ML18153A368

Requests NRC Staff to Further Consider generic,first-of-a- Kind Efforts Involved in Combined Submittal in Establishing Any Fees Associated W/Review of Topical Rept & risk-informed ISI Submittals.Waiver of Fees Requested

ML18153A368
Person / Time
Site:	Surry
Issue date:	02/09/1998
From:	Liberatori L, Saunders R WESTINGHOUSE OPERATING PLANTS OWNERS GROUP
To:	Sheron B NRC (Affiliation Not Assigned)
References
OG-98-015, OG-98-15, NUDOCS 9802240148
Download: ML18153A368 (3)

Text

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Domestic Utilitie* .

American Electric Power Carolina Power & Light Commonwealth Edison Consolidated Edison Duquesne Light Houston Lighting & Power New York Power Authority Northeast Utilities Northern States Power Pacific Gas & Electric Southern Nuclear Tennessee Valley Authority TU Electric Union Electric Virginia Power International Utilities Electrabel Kansai Electric Power Korea Electric Power Nuclear Electric pie Nuklearna Elektrana Duke Power Public Service Electric & Gas Wisconsin Electric Power Spanish Utilities Georgia Power Rochester Gas & Electric Wisconsin Public Service Taiwan Power Florida Power & Light South Carolina Electric & Gas Wolf Creek Nuclear Vattenfall OG-98-015 February 9, 1998 Dr. Qrian W. Sheron Acting Associate Director for Technical Review Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

References:

1. Letter from Mr. Anthony R. Pietrangelo ofNEI to Dr. Brian W. 'Sheron ofNRC transmitting WCAP 14572, Revision 1 and WCAP-14572, Revision~; Supplement 1, dated October 10, 1997.

2. Letter from Mr. R. F. Saunders of Virginia Electric and Power Company to NRC, "Virginia Electric and Power Company Surry Power Station Unit 1 Risk~Informed Inservice Inspection Pilot Program," Docket No. 50-280, dated October 31, 1997.

3. Letter from Mr. Ronald M. Scroggins, U.S. Nuclear Regulatory Commission to Mr. Stephen D. Floyd, Nuclear Energy Institute, dated May 14, 1996.

4. Letter from Mr. Gordon E. Edison ofNRC to Mr. R. F. Saunders of Virginia Electric and Power Company, "Surry Unit 1 - Risk-Informed Inservice Inspection Pilot Program (TAC No.

MA0125)," dated December 23, 1997.

Subject:

Westinghouse Owners Group Review of Westinghouse Owners Group Topical Report and Surry Unit 1 Risk-Informed Inservice Inspection Submittals Dear Dr. Sheron; The Westinghouse Owners Group recently submitted a revised topical report in Reference 1 and Virginia Electric and Power Company, in cooperation with the WOG, provided a corresponding pilot plant submittal for Surry Unit 1 in Reference 2 to be reviewed by the NRC as an acceptable approach for establishing risk-informed inservice inspection (RI-ISi) programs. This letter requests the NRC Staff to further consider the generic, first-of-a-kind efforts involved in this combined submittal in establishing any fees associated with the review of these documents.

As outlined in Reference 3, the NRC has already waived any fees associated with the review of the WOG.

Topical report. The NRC agreed that the waiver request for this document meets criterion tllJ:ee of Footnote 4 to 10 CFR 170 .21. This footnote states that fees will not be assessed for requests/reports submitted to the NRC ?-S a means of exchanging information between industry organizations and the NRC for the purpose of supporting generic regulatory improvements or efforts. -~ - - --- - --~ -~----

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The Surry Unit 1, or Surry, submittal is tightly integrated with the WOG Topical Report. While the Surry submittal provides plant-specific information on RI-ISi, it also includes generic, first-of-a-kind approaches that will support your planned generic regulatory improvement activities. For example, the NRC recently issued a request for additional information (RAJ) in Reference 4 based on a preliminary review of the Surry RI-ISi pilot program submittal. The staff determined that more information is needed in five areas. While the first area deals with the results of the probabilistic risk assessment (PRA) and pipe failure calculations, responses to the remaming four areas require either generic or first-of-a-kind efforts related to -

• implementation, monitoring, and corrective action programs,

• how the requirements ofNRC draft Standard Review Plan Chapter 3.9.8, Subsection 1.2.1 are addressed dealing with defense-in-depth, adequate safety margins, and associated engineering analyses, and

• required sensitivity studies to address the impact of highly uncertain PRA modeling assumptions and techniques.

The WOG is assisting in the development of appropriate responses to these RAls because this information will set a precedent for owners who decide to embark on RI-ISi programs for their nuclear units following Surry.

Given this interrelationship of the Surry pilot plant submittal to the WOG Topical Report and the first-of-a-kind efforts required to support your planned generic regulatory improvement activities, a waiver of fees to review this submittal is also requested. In particular, we believe that this waiver request for the Surry submittal also meets criterion three of Footnote 4 to 10 CFR 170.21. Additionally, we believe the Surry submittal meets criterion two of Footnote 4 to 10 CFR 170.21 where information is being provided to assist the NRC in developing a regulatory guide. The information, approaches, and results from Surry will assist the NRC in finalizing draft DG-1063 and its companion Standard Review Plan Chapter 3.9.8.

We appreciate your consideration of this request, and we would be pleased to further discuss this matter with you by telecon or by meeting, as required.

Please direct any questions or comments to either of us. Mr. Liberatori can be reached at 914-734-567 6 and Mr. Saunders can be contacted at 804-273-2101.

Very truly yours, Louis F. Liberatori, Jr., Chairman Robert F. Saunders, Vice President Westinghouse Owners Group Nuclear Engineering and Services Virginia Electric and Power Company 980G015.DOC

WOG..:98-015*

February 9, 1998 cc: Mr. Samuel J. Collins Mr. Joseph Callan Dr. Goutam Bagchi Dr. Syed Ali Mr. Gary Holahan Mr. Ashok Thadani Mr. Gus Lainas Mr. Ronald M. Scroggins Mr. Gordon Edison Mr. Ralph Beedle, NEI Mr. Tony Pietrangelo, NEI Mr. BiffBradley, NEI Mr. Ernie Throckmorton, Virginia Power Mr. James McCarthy, Virginia Power WOG Steering Committee WOG Materials Subcommittee WOG Risk-Based Technology Working Group M.M. DeWitt - BCE 5-36 N.J. Liparulo - BCE 4-15 S.D. Rupprecht- BCE 4-16 AP Drake - BCE 5-16 H.A. Sepp - BCE 4-07A J. Bastin - Rockville Nuclear Licensing Center 980G015.D0C