Text

Handouts for June 10 - 11, 2003 Meeting Re STARS-IRAG/NRC Workshop
	ML031920649
Person / Time
Site:	Palo Verde, South Texas
Issue date:	06/10/2003
From:	Donohew J; NRC/NRR/DLPM/LPD4
To:	;
References
	Download: ML031920649 (160)
	v • d • e

NRC FORM 655 US. NUCLEAR REGULATORY COMMISSION TRANSMI1TAL OF MEETING HANDOUT MATERIALS FOR IMMEDIATE PLACEMENT IN THE PUBLIC DOMAIN This form is to be filled out (typed or hand-printed) by the person who announced the meeting (ie., the person who issued the meeting notice). The completed form, and the attached copy of meeting handout mateials, 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) 50-498, 50-499, 50-528, 50-529, and 50-530 Plant/Facility Name South Texas Project, and Palo Verde Station.

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 attached to the meeting notice.

NAME OF PERSON WHO ISSUED MEETING NOTICE TITLE Jack Donohew Senior Project Manager OFFICE Office of Nuclear Reactor Regulation DMSION Division of Licensing Project Management BRANCH Project Directorate IV Distrbution of this form and attachments:

Docket File/Central File PUBLIC - jO(

NRC~~~ FO. 6.. (_199 P.NE O NRCCE AE hstr,wsdsge sn no NFiC FORM ff58 (ti999) PiNTi_D FIECYCLED PAPER This lnn was desigined using, InForms

June 10 and 11, 2003 Kansas City Following is a workshop agenda. The flow of the workshop is from Licensing submittal scheduling issues to quality to change processes. The workshop is meant to be panel discussion with one or more NRC and STARS person on the panel (as indicated by the topic). Each panelist will present an aspect or perspective of the topic. Once complete, the session will be open for questions with a member of RASIG taking turns as moderator/facilitator. STARS panelists will eitherbe e 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 aflemoon. A discussion session has been scheduled for the second aftemoon. Since IRA G will begin their Quaterly meeting that aftemoon, 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 experence and discussion.

STARS I NRR Projects Licensing Workshop June 10 and 11, 2003, Kansas City Tuesday, June 10. 2003 MORNING SESSION 8:00 - 8:30 WELCOME and INTRODUCTION NRC - Herb Berkow STARS - Don Woodlan 8:30 - 10:00 LICENSING ACTIONS - SCHEDULING (Panel Discussion)

NRC Work Controls NRC - Steve Dembek

Impact on submittals

Improving efficiency (things licensees can do to improve work assignment, work flow)

Revised Project Manager Responsibilities Potential Benefit:

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 NRC-Dave Jaffe Support Plant Activities STARS - Glenn Michael

Scheduling and timing of submittals Potential Benefit:

Submfttals associated to outage implementation are always of interest.

Additional plant evolutions (e.g., steam generator replacement, power uprates) would also fall in this category. Licensees depend on the license amendment to exit their outage. The NRC requires submitals of quality to ensure the schedule can be met. This discussion is intended to focus on the elements that ensure both NRC end Licensee are satisfied.

9:45 - 10:00 Break 1

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 Benefi:

This section would provide a forum to ask questions about the current process, the process mechanisms, and requirements. This would provide for appropriateand 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 Benefi:

This would be a quick review of areas discussed in earlier workshops to ensure progress continues and eny back lapses are caught and corrected.

One item of discussion involves the addressing of correspondence to the NRC. Recent lefters have had anomalies in address requests. A brief review and discussion will ensure licensees understand the system and ramifications. It will also provide a forum for tools licensee use to ensure correspondence is correct prior to mailing.

11:30-12:30 Lunch 2

STARS 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 Clarfying Information

NRC experience

Licensee experience (trends)

Potential Beneft:

In recent years the role of SERs has been down played. However, they are still play a role 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 Benefi:

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 Beneft:

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 Benefi:

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 I NRR Projects Licensing Workshop June 10 and 11. 2003, Kansas City Wednesday. June 11. 2003 MORNING SESSION 8:00 - 8:15 SECOND MORNING WELCOME 8:15 -10:45 CHANGE PROCESSES (8:15 - 9:00) Processing Submittals Associated to NRC - Dave Jaffe Security Issues STARS - Stan Ketelsen

Guidance for deciding when to submit Safeguards information vs. Sensitive Information vs. Non-safeguards

Improving efficiency Potential Benefit:

With the intensity of issues relating to security transmitting information that is safeguards or non-safeguards or sensitive 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 NRC - Bob Gramm Associated to Orders. Process IRAG - Rich Luckett Guidance Potential Benefit:

Since much of the change to security conditions has been done in response to an order, mechanisms to change those conditions are not clear.

Discussion on this topic will ensure the proper reviews and submittals are performed. Discussion should include the role of the NRC Project Manager.

9:30 - 9:45 BREAK 5

STARS I NRR Projects Licensing Workshop June 10 and 11, 2003, Kansas City Wednesday, June 11. 2003 MORNING SESSION (after break)

(9:45- 10:15) Perry Decision NRC - Jack Donohew STARS - Don Woodlan

Implications - How to stay out of the same situation

Application continues?

Potential Benefit:

Although it was stated at the 2002 Licensing Information forum that the Perry Decision was a document with one time use, t continues to be an issue.

Licensees do not wish to find themselves in a situation where there is question as to the limfts 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 Beneft:

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 a

S 0

6

STARS I NRR Projects Licensing Workshop June 10 and 11, 2003, Kansas Ciy Wednesday. June 11. 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 tems and may be fashioned after the STARS delta/plus model.

Effectiveness

Challenges

Measurable

Future Activities

What was most

Types of Success

Follow-up beneficial? challenges?

P ideas?

Improvements

What was most a Barriers?

Other?

Communication effective?

12:00 Adjourn / Lunch Wednesday, June 11. 2003 AFTERNOON (Post Workshop Session) 1:00 - 3:00 Licensee Closed Session STARS -

This is an impromptu session for sharing experience and discussing workshop questions. The session should be facilitated by an experienced licensing person from each STARS plant.

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STARS Presentations

WELCOME AND INTRODUCTION STARS/NRR Projects Licensing Workshop, June 10, 2003 Don Woodlan wpm I3 Welcome

Strategic Ieaming and Resource Sharing

AmerenUE, TXU Electric, Pacific Gas and Electric, STPNOC, Arizona Public Service Co. and Wolf Creek NOC

NRR Projects representatives

Members of the Public 4,,.,:

Introductions

- Please introduce yourself with brief bio

- Current job

- Work history

- Years inlicensing/projects or related work

- Area of expertise

- Other info of interest vo 3 I

Purpose and Objectives

Meet your STARS regulatory affairs counterparts

Meet your NRR projects people v Open discussion on several key topics view a~~

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 GRO Housekeeping

Meals

Breaks

Restrooms

Attendance List Other vn0 __~~~~~~~~~~~~~~~~~~

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/ST

- NRC Orders

Tech Spec Changes

- Core Reloads (e.g., DNBR)

- New Methods

- Power Uprate

Exemptions Challenges

LAR Scheduling must Consider:

- Licensing resources

- Preparation time

- Peer quality-review time

- Cross organization reviews

- On- and Off-site Safety Commiinee Reviews

- NRC review

- lmplementation time

LARs to support the plant require early, complete planning I

Licensing Document Change Request (LDCR) Process

LARs may be identified by anyone on site by using the LDCR process.

- Licensing must determine where the LDCR fits in with the other LARS being prepared.

Licensing manages the LARs by using the Licensing priority List (LPL).

Licensing Priority List (LPL)

List of "Top Ten" LARs.

- Actively being prepared

- Subminal/approval 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

- Opeations

- Engineering

- Outage Management

- PRA

- Nuclear Fuels Licensing Priority List (LPL)

LPL Performance Indicators

- Input to monthly departmental report

- Number of LARs submitted

- Average age of LARs

- NRC review time

- NRC review fees Licensing Priority List (LPL)

Emergent needs may push LARs down the list:

- NRC Order relief requests

- Emergent ISI relief request 9

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.)

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)

Changes to be actively worked Description of Change Restraints NRA RE Submital Sponsoring Date LDCR STARS?

Schedule Org Started No.

Working 1 TSTF-283 for EDG surveillance None J Proctor Second Qtr 2003 PRA 6/4/02 03-TOOl Y limitations (TS 3.8.1 and 3.8.4) 2 MSSV TS changes (TS 3.7.1) None G Michael Third Qtr 2003 NFM 11/14/01 01-TO01 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 1 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 (TS 3.8.1) 7 Relaxation of specific ISI R Rogalski TBD ISI TBD NA N requirements in License Order Need by Spring Sections IV.C (1) and IV.C (2) 2004 outage requiring volumetric examination of the RPV head vent nozzle 8 Administrative changes: delete None D Gregoire TBD Licensing 11/1/01 01-TO10 N reporting license condition, 02-TO01 remove round cell batteries, add note to SR 3.8.1.2, and correct MSIV/MFIV applicability (TS 3.7.2 and 3.7.3).

9 Revise TS 3.1.5 condition B for None TBD TBD OPS TBD 99-TO05 N one CEA position indicator channel operable to state that there is only one CEA position indicator channel OPERABLE for one or more CEA per CEA group.

05/2/03 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 in 68 FR assigned 16579, April 4, 2003. Also see letter from NEI to NRC dated April 28, 2003, containing revised TSTF-359.

05/27/03 2

Licensing Priority List (LPL) Honorable Mention Description of Change Restraints Notes and Comments LDCR No. STARS 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 perrormance. 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 certfied 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 Mentlon Description of Change Restraints Notes and Comments LDCR No. STARS 14 Add note to EC specification (TSTF-351) None N 15 Delete TS hydrogen recombiner requirements NRC is working on TSTF to be developed after Rule Y 10 CFR 50.44 Rule change, which Is planned for early change 2003.

16 ISI relief request to use Code Case N597 for Need ISI justification N localized thinning analyses 17 ISI Code Case 532 (TSTF-412) Per M. Melton, this request should N not be needed because the Code Case is expected in the next RG 1.147 revision 18 Revise pressure-temp limits per 3/4.4.8 to Need Engineering 97-001 N incorporate revised instrument uncertainties. input (LDCR).

PTLR - This TS change would remove the RCS pressure and Temperature Llmits 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 1 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 alternative R Rogalski 5/22/02 "to 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 I and 3" 4 License recovery time from low power testing R Wilferd 02-T002 8/28/02 8/31/03 III N 5 CPC upgrade: DNBR, TS 3.2.4; RPS D Gregoire 01-T003 11/7/02 7/1/03 I N Instrumentation - Operating, TS 3.3.1; (102-04864)

CEACs, TS 3.3.3.

6 IST relief request for Unit 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 Rogalski 02-T004 4/15/03 None specifled IlIl N and WEI) (Sholly'ed 5/27103) 02-T006 (102-04926) 9 Qualification of licensed operators - TS 5.3.1 R Rogalski 01-T014 4/25/03 April 2004 III N (RIS 01-01) (102-04930) 10 ISI Relief Request 23 - Altemative Repair R Rogalski 5/15103 9/15/03 1 N Request for Pressurizer Heater Sleeves (102-04941)

____ (temperbead) I Category I: A Category I submittal is needed to be approved by the NRC for a specific plant evolution or startup after a plant refueling outage. It would be of prime importance for the NRC to meet the requested approval date for this category of submittal and there is very little flexibility available for having the submittal approved beyond the date requested. Delay would Impact power productfon.

05/27/03 s

Submittals Currently with NRC Category II: A Category 11submittal Is needed to be approved by the NRC for general purposes, but not a plant specific evolution or outage. A category 11submittal 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 flexlbflity can only be determined on a case by case basis. Delay may Impact power production.

Category III: 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 Inthe TS does not have an impact. Delay would not Impact power production.

05/27/03 6

Submittail Annrovnd bv NRC in 2o0 Description TAC Nos. Date Date NRC Review STARS? Date Submitted Approved Time Implemented (Months)

I 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 M86441 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 M87855 4/4/03 4/25103 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 - TXU Energy Panel Members

Jack Donohew - Project Manager for Callaway, Wolf Creek and Palo Verde

David Jaffee - Project Manager for CoTanche Peak and Diablo Canyon

Mohan badani - Project Manager for South Texas Project

&10 LICENSING ACTIONS QUALITY OF SUBMITTALS A. hnprovements trends)

Industry (NET) Templates for Linsing Actions (LARs) & Code Relief Requests (RRs). Are they working? Do they elicit the appropriate infonnation to minimize RAk?

NRC Project Manager insights....

.... ~~~~~~~~~~~~~~~

1

LICENSING ACTIONS QUALITY OF SUBMITALS A. Lases (trends)

Code Relief Request (RR) content omissions

RAls resulting from adaptation of generic. industry topical reports (Ucensee omission of required plant specifK information; NRC SER specificity)

WordPerfect vice Word software. Why are some licensees constrained to use of WordPerfect?

NRC Project Manager insights...

LICENSING ACTIONS QUALITY OF SUBMITTALS A. Addressins Coresnondence - Avoidin Error Trans

Addres Rutes andPolicies -NRC PM Guidance

Comapodene Addesses forOrdes. Securty Ordem Bulktins. Geneic Lensa.ac

Consequenesotinercey Addressed Corpondence - NRC PM Guidance

Licensee Pracices andTools:

e UKefrSUld~ Tnewyse Clecta d Psotfteades

' Oshms..

oter 2

STARS / NRR Projects Licensing Workshop June 10 &11. 2003 Quality and Roles of SERs Today Dave Shafer Callaway Role of SER Provides the Basis for NRC Approval Level Details Varies Based on:

- Subject natter

- Point in n wten SER was icsud NRC Approvals Generally Fall In 3 Cateaories

Conformance to an Appiable Standard

Plant Specifc Review of a Deviatbon to an Applicable Standard -

. Plant Spefic Review here tere no Standard None Eit

Pre-dates Sta I

Callaway SER Review Practices Iriorwial Review

Not ProCedurhZed

PreApprovalI PosS.AvovaI

Swr PMs hPt pnovded "

at wd akw " b cwnwert Sm hwe povided SER's sir aI Val

RaesulI Follow-Up hove Veried

,ypos ui EeWa we soimeties pvded IDNRC

. Faa tuueS re prvid b NRC

. Co Lew

. Revised SER

iy Sigrdfrt tsues we not Coraislernlly Addessed Future Plns

Callaway wi Fonnmize Process for Review

-Normaly Complete Review Prior to Inplernentalon Use ft Correctve Action Program to Address ksues Sicnificant Issue Examples NRC Approv df OrgLnal Lcense Condition on SGTR

-Serondary dide bolalion valves not considered ClVi

Feedwater Reg I Bypass valves nol in Tech Specs 2

NRC Aroroval of SGTR Callaway analyzed 2 cases

-Stuck Open ASD

-Failed open fow control vaie (SG OveI?)

Calaay concluded: -

-No SG overI (cse but ...)

-Stuck open ASD was bouncing case and added to FSAR NRC requested Calaway forc overfir

-Callaway anaysis sbalshowed was bounded by ASD case

-Callaway conidered forced overfin. as beyond icensing -

basis NRC Approval of SGTR Cont'd -

NRC SER rejected talaway contention ut overfill did not occur

- Approved LC based on:

Forced overfill analysis Independent NRC dose calcubtions RCS activiy lmits i T/S Distance to exclusion area and LPZ boundaries Callaway maintained overrfil was not a Lcensing asis but did not address SER approval basis Callaway Is submitting updated analysis his month Secondary Side Isolation Valves not Considered CIVs Anent a rte TS perlawdrv lo MSVs & FIVs R ed Isoon lnes tm T6.&1 3TS

-Added spec b MFVs (a b MSNn)

NRC iaagreed on base for appv

-Cafty mctied change based vaves ret bers CVs NRC accepted based other TS edsted and n effecive rne i response Wm

- NRC Specfied in SER mat TS ases nguae be no

-TS avoded ahIS I TS FSR bas Is santo Wy we not Crli 3

-f _°+UNITED STATES NUCLEAR REGULATORY COMMISSION WASHtNGTON, O. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMEN'T NO. 18 TO OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT I DOCKET NO. 50-483 INTRODUCTION By letter dated September 29, 1986, and suDPlement thereto dated February 2, 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 isolation valves MSIVs) and to the ain feedwater isolation valves (MFIVs). The principal effect of the proposed changes would be to clarify the Technical Specifications pertaining to the MSIVs and to the Y'FIVs in particular. We have reviewed the proposed changes and find them to be acceptable as discussed below.

DISCUSSION AND EVALUATION The licensee sunmarizes their amendment request by stating that the request Provides clarification and restructures the Technical SDecifications asso-ciated with the MSIVs and MFIVs. Further, no changes are being made to the valves or their resDonse 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 indicated in Table 3.3-5, whereas the valve closure time, for the valve to be considered operable, would be given n 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 specification 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 roposed change to be acceptable.

The Containment Isolation Valves (Table 3.6-1) include a list of the MSIVs and MFIVs under the table notation Other Automatic Valves.' The maxinium iso-lation time for these valves is presently indicated as 5 seconds. The licensee proposes to replace the 5 seconds with N.A. (not aplicable). The 5 seconds requirement would then appear n other technical specifications as discussed previously.

The licensee partially justifies the changes in Table 3.6-1 on the basis that the MSIVs and MFIVs are not containment isolation valves because the valves are not required to meet containment isolation criteria since the containment

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 MF!Vs are not containment solation valves conflicts with General Design Criterion 57 which states in part:

Each line that penetrates primary reactor containment and s 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 isolation valves, we find the changes to Table 3.6-1 are acceptable because the specifications for the MSIVs and MFIVs apDear elsewhere in the Technical Specifications and there is no effective change in the over-all response time of the valve closures. Also the licensee states and the staff finds that the licensee's proposed change in 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 MFIVs 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 approDriate 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 proDoses 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 ermit auxiliary feedwater addition in the event of a main steam or feedwater line break nside contain-ment; and 2) ensure that no more than one steam generator will blow down in the event of a steam line ruoture which a) minimizes the positive reactivity effects of the Reactor Coolant System cooldown associated with 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.

A1

CALLAWAY - SP TABLE 3.2-3 (Sheet 2)

Reaulatorv Guide 1.29 Position Union Electric

a. The reactor coolant pressure a. Complies.

boundary.

b. The reactor core and reactor b. Complies.

vessel internals

c. Systems* or portions of systems c. Complies. See Item 2 below.

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 d. Complies. See Item 2 below.

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 e. Not applicable to the Callaway Plant, systems of boiling water reactors ...

f. Those portions of the steam and f. Complies with the exception that the feedwater systems of pressurized words "or remote manual" are water reactors extending from considered to be inserted after the and including the secondary side word "automatic." This option is of steam generators up to and included to avoid an unnecessary including the outermost complication (leading to decreased containment isolation valves, and plant reliability) in the line which is connected piping of 2-1/2 inches not normally provided with automatic or larger nominal pipe size up to closing valves.

and including the first valve (including a safety or relief valve) Note that valves in lines emanating that is either normally closed or from the steam generator are for capable of automatic closure secondary side isolation, not during all modes of normal containment isolation.

reactor operation.

Rev. OL-13 5103 A '

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-13 5/03 r.

STEAM LINE II

BARRIER I

I I

FEED LINE BLOWDOWN LINE CONTA INMENT BOUNDARY Rev. OL-O 6/86 CALLAWAY PLANT FIGURE 6.2.42 STEAM GENERATOR AND ASSOCIATED SYSTEMS AS A BARRIER TO THE RELEASE OF RADIOACTIVITY POST LOCA

1

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 Specifications, primarily toward the objective of clarification.

No changes are being made to the valves or to their response times. We have reviewed the roDosed 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 OPERABJLITY" appear. We would suggest adding the words:

"of the main steam isolation valves and" after the word OPERABILITY in each place. Also the following statements should be removed from the Bases section.

"The MSIVs ad 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 Published 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 ot Missouri.

No public comments were received, and the state of Missouri did not have any coments.

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 in the proposed manner, and (2) such activities will be conducted in compliance with the Comission's regulations and the issuance of this amendment will not be inimical to the comron 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: arch 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 115)

AmerenUE

- Callaway based it on dual actuators on MFIVs

- Feed Reg valves are not primary success path (10CFR 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.

f .+

4U;U.LAH REGULATORY COMEMISSION

'r>IflIfl~'~ WASHINGTON, D.C. M55-OT 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 MFC&BVs credited in the accident analysis is to provide a backup to the MFIVs 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 IE 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

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 in 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 MFIV, 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 Df 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.

kny associated increase n 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 n inadvertent reactor trips.

n fact, the licensee stated that the requantified (requantified 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 in core damage frequency (CDF).

F,

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 impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

A4'

Your Feedback

For SGTR Approval What should we have done?

For Secondary Side Isolation Valves 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?

Bulletin 2002-01 Request for Additional Information (RAI)

Lessons Learned STARSINRR Projects Licensing Workshop, June 10 2003 Ken Petersen I

Industry Concerns

Significant NRC and Licensee resources expended to address RAIs

Can we minimize utility RAIs?

Can we avoid another industry RAI?

- Bulletin 2002-01 MM X Issues

What techniques can be used to minimize the likelihood of RAs?

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 RAIs

Clearly define the NRC question or request.

Conduct a critical review of response.

Define the NRC Question or Request

Break down complex questions into parts.

- Bulletin 2002-01 RAI - 69 parts

What if you can not defme NRC question or request?

- Check with peers or call the NRC Critical Review of Response Response must completely addresses the question or request.

- Ensure ALL parts of a complex question are addressed.

- Statements of fact must withstand the future review" test.

Y103 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 correctly.

,0OW I 3

Safety Conscious Work Environment Mohan Thadani Stan Keteisen

Background

The following background will be addressed by Mohan Tladani

- Commission's Statement of Policy

- SCWE vs Safety Culture

- Discrinmination Task Group

- Staff Requirnents Memorandum (3126/03)

NEI Recommendations

Three areas addressed:

- Office of Investigation (01) Techniques

- Development of Altenative Dispute Resolution (ADR) Process

- Development of SCWE "Best Practices" l

Assessment of OI 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 industry's 'tool box"

- Develop guidance for management training on SC WE-reated issues

- Recommend NRC defer internal efforts pending completion of ongoing industry activities 2

INFORMAL COMMUNICATIONS STARS/NRR PMrects LUensin Workshop Jtne 10 2003 Jack Donohew - NRC Project Manager Fred Madden - TXU Energy INFORMAL COMMUNICATIONS A. Infonal Commluicaion - What is it? Typicatly e-mafi and telephone discussions and conference eails.

B. Guidelines -

. When tmdhowo a

Projt Manager direcijnd r pective. ..

C Whaito Ex

. What a te pitralls

When Dd why does e-otail becone dockeedt

Project Manprspeclive....

"I-n INFORMAL COMMUNICATIONS Experiences

1. Comanche Peak provides to Project Manager e-mail eopy of correspondence

2. Comanche Peak provides draft responses to RAls via e-mail to ensure completeness of proposed responses

3. Regular (several times per week) communications between Project manger and lcensing had

4. Appreciate efforts of Project Mmager to explicitly define technical issues S. Other experiences....

dnw 1

NRC Orders Orders .... Once you implement them, what Is the mechanism for changing a condition In them?

NRC Orders 52.202 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:

1

NRC Orders lltte IEue i~ao t its eeele di eSerePni stI te lw acW-s We r e ,AKOn, gr. I1 ,Jwr'hede.

" at O F IH St to ee.. NeSter pon awhle *rn nferta diXder U eSa or OdnSt CIO tetSIIC d rhI1Rs a WAYbe estsodn NWsOar.

hor_f hieAtofoVW Sto W "r. rS O u heorog 0i 1fwnpot St It dWdt.

h pl e sliete ktW n aelhr pen tu merAd in - 10 to Ceir.

E)studyW hens hof Olde.Vsg I taO to 11 dei' so se is Ceuenissuon beds toiC su eyfw&e o hs0 1 t weh e el a g Ste udtOnii Il. te rer my poid. Id Mate eti n li rOe Sta eden e enerlydyeprt trSitede NRC Orders

12) iil The iicee er ether ersonb whn tbe t Conisson ha sued en edrately etlecbye order wy.CI addition lo ermni a heratng.

t tme tneanser i tled or d orer. ieve ft presinV ofiier D Setasidethe Inwitereffeciveneso lt arOr an th gound NWt the Order.itidicS toe reedd aissndaie iectnot t en adequate ividsenee bt dite re arltdn ittdd ategaior. or erwer. The mebon muit ste with paolito the reasors why to order t based en ae e evidence anm % e ecmompate by ainit theedeeeie e es oi The NRC he shnrasnd whyithEin( r eiofeerriece i t tn.b the iin e edecde byopesIgcar aedbaa=hng In pendency oftowln er any eher tIe presiw fay t Stayto inedat ce at to der. er n Nits own mo. or up maton ct tie icenee eirother pison. Thtepresidig officr WItsld toe inotia ete eettsl theOrderiit finds bet tore iCadequte evidenet ht4ipmpWeia n teceness. An order utoding bwnete efevene wil cortiute toett qeency teonan riW Me etecvenresn. An der seutegaside int te efecbeness wnl be reerred p=anipily DtneConwnisean btel midwi rrst beellecive pendn hatter oer o te ConaiorL NRC Orders An answer rmaty consent to te ry Sten erder sunstrtilly thlefrmnproedJ h t e rder ith respeCt to iai tJ sonte dW Ste aCto i ee t rder .eThe corisent in to answer r other written document d the kcansee or other person towhon te order his been isued to the intry d an order sha Constitute a waiver bsythe tieensee Cr Other persoJn dt a hearvig.

idings od tct end ectusicns ct law aneld *11at) rlt to teet irnssion and uical review or to Contest tse valdty of the order ah*ny tcrum as to hose maitters wich pive been eonsented to or aed toro n which a hearing his net been wuquested An orer tt haBs bDeen eontled to ah iEe thle earns terce and afect as an crder mrude althering by a prsiai 1J dhoaor ihe Carnissicn. aind Sihe!be effectve as5 (i) Uthb ordrt bivolves the moificatton dte peel50 icen e a*rC a sCktht. the requbements d §50.1t9c tnis chapter shell be tltowedL uress the bensee htWsconsentedt to the action requed.

2

NRC Orders Lets Talk Process.

How does a Licensee change a condition of an order?

For example an order requires the Installation of a certain feature to enhance station security. However after a period of time the licensee Identifies an Improved feature that would work better.

How is a change to the order Initiated, so the licensee can utilize the improved feature?

NRC Orders Lets Talk Process .....

What can the licensee do?

- Write a letter to the NRC asking for permission to provide a substitute feature that rmeets the substantial Intent of the order.

- nitiate 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 Commission. The terms and conditions of the license shall be subject to arendment, 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

.ss F o o o. - -

NRC Orders ifilien 4l 1_W l c.. a.m'.ledfg fclwu nd0s54 7 w Sh.Se Cbi dto d 4 (en Setwd GenedePi_we *iw.e

.m)wau nl nyi > i.e 1 ut aarbae*. :raro pntr a pD. e Vi Cew sero. Aiw. den. S br0h*

~

.vemWi adine 5.41 1biris a~g to 605163.51831.s ~ ~ in

~~f JD4m. 1i; s

(2)Tie iwg mO m . 5 ir UteP1441rwiId ft 1gr4411LPt1C P6 osr. _ IicvI DIe' Cwwsn irm' (to wr diae.

Xr' er4cmS aaies r14 i_J made aulie. or Coman a51 Ibr a p.Id di dm waln.4h. do it X. 144 Id SWu1m . - ipued h r.50.4 1114411 waaO ae.e. II 441 ci'5 1415141 mWo eas aer the Seto sMgc weny

'wrher pn 5n mgs1"a 3, Mm NRC Orders 550.90 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 arnendment 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 fS04 Wrltten Communications.

1 (4) Socuafyian and relatedsubntats Mten conrtiaons.

as defined h pigrsphs (bX4Xi) tough () O ls sCtion rtust be submittd as fIlows: The ui9ned Ogirl end ure Copies to the uclear Regulatory ComIssIon Domene Cntd Desk.

Washington DC 20555, and tIwo pies io theo seopriate Regions Ofic; (ii) Change to souty plan 9uard Wig nd qusatcotion plan.

r feguards contngency plan wade without por Cmmission pol pue to -50.54(p (lv) Appicotion to mendrent of physical seaity pn. ard tranir and quarfcation plan. or segurds continency plan pusuart to 50.90.

4

PERRY DECISION STARSJNRR Projects LJWensing Workshop June 11.2003 Don Woodlan M ,I 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 10CFR50 Appendix H continued to be met in Regulatory Point

What is threshold needing a License Amendment for making changes which need 'pnor NRC approval"

Goes back to meaning of Section 189a of Atomic Energy Act re hearing rights and public involvement

Does the change create "greater operating authority 1i*D 3 1

Industry Concerns

NRC referred to Perry Decision to require that several changes needed License Amendment to adopt

Examples:

- Fire protection altenate rule

- BWR Integrated Surveillance Program

- NEls Steam Genertor Program

".XI NRC Approval without License Amendments

- Exemptions

- QA Program changes

- E Plan changes

- Code relief

- Fire Protection Plan changes

- Some Security Program changes

.n 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?

w.le &

2

Regulatory Activity

NEI letter opposing the recent NRC use of the decision

NRC position presented at 2002 NEI Licensing Forum MIm Potential Position

- Changes which actually change license need LAR

- Changes need LAR if required by IOCFRSO.59 Evaluation

- Changes in Tegulations which require prior NRC approval do not require LAR unless so stated

- Other changes should require an LAR if a 10 CFR 5059 Evaluation would have required one (e.g.,

topical reviews)

Wi,e 3

50.59 Revised Rule Follow-up

.X . . .......

USA 50.59 Task Team Benefits and Challenges Evaluations Performed Since Rule Implementation No.of Callaway 3 Comanche Peak a Diablo Canyon 22 Palo Verde 43 South Texas 13 WolfCrk 4 1

w e-Regulatory Reporting Requirement "The licensee shall submit, as specified in Sec.

50.4,. report containing a brief description of any changes, tests, and experiments, including a summary of the evaluation of each. A report must be submined at intervals not to exceed 24 months."

NEI 96-07 Reporting Guidance

'A aummary of 10 CFR 50.69 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 Guldance

'A summary of 10 CFR 50.59 evaluations for actvibes Implemented under 10 CFR 50.59 musl be provided to NRC. Activities that were screened out, canceled or implemented via license amendment need not be Included In this reporL 2

Resource Manual Reporting Guidance (Coutioued)

Each evaluation will nclude an Actifty description and s Sumrnary of Evaluation. These sections will become the basis for preparhg the 10 CFR 50.59 Summary Report.

The activity description and sunmmary sectins for each evaluation should address the hIportant attributes of the activity as well as the significant results and conclusions of the evaluation In as brief and concise a nnner as practical In order to keep the report brief and concise."

3

OPEN SESSION STARSNRR Projects Licensing Wotkshop. Jume 11,2003 Don Woodan Mn I Other Topics as lime Allows

NRR pTojects involvement in Level 3 SDPs m-1

Work Shop Wrap-Up STARSJNRR Projects Licensing Wotkshop, June 10, 2003 Diane Hooper/Herb Barkow wiJ

EfkrCtiVwfA *halDlnges *Me=uringSuccess*FutureAtiviies Mo0t *Types *PIIdea *Followup berefciai? -Barres .ouw *bnprovenents

-Mont Conmumucaio effcve I

NRC PRESENTATIONS STARS/NRC LICENSING WORKSHOP June 10 and 11, 2003 Kansas City, Kansas

ch~~~~~

I& "- NRCv Work Controls Stephen 2ek Section Chi Tuesday, June 10

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 Zs Centralized Work Planning >oess?

Tool to help organize, understand manage the workload of the office

Optimizes the matchup of resource demanl resource availability

Works from an office perspective rather than a project perspective

Integrates work of the office :

June 10, 2003 4 Desired rmes

More efficient and effective use ice resources

Better predictability

Better quality control

Continuous improvement

June 10,1i2003 5 Critical Infor tion 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 or the PM?

See Handout

June 10, 2003 7 What can licenbees 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 lmementation Plan

FY03

- Define and communicate responsibil to staff

- Pilot standardized characterization process

- Pilot standards development process

- Standardize process steps for another product

FY04

- Apply characterization and standards development process two more products

- Standardize process steps for another product (or two)

- Update skills database and prioritization scheme

- Develop and pilot performance monitoring scheme

9 Imple ntation Plan (cont ned

FY05

- Repeat cycle of standards development a s definition as needed

- Develop scheduling and planning optimization

- Implement performance monitoring scheme

FY06

- Start cycle of systematic process review and improvement

- Pilot centralized scheduling

P if

, gr 1-0 Centralized Work

,1* *** t Planning S tephenw. t ek Section Chle Tuesday, June 10

John Harrlson 10t30102 The Role of the DLPM Project Manager Before and After the Centralized Work Planning Pilot Program

f Before Pilot After Pilot i 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 Forn 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 negotiateso completion date with each nvolved section SC provides completion date based on PM's required completion date 9 PM negotiates? hours with each irnolved section STR provides hours along wnth 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 nputs 12 PM forecasts his estimated completion date PM forecasts his estimated start date, completion date, and level of effort 13 PM resolves or coordinates resolution of technical issues Same 14 PM periodically checks Hreview is on schedule Technical Branch DPRs periodically check f review is on schedule, and reports back to PM. Special attention is paid to urgentoutage related amendments 15 PM issueS final product (FR Notice, SE, Amendment, and Same Transmittal letter)

DPR - Division Planning Representative SC - Technical Branch Section Chief WPC - Work Planning Center PM - DLPM Project Manager STR - Senior Technical Reviewer CA~WPCW"MetrPM "o chnnge.wpd

~z s4vk Managing Schedules for LARs to Support Plant Activities Davia affe Senior Project NRC Comanche Peak Steam EXhation Tuesday, June 10,

,// #g>>Routine Com unication s (No>urprises)

Discuss Schedules with PM Weekly (Use TAC Nos. to Avoid Confusion)

Occasionally Remind Us of Planned Outages

Inform Us Promptly of Emergent Situations

Occasionally Contact Section Chief (Important for Emergent Situations) 2

The BIGPicture

Only Submit LARs that you can su rt (Assume you can Answer a Reasonab o 15 Question RAI in 60 days)*

No Licensing Actions at the NRC for more a One Year (Subdivide Review into Parts)

Schedule as a Prominent Part of Submittal (Key to Specific Event and Defensible)

10 CFR 2.108 Allows the NRC to Deny an Application for Failure to Respond to an RAI 3

Sche le for Routine LAR Moderateompexity (No Generic PribbLms)

Time able I 7 3t> $j'S,4.,#.,,,'t...+.$.;~~~~~~~

n .

A.0. ,,

1St Day Submit LAR 1st Month Reviewers Assigned Noticed in Federal Register I

3rd Month RAI to Licensee 9

5th Month Response to RAI thMonth Issue License Amendment

High Quality Submittal

Plenty of Support 4

Emergen& xigency

Emergency (10 CFR 50.91(a)?

Requires an Explanation of Why the &ction Could NOT be Handled in a Routine N (Act in 0 to 7 Days)

Exigency (10 CFR 50.91(a)(6))

Required when Licensee and NRC Must Acf "Quickly" (Act in I to 3 Weeks)

NRR NOED (Followed by an Amendment within 4 Weeks) 5

Managing Schedules O,

0& for LARs to Support Plant Activities Davi Jaffe r

Senior Projecth NRC Comanche Peak Steam >1 aton Tuesday, June 10,

-- 7 1-NRC Fees and Fee Waivers Stephen I g bek Section Chie Tuesday, June 10

2 K' equireme s for Fees "

Required by law to assess fees to re r most o f our budget

- FY2002 annual fee for power reactors licen operate is $2,849,000 and the hourly rate for s is $156

- FY2003 numbers should be available before the em the month

Fees are sent to treasury, are not retained by the NRC, and do not directly affect amount of funds available to NRC

Fees for Lic sing Actions

Regarding licensing actions, assesses fees for:

- Pre-application consultations

- New applications, amendments, & renewa

- Standard technical specifications

- Other licensing tasks requinng NRC approva

June 10, 2003 4 Billable Doc idated Activity

Bil lable P t Manager10 act ivities inc Docket specific s such as: m

Work licensing acti m

Discussions with NR L on plant specific issues

Site visits

Responding to licensee questions

Attendance at this meeting

Billabl on-Docket Related Acvities

Non-docket specific activities, suc

- Training

- Performing administrative tasks

- Scheduling, planning, coordinating work with te staff

- Staff meetings

If a Project Manager has more than on docket, th non-docket specific activities are prorated equally M to all assigned dockets

June 10, 2003 6 Non-BillableActivities

Can not bill licensees for the fong Project Manager activities:

- Leave, rulemaking, voluntary (unpaid) overtime, preparation of generic guidance documents, Freedom of Information Act requests, union activities, Combined Federal Campaigns

June 10, 2003 7 Fee ExEmptions

NRC grants fee exemptions as ws ( see 10 CFR 170.11):

- 1) Nonprofit educational institutions

- 2) Performance assessments or evaluation' which the licensee volunteers at NRC's req and that are selected by the NRC

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~8 Fee Exemprions (continued)

3) Requests or reports submitted e NRC:

- Response to a GL or Bulletin (except itsting an amendment)

- Response to an NRC request (Associate Off ; tor or above, e.g., Brian Sheron or Bill Borchardt to resolve an identified safety, safeguards, or environmental issue, or to assist NRC in developi rule, regulatory guide, policy statement, generic let

or bulletin; or

- Means of exchanging information between industry organizations and the NRC to support NRC' s generic regulatory improvements or efforts.

June 10, 2003 9 Fee Exemptions (continued)

Regarding requests or reports submitted to the NR

- This fee exemption applies only when:

1) Report/request has been submitted to the NRC to supp 's development of generic guidance and regulations (e.g., reg ilo guides, and policy statements; and

2) The NRC, at the time the document is submitted, plans to use one of the purposes stated in the above paragraph

If you believe you meet the criteria for a fee exemption, request it with the application

The decision on the fee exemption should be made prior to significant work being performed on your request

Examples (See Handout)

OCFO WAIVERS UNDER 10 CFR 170.11 DATE OF LICENSEE NAME SUBJECT DECISION BASIS LETTER 04/15/2002 GF Ntuclear l.nergy GE disputes the $1.377.0M odefcrtcd costs Denied Licensee was aware ordercrred costs. delayed billing does not relieve GE assessed undcr Part 170 for the review of the of its legal obligation to pay the ess associated with the services that the Gcneral Elcctric Standard Safcly Analysis Report NRC provided in response to GEs request or standardized design review.

(GESSAR). Rviews were ended in 19S5 and 1986.

costs were deerred undcr the ce nile.

02/14/2002 Electric Powa Research Inst. Reqest waiver of fess for review of IPRI 'sTopical Denied TR- 102323. Rev. 2 was not submitted for the purpose of supporting NRC Report TR-102323, Rev 2. 'Guidelines for generic regulatory improvements or efforts, and NRC has no plans to revise Electromagnetic Interfemece (EMI) Testing in RG 1I.180 to endorse TR-102323. Rev 2.

Power Plant Equipment.

02/05/2002 Nuclear Energy Insitute Reqttest waiver of fees to review EPRI Technical Granted Revisions F and Gwere submitted for the pirpose of supporting NRCs Report entitled, "Guidelines for Addressing Fatigue generic regulatory improvemnents relatcd to the treatment of fatigue Environmental Effects in a License Renewal environmental effects.

Application' 12/20/2001 Dairyland Power Cooperative Exemption from assessment of new Part 171 Denied OBRA-90 is consistent with the intent of the statute to collect 100 percent Decomissioning and Spent Fuel Pool annual fee. of the NRCs budget authority as it applies to all licensee in the class Request based on old. and small. thereby establishng a fair and eqtitable basis for assessing annual fees for those licensees in decommission and/or have spent fuel pools.

12/0512001 Southern NuclearOp. Co. Partial exemption to 10 CFR 170 fees for License Granted As the ftrst BWR, a part of the safety review contributed to the Renewal development of generic regulatory documents.

1012312001 CEOG CENPSD-994, -995, and -996. "Joint Application Granted - PartialThe revieweffort fromJan. 3, 1996the February 28, 1997 was used to Reports for Safety Injection Tank (SIT), Low support generic regulatory improvements.

Pressure Safety Injection (LPSI). and Emergency Diesel Generator, (EDG) Allowed Outage Tire (AOT) Extensions" 09/1712001 CEOG CE NPSD-1 186 - TECHNICAL JUSTIFICATION DENIED SUBMITTAL OF REPORT DOES NOT MEET THE THE FEE WAIVER FOR RISK INFORMED MODIFICATION TO CRITERIA OF FOOTNOTE 4 TO 10 CFR 170.21.

SELECTED REQUIRED ACTION END STATES FOR CEOG PWRs 09/13/2001 .YLAND POWER COOPERAFULL OR PARTIAL EXEMPTION FROM TIE DFNIED EXAMINED BUDGETED COSTS ALLOCATED TO THE LAC3WR SPENT FUEL STORAGE/REACTOR AND HAVE DTERMINED THAT THERE IS NO SIGNIFICANT DECOMMISSIONING ANNUAI FEE DIFFERENCE BETWEEN THE NRC'S REGULATORY COSTS FOR THE LACBWR AND THOSE FOR OTHER LICENSEES IN TIIE SPENT FUEI STORAGE/REACTOR DECOMMISSIONING CLASS.

rage 1 of6 Thtnsday, Mny Thursday, 2003 29, 2003 May 29, Pnge I o6

DATE OF LICENSEE NAME SUBJECT "DECISIONBAI BASIS LETTER 06/13/2001 EPRI REVISE) RISK-INFORMED INSI-RVICI: GRANTF.D rOOTNOTE 4 -

NsPrCTIoN EVAIUATION rR(x EDI IRI lNrORMATION TO BE USED TO Si IPPORl NRCS GENERIC REIUIL,ATORY IMPROVEMFNI'S. SPECIFICALLY RE: RI-ISI 03/02/2m0 TVA RI-ISI AS AN ALTERNATIVE FOR ASM. ANrED- PART PART 170.1 I(b I - PARTIAL WAIVFR IS APPROPRIATE FOR THAT SECTION Xi CODE CLASS PIPING ANI) PORTION OF THE BFNS UNIT 3 StInMITTAI. THAT STAFF AUSTENI'I'IC STAINLESS STEEl. PIPING FOR DETERMINED HAD GENERIC APPLICABILITY.

BROWNS FERRY UNITS 2 ANI) 3 02/27/2001 VE:Pco REQUEST FEE WAIVER IOR SIIRRY GRANTED PART 170.1 I(bX I) - PARTIAL WAIVER FOR PORTION OF THIS INDEPENDENT SPENT FUEL STORAGE. FIRST-Or-A-KIND REVIEW EFFORT TI IAT SUPPORTS INSTALLATION LICENSE RENEWAL DEVELOPMENT OF THE GENERIC PART 72 LICENSE RENEWAL PROCESS.

01/18/2001 CON EDISON CO. ACCIDENT SOURCE TERMS FOR lIGI IT- GRANTED PART 170.11 (bX I) - STAFF USED EXPFRIENCE TO ASSIST IN WATER NUCLEAR POWER PLANTS PREPARATION OF THE REGULATORY GUIDANCE, STANDARD REVIEW PLAN AND RULEMAKING.

01/16/2001 VEPCO ALTERNATIVE RADIOLOGICAl. SOURCE GRANTED PART 170.1 I(b)1I) - STAFF USED EXPERIENCE TO ASSIST IN TERMS FOR EVALUATION DESIGN BASIS PREPARATION OF THE REGULATORY GUIDANCE, STANDARD ACCIDENTS AT NUCLEAR POWER RXs REVIEW PLAN AND RULEMAKING.

01/16/2001 GRAND GULF NOS 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 TIIE RULE AND ASSOCIATED RG.

07/31/2000 TXU ELECTRIC CO. CONTROL OF HAZARD BARRIERS GRANTED PART 170.1 I(b)(1) - INFORMATION PROVIDED IN THE TOPICAL REPORT LED TO THE CONCLUSION THAT THE RESOLUTION OF THIS ISSUE IS GENERIC IN NATURE AND NOT PLANT SPECIFIC 02/08/2000 TXU ELECTRIC FIRST-OF-A-KIND RISK-INFORMED GRANTED PART 170.1 l(b)(I) - TXU ELECTRIC PARTICIPATION IN THE RI-IST INSERVICE TESTING PROGRAM TO PILOT EFFORT PROVIDED NRC WITH A PERMANENT APPROACH DETERMINE INSERVICE TFST FREQUENCIES TO RI-IST. EXPERIENCE GAINED THROUGH THE PILOT FOR CERTAIN VALVES AND PUMPS THAT APPLICATION IN THE PROPOSED RULEMAKING PROCESS TO ARE CATEGORIZED AS LOW SAFETY MODIFY 50.SSa TO EXPLICITLY ENDORSE RI-IST METHODOLOGY.

SIGNIFICANT 01/06/2000 MOAB MILL SITE COURT APPOINTED GRANTED PART 170.1 1(bX ) - ALL FUNDS AVAILABLE TO PWC FROM THE PRICEWATERHOUSECOOPERS LLP (PWC), TRUST SHOtULD BE USED TO OPTIMIZE SITE REMEDIATION.

TRUSTEE FOR ATLAS MOAB MILL ATLAS DECLARED BANKRUPTCY AND PURSUANT TO THE TERMS OF SETIEMENT COURT-APPROVED REOGRANIZATION NOT REQUIRED TO COMPLETE THE REMEDIATION. EXEMPTION GIVEN TO PWC (TRUSTEE) IN THE PUBLIC INTEREST.

rage 2 or6 Thursday, May 29, 2003 Page 2of 6

DATE OF LICENSEE NAME SUBJECT DECISION BASIS LETTER 10/29/1999 ARIZONA PUBLIC SERV. RISK-INFORMIED INSIRVICE TESTIN( GRANTED PART 170.1 I(b ) - APS WAS ASKED TO PARTICIPATE IN PILOT PROGRAM PILOT PL.AN'I' Rl.VII.W I'RO(;RAM ANI) NRC ACCEPTED TIJEIR SUBMITTAL, UTILIZE)

'I 11- EXPERIENCE GAINFD IIIROU(;II THE REVIEW TO MODIFY 50.55a () EIXPlICITLY E,NDORSE RI-IST METHODOLOGY.

10121/1999 PA POWER & LIGHT CO PART 50 XIM1'IION R,Qtll.ST Rl: TIlIE GRANTED I'ARr 170.1 1(b)( I) - PA P&L WAS REQJIRFD TO REQUEST CONDUCT OF A FI 11.1 PARTiciPATION EXEMPTION FROM PART 50 REQUIREMENT DUE TO FEMA AND EXERCISE 01!11 IE ONSITE AND oFFsIr NRC REGION I'S NEED TO RESCHFDULE EMERGENCY EXERCISE EMERGENCY PL.ANS AT'Ii IEIR SITE - SI IOULD NOT HAVE TO INCJR COSTS FOR REVIEW OF PART 50 EXEMPTION.

07/2711999 VARIOUS NRR'S PILOT INSPECTIoN PROGRAM - GRANTED PART 170.1 I(bXl) - FEE IS WAIVED FOR CERTAIN INSPFCTION REGULATORY OVERSIGHT PROGRAM - 13 EFFORT RELATED TO NRRS NEW REGULATORY OVERSIGHIT PLANT INSPECTIONS PROCESS THAT AFFECTS ALL NUCLEAR POWER PLANTS. FULL IMPLEMENTATION WILL COMMENCE PENDING SUCCESSFUL COMPLETION OF PILOT PROGRAM.

04/30/1999 IN UNIV.MEDICAL CTR IUMC AND ROJDEBtSII VF,TERANS ADMIN. GRANTED PART 170.1 I (bXl1) - SEPARATE LICENSES ARE MAINTAINED, MEDICAL CTR (VAMC) EXPLORING FACUJLTY MEMBERS HAVE JOINT APPOINTMENTS BETWEEN POSSIBILITY OF INCINERATING l)MC AND VAMC. IUMC IS CURRENTLY LICENSED BY NRC TO RADIOACTIVE WASTE GENERATED BY PROCESS/INCINERATE ITS OWN RADIOACTIVE AND VAMC. HAZARDOUS WASTES. AS PART OF SHARE PROGRAM IUMC WILL INCINERATE VAMCs WASTE WITHOUT A PROFIT MARGIN BUILT INTO THE COST FOR TIME AND MATERIALS. PUBLIC INTEREST.

04/21/1999 ALPHA-IDAHO, LLC APPLICATION FOR A NEW LICENSE FOR GRANTED PART 170.1 (bX I) - NO NEED TO AMEND YOUR LICENSE TO CALIBRATION USING SMALL QUANTITIES INCLUDE FEE CATEGORIES IC AND 2C 3ECAUSE OF THE SMALL OF VARIOUS NUCLEAR MATERIALS FEE QUANTITY OF SPECIAL NUCLEAR MATERIALS COULD BE CATEGORY 3P. LCENSEE THEN WANTED TO GENERALLY LICENSED. WAIVE APPLICATION FEE IC AND 2C ADD TO LICENSE CATEGORIES IC AND 2C. AS WELL AS AMENDMENT PEE.

03124/1999 nGlE COMPANY CALVERT CLIFFS NPP - APPLICATION FOR GRANTED PART 170.1 I(bXI) - APPLICATION REPRESENTS FIRST-OF-A-KIND LICENSE RENEWAL FFFORT FOR BOTH NRC AND INDUSTRY. STAFF INTENDS TO UTILIZE EXPERIENCE GAINED TO DEVELOP GENERIC IMPLEMENTATION GUIDANCE FOR LICENSE RENEWAL PROCESS FOR WHOLE INDUSTRY. (PARTIAL) 03124/1999 DUKE ENERGY CORP. OCONEE NPP - APPLICATION FOR LICENSE GRANTED PART 170.1 I(bXI)1 - APPLICATION REPRESENTS FIRST-OF-A-KIND RENEWAL EFFORT FOR BOTH NRC AND INDUSTRY. STAFF INTENDS TO UTILIZE EXPERIENCE GAINED TO DEVELOP GENERIC IMPLEMENTATION GUIDANCE FOR LICENSE RENEWAL PROCESS FOR WHOLE INDUSTRY. (PARTIAL)

Page 3 of 6 Tharsdny, May Thursday, 2003 29, 2003 May 29, Poge 3of 6

DATE OF LICENSEE NAME SUBJECT DECISION BASIS LETTER 03/1111999 CENTFRIOR PERRY LEFAD PIlOT PLANT APPLICATION GRANTED PART 170.1 1(b)(1 ) - FIRST-OF-A-KIND APPLiCATION FOR Tl Il.

FOR Tl. I ISI: oF IIE RFVISF.I) ACCIDE NT REVIEW OF REVISED ACCIDENT SOUlRCE TERM - STAFF USED SOI IRCEIRM MII IODOLGY EXPERIENCE IN PREPARATION OF REGULATORY GUIIDANCE.

S'ANI)ARD REVIEW PLAN AND ASSOCIATED RULEMAKING.

09104/1998 SUPERIOR WELL SERV. WillHDRAWAI OF AMENDMENT TO ADD A GRANTI) PART70.1 I(bXI) - LICENSEE OBTAINED TIlE GENERALLY-CESIUM 137 SEALFD SOURCE, TO THEIR LICENSED DEVICES FROM THE MANUFACTJRER AND LICENSE WITII)REW THE APPLICATION FOR A SPECIFIC LICENSE. NRC REVIEWER DIED AND WORK ASSIGNED TO OTHER STAFF WHO DIDN'T KNOW ABOUT THE WITHDRAWAL OF THE SPECIFIC LICENSE APPLICATION. COSTS REFUNDED 09/01/1998 VT YANKEE NUCLEAR VT YANKI,F PI,OT PlANT - RISK- GRANTED IART 170. l(bXI) - PROVIDES THE PERMANENT APPROACH TO INFORMEI) INSERVICE INSPECTION RI-ISI - STAFF INTENDS TO UTILIZE EXPERIENCE GAINED THROUGH THE PILOT APPLICATIONS IN PROPOSED RULEMAKING PROCESS TO MODIFY 10 CFR 50.55a & RELATED GUIDANCE DOCUMENTS.

08/1811998 ENtEROY ANO PILOT PLANT - RISK-INFORMED GRANTED PART 170.1 I (bXI) - PROVIDES THE PERMANENT APPROACH TO INSERVICE INSPECTION RI-ISI - STAFF INTENDS TO UTILIZE EXPERIENCE GAINED THROUGH THE PILOT APPLICATIONS IN PROPOSED RULEMAKING PROCESS TO MODIFY 10 CFR 50.55a 06/16/1998 VARIOUS NMSS RFQUEST - EXEMPTION FROM FEE GRANTED PART 170.1 I(b)(1) - THERE IS NO TECHNICAL REVIEW REQUIREMENTS FOR LICENSE AMENDMENT ASSOCIATED WITH THE ISSUANCE OF AMENDMENTS; FILED BY AND ISSUED TO FIXED GUAGE ISSUANCE OF AMENDMENTS IS AN ADMIN. MATTER; AND SELF-SHIELDED IRRADIATOR MAINTAINING LISTING OF CURRENT RSO IS FOR THE LICENSEES TO CHANGE THE RADIATION CONVENIENCE OF THE AGENCY SAFETY OFFICER (RSO) 06/12/1998 VEPCO SURRY PILOT PLANT SUBMITtAL - RISK- GRANTED PART 170.1 I(bXI) - PROVIDES THE PERMANENT APPROACH TO INFORMED INSERVICE INSPECTION - RI-ISI - STAFF INTENDS TO UTILIZE EXPERIENCE GAINED THROUGH THE PILOT APPLICATIONS IN PROPOSED RULEMAKING PROCESS TO MODIFY 10 CPR 50.S5a 02/26/1998 INTERSTATE NUC. SERV. LICENSEE CONDUCTED SOME SITE GRANTED PART 170.1 I(bX I) - ONE-TIME ACTIVITY WILL FACILITATE REMEDIATION WORK IN VOLUNTARY DFCONTAMINATION OF THE NUCLEAR LAUNDRY FACILITY COOPERATION WITH NRC REGION I STAFF THAT IS IN THE POSSESSION OF A NON-LICENSEE. NO FEE AT A FORMER NUCLEAR LUNDRY FACILITY. CHARGED FOR AMENDMENT TO INS LICENSE TO TEMPORARILY RECEIVE AND STORE RADIOACTIVE WASTE.

Page 4 ot6 Thnsrday, 29,2003 May 29, Thursday, May 203 Page 4or6

DATE OF LICENSEE NAME SUBJECT DECISION BASIS LETTER I1/12/1997 ATLAS CORP. FE, IOR MODELING ANI) 17EIRMINATION GRANTED PART 170.1 (b)I) - NRC AGREED TO FIJND ONE TASK IN ORDER OF SFEPAGE FROM TI-IE TAII.lN(iS INTO T ll rO ISSUE TIlIE FINAI, ENVIRONMENTAL IMPACT STATEMENT GROUN)WATER OVIER TIlE 100-YEAR (I:lIS) SO mI1AT ATLAS COULD IR(X'O.E.D TO RECAI.IM T IE 10.5 DESIGN LIFE OF THE RECLAMATION MILLION lONS OF UIRANIUM MILL TAILINGS AT THE SITF.

1'ASK ISVIEWED AS A CONFIRMATORY ANALYSIS OF ANALYSIS ALREADY PERFORMED BY NRC AN) ORNL FOR WHICH ATIAS WAS BILLED IN THlE PAST.

10/03/1997 Arizona Public Service CO. Request fc cxemption inder the provision of Part (Granted NRC agrees that the submittal meets the criteria or the fee waiver provided 170.21, footnote 4, item 3 for NRC review of the in 170.21, Footnote 4, item 3. The National Technologut and Advancement NIST National Voluntary Lab. Accreditation Act of 1995 requires agencies to use conscsus technical standards unles Program (NVLAP) to determine if it contains they are not appropriate to agency needs. NRR confirmed that clarification controls sufficient to allow NRC licensees and 10 of the audit requtirements of NVLAP accredited laboratoricis is a matter of CFR 50 Appendix B auidet calibration service generic interst to all nuclear plant licensees.

providers to not have to audit NVLAP accredited laboratories.

09/08/1997 ST. LOUIS UNIV. REQUEST EARLY IMPLEMENTATION OF GRANTED PART 170.1 l(b)l)- LICENSE WAS AMENDED TO GRANT REVISED 10 CFR 35.75 DUE TO A PATIENTS HOSPITAL AUTHORITY TO IMPLEMENT THE PROVISION OF 10 MEDICAL CONDITION AND UNIQUE CFR 35.75 EARLY, SO AS NOT TO UNNECESSARILY DELAY PERSONAL CIRCUMSTANCES MEDICAL TREATMENT TO PATIENT. ALL ELEMENTS WERE IN PLACE FOR ADMINISTERING TIF FINAL RULE, NO TECHNICAL REVIEW WAS REQUIRED TO GRANT REQUEST. HOSPITAL WOULD HAVE TO PASS ON COSTS FOR AMENDMENT, IT WAS DEEMED UNFAIR TO BURDEN PATIENT WITH AMENDMENT FEE DUE TO UNFORTUNATE TIMING OF MEDICAL CONDITION. (2 WEEKS PRIOR TO NEW RULE) 06/23/1997 KINNCO/KINNSCAN OGC REQUESTING THAT NRC NOT ASSESS GRANTED PART 170.1 l(b)(1) - IN PUBLIC INTEREST TO TRANSFER LICENSE AN AMENDMENT FEE TO KINNCO OR BACK TO KINNCO, HAVE SETTLEMENT AGREEMENT SIGNED, KINNSCAN FOR NAME CHANGF, TO COLLECT THE UNPAID ANNUAL FEES AND CIVIL PENALTIES TRANSFER THIE TITLE OF ITS MATERIALS AND CLOSE THE CASE.

LICENSE FROM KINNSCAN TO KINNCO.

04/21/1997 VARIOUS NRR'S PILOT INSPECTIONS FIRE GRANTED PART 170.1 I (b)(l) - PRIMARY PURPOSE OF THE PILOT PROTECTION FUNCTIONAL INSPECTION INSPECTIONS IS TO TEST THE DRAFT FPFI PROCEDURE AND (FPI) PROGRAM IDENTIFY NEED FOR ANY REVISIONS BEFORE PROCEDURE IS INCORPORATED INTO THE REACTOR INSP PROG.

01/24/1997 DR. DALE E. EDLIN MORE THAN ONE LICENSEE I IAVING THE GRANTED PART 170.1 I (bXI1) - AMENDMENT REQUJEST FILED BY DR. EDLIN SAMF PLACF OF USE ON THEIR LICENSE TO REMOVE THE DUPLICATE LOCATION FROM HIS LICENSE TO CAUSES CONFLICTS IN AUlTllORITY AND CONFORM WllH AGENCY POLICY SHOULD BE EXEMPT FROM RESPONSIBILITY OVER Til E RADIATION FEES SAFETY Page 5 of 6 Thursday, Mly 29,2003 Thnfrsdny, May 29, 2003 Pae of 6

DATE OF LICENSEE NAME SUBJECT DECISION BASIS LETTER 11(29/1996 NEI Risk-Informed Inservice Inspection Evalutiaion (;ranted The non-proprietary version is not subject to Fees in accordance with Procedure. EPRI Report TR-1067()6. This is the criterion three or Footnote 4 or 10 (CFR Part 170.21.

non-proprietary version of 'I'R- 1062 1%.

09/18/1996 VARIOUS NMSS REQUlST - EXEMIl-l'ON I-ROM (RANTED PART 170.1 I(bM I) - THERE IS No TrE.C INICAL REVIEW REQUIREMIENTS FOR LICENSE AMI-NI)MI-N1 ASSOCIATED WI'H THE ISSUANCE OF AMENDMENTS:

FEES FILED BY AND ISSiD ()OPORTABlE ISSllANCE OF AMENDMENTS. IS AN ADMIN. MATTER; GAUGE LICENSEES TO Cl IAN(;E T I1 MAINTAINING CURRENT RSO IS FOR CONVENIENCE OF THE RADIATION SAFETY OFFICE.R (RSO) COMMISSION.

05/30/1996 BG&E and Duke Power Co. Partial waiver fo Part 170 fees for the review of Granted-Partial The part of the NRC review that supports the development of the standard generic license renewal technical reports for one review plan, regulatory guide, and inspection guidance meets criteria 2 of licensee from each owners group. footnote 4 Of 170.21. NRR established both a generic and a site specific TAC in order to separately keep track of the time being expended for each review and to provide a record upon which to bill Part 170 fees for the plant specific reviews.

0602/1I994 CEOG CEN-607 - REACTOR VESSEL HEAD GRANTED PART 170.1 l(bX1) - REPORTS PROVIDE INFORMATION THAT IS PENETRATION CRACKING BEING USED TO DETERMINE WHAT, IF ANY, GENERIC REGULATORY ACTIONS ARE NEEDED TO ADDRESS A GENERIC SAFETY CONCERN.

06102/1994 B&WOG BAW-10190P - REACTOR VESSEL HEAD GRANTED PART 170.1 (b)(I) - REPORTS PROVIDE INFORMATION THAT IS PENETRATION CRACKING BEING USED TO DETERMINE WHAT. IF ANY, GENERIC REGULATORY ACTIONS ARE NEEDED TO ADDRESS A GENERIC SAFETY CONCERN.

05127/1994 SQUG GENERIC IMPLEMENTATION PROCEDURE GRANTED REPORT WAS EXEMPT FROM 170 FEES - SUBMITTED IN (GIP) SEISMIC QUALIFICATION UTILITY RESPONSE TO GENERIC LETTERS& DID NOT RESULT IN THE GROUP GENERIC BASIS FOR UTILITIES TO REVIEW OF AN ALTERNATE METHOD OR REANALYSIS TO MEET ADDRESS ISSUES IN GL 87-02 THE REQUIREMENTS OF GL 87-02 (BEFORE FOOTNOTE) 0520/1994 NEI EPRI-102470 - ANALYSIS OF HIGH- GRANTED DEST INTEREST OF COMMISSION NOT TO ASSESS FEES UNDER FREQUENCY SEISMIC EFFECTS PART 170.21 - INFORMATION SUPPORTS POTENTIAL GENERIC REGULATORY IMPROVEMENTS. (BEFORE FOOTNOTE) 04/14/1994 NEI SAFETY RELATED MOTOR OPERATED GRANTED PART 170. 1 (bX1) USE OF METHODOLOGY WILL PROMOTE VALVE TESTING AND SURVEILLANCE - GL UNIFORMITY IN THE DETERMINATION OF VALVE SWITCH 89-10 EPRI FINAL TOPICAL REPORT SETTINGS & UTILITY RESPONSES TO GL 89-10 Page 6 of 6 Thursday, May 29,2093 May 29, 2003 Page 6 of 6

(IV I tA Quality of Submittals Revisited Jack Donohew Senior Pri LManager, NRC Callaway I1 Ej Station Palo Verde Nuclear g Station 0

Wolf Creek Nuclear .on Tuesday, June

June 11, 2003 2 Guida ce

LIC-101, Amendments

LIC-102, Relief Request Reviews

LIC-103, Requests For Exemption From The Regulations

NEI White Paper Dated August 2001 1

1~~~~~~~~I'A

June 11, 2003 3 Goals of Lice es 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 ded

Provide date licensing action needed Lthe basis

Provide time to implement amendment

Provide precedents

Provide electronic copy of submittal and clean copy of TS pages

June 11, 2003 5 IOOF "4(a)

Signed original of written corM ndence to DCD, Washington, DC 20555

List NRC-specified addresses on submf as receiving copy

6 Incorrect Addr sed Submittal U ?* . rving, PM Upon sends con original, if p lo DCD

1zp Aq,A Quality of Submittals Revisited ack Donohew Senior I Manager, NRC Callaway I Station Palo Verde Nuclear bm LGStation 0~~~~~~~

Wolf Creek Nuclear CEX Ca on Tuesday, June

0) n e-ci 0 Quality and Role of SERs Today Robert A unm Section Chic Tuesday, June 10

2 ROLE OF FETY EVALUATI ONS

LIC-100 defines statureon licensing basis hierarchy (SE vs SER)

LIC- 0 1 and LIC- 102 provide outlines content

- Introduction

- Regulatory Evaluation

- Technical Evaluation

- Commitments

- Conclusion

SEs provide regulatory basis for NRC decisions or licensing actions

3 EVALUATIONSa,ontinued N6-

SEs cite pertinent regulations and re criteria

SEs describe staff rationale for why chang r is/is not acceptable

4 ROLN SAFETY EVALUATIONScontinued

Licensees provide licensing bases information a of application

Staff works with licensee to capture important inforMa the licensing basis

- License condition

- TSs

- Other licensee controlled document (FSAR, TRM, QA program

- Commitment

SEs describe licensee commitments relied upon to make licensing decision

SEs are generally not directly enforceable

June 10, LE OF SAFETY 5 EVALATIONS continid

Unique Cases where SEs may contain new licens is information

- ASME code relief under IST 50.55a(f)(6)(i) and Inservic n 50.55a(g)(6)(i)

- For relief sought when code requirements are impractical, "Th .*

commission may grant relief and may impose alternative require

SEs provide insights for licensee consideration on what informati i 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 QUALITYNOF SEs

Guiding procedures and instruction IC-101, LIC-102, DLPM Handbook)

Multi-level and -functional reviews perform F technical staff, OGC, and DLPM

Expectation is that staff products are accurate an fully support licensing decisions

June 10, 2003 7 QUALITY OFSEs - 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

- LAforintegrated SE

- DLPM SC for integrated SE (documented) rl

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 .

n VC041 11A.

01

-. o-- pA-Ilb-s-o

-X Quality and Role of

* *

4c , SERs Today Robert A. mm Section Chle Tuesday, June 10,

PROCESS STANDARD: Assessing Safety Evaluation Quality - For Integrated SE Package TASK: Prepare safety evaluation input for licensing actions satisfying the attributes listed below (i.e., A through F)

ITERATION PC 1 2 3 4 (circle)

Plant & TAC Number(s):

Prepared By: Date Submitted:

Peer Consultation (PC) By: Date Reviewed:

Peer consult is highly recommended; however, it is optional. It should be used to determine if the attributes described below have been successfully incorporated into the safety evaluation input prior to concurrence.

Section Chief Review: Date Reviewed:

A'TIRlBUTE Y N COMMENT A The introduction section briefly describes the amendment request (LIC-IOI, 4.5.1).

B The regulatory evaluation section provides the regulatory framework for the licensee's action, including a summary of design features, licensing bases, and relevant regulatory standards/acceptance criteria (LIC-101, 4.5.2).

C The evaluation section includes an independent analysis of the proposal in terms of the regulatory requirements, established staff positions, industry standards, or other relevant criteria; document covers the full scope of important issues. Each evaluation subsection specifically identifies the basis for approving or disapproving the amendment request (LIC-101, 4.5.3).

ATTRIBUTE 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 gramnatical errors as Low or High. Errors are low if they are few and manageable such that they are easily corrected, and high if errors are numerous or a consistent pattern of mistakes appear. Return to TB/author if l___ SE contains a high number of errors.

DLPM Licensing Assistant (LA) (or optional secretary) Typographical Grammatical review includes Attributes D and F from the template errors detected errors detected above. (See Attribute F (See Attribute F for instructions) for instructions)

Date LA Review: Reviewed:

Additional Comments:

0, N'A "I

itt,

.16.

, 'cc p f-io -

Use of Task nterface Agreements DyLanne neaud Intern, Tuesday, June 10

What is ask Interface Ag reemItTA)

A request for technical assistance from a region or another NRC office that contains questions on subjects U within the scope of NRR's mission and responsibilities 4

June 10, 2003 3 Reason )rTIAs

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 a on 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

TIA Lead PM

A management representative of at least t Branch Chief level from the requesting office

June 10, 2003 6 P rotes

Issue is discussed by telephone

Submittal mutually agreed upon within a week of initial request

Approval of the NRR TIA SES Process Owner

ue7 Anot needed in the fol low i i-cases:

The staff has previously expressed a posi

The inspection findings involve the performanc 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#ed (continued):

o not concern policy

Mutually agreed to have very o a significance and can be answered b tlphone or e-mail

June 10, 2003 9 PrI rio aTIA

Safety and risk significance

Operational impact

Regulatory impact

10 Licen Involvement

Interaction with licensee encoui, I to obtain clear and accurate informatil

A written submittal from a licensee may requested

Adverse impact on the licensee

co 'PA~~~~

k ~~-0' 0% :P~Use 01 asK interiace Agreements DyLanne A1 Intesa J ,

Tuesday, June 10

Bulletin 2002-01 RAI Lessons Learned Donohew r"

Senior .nager, NRC Callcaway N station Palo Verde Station Wolf Creek Nuclear C Tuesday, June

June 10, 2003 2 Bu12002-01 RAI Lesson arned

Bulletin 2002-01 not explicit on w NRC wants to know

- what components were inspected

- how inspections were performed

- how discrepancies were dispositioned

In RAI, staff acknowledged that it was not clea bulletin

NRC generic communication process does not len itself to being specific

- evolving knowledge of problem

- political realities

- timeliness demanded for generic communication being issued vs. being specific Information will be exchanged following the generic communication is this not what is to be expected

June 10, 2003 3 Bulletin 2002-1 Lessons Learne

NRC and industry have different audiences

- Licensees need to convey there is no severe problem and it is contrbe wti existing licensing basis

- NRC needs to convey there is problem (why else the generic comnmunica ~dI controlling the problem K

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 g

Perhaps similar situations just can not be avoided

- Bulletin 2002-01 reflected NRR need to quickly request informationat

Bulletin 2002-01 RAI Lessons Learned

k Donohew Senior Proq nager, NRC Callaway tation Palo Verde Nt Lt [. u. Station Wolf Creek Nuclear (

Tuesday, June

Safety Conscious Work Environment Moha . Thadlani Sei iior Project 6' . er, NRC Cooper Nucle South Texas P Tuesday, June 10,

~~afe{y Conscious Work EPvironment

Commission's Statement of o

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))

2 June 10, 2003 June 2003 2

onscious Work Envirbi nent

The Staff's Responses to March 26, 2003 SRM

The SRM Outlines the Commission' s Recommendations June 10, 2003

l l:

40 f.,

'T i-0 Safety Conscious Work Environment Moha hThlcidani Senior Project er, NRC Cooper Nucle South Texas P Tuesday, June 10,

Informal Communications (e.g.7 email draft J a')

information)

Donohew Senior Pro a nager I NRC Callaway tion Palo Verde Nuclear -isStation Wolf Creek Nuclear Tuesday, June

2 IA Commrunications

Emails and Letters which do not go through t Document Control Desk (DCD) quickly provides copies to P submittals going to DCD provides informal or draft on does not go through licensees' QC/QA checks

COM-203, "Informal Interfacing and Exchange of Inform E 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 I nformnommun ications

Informal Communications help improve efficie

- Quickly helps determine if what NRC needs on the t isbeing provided

- Avoids multiple letter exchanges between NRC/License

Information used to make a regulatory decision must be N docketed

Substantial information (letter needed) vs. Clarification (email call from licensee)

- PM judgment

June 10, 2003 4 nfor nommunications (e.g., +a

RAls can be docketed several ways

- letter issued by staff and responded to by licen

- letter submitted by licensee referencing emails/calls

Docketing informal communications in ADAMS

- memo to docket file descrbing call and/or describing/attaching em

- emails may have statements that information provided is confidential

Informal communications should not include inform that would be withheld from public

- proprietary information

- safeguards information

Informal Communications Aq

-0~

(e. g" email draft J information) igDonohew Senior Pro Lnager, NRC Callaway ion Palo Verde Nuc O4 Wolf Creek Nuclear Tuesday, June

Processing Submittals 0~

Associated with Security Issues Davi Jaffe Senior Project h NRC Comanche Peak Steam tiotin Wednesday, June 1

2 Protecting Sa eguards Information Withholding Sensitiv Information

Regulatory Issues Summary 200

- William Reckley

Fall 2003 NEI Licensing Issues Forum

June 11, 2003 3 DocuTments 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 En whose compromise would assist in the design, manufacture, or of nuclear weapons

June11,2003cuments W ithheld 4 from Pub i Disclosure Classified Information

Information concerns physical protection vulne may be classified information.

Clearance and "need-to-know" required for access I

5

\Documents Withheld fro1/2PublicDisclosure Safeguards Information (SGI)

Sensitive unclassified information authorized by Energy Act

SGI concerns the physical protection of operating powe reactors, spent fuel shipments, strategic special nuclear material, or other radioactive material.

June11, 2003 ments Withheld from 6 Publc isciosure 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 commerci inancial information within the meaning of subsection 9.17(a)(4 chapter.

(1) Correspondence and reports to or from the NRC which contain information or records concerning a licensee's or applicant's physic protection, classified matter protection, or material control and accou program for special nuclear material not otherwise designated as Safeguards Information or classified as NSI or RD

J13tKocumentsV Withheld from bic Disclosure Other Sensitive Unclassified I ation

The NRC expects that licensees will continue est withholding of some information using this provis

The NRC believes that the volume of material reques3 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 Submis6 ddressing Securit sues

'A

Chang volving Physical S

FSAR Updates

Miscellaneous Issue Under 10 CFR 2.790

Processing Submittals I-Associated with Security Issues Davi Jaffe Senior Projectd NRC Comanche Peak Steam ation Wednesday, June 1

Making Changes to nP the Plant Associated 0

0 to Orders -

Process Guidance Robert A.ll Section Chie Wednesday, June 1

- ~~~~~~~~~~

rcl 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 he t and safety, licensee interference with inspection/investigation

Revocation orders: for conditions which would warrant refusal of a license on an original application

Ordersontinued

Cease and desist orders: stop an uthorized activity

10 CFR 2.202

NRC Enforcement Manual Section 5.8, "Orde Modifying, Suspending, or Revoking License"

Staff Handbooks

4 Opr rnrscontinued

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 10, 2003 10, 2003 June 55 Order' continued

Response may consent to order wh waives rig][it to hearing

Response may present facts supporting pos for not consenting to the order and reasons w the order should not have been issued

Response can demand a hearing to move Commission to set aside immediate effectiveness of the order

June 10, 2003 6 MODIFYINGAN ORDER

Provisions of an order can be mody:

- 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 MODIFYNG AN ORDER -

contined

If a hearing, becomes effective as determined in the hearing

Requests for extension of time to request a hearing can be made N to OE (or as described in the Order)

June 10, 2003 8 EXAMPLEStOF ORDERS EA 03-009 Interim Inspection Requirements for PWR R eads

Order effective immediately until superceded by 50.55a cha swer or request for hearing does not stay immediate effectiveness

"...all PWR Licenses identified in the Attachment to this Order sha X modified to include the inspection requirements for RPV heads and a l 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 EXAMPL&F ORDERS-contiiinie d EA 03-038: Compensatory Measures for Fitness-forDuancements for Security Force Personnel ~t

Order effective immediately, answer or request for hearing do immediate effectiveness

"All Licensees shall.. .comply with the requirements described in A iT l 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 regulationsMi tI license

Licensees to submit an implementation schedule in 35 days and report when full compliance achieved

"The Director, Office of Nuclear Reactor Regulation may, by letter, relax or rescind any of the above conditions upon demonstration by the Licensee of good cause."9

P,%

f-e Making Changes to a the Plant Associated 0 ;to I: Orders -

- ,t Process Guidance Robee 1 Wednesday, June

Perry Decision I

aV*

ack Donohew Senior PrrManager, NRC Calla ,wa 1a Station Palo Verde:.Nucleartion Wolf Creek Nuclear ! lY oin Tuesday, June

2

~~ecision

Perry Decision: ASLB decision that a change to th e wal schedule for RPV material specimens per Part 50 Appn licensing amendment.

Commission reversed decision: Only agency approvals grantdt exceed existing licensing authority" are license amendments.

- withdrawal schedule change conforming to ASTM standard not a license amendment

- a change not conforming to ASTM standard is a license amendment.

3 PerryXcision

10 CFR Parts 2 and 50 allows a fe s for the staff to approve a license change:

- Exemption per 50.12

- Relief request per 50.55a

- Order per 2.202

- Amendment and Security program change per 50.90

- QA and EP program change per 50.54

NRC approval must be by one of the above methods

Orders can include the method for changing the requirements in the order (i.e., the RPV head inspection order).

June 11, 2003 4 Perry sion

Examples

- Comanche Peak RTT change in corn and method of verification in TS RT d

- Diablo Canyon probability of detection in Note 2 stating upper voltage repair limit calculated by GL 95-05

qi~~~ki Perry Decision Jack Donohew Senior PrZ LManager, NRC Callaway I Station Palo Verde Nuclear a Station Wolf Creek Nuclear tion Tuesday, June

OD

'-I.-

is" 50.59 Revised Rule Follow-up Moha. Thvadani Senior Project er, NRC lh

~~i*,

Cooper Nucle South Texas F Wednesday, June 11

Revis,eds Rule FIw-up

Revised Rule effective March

Guidance (RG 1. 187, NEI 96-07, Part.

Inspection Procedure 71111.02 June 10, 2003

095 Revised Rule Folow-up

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

N09,14 iks 11 0

iF 4c i-

-4 01 50.59 Revised Rule Follow-up Mohal C. ThadaniT Set ior Project NRC Cooper Nucle South Texas P Wednesday, June 11

ML031920649

Contents

Text

Introductions

SUMMARY

1.0 INTRODUCTION

3.0 STATE CONSULTATION

4.0 ENVIRONMENTAL CONSIDERATION

Background

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ML031920649

Text

Introductions

SUMMARY

1.0 INTRODUCTION

3.0 STATE CONSULTATION

4.0 ENVIRONMENTAL CONSIDERATION

Background

Navigation menu

Search