ML090540092

Summary of the License Renewal Meeting Between the U.S. Nuclear Regulatory Commission Staff and the Nuclear Energy Institute

ML090540092
Person / Time
Site:	PROJ0690
Issue date:	03/03/2009
From:	Homiak M NRC/NRR/DLR/RPOB
To:	Nuclear Energy Institute
Homiack, M, NRR/DLR/RLRB 415-1683
References
Download: ML090540092 (9)

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March 3, 2009 ORGANIZATION: Nuclear Energy Institute

SUMMARY

OF THE LICENSE RENEWAL MEETING BETWEEN THE U.S.

NUCLEAR REGULATORY COMMISSION STAFF AND THE NUCLEAR ENERGY INSTITUTE The U.S. Nuclear Regulatory Commission staff (NRC or the staff) and representatives of the Nuclear Energy Institute (NEI) met on January 28, 2009, to discuss generic license renewal topics and license renewal process improvements. Enclosure 1 lists the meeting participants and Enclosure 2 provides the meeting agenda. A summary of the discussion follows.

1. Status of License Renewal Interim Staff Guidance (LR-ISG)

a. Staff Guidance Regarding the Station Blackout Rule (10 CFR 50.63) Associated with License Renewal Applications (LR-ISG-2008-01)

The staff indicated that it is still holding discussions internally on this LR-ISG and acknowledged that NEI had provided useful comments on the draft. The staff stated that the schedule for resolving this issues generically has not been established and, as such, it is expected to continue to appear during plant-specific license renewal application reviews. NEI commented that the staff should clarify the technical basis for establishing the scoping boundary and to define the transmission system voltage. NEI expressed concern that the staff has not resolved the issue. NEI commented that backfitting regulations should apply if the scoping boundary is outside the plants current licensing basis.

b. Changes to NUREG-1801, Revision 1, Generic Aging Lessons Learned (GALL)

Report Aging Management Program XI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (LR-ISG-2007-02)

The staff indicated that this LR-ISG is in the final approval stage and final guidance may be issued as early as February 2009. The staff mentioned that it recently delayed approval so that it could add a backfitting discussion to the LR-ISG, which is in response to a recommendation from NRC Office of the Inspector General (OIG) audit on the effectiveness of the license renewal program (OIG-07-A-15).

c. Updates to the License Renewal Interim Staff Guidance Process (LR-ISG-2007-01)

The staff stated that it is currently finalizing a proposed LR-ISG process revision and plans to request in the Federal Register public comments on the proposal.

The proposed revision will include administrative updates and extend the process for revising certain guidance documents associated with the staffs environmental review of license renewal applications. The staff is also augmenting the process in response to a recommendation from the NRCs OIG audit. The staff will

propose to include in each LR-ISG a new backfitting discussion section to document the staffs determinations as to whether an LR-ISG involves newly identified SSCs, and if it does not, then whether the LR-ISG constitutes backfitting. The staff will also propose to eliminate the clarification and compliance LR-ISG designations, and instead rely on the new backfitting discussion for specifying licensee implementation of LR-ISGs.

2. Status of the GALL Report Update The staff stated that it is finalizing the schedule to complete the update and has procured contract support. NEI indicated that it is finalizing comments for the staffs consideration and plans to submit them in several packages as follows: aging management program comments within the next few weeks, followed by electrical and structural comments by the end of February 2009, and all comments by the end of April 2009. NEI asked whether the NRC is considering placing the GALL Report on the NRCs public Web site to make updating it easier.

3. Status of the Generic Environmental Impact Statement (GEIS) Rulemaking The staff indicated that it plans to issue the draft GEIS in summer 2009 and the final GEIS in the middle of 2011. The staff suggested that it will use a standard 75-day period for submitting public comments on the draft GEIS. Also, the revised GEIS will be more user-friendly with a resource-based approach, rather than the current systems approach.

NEI requested the staff to specify an implementation date for the revised GEIS so that applicants can have advance notice to better prepare their license renewal applications.

The staff indicated that the content requirements would not change radically and implementation of the revised GEIS could be handled similarly to the implementation of GALL Report, Revision 1.

4. Streamlining the License Renewal Process for Life Beyond 60 Years NEI indicated interest in future discussions for streamlining the license renewal process and determining the staffs review focus on these applications. NEI stated that, after the first license renewal, subsequent renewals will be less complex because the aging management programs will already be in-place. Also, as with the first decision to apply for license renewal, licensees will likely make early decisions to apply for subsequent license renewals so as to better plan for their plants futures. NEI reminded the staff that some licensees are eligible to re-apply for license renewal as early as 2009, but most-likely the NRC could expect to see these types of renewal applications as early as 2013.

The staff indicated that it is interested to obtain more operating experience to better ascertain the effectiveness of license renewal aging management programs. The staff commented that subsequent license renewals will most likely be focused technically, rather than on procedure. To facilitate its planning and budgeting, the staff stated that it soon plans to issue another regulatory issue summary to request written notification of when licensees intend to submit license renewal applications. The staff requested that any licensee planning to submit a license renewal application for life beyond 60 years also provide such notification to the NRC.

In addition, a representative from the NRCs Office of Nuclear Regulatory Research stated that there are currently five technical focus areas being considered for plant operation beyond 60 years: (1) electrical cables, (2) concrete materials, especially in high-temperature and high-radiation environments, (3) reactor vessel and internals components, (4) buried and submerged structures, and (5) coatings. The staff stated that it is working to identify any new technical issues as soon as possible while working with the industrys technical organization, the Electric Power Research Institute.

Regarding coatings, NEI commented that inspection programs are usually taken credit for preventing aging, not the coatings themselves. NEI also stated that aging concrete could potentially be a significant limiter on plant life because replacing concrete is difficult.

5. New Topics

a. Acceptance Reviews The NRC stated that licensees need to submit complete license renewal applications. Providing the required information later is not acceptable and does not constitute a complete application acceptable for docketing.

b. Application Review Schedules The NEI commented that sometimes license renewal review milestones posted on the NRCs public Web site are not accurate and complete. NEI stated that the cut-off date for submitting responses to requests for additional information (RAIs) is an important milestone for applicant planning. Also, NEI stated that sometimes there is confusion as to this final cut-off date. The staff responded that it attempts to present the Advisory Committee on Reactor Safeguards with a safety evaluation report with no open items. To achieve this goal some leeway in determining the final RAI cut-off date is preferable. NEI agreed with the staff that sometimes it is beneficial to not set a hard date.

The staff stated that some review schedules have been delayed for various reasons, but the NRC is aware that lengthening the review process can cost applicants more money (e.g., to maintain contractor support). The staff stated that it is working to finalize review schedules around 24 months for the latest five license renewal applications.

c. Audit Process The NEI commented that changes to the license renewal audits have resulted in more RAIs. NEI suggested that a future workshop could be helpful to gauge the effectiveness and efficiency of these changes. The staff stated that it does not want to lose the efficiencies of the audit process and it is tracking the number of RAIs issued for each license renewal review. NEI commented that applicants want to know how to plan for these audits, and also whether applications should be changed to reduce RAIs. NEI agreed with the staff that the audit process is

helpful for eliminating unnecessary RAIs, and the staff stated that it is open to any suggestions to improve the audits.

d. Inspections Under NRC Inspection Procedure 71003 The NEI commented that, after completion of the first post-renewal inspections under NRC Inspection Procedure 71003, it may be beneficial to look at the process to determine whether any lessons can be learned. The staff said that it will consider this recommendation for the future.

e. Use of NRC Regulatory Guide 1.207 for License Renewal The NEI raised a question as to whether NRC Regulatory Guide 1.207 for evaluating fatigue analyses for new reactors also is acceptable for license renewal of existing operating plants.

f. Web Compatible CDs The NEI provided comments on improving instructions for submitting electronic copies of license renewal applications for posting to the NRCs public Web site.

6. Public Participation No member of the public chose to provide comments or ask questions at the meeting.

\RA\

Matthew Homiack, General Engineer Program Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/encls: See next page

ML090540092 OFFICE PM:RPOB:DLR LA:DLR BC:RERB:DLR BC:RPOB:DLR NAME MHomiack SFigueroa BPham TTate DATE 03/3/09 03/3/09 02/26/09 03/3/09

Participant List License Renewal Meeting between the U.S. Nuclear Regulatory Commission (NRC) Staff and the Nuclear Energy Institute January 28, 2009 PARTICIPANT AFFILIATION Brian Holian NRC Bo Pham NRC Travis Tate NRC C. E. Carpenter NRC Matthew Homiack NRC Al Fulvio Exelon Mike Heath Progress Energy Dave Flyte PPL Susquehanna Ken Putnam FPL - Duane Arnold Ray Kuyler Morgan Lewis Arden Aldridge South Texas / STARS Anthony F. Ploplis Progress Energy Cliff Custer FENOC Massoud Tafazzoli Areva Abbas Mostala Energy Northwest Columbia Generating Station Christopher Mallner Progress Energy Bill Victor NPPD David Bremer NPPD Michael Semmler Westinghouse Reza Ahrabli Entergy Rick Buckley Entergy Alan Cox Entergy Eric Blochor STARS - Worley Parsons Loyd Wright SCE - STARS Gary M. Adkins TVA Michael R. Fallin Constellation Julie Keys Nuclear Energy Institute Deann Raleigh* SCIENTECH

• Participated by teleconference ENCLOSURE 1

Agenda License Renewal Meeting between the U.S. Nuclear Regulatory Commission (NRC) Staff and the Nuclear Energy Institute (NEI)

January 28, 2009 Generic License Renewal - Topics Lead

1. Status of License Renewal Interim Staff Guidance (LR-ISG) NRC

a. Staff Guidance Regarding the Station Blackout Rule (10 CFR 50.63) Associated with License Renewal Applications (LR-ISG-2008-01)

b. Changes to NUREG-1801, Revision 1, Generic Aging Lessons Learned (GALL) Report Aging Management Program XI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (LR-ISG-2007-02)

c. Updates to the License Renewal Interim Staff Guidance Process (LR-ISG-2007-01)

2. Status of the GALL Report Update NRC

3. Status of the Generic Environmental Impact Statement (GEIS) NRC Rulemaking

4. Streamlining the License Renewal Process for Life Beyond 60 Years NEI

5. New Topics NRC/NEI

6. Public Participation All ENCLOSURE 2

Letter to the Nuclear Energy Institute, from M. Homiack, dated March 3, 2009

SUMMARY

OF THE LICENSE RENEWAL MEETING BETWEEN THE U.S.

NUCLEAR REGULATORY COMMISSION STAFF AND THE NUCLEAR ENERGY INSTITUTE DISTRIBUTION:

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Nuclear Energy Institute Project No. 690 cc:

Ms. Christine S. Salembier, Commissioner Mr. Garry G. Young State Liaison Officer Manager, License Renewal Services Department of Public Service 1448 SR 333, N-GSB-45 112 State Street, Drawer 20 Russellville, AR 72802 Montipelier, VT 05620-2601 Ms. Lorrie Bell, Project Manager Mr. Frederick W. Polaski Wolf Creek Nuclear Operating Corporation Manager License Renewal P.O. Box 411 Exelon Corporation Burlington, KS 66839 200 Exelon Way Kennett Square, PA 19348 Mr. Roger Stewart Progress Energy Carolinas, Inc.

Mr. Clifford I. Custer 3581 West Entrance Road Project Manager, License Renewal RNP A9 FirstEnergy Nuclear Operating Company Hartsville, SC 29550 P.O. Box 4 Route 168 (Mail Stop SIM-2) Mr. Michael H. Crowthers, Supervisor Shippingport, PA 15077 Nuclear Regulatory Affairs PPL Susquehanna, LLC Mr. Paul Gunter, Director Two North Ninth Street (GENPL4)

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