ML17257A299
| ML17257A299 | |
| Person / Time | |
|---|---|
| Issue date: | 09/29/2017 |
| From: | Bennett Brady NRC/NRR/DLR/RPGB |
| To: | Stuchell S NRC/NRR/DLR/RPGB |
| Brady B, NRR-DLR 415-2981 | |
| Shared Package | |
| ML17257A298 | List: |
| References | |
| Download: ML17257A299 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 29, 2017 MEMORANDUM TO: Sheldon Stuchell, Chief Projects Management and Guidance Branch Division of License Renewal Office of Nuclear Reactor Regulation FROM: Bennett Brady, Senior Project Manager /RA/
Projects Management and Guidance Branch Division of License Renewal Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF PUBLIC MEETING TO DISCUSS NRC STAFFS COMMENTS ON NEI 17-01, INDUSTRY GUIDELINE FOR IMPLEMENTING THE REQUIREMENTS OF 10 CFR PART 54 FOR SUBSEQUENT LICENSE RENEWAL On August 24, 2017, the U.S. Nuclear Regulatory Commission (NRC) held a Category 2 public meeting with stakeholders to discuss the NRCs staff comments on the Nuclear Energy Institutes (NEIs) NEI 17-01, Industry Guideline for Implementing the Requirements of the Title 10 of the Code of Federal Regulations (10 CFR) Part 54 for Subsequent License Renewal, Revision 0. NRC provided comments with the intention that the comments will be incorporated into a revision of the industry guidance. If a revised NEI 17-01 is submitted and the NRC staff finds it acceptable for use by licensees, the NRC intends to update, Regulatory Guide (RG) 1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, Revision 1.
Meeting Summary At the beginning of the meeting, NRC reviewed the steps to revise and issue RG 1.188, Revision 2. The NRC staff then described the development of their comments on NEI 17-01 (ADAMS Accession No. ML17228A684), including binning them, first, according to their significance in meeting the requirements of 10 CFR Part 54 and, second, in terms of providing acceptable aging management programs (AMP) and activities. The NRC staff also gave examples of comments that might be useful to readers of NEI 17-01.
CONTACT: Bennett Brady, NRR/DLR/ RPGB 301-415-2981
S. Stuchell Comments on statements considered inconsistent with 10 CFR Part 54:
- Applicants cannot delay until some later time in the subsequent period of extended operation a technical rationale that demonstrates that the current licensing basis (CLB) will be maintained.
- Although an applicant may be able to demonstrate that it is not possible for an aging effect to result in a loss of the structures and components intended function(s), however the applicant must still manage the aging effect.
- The technical information in an application must contain and justify the methodology used for scoping and screening components into aging management reviews.
- An applicant cannot elect to defer completing the evaluation of a time-limited aging analysis (TLAA) until after submittal of the subsequent license renewal application (SLRA).
Comments that identify additional information necessary for applications, AMPs, and TLAAs
- AMPs should be enhanced when operating experience indicates that the effects of aging may not be adequately managed.
- If an applicant is taking an exception to a GALL-SLR AMP, the applicant needs to provide a justification on why the applicants modified program, with respect to the identified exception or exceptions, is sufficient to maintain the CLB.
- The initial submittal must contain sufficient information necessary for the NRC staff to complete its review, which could necessitate including specific portions of supporting documentation information in the SLRA.
Example of suggestions that may be useful for applications, AMPs, and TLAAs
- The reference to the pressurized thermal shock (PTS) rule should also reference the alternate PTS rule, 10 CFR 50.61a
- Remove reference to 71002 inspections as NRC will not be conducting 71002 inspections for subsequent license renewal.
- Section 4.7 of NUREG-2192 (SRP-SLR) provided an expanded list of potential plant-specific TLAAs. For plant-specific TLAA discussion in NEI 17-01, NEI should consider making the list of potential plant-specific TLAAs consistent with those in Table 4.7-1 of the SRP-SLR report.
- Include more detailed discussion of operating experience (OE) and enhancements of the AMP due to OE in the discussion of each AMP, for example, instances where OE has demonstrated that AMPs were not effective during the PEO.
- Consider adding criteria that would call for the SLRA to be peer reviewed by other licensed utilities or in combination with an industry organization.
The attendees agreed that another meeting to discuss license renewal topics should be held in October or later.
S. Stuchell Public Comments:
A comment was provided from a member of the public participating via teleconference on past events at nuclear power plants that was not related to the meetings discussion of draft documents for SLR.
Participants List:
Name Affiliation George Wilson Nuclear Regulatory Commission (NRC)
Joe Donoghue NRC Sheldon Stuchell NRC Bill Rogers NRC Allen Hiser NRC Theresa Buchanan NRC Bennett Brady NRC James Medoff NRC Carol Moyer NRC Albert Wong NRC Mitzi Young NRC Bill Holston NRC Angela Buford NRC Heather Jones NRC James Gavula (via teleconference) NRC Evelyn Gettys NRC Jerud Hanson Nuclear Energy Institute (NEI)
Paul Aiken Dominion John ORourke PSEG Nuclear Jana Bergman Curtis Wright Steve Franzone FPL/NextEra Albert Piha Exelon Craig Heah Dominion Steven Burdick Morgan Lewis Fred Polaski Polaski Consulting Marvin Lewis (via teleconference) Self
ML17257A298 Meeting Summary ADAMS Accession No. ML17257A299 NRC Presentation ADAMS Accession No. ML17243A006 *concurrence via e-mail OFFICE PM:DLR:RPGB LA:DLR:RPGB BC:DLR:RPBG PM:DLR:RPGB NAME BBrady YEdmonds SStuchell BBrady DATE 9/14/2017 9/26/2017 9/7/2017 9/29/2017