §50.4, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
NRC Orders 150.4 Wrfen conalwnlcatlons.
(4) SscuLty pan and related uajmints Wrktlen awnm,nitos.
as defrmd in paragraph (bX4XI) tmo (lv) of this stctio tnst be subnitted as folows: The signed igatl and tIsae copies to tte Nueta Regulatory Commission, DoCment Contri Desk.
Washngton. DC 20555. and lWo copies to te appropriate Regional Ofte; fi) Change to ar4y pban guardr taing and qe5fmtion plan.
Or safeguds corigenrcy plan mde whout pt Commission approvel pulsuant to 550.54(p);
(iv) Applicalion for amendment d physicat seclty plan, grd mning and qulfmtolion plan, or sagf coingency pbn pUrsu1rd to jSM.90.
4
PERRY DECISION STARSNRR Projects Licensing Workshop, June 11.2003 Don Woodlan 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 Mbl Regulatory Point
- What is threshold needing a License Amendment for making changes which need "prior NRC approval"
- Goes back to meaning of Section 1 9a of Atomic Energy Act re hearing rights and public involvement
- Does the change create "greater operating authorit' 1
Industry Concerns
- NRC referred to Perry Decision to require that several changes needed License Amendment to adopt
- Examples:
- Fire protection altemate rule
- BWR Integrated Surveillance Program
- NEls Steam Generator Program NRC Approval without License Amendments
- Exemptions
- QA Program changes
- E Plan changes
- Code relief
- Fire Protection Plan changes
- Some Security Program changes vXzm 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?
VoUl 2
Regulatory Activity
- NEI letter opposing the recent NRC use of the decision
- NRC position presented at 2002 NEI Licensing Forum vilm Potential Position
- Changes which actually change license need LAR
- Changes need LAR if required by I 0CFR50.59 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 Evahation would have required one (e.g.,
topical reviews) vllxn a
3
50.59 Revised Rule Follow-up USA 50.59 Task Team Benefits and Challenges y m
,-S-,,,..,*1':'..
Evaluations Performed Since Rule mplenentation No. of PA Evaluations Caflaway 3
Comanche Peak 8
Diablo Canyon 22 Palo Verde 43 South Tes 13 Wolf Creek 4
I
Regulatory Reporting Requirement
-The licensee shall submit, as specified in Sec.
50.4, a Teport containing a brief description of any changes, tests, and experimcnts, including a summary of the evaluation of each. A report must be submitted at intervals not to exceed 24 months."
NEI 96-07 Reporting Guidance
'A summary of 10 CFR 50.59 evaluations for activities implemented under 10 CFR 50.59 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 50.59 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 d 10 CFR 50.59 evaluations for acfivities implemented under 10 CFR 50.59 must be provided to NRC. Acthities that were screened out, canceled or inplemented via license amendment need not be ncluded In this report."
2
Resource Manual Reporting Guidance Komdmed)
'Each evaluation wig kdude an Activity description and a Summary of Evaluation. These sectins will become the basis for preparng the 10 CFR 50.59 Summary ReporL The scUvity description and summary sections for each eluation should address the nportant attributes of the activity as well as the signifticant 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 STARSrR Projects licensing Workshop.Jime 11,2003 Don Woodlan Mnl I
Other Topics as Time Allows
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NRC PRESENTATIONS STARS/NRC LICENSING WORKSHOP June 1 0 and 1 1, 2003 Kansas City, Kansas
..= &NRC Work Controls PI'e
- ax Stephen Section Clue Tuesday, June 10 Dek
June 10, 2003 2
Overview of Pesentation
- What is CWP?
- Desired outcomes
- Critical information
- What's different for the PM?
- What can licensees do to help?
- Implementation plan
What is NR ks Centralized Work Planning roess?
- Tool to help organize, understan 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 E
June 10, 2003 4
Desired rmes
- More efficient and effective use ofl resources
- Better predictability
- Better quality control
- Continuous improvement
June 10, 2003 5
Critical nfornation 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
6 What's Differe for the PM?
- See Handout
June 10, 2003 7
What can licensiees do to help?
- Nothing surprising here:
- Submit high quality documents
- Make it easy for NRC to determine whi 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, 2003 8
Im ntation Plan
- FY03 Define and communicate responsibili to st Pilot standardized characterization process Pilot standards development process Standardize process steps for another product taff
- FY04 t
Apply characterization and standards development proces two more products Standardize process steps for another product (or two)
Update skills database and prioritization scheme Develop and pilot performance monitoring scheme A
X, S
Ne i\\<7 wommommommmonommum
Imple ntation Plan (conti nŽed
- FY05 Repeat cycle of standards development a definition as needed Develop scheduling and planning optimization Implement performance monitoring scheme
- FY06 Start cycle of systematic process review and improvement Pilot centralized scheduling
0) 0 Centralized Work Planning Stephen Section Clic bek Tuesday, June 10
John Hardson 10130/02 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 nvoved section SC provides completion date based on PM's required completion date 9 PM negotiates' 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 retumed 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, complefon 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 review Is on schedule, and reports back to PM. Special attention Is paid to urgentloutage related amendments 15 PM issues final product (FR Notice, SE, Amendment, and Same Transmittal letter)
DPR - Division Planning Representative PM - DLPM Project Manager SC - Technical Branch Section Chief STR - Senior Technical Reviewer WPC - Work Planning Center C:WPGWMnt?uPM lob chnr,wpd
'% Fk'p Rtco qsp Managing Schedules for LARs to Support Plant Activities Davu ProjectA Jaffe Senior NRC ation Comanche Peak Steam Tuesday, June 10,
\\'n2g) Ro utneo om m u n icatio n s
(No>urprises)
- Occasionally Remind Us of Planned Outage
- Inform Us Promptly of Emergent Situations
- Occasionally Contact Section Chief (Important for Emergent Situations) 2
The BI icture
- 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)
So 15
- 10 CFR 2.108 Allows the NRC to Deny an Application for Failure to Respond to an RAI 3
SCheule for Routine LAR Moderateomplexity (No Generic r4 Lms) rJ'nie2 Table X-t§>+.(vY
Acti6ii Taken 1St Day Submit LAR 1st Month Reviewers Assigned Noticed in Federal Register 3rd Month RAI to Licensee I
5th Month Response to RAI 7 th Month Issue License Amendment
- High Quality Submittal oPlenty of Support t
4
Emergen6y/Exigency Emergency (10 CFR 50.9 1 (a)
- Requires an Explanation of Why th cti 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 Ac "Quickly" (Act in 1 to 3 Weeks)
7,~
P RG44 110Managing Schedules P:,@ for LARs to Support Plant Activities Dav 2affe Senior Project NRC Comanche Peak Steam aion Tuesday, June 10,
C, im t-4 NRC Fees and Fee Waivers Stephen Section Chie
.. 11l Tuesday, June 10'
2 equiremnets for Fees'-
- Required by law to assess fees to re r most o-our budget FY2002 annual fee for power reactors licen operate is $2,849,000 and the hourly rate for s v
is $156 FY2003 numbers should be available before the e the month
- Fees are sent to treasury, are not retained by the NRC, and do not directly affect amount of funds available to NRC If
June 10, 20033 3
Fees or censing Actions
- Regarding licensing actions, ases fees for:
- Pre-application consultations
- New applications, amendments, & renewa
- Standard technical specifications
-Other licensing tasks requiring NRC approv(
3ks w
June 10, 2003 4
Billable Doc rRelated Activity
- Billable P ct Manager activities inc
- Docket specific s,
- Work licensing acti
- Discussions with NR a
on plant specific issues
- Site visits
- Responding to licensee questions
- Attendance at this meeting
Billal on-Docket Related AcMvties
- 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 X
non-docket specific activities are prorated equally to all assigned dockets 4-
June 10, 2003 6
Non-BillableActivities
- Can not bill licensees for the fo ing Project Manager activities:
- Leave, rulemaking, voluntary (unpaid) overtime, preparation of genenc guidance documents, Freedom of Information Act requests, union activities, Combined Federal Campaigns
June 10, 2003 7
Fee Eximptions
- 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 req and that are selected by the NRC ee9
Fee Exempions (continued)
- 3) Requests or reports submitte he NRC:
Response to a GL or Bulletin (except ting an amendment)
Response to an NRC request (Associate Offt tr or above, e.g., Brian Sheron or Bill Borchardt to resolve an identified safety, safeguards, or environmental issue, or to assist NRC in developi w X
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.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~9 Fee Exemp ion (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 t C
's development of generic guidance and regulations (e.g., reg fid guides, and policy statements; and
- 2) The NRC, at the time the document is submitted, plans to use 9 f 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 GF Nuclear Encrgy CE disputes the $l.377.000 ordercrrcd cosis assessed under Pat 170 or thc rvicw of thc Gcneral lectric Standard Safety Analysis Report (GESSAR). Rviews were cndcd in 1985 and 1986.
costs weme dcferred under the fee nilc.
Denicd l,icense was aware ordefcrred costs. delayed hilling docs not rclieve GE of its lcgal obligation to pay the fcss associated with the services that the NRC provided in response to GE's request for a standardized design review.
02/14/2002 Electric Power Research Inst. Request waiver of less for review of EPRI s Topical Report TR-102323. Rev 2. "Guidelincs for Electromagnetic nterfemcce (I.MI) Testing in Power Plant Equipmcnt.
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.
02105/2002 Nuclear Energy Insitute Request waiver of fees to review EPRI Technical Repor entitled. 'Guidelines for Addrcssing Faliguec Environmental Effects in a License Renewal Application" Granted Revisions F and G were submitted for the purpose of supporting NRCs generic regulatory improvements rclated to the treatment of fatigue environmental effects.
12/20/2001 Dairyland Power Cooperative Exemption from assessment of new Part 171 Decomissioning and Spent Fuel Pool annual fee.
Request based on old. and small.
12/05/2001 Southem Nuclear Op. Co.
Partial exemption to 10 CFR 170 fees for License Renewal Dcnied OBRA-90 is consistent with the intent of the statute to collect 100 percent of the NRCs budget authority as it applies to all licensee in the class thereby establishng a fair and eqtitable 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.
1023/2001 CEOG CE NPSD-994. -995, and -996. "Joint Application Granted - Partial The 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 Eiergency Diesel Generator, (EDO) Allowed Outage Time (AOT) Extensions" 09/17/2001 CEOG CE NPSD-1 186 - TECHNICAI JUSTIFICATION FOR RISK INFORMED MODIFICATION TO SELECTED REQUIRED ACTION FND STATES FOR CEOG PWRs 09/13/2001
- YLAND POWER COOPERA FULL OR PARTIAL EXEMPTION FROM THE SPENT FUEL STORAGE/REACTOR DECOMMISSIONING ANNUAL FEE DENIED SUBMITTAL OF REPORT DOES NOT MEET THE THE FEE WAIVER CRITERIA OF FOOTNOTE 4 TO I CFR 170.21.
DENIED EXAMINED BUDGETED COSTS ALLOCATED TO THE LACBWR AND HAVE DTERMINED THAT THERE IS NO SIGNIFICANT DIFFERENCE BETWEEN THE NRCS REGULATORY COSTS FOR THE LACBWR AND THOSE FOR OTHER LICENSEES IN TIlE SPENT FUEI STORAGE/REACTOR DECOMMISSIONING CLASS.
Thursday, May 29,2003 Page 1 of6 Thisrsday, May 29, 2003 Pnge I o6
DATE OF LETTER LICENSEE NAME SUBJECT
' DECISION I.t BASIS 06/13/2001 03/02/2001 02/27/2001 01/18/2001 01/16/2001 01/16/2001 EPRI TVA vI,rco CON EDISON CO.
VEPCO GRAND GULF NGS REVISED RISK-INFORMED INSIRVICE GRANTED IOOTNOTE 4-INSPECTION EVALUATION PR(XI ) IRI:
INFORMATION TO BE USED TO St IlP)PORT NRCS GENERIC RI(;IJL,ATORY IMPROVEMENTS. SPIECIFICALLY RE: RI-ISI RI-ISI AS AN ALTERNAIlViE FOR ASMF.
ANrIi) - I'AR'r-PART 170.1 I(bX I) - PARTIAL WAIVFR IS APPROPRIATE FOR THAT SECTION XI CODr CLASS PIPING ANI)
PORTION OF THE BFN'S UNIT 3 S IRMIT'Al, THAT STAFF AUSTENI'I'IC STAINLESS STEEL. PIPING FOR
)FTERMINED HAI) GENERIC APPLICAB1ILTY.
BROWNS FERRY UNITS 2 ANI) 3 REQUEST F EE WAIVER FOR StIRRY GRANTE)
PART 170.1 lI(bI) - 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.
ACCIDENT SOURCE TERMS OR LIG6 IT-GRANTED PART 170.1 l(bXI) - STAFF USED EXPERIENCE TO ASSIST IN WATER NUCLEAR POWER PLANTS PREPARATION OF THE REGULATORY GUIDANCE, STANDARD REVIEW PLAN AND RULEMAKING.
ALTERNATIVE RADIOLW.ICAl, SOURCE GRANTED PART 170.1 (bXI) - 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.
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 02/08/2000 01/06/2ooo TXU ELECTRIC CO.
TXU ELECTRIC MOAB MILL SITE 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 PART 170.1 I(bX1) - INFORMATION PROVIDED IN THE TOPICAL REPORT LED TO THE CONCLUSION THAT THE RESOLUTION OF THIS ISSUE IS GENERIC IN NATURE AND NOT PLANT SPECIFIC GRANTED PART 170.1 I(bXI) - 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 RI-IST METHODOLOGY.
GRANTED PART 170.1 I (b)(1) - ALL FUNDS AVAILABLE TO PWC FROM THE TRUST SHOULD BE USED TO OPnMIZE SIT, REMEDIATION.
ATLAS DECLARED BANKRUPTCY AND PURSUANT TO THE TERMS OF SETTLEMENT COURT-APPROVED REOGRANIZATION NOT REQU)IRED TO COMPLETE THE REMEDIATION. EXEMPnON GIVEN TO PWC (TRUSTEE) IN THE PUBLIC INTEREST.
Thursday, May 29, 2003 Page 2 ol6 Thnrsday, May 29, 2003 Page 2 o6-
DATE OF LETTER LICENSEE NAME SUBJECT DECISION BASIS 10/29/1999 ARIZONA PUBLIC SERV.
10121/1999 PA POWER & LIGHT CO RISK-INFORMII) INSURVICE, TESTING PROGRAM PILOT PLANT REVIEW PART 50 EXIEM TlION Rl:,QI IESI RE: Ti II:
CONDUCT OF A l Ji.l PARTICIPATION EXERCISE OF ll lE. ONSITE AND OFsrE EMERGENCY PlANS GRANTED PART 170.11 (bX I) - APS WAS ASKED TO PARTICIPATE IN PILOT PRO(GRAM AND NRC ACCEPTED THEIR SUBMITTAL. UTILI7.E)
[I EXP.RIIEN('Ii GAINED TIIROUGHi THE REVIEW TO MODIFY 5w.55a
.XPLICITLY ENDORSE RI-IST METIIoDOLO(iY.
GRANTED PAR'I' 70.1 I(b)(I) - PA P&L WAS REQtUIRED TO REQUEST EXEMPTION FROM PART 50 REQUIREMENT DUE TO FEMA ANI)
NRC REGION I'S NEED TO RESCHFDULE EMERGENCY EXERCISE AT TI IEIR SITE - SiIOULD NOT HAVE TO INCIJR COSTS FOR REVIEW OF PART 50 EXEMPTION.
07/27/1999 VARIOUS NRRS PILOT INSPECTION PROGRAM -
REGULATORY OVERSIGHT PROGRAM - 13 PLANT INSPFCllONS GRANTED PART 170.1 l(b)( I) - FEE IS WAIVED FOR CERTAIN INSPECTION EFFORT RELATED TO NRRS 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 IUMC AND ROuDEBUSH VETERANS ADMIN.
GRANTED PART 170.1 I (bX I) - SEPARATE LICENSES ARE MAINTAINED, MEDICAL CTR (VAMC) EXPLORING FACULTY MEMBERS HAVE JOINT APPOINTMENTS BETWEEN POSSIBILITY OF INCINFRAtlING IUMC AND VAMC. IUMC IS CURRENTLY LICENSED BY NRC TO RADIOACTIVE WASTF, 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.
APPLICATION FOR A NEW LICENSE FOR GRANTED PART 170.1 I (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. LCFNSEE THEN WANTED TO GENERALLY LICENSED. WAIVE APPLICATION FEE IC AND 2C ADD TO LICENSE CATEGORIES IC AND 2C.
CALVERT CLIFFS NPP - APPLICATION FOR GRANTED PART 170.1 l (b)( I) - APPLICATION REPRESENTS FIRST-OF-A-KIND LICENSE RENEWAL EFrORT FOR 130TH NRC AND INDUSTRY. STAFF INTENDS TO UTILIZE EXPERIENCE GAINED TO DEVELOP GENERIC IMPLEMENTATION GUIDANCE FOR LICENSE RENEWAL PROCESS FOR WHOLE INDUSTRY. (PARTIAL)
OCONEE NPP - APPLICATION FOR LICENSE GRANTED PART 170.1 I (b)( I) - APPLICATION REPRESENTS FIRST-OF-A-KIND RENEWAL EFFORT rOR 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 BG&E COMPANY 03/24/1999 DUKE ENERGY CORP.
Thursday, May 29,2003 Page3nt6 Thursday, My 29, 2003 Page 3 of6
DATE OF LETTER LICENSEE NAME SUBJECT DECISION BASIS 03/11/1999 CENTPRIOR PERRY - I.iAI) PILOT PLANT APPLICATION FOR'll I I SF o: 11 IF REVISED ACCIDENT SOl IRC lwEAM METI IOD)OLGY 0910411998 SUPERIOR WELL SERV.
Will IIDRAWAI. (F AMENDMENT TO ADD A CESIUM 137 SE,AL,ED SOURCE TO TH IEIR LICENSE GRANIID PAR'T' 170.1 I(hXI) - FIRST-OF-A-KIND APPLICATION FOR TlIr, REVIEW OF REVISED ACCIDENT SOJRCE TERM - STAFF USED EXIIERIIENCI IN PREPARATION OF REGIJLATORY GuIlDANCE.
STANDARD REVIEW PLAN AND ASSOCIATED RUI,EMAKING.
GRANTE)
IARrI 170.1 I(b I) - LICENSEE OBTAINED THE GENERALLY-LICENSED I)EVICES FROM THE MANUFACTtRER AND WIlI II)REW Tl IE APPLICATION FOR A SPECIFIC LICENSE. NRC REVlEWER DIED AND WORK ASSIGNED TO OTHER STAFF WHO DIDNT KNOW ABOUT THE WITHDRAWAL OF THE SPECIFIC LICENSE APPLICATION. COSTS REFUNDED 09/01/1998 VT YANKEE NUCLEAR VT YANKPE PILOT PLANT - RISK-INFORMED INSERVICE INSPECTION 08/18/1998 06/161998 06/12/1998 ENTERGY VARIOUS VEPCO ANO PILOT PLANT - RISK-INFORMED INSERVICE INSPECTION NMSS RFQUEST - EXEMPTION FROM FEE REQUIREMENTS FOR LICENSE AMENDMENT FILED BY AND ISSUED TO FIXED GUAGE AND SELF-SHIELDED IRRADIATOR LICENSEES TO CHANGE THE RADIATION SAFETY OFMICER (RSO)
SURRY PILOT PLANT sUBMITTAL - RISK-INFORMED INSERVICE INSPECTION -
GRANTED PART 170.1 I(bXI1) - PROVIDES THE PERMANENT APPROACH TO RI-ISI - STAFF INTENDS TO UTILIZE EXPERIENCE GAINED rHROUGH THe PILOT APPLICATIONS IN PROPOSED RULEMAKING PROCESS TO MODIFY 10 CFR SO.55a & RELATED GUIDANCE DOCUMENTS.
GRANTED PART 170.1 I(bXI) - PROVIDES THE PERMANENT APPROACH TO RI-ISI - STAFF INTENDS TO UTILIZE EXPERIENCE GAINED THROUGH THE PILOT APLICATIONS IN PROPOSED RULEMAKING PROCESS TO MODIFY 10 CER 50.55a GRANTED PART 170.1 I(bX1) - THERE IS NO TECHNICAL REVIEW ASSOCIATED WITH THE ISSUANCE OF AMENDMENTS, ISSUANCE OF AMENDMENTS IS AN ADMIN. MATrER; MAINTAINING LISTING OF CURRENT RSO IS FOR THE CONVENIENCE OF THE AGENCY GRANTED PART 170.1 1(bXI) - PROVIDES THE PERMANENT APPROACH TO RI-ISI - STAFF INTENDS TO UTIIZE EXPERIENCE GAINED THROUGH THE PILOT APPLICATIONS IN PROPOSED RULEMAKING PROCESS TO MODIFY IO CFR 50.55a GRANTED PART 170. 1 (bX I) - ONE-TIME ACIVITY 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.
02/26/1998 INTERSTATE NUC. SERV. LICENSEE CONDUCTED SOME SITE REMEDIATION WORK IN VOLUNTARY COOPERATION WITH NRC REGION I STAFF AT A rORMER NUCLEAR LUNDRY FACILITY.
Thursday, May 29,2003 rage 4 of 6 Thursday, May 29, 2003 PRge 4 f 6
DATE OF LETTER LICENSEE NAME SUBJECT DECISION BASIS 11/12/1997 ATlAS CORP.
10/03/1997 Arizona Public Service CO.
09108/1997 ST. LOUIS UNIV.
06/23/1997 KINNCO/KINNSCAN 04/21/1997 VARIOUS 01124/1997 DR. DALE E. EDLIN FFE FOR MODELING ANI) DETERMINATION (iRANT.)
OF SiF,PA(!i FROM TI., TAI,IN( iS INTO Tl Il.
(ROUNDWATER OVER Till. I(M-YE-.AR DFSIGN lIIF, OF THE Rl.AMATioN Request fee cxemption inder the provision of Part Granted 170.21. footnote 4, item 3 for NRC rvicw 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 n 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 PATIENT'S MEDICAL CONDITION AND UNIQUlE 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 LICE,NSE FROM KINNSCAN 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 THIEIR l,ICFNSE CAUSES CONFLICTS IN AtJlHORITY AND RESPONSIBILITY OVER TIIE RADIATION SAFETY PART 170.1 I(bx1) - NRC AGREFD TO FUND ONE TASK IN ORDER To ISSUE T IE FINAI, ENVIRONMENlAL IMPACT STATEMENT (FE IS) SO TIIAT ATLAS COUILI) PRO(EID TO RECAIIM TIIE 10.5 MILLION TONS OF URANIUM MIll.l TAILINGS AT THE SITE.
T'ASK IS VIEWED AS A CONFIRMATORY ANALYSIS OF ANALYSIS ALREADY PERFORMED BY NRC ANt) ORNL FOR WIIICH ATIAS WAS BILLED IN THE PAST.
NRC agrees that the submittal meets the critcria for the fee waiver provided in 170.21. Foolnote 4, item 3. The National Technologu and Advancement Act of 1995 requires agencies to use consensus technical standards unies they are not appropriate to agency neds. NRR confirmed that clarification of the audit requirements of NVLAP accredited laboratorieis is a matter of generic interest to all nuclear plant liccnsees.
PART 170.1 1 (b)( I) - 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 THtE FINAL RULE. NO TECHNICAL REVIEW WAS REQUIRED TO GRANT REQUEST. HOSPITAL WOtJLD 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 170.1 1 (b)( 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 (b)(1 ) - AMENDMENT REQUEST FILED BY DR. EDLIN TO REMOVE THE DUPLICATE LOCATION FROM HIS LICENSE TO CONFORM Wll AGENCY POLICY SHOULD BE EXEMPT FROM FEES Thursday, May 29, 2003 PageS of 6 Thtursday, May 29, 2003 Page of 6
DATE OF LETTER LICENSEE NAME SUBJECT DECISION BASIS I 1/29/1996 NFI Risk-Informcd nservicc Inspection valuation Procedure. EPRI Report TR-.106706. This is the non-proprietary version ot'T'R-10621.
09/18/1996 VARIOUS NMSS REQUEST-EXEMP'I'ION IROM REQUIREMI:NTS FOR LICINSI AMIi.NDMI.N'I FEES FILED BY AND ISSI I) TO PORTABLEI GAUGE LICENSEES TO CH IANGE TIl El.
RADIATION SAFETY Ol:FICI-ER (RSO) 05/30/1996 IJG&E and Duke Power Co. Partial waiver fo Parl 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 UTILIltY GROUP GENERIC BASIS FOR UTILITIES TO ADDRESS ISSUES IN GL 87-02 0S/20/1994 NEI EPRI-102470 - ANALYSIS OF HIGH-FREQUENCY SEISMIC EFFECTS 04/14/1994 NEI SAFETY RELATED MOTOR OPERATED VALVE TESTING AND SURVEILLANCE - GL 8910 EPRI FINAL TOPICAL REPORT Granted The non-pmprietary version is not subJect to fees in accordance with criterion three of Footnote 4 of 10 CFR Part 170.21.
GRANTED PART 170.1 I(bX I) - TIIERE IS NO TECI INICAL REVIEW ASSOCIATED WITH TIIE 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 170.11 (bX 1) - 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 I(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 LETTERS& 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 170.1 (bX1) USE OF METHODOLOGY WILL PROMOTE UNIFORMITY IN THE DETERMINATION OF VALVE SWITCH SETTINGS & UTILITY RESPONSES TO GL 89-10 Thursday, May 29, 2003 Page6ol6 Thursday, May 29, 2003 Page 6of 6
'b-I*
NN 4
0 Quality of Submittals Revisited Jack Donohew Senior Pr?
lManager, NRC Callaway
, Station 1
Palo Verde Nucleat E Station Wolf Creek Nuclear C tion Tuesday, June
2
- LIC-lOl, Amendments I
- LIC-102, Relief Request Reviews
- LIC-103, Requests For 4
Exemption From The Regulations
- NEI White Paper Dated August 2001
\\X
June 11, 2003 3
Goals of Licensees and NRC
- Licensee sends all the informat 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 rovements Jed
- Provide date licensing action neededt Lthe basis
- Provide time to implement amendment
- Provide precedents
- Provide electronic copy of submittal and clean copy of TS pages
June 11, 2003 5
10 CFR>§O.4(a)
- Signed original of written cor den to DCD, Washington, DC 20555
- List NRC-specified addresses on submi as receiving copy Lce
June 11, 2003 6
Incorrect Addr
!d Submittal
- Upon rZ ing, PM 1
sends copy9 original, if p DCD tf'
-Nfk 00 MP N
4) 11.4 10 1'. -
Quality of Submittals Revisited ack Donohew Manager, NRC Senior I Callaway
.1 Palo' Wolf Verde Nuclear r tation I ~~a
! i EStation X
~on Creek Nuclear C Tuesday, June
f-ci Q
(ualiyand Role of SERs Today Robert A Section Che Tuesday, June 10.
June 10, 2003 2
ROLE OF AETY EVALUATIONS
- LIC-lOl0 and LIC-102 provide outlines content Introduction Regulatory Evaluation Technical Evaluation Commitments Conclusion
- SEs provide regulatory basis for NRC decisions on licensing actions
June 10, 2003 3
ROLE SAFETY EVALUATIONS continued
- SEs cite pertinent regulations and reO criteria
- SEs describe staff rationale for why chang is/is not acceptable
June 10, 200 4
ROL 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 progra Commitment SEs describe licensee commitments relied upon to make licensing decision SEs are generally not directly enforceable
June 10,2003 OLE OF SAFETY 5
EVALATIONS continii '
Unique Cases where SEs may contain new licensin is information ASME code relief under IST 50.55a(f)(6)(i) and Inservice 50.55a(g)(6)(i)
For relief sought when code requirements are impractical, "' l commission may grant relief and may impose alternative requiri SEs provide insights for licensee consideration on what inform include in FSAR updates per 50.71(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
- Expectation is that staff products are accurate an(
fully support licensing decisions
June 10, 2003 7
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)
June 10, 2003 8
QUALITY OF SEs - continued
- Results evaluated and trended Office level basis
- Office Instruction to be prepared follo pilot
- Quality Initiative to expand to include othe NRR work products
0 N. %1
'U.
14S.%
0 lz
- 01.
Quality and Role of SERs Today Robert A.
mm Section Chie a
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):
Date Submitted:
Prepared By:
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-IOI, 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).
AITRIBUTE 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 requirements, or standard industry practice). Where appropriate, the SE identifies the regulatory commitments made by the licensee.
E Evaluation Conclusion - Document includes a summary 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 pattem 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 nstructions)
Date LA Review:
Reviewed:
Additional Comments:
0)
Use of Task Interface S
Agreements DyLanne A
InteT, N Tuesday, June 10 ieaud
June 10, 2003 2
What is k Interface N(TyI A)
Agreeme
- 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 responsibilities Cv.-.A.
If.
K
,rE F
June 10, 2003 3
Reason *r 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 el
- TIA SES Process Owner
- A management representative of at least t Branch Chief level from the requesting office
June 10, 2003 6
Pro
- Issue is discussed by telephone
- Submittal mutually agreed upon within a week of initial request
Jne 1,20 Anot needed in the followiii4-cases:
- The staff has previously expressed a posi
- The inspection findings involve the performancsk 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 ne-(continued):
Do not concer policy
- Mutually agreed to ha significance and can bt telephone or e-mail ie very lo'"
e answered F
I.,
June 10, 2003 9
Prio aTIA
- Safety and risk significance
- Operational impact
- Regulatory impact
10 Licen Involvement
- Interaction with licensee encoufc obtain clear and accurate inform; to 1'I
- A written submittal from a licensee ma) requested
- Adverse impact on the licensee
LOUse of Task Interface Agreements
-C.
DyLanne Intem 10 Tuesday, June I10 teaud
Bulletin 2002-01 RAI Lessons Learned c Donohew Senior Pro Callaway Palo Verde Nuclear Wolf Creek Nuclear Tuesday, June r, NRC I
I
June 10, 2003 2
B in 2002-01 RAI Lesson arned Bulletin 2002-01 not explicit on wl know what components were inspected how inspections were performed how discrepancies were dispositioned I NRC wants to In RAI, staff acknowledged that it was not clear 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-Lessons Learne NRC and industry have different audiences Licensees need to convey there is no severe problem and it is contr oblem within existing licensing basis
-NRC needs to convey there is problem (why else the generic communica
~~t 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 dom Perhaps similar situations just can not be avoided Bulletin 2002-01 reflected NRR need to quickly request information
%FfopJ%l 0~ ;>,
a I
Bulletin 2002-01 RAI Lessons Learned
\\\\<
~Donohew, Senior Pro nager, NRC Callaway a tion Palo Verde Nuclear
- I Station Wolf Creek Nuclear ji tac i1 n Tuesday, June*
Safety Conscious Work Environment MOh^& Thadani Senior Projec er NRC Cooper Nuce Tuesday, June 10,
aSfedy Conscious Work Pvironment Commission's Statement of P
- Safety Conscious Work Environment/
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
June 10, 2003 2
Safe Cnscious Work Eninnent
- The Staff's Responses to March 26, 2003 SRM
- The SRM Outlines the Commission's Recommendations June 10, 2003
tN
'U-Safety Conscious Work Environment
. 7 Mohal Z. Thadani Senior Project I ger, NRC Cooper Nucle(
South Texas I Tuesday, June 10,
Informal Communications
.4 '
1 Aq isp (e.g., email draft j
information)
$ Donohew Senior Pro Callaway
- anager, b~%
N.
a NRC on Palo Verde Nu n
Wolf Creek Nuclear E an Tuesday, June
2 I
Communications
~ email)
Emails and Letters which do not Control Desk (DCD) q_uickly prov submittals going to DCD provide does not go through licensees' C Document L..
3s informal or draft
)C/QA checks COM-203, "Informal Interfacing and Exchange of Inform 711 with Licensees and Applicants' covers conference calls where summaries are written in record books allows for informal communications between NRC/Licensees per 2.102 Information used to make a regulatory decision must be docketed
June 10, 2003 3
nfornnommunications Informal Communications help improve effic Quickly helps determine if what NRC needs on the t is being provided Avoids multiple letter exchanges between NRC/Licensee Information used to make a regulatory decision must be docketed Substantial information (letter needed) vs. Clarification (emalil call from licensee)
PM judgment
June 10, 2003 4
Infornommun ications (e.g.
al RAls can be docketed several ways letter issued by staff and responded to by licens 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 inforrr that would be withheld from public proprietary information safeguards information
Informal Communications A.'
(e.g., email draft information) jk Donohew Senior Pro]
tanager, NRC Callaway
'M Palo Verde Nuclear Wolf Creek Nuclear (
Tuesday, June
~40:%
C~
f-Processing Submittals Associated with Security Issues David Jaffe Senior Project Comanche Peak Steam NRC o~tin Wednesday, June 1
June 11, 2003 2
Protecting uards Information Withholding S
Information
- Regulatory Issues Summary 2003
- Fall 2003 NEI Licensing Issues Forum
June 11, 2003 3
Docuirnents Withheld from 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 Enei whose compromise would assist in the design, manufacture, or ul of nuclear weapons
Je0ocuments Withheld 4
from Pubi Disclosure Classified Information
- Information concerns physical protection vulne l
may be classified information.
- Clearance and "need-to-know" required for access
June 1 5
i Documents Withheld fro>Public 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.
June11, 2003 uments Withheld from 6
PuŽliscosure 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 commer 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 accoui t
program for special nuclear material not otherwise designated as Safeguards nformation or classified as NSI or RD
-U12OOWocumentS Withheld 7
from ic Disclosure Other Sensitive Unclassified In ation
- The NRC expects that licensees will continue est withholding of some information using this provis
- The NRC believes that the volume of material requesedg 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).
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~8 Submis ddressing Securit sses
- Change.volving Physical S
- FSAR Updates
- Miscellaneous Issue.
Under 10 CFR 2.790
Processing Submittals Associated 0
with Security Issues Da' Jaffe Senior Project M
'WNRC Comanche Peak Steam' Lation Wednesday, June 1
Making Changes to the Plant Associated to Orders -
Process Guidance Robert Al Section Ctl Wednesday, June
June10, 2003 2
frd rs
- NRC may modify, suspend revoke a license with an order
- License modification orders: change in
- ent, procedures, personnel, or management co
- Suspension orders: remove threat to public 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:
activity stop an authorized
- NRC Enforcement Manual Section 5.8, "Order Modifying, Suspending, or Revoking License"
- Staff Handbooks
4 rdbs - continued
- The 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 IO,'
^re 5
Jure er 5
continued
- Response may consent to order wh aives rigl to hearing
- Response may present facts supporting posi for not consenting to the order and reasonsw j the order should not have been issued
- Response can demand a hearing to move Commission to set aside immediate effectiveness of the order it
June 10, 2003 6
MODIFYIN&A9N 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
MODIFYFG AN ORDER-
- If a hearing, becomes effective as determined in the hearing
- Requests for extensfio of time to request a hearing can be made to OE (or as described in the Order)
June 10, 2003 8
EXAMPLESSOF ORDERS EA 03-009: Interim Inspection Requirements for PWR R ads Order effective immediately until superceded by 50.55a cswer or request for hearing does not stay immediate effectiveness
"...all PWR Licenses identified in the Attachment to this Order sh 1
modified to include the inspection requirements for RPV heads and a i
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
EXAMPLESOF ORDERS-contiued EA 03-038: Cpensator Measures for Fitness-for JSh L 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 I
2 to this Order except to the Licensee's security plans."
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."
tpA 1:'
'-l Making Changes to the Plant Associated to Orders Process Guidance Robert A.
Section Chie mM Wednesday, June I
Perry Decision Senior ]
Calla Palo Verde I Wolf Creek ack Donohew Manager, NRC way Station Nuclear S !
h W Station Nuclear
. ion Tuesday, June
2 l pcirs C
oeciio
schedule for RPV material specimens per Part 50 Appen licensing amendment.
- Commission reversed decision: Only agency approvals grantd "exceed existing licensing authority" are license amendments.
withdrawal schedule change conforming to ASTM standard not a license X
amendment a change not conforming to ASTM standard is a license amendment.
June 11,20033 Perrycision 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 co 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 Senior I Calla Palo Verde I Wolf Creek ack Donohew Manager, NRC w
ay~~~~~~~~~~~~~~~~~~~~
way Sta~tatio Nucle;arl t
Station Nuclear don Tuesday, June
'U "a-d 50.59 Revised Rule Follow-up Moha'? C. Thadani Setiior Project Cooper Nuc1e3 South Texas NRC WX v Wednesday, June 11
Reevised Rule Fdwup
- Revised Rule effective March 1
- Inspection Procedure 71111.02 June 10, 2003 2
z59 Revised Rule Foowup
- Experience NRC staff has questions about the approp s of the licensees implementation NEI believes that the NRC is inconsistent in judgi applicability of 10 CFR 50.59
- Future Action Industry Meeting - Need for Further Guidance?
June 10, 2003
0) 4'-
I-,
- 4 n0 50.59 Revised Rule 8
~Follow-up Moh
. Thadani Senior Project er, NRC Cooper Nucle South Texas P Wednesday, June 1