ML092220522

Summary of Meeting with Nuclear Energy Institute to Discuss Generic License Renewal Topics and Activities

ML092220522
Person / Time
Issue date:	08/20/2009
From:	Spivack I NRC/NRR/DLR/RPOB
To:	Nuclear Energy Institute
Spivack I, NRC/NRR/DLR/RPOB, 415-2564
Shared Package
ML092220512	List: ML092220522
References
Download: ML092220522 (13)

Text

August 20, 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 July 29, 2009, to discuss generic license renewal topics and activities. Enclosures to this letter are: (1) list of meeting participants, (2) meeting agenda, (3) NRC presentation on Operating Experience Review, and (4) NRC presentation on Electric Power Research Institute (EPRI) Mechanical Tools. A summary of the meetings discussions follows.

1. Generic Environmental Impact Statement Status (GEIS)

a. NRC staff stated that the draft GEIS will be issued by the end of July. There will be a 75 day comment period. An extension has to be formally submitted to the Commission and will be considered. There is no red line version available due to major formatting changes. The statements of consideration in the Federal Register proposed rule states each change to the GEIS.

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

a. Boral Degradation in Spent Fuel Pool NRC staff stated that an LR-ISG is expected to be issued in August which will propose a new aging management program (AMP) with regards to the degradation of Boral in spent fuel pools. This issue is also being addressed under 10 CFR Part 50 by an Information Notice for reactors in the initial operating period. Because the aging management of materials also needs to be addressed for the period of extended operations, the LR-ISG will address the issue under 10 CFR Part 54.

Technical staff from the office of Nuclear Reactor Regulation technical divisions will work closely with technical staff from the Division of License Renewal in addressing emergent issues that involves activities regulated under 10 CFR Part 50 and Part 54.

b. Revision to the LR-ISG Process (LR-ISG-2007-01)

NRC staff stated that they received NEIs comments on the proposed revision to the LR-ISG process. Most of the comments that were received were related to the referenced Regulatory Information Summary (RIS) on implementation of 10 CFR 54.37(b). The rest of the comments were mostly editorial. The staff responded to one comment which it believes confused the difference between a regulatory analysis and a regulatory evaluation. The staff will only conduct a regulatory analysis for situations requiring a backfit per 10 CFR 50.109. A meeting may be conducted in the future to discuss the resolution of comments related to

newly identified structures, systems, and components (SSCs) in the revision to RIS 2007-16. The LR-ISG process document is scheduled to be finalized by the end of August. The LR-ISG process document will address newly identified SSCs by reference to the RIS.

c. Electrical Cable Connections Not Subject to 10 CFR Part 50.49 Environmental Qualification Requirements (LR-ISG-2007-02)

NRC staff stated that this LR-ISG is on track to be issued soon. This LR-ISG will clarify the one time inspection of a representative sample of electrical connections.

The Office of General Counsel is currently reviewing the backfit evaluation discussion.

d. Station Blackout Rule Associated with License Renewal (LR-ISG-2008-01)

NRC staff stated that this LR-ISG was withdrawn and has been published in the Federal Register on July 13, 2009. It is up to the individual plants to evaluate their own operating experience and maintenance program to ensure that they maintain proper operating voltage. Plants will be evaluated individually based on their current licensing basis.

3. 50.59 License Renewal Commitment Wording

a. The NRC staff discussed an on-going review of a particular license renewal-related license conditions. One of the standard license conditions included in a renewed license allows an applicant to make changes to license renewal commitments, consistent with the requirements of 10 CFR 50.59, pending the incorporation of these commitments into the Updated Final Safety Analysis Report. The specific language used in this license condition is under review to close a potential loophole that could allow an applicant to use a 10 CFR 50.59 review to change or remove a license renewal commitment without fully evaluating the impact on the current licensing basis.

The staff added that although it is important to make sure the language in license conditions is correct and sufficient, no examples had been identified to date of an applicant having made an inappropriate change to a license renewal commitment.

Finally, the staff stated that the revised version of this license condition would be shared with NEI during a future quarterly meeting once the revision has been appropriately vetted through the agency.

4. Status of Regulatory Information Summary (RIS) for:

a. 10 CFR 54.37(b) implementation for License Renewal NRC staff is currently discussing what would be appropriate for what is considered newly identified SSCs. The staff is still working on making the appropriate implementation and interpretation of this rule for modifications/changes after the

license is renewed. Some of the concerns address replacement equipment that is installed after the renewed license is issued and was also scoped in during the license renewal review. There may be a need to conduct a public meeting to discuss this issue.

The industry stated that the design change process addresses the maintenance of equipment during the remaining term of operation. An NEI representative stated that the design change process considers evaluating the equipment for the life of the plant up to 60 years.

b. Giving NRC Advanced Notice of Intent to Pursue License Renewal NRC staff issued a RIS that requested advanced notice of intent to pursue a license be submitted by the end of August. Also, the RIS requests information related to changes to previously announced plans. Further, the RIS requests information related to licensees interests in pursing a second renewal. This information is important for the NRC in order to prepare the budget and other resource needs. This RIS will probably be issued every year.

5. License Renewal Guidance Documents Update

a. NRC staff stated that the Generic Aging Lessons Learned (GALL), Standard Review Plan (SRP) for License Renewal Review, a basis document for all the changes between the 2005 GALL and the 2010 GALL, and a NUREG that will discuss how all of the comments are resolved will be issued in December 2010. The NRC staff is currently reviewing and updating the AMPs in the GALL Report. The NRC has developed integrated teams from different divisions and offices inside the NRC to evaluate the changes proposed to GALL. The NRC website has a full schedule of the GALL update project.

An NEI representative stated that they updated their license renewal document from the 2001 GALL to the 2005 GALL. The NRC stated that there might be a concern between the safety differences between licensees who committed to older and newer versions of GALL. An NEI representative stated that emerging issues would be covered by the current operating licensing process.

6. Adequate Information Needed in License Renewal Applications when not Consistent with the GALL Report

a. NRC staff stated that the current license renewal safety audit process focuses on AMPs that the applicant claims are consistent with the GALL Report. Previously, the audits were also used to evaluate the exceptions and enhancements of AMPs and time limited aging analyses (TLAAs). For programs not consistent with GALL, there needs to be sufficient information in the application for the NRC staff reviewer to review the information at Headquarters. Insufficient information in the application will cause requests for additional information to be written.

7. Discussion on Operating Experience:

a. Operating Experience for New and Existing Programs NRC staff presented slides discussing the relevant operating experience that needs to be addressed by the applicant (Attachment 3: Agencywide Document and Management System (ADAMS ML092220519). The presentation lists the type of plant specific operating experience that needs to be taken into consideration. The operating experience program element criterion was discussed, as well as the NRC review of relevant operating experience.

NEI asked if the SRP could be revised to include more information regarding operating experience reviews. NRC staff is currently updating the SRP and is discussing increasing the information related to operating experience reviews.

b. Use of EPRI Tools NRC staff presented slides discussing the lessons learned and examples with applicants using EPRI Tools (Attachment 4: ADAMS ML092220518). In the first example, an applicant utilized EPRI tools to justify elimination of applicable aging effects from evaluation by only citing EPRI tools. NRC staff indicated that if EPRI tools is used in this manner that the applicant should also provide the technical basis. In the second example, an applicant credited EPRI Tools in the mechanical system operating experience review for aging effects requiring management which is different from the approach described in NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule.

The applicant subsequently conducted a plant specific operating experience review for the period EPRI Tools were previously credited and no new aging effects were identified. The staff indicated that the use of EPRI tools as a substitute for plant specific operating experience must meet Section A.1.2.3.10 of the SRP.

8. Differences/Overlap Between Inspections for Flood Protection for 10 CFR Part 50 Review versus 10 CFR Part 54 Review NEI asked if there could be some overlap between the inspections conducted under 10 CFR Part 50 and those conducted under 10 CFR Part 54 review for opening manhole covers for inspection. NRC staff stated that headquarters and regional offices attempt to coordinate their inspection activities so that the licensee can minimize the opening/closing of manhole covers. NRC staff stated that they are currently improving their inspection procedures and will consider the benefits of coordinating inspections to address this issue.

9. Logistics with Large Audit Team Size The NEI asked why the audit team size has increased in size over the last audits. The NRC stated that the increase in size was a result of training needs. The NRC coordinates the

audit inspections with the licensee including the size of the audit teams. The NRC is also splitting audit inspections so that the team size can be reduced. NEI requested that a detailed schedule be provided if there is a large audit team size so that the licensee can coordinate their staff resources.

10. Status of Buried Piping and Inspection Requirements NEI asked if the NRC could update the NEI on the status of buried piping and inspection requirements related to license renewal. NRC staff stated that they are evaluating the inspection programs and operating experience related to buried piping. The results of the evaluations might impact the next revision of GALL and the inspection programs.

11. New Topics NEI asked if the current position on socket welds has changed. NRC staff indicated that the position remains the same, and is specified in GALL XI.M35. What was quoted from an NEI call summary or conference call transcripts do not form a staff position, and, therefore, should not be interpreted as the staff position. The staff will accommodate further discussion with NEI and the industry if more specific guidance is needed.

12. Public Participation No member of the public provided comments or asked questions at the meeting.

The next meeting is scheduled for Wednesday, October 28, 2009, at 1:00 pm at a location to be determined. There was also a discussion regarding having a meeting every four months instead of every three months.

/RA/

Ian F. Spivack, Engineer Program Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation

Enclosures:

As stated cc w/encls: See next page

ML092220512 (Package), ML092220522 (Summary), ML092220519 (Enclosure 3), ML092220518 (Enclosure 4)

OFFICE PM:RPOB:DLR LA:DLR BC:RPOB:DLR PM:RPOB:DLR NAME ISpivack IKing TTate (DDrucker for)

ISpivack (signature)

DATE 08/17/09 08/14/09 08/20/09 08/20/09

ENCLOSURE 1 Participant List License Renewal Meeting between the U.S. Nuclear Regulatory Commission (NRC) Staff and the Nuclear Energy Institute July 29, 2009 Participant Affiliation Brian Holian NRC Sam Lee NRC David Wrona NRC David Pelton NRC Bo Pham NRC Travis Tate NRC Jerry Dozier NRC Allen Hiser NRC Bob Gramm NRC Matthew Homiack NRC Kim Green NRC David Drucker NRC Raj Auluck NRC Emmanuel Sayoc NRC Evelyn Gettys NRC David Alley NRC Wilkins Smith NRC Albert Wong NRC Elaine Keegan NRC Don Brittner NRC James Shea NRC Daniel Mills NRC Ian Spivack NRC James Medoff NRC Jim Davis NRC John Daily NRC Duc Nguyen NRC Jennifer Davis NRC Bart Fu NRC Jim Isom NRC Rachel Vaucher NRC - (ASN)

Eric Blocher STARS Michael Fallin Constellation Energy Jim Riley NEI Fred Polaski FPL Rick Buckley Entergy Alan Cox Entergy Participant Affiliation Garry Young Entergy Gary L. Stevens Structural Integrity Associates Kathryn Sutton Morgan Lewis Ken Brune TVA Cliff Custer FENOC Gary M. Adkins TVA Loyd Wright SCE / STARS Richard Cliche FPL - Seabrook Ken Putnam FPL - Duane Arnold Gene Eckholt Xcel Energy Massoud Tafazzoli AREVA

ENCLOSURE 2 Agenda License Renewal Meeting between the U.S. Nuclear Regulatory Commission (NRC) Staff and the Nuclear Energy Institute (NEI)

July 29, 2009 Generic License Renewal Topics Lead

1. Generic Environmental Impact Statement Status Update NRC

2. Status of ISG for:

a. Boral in Spent Fuel Pool

b. 2007-01: Process for Interim Staff Guidance

c. 2007-02: Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements

d. 2008-01: Station Blackout Rule Associated with License Renewal NRC

3. 50.59 License Renewal Commitment Wording NRC

4. Status of RIS for:

a. 54.37(b)

b. Giving NRC Advanced Notice of Intent to Pursue License Renewal NRC

5. License Renewal Guidance Documents Update NRC

6. Adequate Information Needed in License Renewal Application When Not Consistent with GALL NRC

7. Discussion on Operating Experience:

a. Operating Experience for New and Existing Programs

b. Use of EPRI Tools NRC

8. Differences/overlap between Inspections for Flood Protection for Part 50 Review versus Part 54 Review NRC

9. Logistics with Large Audit Team Size NEI

10. Status of buried piping and inspection requirements NEI

11. New Topics NRC/NEI

12. Public participation All

ENCLOSURE 3 NRC-Provided Meeting Handouts

ENCLOSURE 4 NEI-Provided Meeting Handouts

Letter to the Nuclear Energy Institute from I. Spivack dated August 20, 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 cc:

Ms. Christine S. Salembier, Commissioner State Liaison Officer Department of Public Service 112 State Street, Drawer 20 Montipelier, VT 05620-2601 Mr. Frederick W. Polaski Manager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348 Mr. Clifford I. Custer Project Manager, License Renewal FirstEnergy Nuclear Operating Company P.O. Box 4 Route 168 (Mail Stop SIM-2)

Shippingport, PA 15077 Mr. Paul Gunter, Director Reactor Watchdog Project Nuclear Information & Resource Service 6930 Carroll Avenue, Suite 340 Takoma Park, MD 20912 Mr. Hugh Jackson Public Citizen's Critical Mass Energy &

Environment Program 215 Pennsylvania Avenue, SE Washington, DC 20003 Mr. Chalmer Myer 40 Inverness Center Parkway P.O. Box 1295 Birmingham, AL 35201 Ms. Mary Olson Nuclear Information & Resource Service Southeast Office P.O. Box 7586 Asheville, NC 28802 Mr. Garry G. Young Manager, License Renewal Services 1448 SR 333, N-GSB-45 Russellville, AR 72802 Ms. Lorrie Bell, Project Manager Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Mr. Roger Stewart Progress Energy Carolinas, Inc.

3581 West Entrance Road RNP A9 Hartsville, SC 29550 Mr. Michael H. Crowthers, Supervisor Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street (GENPL4)

Allentown, PA 18101-1179 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations 440 Hamilton Avenue White Plains, NY 10601