ML19346E706

Forwards Responses Received to 11 Questions Contained in FRN for 930930 License Renewal Workshop

ML19346E706
Person / Time
Issue date:	02/09/1994
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Rogers, Selin I, The Chairman NRC COMMISSION (OCM)
References
TAC-M93122, NUDOCS 9402280212
Download: ML19346E706 (2)

Text

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February 9, 1994 MEMORANDUM FOR:

The Chairman Comissioner Rogers Comissioner Remick Comissioner de Planque FROM:

James M. Taylor Executive Director for Operations t

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SUBJECT:

RESPONSES TO LICENSE RENEWAL WORKSHOP FEDERAL REGISTER NOTICE QUESTIONS (WITS 9400012)

Reference:

M931222 i

The Staff Requirements Memorandum dated January 12, 1994, asked the staff to e

send the Comission the responses received to the 11 questions contained in the Federal Reaister notice (58 FR 42987) for the September 30, 1993, license renewal workshop. The staff received responses to the questions from the following organizations:

1.

Yankee Atomic Electric Company (letter dated October 8, 1993) l 2.

Nuclear Management Resources Council (letter dated October 12,1993) 3.

Department of Energy (letter dated October 12,1993)

Copies of these letters and the applicable enclosures containing the responses i

l to the questions are Enclosures 1, 2, and 3 to this memorandum.

James M. Taylf/ 9magg by

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l FYC 93-022 S?S93-097 Mr. Samuel J. Chilk Secretary l

United States Nuclear Regulatory Commission Washington, DC 20555 Attention:

Docketing and Service Branch

Subject:

Yankee Atomic Electric Company C:mments on a Public Workshop to Evaluate Alte native Approaches fcr License Renewal (5SFR42987)

Dear Mr. Chilk:

Yankee Atomic Electric Company apprecia:cs the opportunity to provide comments on alternative approaches for license renewal in the anticipation that it will contribute to the basis for modification and improvement of the current license renewal rule. Yankee owns the nuclear power plant in Rowe, Massachusetts and our Nuclear Services Division j

provides engineering and licensing services to other nuclear plants in the northeast including: Vermont Yankee, Yankee, and Seabrock. Yankee was the lead pressurized water reactor in the original DOE /EPRI lead plan: program for license renewal. As a result of our extensive experience in this original e5crt and our continued active involvement in industry and regulatory interactic=s on these issues, we believe we bring a unique perspective on how to materially improve de process of renewinglicenses while at i

the same time assuring public health and safety.

I As stated in the Yankee presentation at the public workshop on September 30, we believe that the License Renewal Rule must be revised to accommodate developments that have occurred since the original rule was publishei Most notable of these is the enactment of the Maintenance Rule which constitutes the regulatory basis for substantive refocusing of the License Renewal Rule. Explicit ecognition that the renewed license, as contemplated by the Atomic Energy Act, is a renewal not a new license and the great difficulty experienced in attempting to implement.he rule as a result of some of the j

definitions it contains, notably Age-Related Degra:iation Unique to License Renewal (ADRUTLR), form the basis of our recommended :hanges.

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ENC 1.0SURE 1

Mr. Samuel J. Chilk October 8,1993 Attention: Docketing and Service Branch Page 2 At the September Workshop, Yankee proposed a simplified and focused approach to the license renewal process which directly addresses these issues and centers on evaluation oflong-lived passive components (equipment or structures) that provide a safety function but which may require additional evaluation or monitoring for the renewal period or may not be adequately bounded by an analysis which had previously been used tojustify their operational life. Development of the rational for an alternative approach to the rule is provided in Attachment 1 to this letter, " Recommendations for Modifications to the License Renewal Rule." Attachment 2 details a specific rule formulation implementing that approach. Attachment 3 discusses the proposed approach in responses to the questions posed in the Federal Register Notice regarding the license renewal workshop.

While we recognize that our proposal goes beyond what NUMARC is recommending, we feel that it makes clear and unambiguous the requirements for renewal without having to interpret words that may have different meanings to different people at different times. The goal of the license renewal rule should be to establish clear criteria for renewal such that the process is well understood, stable and free from uncertainty in regulatory implementation. We believe our suggested rule meets these objectives since it builds on existing regulatory requirements and oversight in the assurance of public health and safety.

Based on the acknowledged difficulty in understanding and implementing the current license renewal rule, and the opportunity presented by passage of the maintenance rule to fix the license renewal rule, we hope the Commission will correct rather than band aid the current rule for the benefit of all licensees for the long term. We believe that the enclosed recommendation does so in a safe, uncomplicated, clear and cost-effective way.

Very truly yours

'J. kV. Edwards Director, Industry Affairs Attachments c:

T. E. Murley W. D. Travers i

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j YANKEE ATOMIC ELECTRIC COMPAhT ATTACHMENT 3 NUCLEAR REGULATORY COhD11SSION LICENSE RENEWAL WORKSHOP QUESTIONS 1.

Will the approach be consistent with the principles oflicense renewal as discussed in the Statement of Considerations for the 6nallicense renewal rule? Will the approach preserve a logical distinction between those age-related degradation issues suitable for license renewal review and other safety issues considered to be adequately addressed by the normal regut ry oversight pmcess for operating reactors?

The principles oflicense renewal in the statement of considerations i

emphasize continuity of plant operation. This approach relies fundamentally on these principles by overt recognition that current programs adequately manage aging degradation. Further, any new phenomenon that may cause deleterious effects at any time in the future will be addressed by the Maintenance Rule provision for corrective action (actually part of Appendix B but which has been incorporated into the 1

Maintenance rule). The notion of some unique age related degradation that may only appear in the renewal period is a bazaar principle upon which to base regulation. The current regulatory process is certainly

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adequate to assure public protection during the renewal period, and the l

individual licensing basis must necessarily continue into the renewal period.

Only the issues associated with continued performance of certain long. lived, passive components would be reviewed for the renewal term. All other issues would continue to be addressed by the individual licensing basis of the plant and the normal oversight process currently in place.

2.

Will the proposed license renewal approach maintain the current licensing basis (CLB)?

The proposed approach is dependant upon the current licensing basis as the primary means of assuring adequate protection of public health and safety in the future as is the case for the current license term. All current f

provisions of the license are proposed to continue into the renewal period.

3.

Is the concept of age-related degradation unique to license renewal, as discussed in the Statement of Considerations for the final license renewal rule, a useful regulatory concept? Should it be eliminated?

The definition of age related degradation unique to license renewal has been at the root of many of the problems with the current rule. Attempts to l

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YANKEE ATOMIC ELECTRIC COMPANY ATTACHMENT 3 NUCLEAR REGULATORY COMMISSION LICENSE RENEWAL WORKSHOP QUESTIONS (Continued)

'T define it rationally have been unsuccessful because it has no physical meaning. The definition merely causes confusicn by introducing the specter of some unknown aging phenomenon that could exist and should be deleted.

Aging phenomena are adequately addressed via a number of maintenance techniques from the start of plant life. Passive long-lived equipment which l

will remain in place during the entire operational life of the facility may need to be addressed in the context of the existing analyses which have enabled their continued use during the initial term. Any necessary monitoring or testing should be identified as augmentation of existing maintenance programs.

4.

For any proposed approach, what standard (e.g.,10 CFR 54.29) do you proposed the NRC apply for issuing a renewed license?

The finding should be based on the principles of the rule and a review by the licensee and appropriate correction of any assumption or condition of the current license which is dependant upon the 40-year license term such that:

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'There is, based on the agency's evaluation of the application and the result of any audit deemed necessary, reasonable assurance that syste ns will perform their required safety function (s) during the renewal penod and that changes made to the plant's current licensing basis in order to comply with this paragraph are otherwise in accord with the Act and the Comminsion's regulations."

1 To grant a renewal license, there is no need for additional engineering analysis to show that current practices, which are entirely acceptable for assuring equipment performance now, will be adequate for the future (same equipment - same desired performance) 5.

How does the proposed approach consider existing licensee programs that help assure acceptable performance or condition of systems, structures and components?

Existing licensee programs are the means by which acceptable performance s

and condition of systems and their constituent components (structures and'or equipment)is assured. These programs, " performance monitoring" 2-causa w

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k YANKEE ATOMIC ELECTRIC COMPANY l

ATTACHMENT 3 i

NUCLEAR REGULATORY COMMISSION LICENSE RENEWAL WORKSHOP QUESTIONS (Continued) programs for the purpose of the revised approach, are in place to provide exactly that assurance now.

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How is the maintenance rule relied on in the proposed approach? Does the scope of the license renewal rule need to be the same as that of the maintenance rule?

The maintenance rule, which will be part of the body oflicensing regulations for all facilities, assures that the performance or condition of l

important systems will not degraded below en acceptable level at any time during plant operation, including operation during any renewal term.

l The comprehensive scope of the maintenance rule covers all safety i

significant systems and other that aren't. There can be no distinction between systems that are important from a safety standpoint in the original l

license period and those that are important for the renewal period. The l

artificial grouping created for license renewal serves only to create a distinction when none should be made.

v 7.

How does the proposed approach reduce uncertainty and promote stability? If areas of uncertainty cr instability remain, how should they be addressed?

The major uncertainty in the present rule is the attempt to implement a dermition (ARDULR) which has no physical reality, use of a uniquely dermed scope that is essentially duplicative of the maintenance rule but j

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defmed differently, and the potential of turning the performance based i

maintenance rule into a prescriptive set oflicense conditions through the IPA process. The proposed approach removes these areas of uncertainty l

and promotes stability by clarifying the fact that the safety of the plants today is maintained by the existing practices and these are to continue, l

augmented by any additional measures that are found necessary from the review. It also recommends that the above concept be imbedded into the SOC.

8.

Would the proposed approach alter other aspects of the finallicense renewal rule, such as content or description of an effective program, contents of a license renewal application, or continuing reporting requirements?

The proposed approach alters the fmal license renewal rule by focusing down to only the significant issues for long lived passive equipment.

I Reporting under the concept of continued operation should continue the i

same as it is now under current practice. crsua 9

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YANKEE ATOMIC ELECTRIC COMPANY ATTACHMENT S l

NUCLEAR REGULATORY COMMISSION LICENSE RENEWAL WORKSHOP QUESTIONS (Continued) 9.

Is the concept of

• fundamental safety importance" as discussed in SECY 93-113 appropriate? Will the proposed approach result in the imposition of regulatory requirements for plant structures or components that are not of" fundamental safety importance?"

No. The proposed approach, however, actually uses the notion of -

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" fundamental safety imporence" by recognizing that a few mgjor components have high visibility, are very safety significant, and, thus, warrant reconfirmation of the adequacy of their performance.' The reactor vessel m. J the containment fall in this category.

10.

Does the proposed approach incorporate consideration of"like-kind" replacemert?

If so, would the term "like-kind" be interpreted with respect to structures and components which are replaced such that they will not experience a service life

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greater than 40 years during the renewal term?

1 Replacement practices are admini*tered by pmgrams implemented under the maintenance rule and, as such, have no place in the discussion of license renewal.

11.

How does the proposed approach consider refurbishment? What is a definition of refurbishment? How should guidelines be established to ensure that the concept of l

" refurbishment" is consistently applied in the implementation of the proposed i

approach to license renewal?

See answer to 10 above.

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(202)572-1280 wimom n sosin Bee Rescent & Drector October 12,1993 hir. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTENTION:

Docketing and Service Branch i

SUBJECT:

Notice of Public Workshop (58 Fed. Rec. 42987k August 12.1993

Dear hir. Chilk:

On behalf of the nuclear industry, Nuclear hianagement and Resources Council (NUhiARC)' is pleased to provide its written comments on matters covered in the h7C's public workshop on license renewal, including responses to the questions set out in the August 12,1993, Federal Register notice (58 Fed. Reg. 42987) announcing the workshop. The industry appreciates the NRC staffs efforts to address the concems that I

have arisen regarding the license renewal rule. Resolution of these concerns is very important for utility planning, decision-making and license renewal implementation.

As discussed by the NUhiARC and industry representatives at the workshop, the industry believes that changes to the license renewal rule are necessary for a stable and predictable regulatory process. The industry continues to support the basic principles of I

the license renewal rule, and the concept of" age-related degradation unique to license IbuiARC is the organization of the nuclear power industry that is responsible for coordinating the combined effons of all utilities licensed by the h*RC to construct or operate nuclear power plants. and of other nuclear industry organizations. in all matters im ohing generic regulatory policy issues and on the regulatory aspects of generic operational and technical issues affecting the nuclear power industry. Estry utility responsible for cr>nstructing or operating a commercial nuclear power plant in the United States is a member of huiARC. In addition. hu! ARC's members include major architect / engineering firms and all of the major nuclear steam supply system vendors.

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r;, f, i ENCLOSURE 2

Mr. Samuel J. Chilk October 12,1993 Page 2 renewal"(ARDUTLR). However, the industry has through extensive experience attempting to implement the rule determined that the definition of ARDUTLR and cenain aspects of the Integrated Plant Assessment process need to be changed to make license renewal the focused process that the Commission intended.

Enclosure I to this letter focuses upon the industry's proposed amendment to the current definition of ARDUTLR,10 CFR { 54.3, and discusses the basis for the industry's proposed modification. In addition, Enclosure I describes the industry's l

approach to the integrated plant assessment process,10 CFR f 54.21, and recommends l

that f 54.21(a)(5) be amended in order to accommodate the ARDUTLR modification.

l responds to the questions posed in the FederalRegister notice.

1 1

The industry intends to supplement the information contained in these attachments by providing the NRC with significantly more detail supponing its comments in November. We expect that the document to be submitted in November will contain a complete proposal identifying all necessary amendments to Pan 54, including amendments addressing documentation and commitments, and an extensive discussion of the bases and support for all recommended modifications.

NUMARC would be pleased to discuss with the NRC the industry's proposed approach to license renewal and to respond to any specific questions regarding the industry's recommendations for modifications of the license renewal rule.

Sincerely,

. / h d C,L A S f

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William H. Rasin WHR/ECG:bjb Enclosures i

l Mr. Samuel J. Chilk r

October 12,1993 Page 3 t

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Chairmain Ivan Selin f

Commissioner Kenneth C. Rogers Commissioner Forrest J.Remick f

Commissioner E. Gail de Planque j

James M. Taylor, Executive Director for Operations Dr. Thomas E. Murley, Director, NRR j

1 Dr. William D. Travers, Deputy Associate Director for Advanced Reactors & License Renewal i

William C. Parler, Esq., General Counsel l

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9 ENCLOSURE 2 1.

Will the approach be consistent with the principles oflicense renewal as discussed in the statement of considerations for the final license renewal rule?

Yes. The indus~try's proposed approach to and revisions of Pan 54 are consistent with the two fundamental principles identified in the Statement of Considerations

(" SOC") accompanying 10 CFR Pan 54. The industry strongly believes that the two l

principles are sound and any revisions to Part 54 should be consistent with these l

principles.

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l As stated in the SOC accompanying the current license renewal rule, the first principle is that, with the exception of age-related degradation unique to license renewal and possibly some few other issues related to i

safety only during extended operation, the regulatory process is adequate to ensure that the licensing bases of all currently operating plants proiide and maintain an acceptable level of safety for operation so that operation will not be inimical to public health and safety or common defense or security.

This principle singles out age-related degradation unique to license renewal as that which should be reviewed for the period of extended operation. It recognizes that aging is ongoing throughout the first 40 years and that such aging is adequately managed by the combination of existing licensee programs and the NRC's regulatory oversight processes.

It also identifies the Commission's conclusion that the NRC's regulatory oversight processes will continue into the period of extended operation and, therefore, will continue to ensure that plants operating during the renewal term will meet the same standard of reasonable assurance as they are required to meet during the current license term.

The industry's proposed approach clearly adheres to the first principle. The approach identifies SSCs ITLR which could have ARDUTLR by focusing the definition of ARDUTLR on that degradation which is " unique" to the period of extended operation.

Under the industry's proposed approach, degradation of an SSC is considered unique if existing programs would be insufficient to prevent loss of an S5C's ITLR function such that plant operation would not be in accordance with the current licensing basis (CLB) during the period of extended operation.

Further, the industry's proposed approach recognizes that regulatory processes contribute to the maintenance of an adequate level of safety both in the current term and m the renewal term. The industry's proposed approach relies upon the staffs implementation ofits license renewal responsibility in a manner consistent with the

Commission's view that current regulatory processes are sufficiently broad and rigorous l

to ensure the public health and safety during the period of extended operation.

The second principle oflicense renewal identified in the Statement of Considerations for the final rule requires that "each plant's current licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the original licensing term." The industry's proposed approach also clearly adheres to this principle. The industry strongly believes that this principle mandates that credit be given to existing programs and activities because they provide reasonable assurance that the performance and condition of SSCs ITLR will be maintained during the term of extended operation in accordance with the CLB.3 As noted, the industry's proposed definition of ARDUTLR reflects the principle that existing programs are adequate to manage the effects of aging in most circumstances by defining ARDUTLR as degradation which could occur notwithstanding the application of existing programs, and the consequence of l

which is that the plant's operation would not be in accordance with the CLB during the period of extended operation.

1(a). Will the approach preserve a logical distinction between those age related degradation issues suitable for license renewal review and other safety issues l

considered to be adequately addressed by the normal regulatory oversight process for operating reactors?

Yes. See above.

2.

Will the proposed license renewal approach maintain the current licensing basis?

l Yes. The industry's proposed approach ensures that the CLB is maintained. He l

industry's proposed definition defines ARDUTLR as degradation to SSCs ITLR the effects of which, notwithstanding the application of existing programs during the period of extended operation, result in loss ofITLR function such that plant operation is not in accordance with the CLB during the period of extended operation. Any SSC determined to be subject to ARDUTLR would be subject to a review of whether an effective taogram review is needed.

3 With respect to most SSCs ITLR, monitoring performance or condition to cornply with the CLB is an efreetive means to detect degradation. The industry's considerable experience with performance and condition monitoring provides a reasonable basis to con:lude that the SSCs covered by such programs and activities will continue to perfor n their intended function during the period of extended operatiert 2

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Under the proposed industry approach, existing programs and activities currently employed to maintain the CLB will continue into the period of extended operation. The industry's proposed defmition of ARDUTLR permits credit to be taken for maintenance rule activities, replacement and refurbishment activities, and other existing programs and activities because the objective and effect of all of these is to maintain the CLB. Thus, under the industry's proposed approach, with the exception of passive, long-lived SSCs that meet pan (a) of the defmition, SSCs ITLR covered by any these three actisities will be deemed not to be susceptible to ARDUTLR. The Commission recognized the value of l

such an approach in its June 28,1993 memorandum to the NRC stafT:

Based upon the agency's experience with currently operatmg reactors, i

the Commission believes that it is appropriate to allow license renewal applicants to rely to a considerable extent on existing activities and programs l

to ensure that a plant will continue to operate safely during the extended period of operation. Such activities and programs, including periodic replacement and refurbishment programs, have proven effective in managing aging during the l

initial license tenn and, hence can serve as a basis for concluding that aging for l

many components, particularly short-lived components, will be effectively managed during the renewal term,if these programs are simply continued for the period of extended operation. For this reason, the Commission wishes to ensure that such activities are given maximum credit where appropriate.

We would emphasize that the concept of the CLB, which is used as the regulatory basis upon which the NRC determines whether a plant is operating in conformance with regulatory requirements and docketed commitments, is evolutionary in nature. The CLB evolves as generic as well as plant specific issues are addressed. Its evolutionary nature has made it a successful regulatory tool-one which can be expected to continue to ensure that aging effects on structures and components will be adequately addressed.

3.

Is the concept of age-related degradation unique to license renewal, as l

discussed in the SOC for the final license renewal rule, a useful regulatory concept? Should it be eliminated?

The concept of age-related degradation unique to license renewalis a reasonable regulatory concept, but its value has been eviscerated by its dermition in the current rule.

The definition in the current license renewal rule forces almost every structure and component imponant to license renewal to be declared by the applicant to be subject to ARDUTLR. While the continued use of the concept of ARDUTLR is supponed by the industry,it is only supponed in conjunction with the industry's revised dermition of the concept. The industry's defmition focuses ARDUTLR on aging that, notwithstanding existing measures, would compromise compliance with the CLB during the period of 3

extended operation. However, it permits (as the Commission intended but the current rule impedes) the applicant to limit the scope of SSCs on which aging assessments must be performed to those necessary to maintain the CLB during the period of extended operation.

4.

For any proposed approach, what standard (e.g.,10 CFR 54.29) do you propose the NRC apply for issuing a renewed license?

The industry currently believes tlia: the standard contained in 10 CFR 54.29 is appropriate and should be retained.

5.

How does the proposed approach consider existing licensee programs that help assure acceptable performance or condition of systems, structures and components?

l The industry's proposed approach would allow applicants to take credit for existing programs if the programs reasonably assure the ITLR function in accordance

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with the CLB during the period of extended operation. Thus, the applicant could disposition the SSCs covered under those programs and activities as not susceptible to ARDUTLR. The industry's proposed approach involves a functional evaluation which we believe is far more effective and practical thar. the mechanistic approach currently embodied in the rule. The approach reflects the industry's belief that if SSCs are covered by the maintenance rule, by replacement and refurbishment activities based upon time or condition, or by mandated regulatory or other existing programs, such programs or activities preclude a structure or component from experiencing ARDUTLR.

6.

How is the maintenance rule relied on in the proposed approach? Does the scope of the license renewal rule need to be the same as that of the i

maintenance rule?

Under the industry's proposed approach, the maintenance rule is directly credited in the definition of ARDUTLR as sufficient to reasonably assure ITLR functions of l

SSCs, other than certain passive, long-lived SSCs, such that the CLB will be maintained j

during period of extended operation. Thus, SSCs ITLR covered under the maintenance rule would t deemed not to be susceptible to ARDUTLR.

l The scope of the license renewal rule does not need to be the same as that of the l

maintenance rule.

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The industry believes that the Commission, in its June 29,1993 memorandum to the staff, in essence, required that an approach which relies upon the maintenance rule be considered. Therein, the Commission stated:

For activities such as those that fall within the scope of the maintenance rule which will become effective in 1996, it is implicit that they have the objective of maintaining the functionality of SSCs as set forth in the CLB. As with our other regulations and regulatory requirements, the maintenance rule need not explicitly reference the CLB to accomplish that purpose.

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7.

How does the proposed approach reduce uncertainty and promote stability?

L If areas of uncertainty or instability remain, how should they be addressed?

The industry's proposed approach reduces uncenainty and stability through suggested modifications to key provisions of the final license renewal rule.

The industry's proposed approach would reduce substantially or eliminate l

uncertainty and stability through the proposed amendment to the definition of ARDUTLR. The industry's proposed approach provides regulatory cenainty by identifying, through the application of specific obiective criteria, those SSCs v Geh must l

be reviewed for ARDUTLR and those which are detennined not to be subject to ARDUTLR. This will allow applicants to determine with a high degree of cenainty and consistency those SSCs ITLR that could be subject to ARDUTLR. For those long-lived passive components meeting the definition's criteria, an analysis pursuant to 10 CFR 54.21 (a)(4)-(a)(6) as applicable would be performed. This approach essentially limits funher evaluation to those long-lived passive SSCs and those SSCs not covered by the maintenance rule, replacement and refurbishment activities or other existing programs.

Another area where the industry's proposed approach is intended to provide greater cenainty and stal ility is the level of detail required for license renewal. Under the current rule, the IPA and all other elements of the license renewal application must be included in the FSAR supplement. The industry believes that this is neither necessary nor consistent with current NRC practice.

The industry believes that the IPA and the FSAR supplement should be different documents - with appropriately different focuses. The proposed approach would require that the information and analyses contained in the IPA would be that necessary to demonstrate that the CLB will be maintained during the period of extended operation.

The FSAR supplement would contain the results and conclusions of the IPA, although 5

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including descriptions of the effective programs, in order to establish an appropriate level of commitment. To accomplish this, certain changes would be required.

i Finally, the industry's approach will reduce uncertainty by making clear that l

evaluations performed on SSCs identified by Pan (a) of the proposed def~mition of i

ARDUTLR should focus on the effects of ARD, independent of specific mechanisms. In this way, inspection and surveillance activities which result in corrective action based on degraded condition can be appropriately credited as precluding ARDUTLR. The considerable experience with such programs demonstrates that SSCs covered by such programs will continue to perform their intended function and maintain the CLB.

'Ihe industry believes that its focus on effects is technicallyjustified and consistent with recent recommendations by NRC staff. In the SECYs issued earlier this year, the staff recognized that it is appropriate to focus on effects. In light of the importance of appropriately focusing the rule on aging effects, and the staffs concunence with that focus, the industry's proposed approach would modify the rule to make clear that where performance or condition monitoring is sufficient to mitigate the efTects of ARDUTLR, it i

i is not necessary to identify or evaluate degradation mechanisms.

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8.

Would the proposed approach alter other aspects of the finallicense renewal rule, such as content or description of an effective program, contents of a

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license renewal application, or continuing reporting requirements?

1 Yes. See answer to question 7.

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9.

Is the concept of" fundamental safety importance" as discussed in SECY 93-113 appropriate? Will the proposed approach result in the imposition of regulatory requirements for plant structures or components that are not of

" fundamental safety importance"?

At this juncture, this concept has not been incorporated into industry's approach.

4 10.

Does the proposed approach incorporate consideration of"like-kind" j

replacement? If so, should the term "like-kind" be interpreted with respect j

to structures and components which are replaced such that they will not experience a service life of greater than 40 years during the renewal term?

i The proposed approach excludes from funher review of ARDUTLR those SCCs which are replaced based on time or condition in accordance with the CLB. Replacement l

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l in this context is the same as under CLB and generally means replacement with a component of equal or greater quality, subject to controls established by 10 CFR 50.59.

Limiting replacement to identical *like-kind" substitutions is overly restrictive and could induce licensees to use original design components when better ones have become available.

11.

How does the proposed approach consider refurbishment? What is a definition of refurbishment? How should guidelines be established to ensure that the concept of" refurbishment" is consir,tently applied in the implementation of the proposed approach to license renewal?

Th' industry's proposed approach allows the applicant to take credit for refurbishment activities based upon time or condition. SSCs subject to such refurbishment would be deemed not to be susceptible to ARDUTLR.

i Refurbishment in this context generally means actions to restore a degraded SSC to an acceptable condition ia accordance with the CLB. Specific guidelines need not be established beyond those reflected in the CLG to ensure consistent application of the refurbishment concept. The NRC's regulatory oversight is sufficient to ensure consistent application of the concept in the implementation of Part 54.

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93 C 12 P3 :C9 i

7 s Cctober 12, 1993 t

Mr. Samuel J. Chilk Secretary of the Commission t

U.S. Nuclear Regulatory Commission

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l Washington, D.C.

20555 l

f ATTN: Docketing and Service Branch f

Dear Mr. Chilk:

l The U.S. Department of Energy is pleased to submit comments to the Nuclear Regulatory Commission on the License Renewal Public Workshop, as published in 58 Federal Register 42987-90 (August 12, 1993), on developing the basis for concluding that the effects of l'

aging will be managed during the extended period of operation.

In particular, responses were solicited to 11 questions related to the extent to which greater reliance can be placed on the maintenance rule and existing licensee programs and the essential l

elements that must be incorporated into the final license renewal process.

The Department responses to the workshop issues and questions are included in two separate enclosures. Enclosure 1 contains the responses to the workshop 11 questions, while Enclosure 2 specifies the sections of the license renewal rule to be amended i

and sets forth the proposed text. Enclosure 2 provides a concise statement of the Department's interest in the recommended i

rulemaking in Section I; Section 11 sets forth the specific issues l

involved, the Department's views and justifications with respect to those issues, and the relevant data and information supporting the amendments; and Appendix A " red-lines" the affected sections.

l The Department believes that modifications to the Rule as suggested in the enclosures will lead to a more predictable, stable, and efficient licensing process.

he ENCLOSURE 3

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We would be pleased to. discuss this matter with you further and if there are any questions, please contact Dennis Harrison at l

l 301-903-2884.

Sincerely,

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'E. C. Brolin re l

Acting Director 1

Office of Nuclear Energy 2 Enclosures t

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ENCLOSURE 1 l

DEPARTMENT OF ENEAGY LICENSE RENEWAL WORKSHOP QUESTION RESPONSES j

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ENCLOSIrRE I DEPARTMENT OF ENERGY LICENSE RENEWAL' WORKSHOP QUESTION RE20NSES QUESTION 1A Will the approach be coa:!ctent with the principles of licensk renewal as j

discussed in the SOC for the final license renewal rule?

i ANSWER 1A:

1 The first principle states, "with the exception of age-related degradation unique to license renewal and possibly some few other issues related to safety only during extended operation, the regulatory process is adequate to ensure that the licensing bases of all currently operating plants provide and i

maintain an acceptable level of safety for operation so that the operation will not be inimical to public health and safety or common defense and security." The proposed approach also focuses on age-related degradation anique to license rent sal as the one issue which is applicable to all plants.

The approach recognizes the role of the regulatory process as ensuring that the current licensing cases for all plants will continue to provide and maintain an adequate level of safety. Specifically, some regulatorily.

prescribed programs preclude a structure or component from experiencing age-related degradation unique to license renewal (ARDUTLR). Where these programs exist, the approach relies on the established regulatory process to ensure that the current licensing basis (CLB) is maintained.

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The second principle states that "each plant-specific current licensing basis must be maintained during the renewal tem in the same manner and to the saac extent as during the original licensing term." The second principle continues to be maintained under the proposed approach. The same provisions contained in the final license renewal rule continue to ensure adherence to the licensing basis (i.e., 654.22, 654.33(d), 654.37(b), 654.37(c), 554.33(e)).

These provisans, together with the continuation of the Nuclear Regulatory Commission's (NRC) regulatory oversight program, and the implementation of activities to manage any identified ARDUTLR will ensure that the CLB will be maintained throughout the term of the renewed license in the same manner and to the same extent as during the original term.

l QUESTION IB:

Will the approach preserve a logical distinction between those age-related degradation issues suitable for license renewal review and other safety issus considered to be adequately addressed by the normal regulatory oversight process for operating reactors?

MSWER IB:

The Department of Energy (Department) approach continues to preserve a logical distinction between those age-related degradation issues suitable for license renewal revi.w and other safety issues consistent with the Statement of Considerations (SOC) accompanying the Final License Renewal Rule. Namely,

2 issues that are relevant to both current plant operation and oceration during the extended period must be addressed within the present licensing term rather than at the time of renewal.

Issues that are unique to the license renewal period will be addressed through the license renewal process rather than during the current licensing term. The staff's review of the licensees renewal application, including the Integrated Plant Assessment (IPA), and opportunity for public hearing will ensure appropriate oversight of unique aging issues.

QUESTION 2:

Will the proposed license renewal approach maintain the current licensing basis?

ANSWER 2:

The current licensing basis is maintained in general by the regulatory 4

oversight process but more specifically by the continuance of regulatorily prescribed programs (including, for example Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Section 65 (50.65) " Requirements for Monitcring the Effectiveness of Maintenance at Nuclear Power Plants"), licensee plant-specific comitments, and through activities to manage SSCs that are ITLR and deter.nined to be subject to ARDUTLR.

QUESTION 3:

Is the concept of age-related degradation unique to license renewal, as discussed in the SOC for the final license renewal rule, a useful regulatory concept? Should it be eliminated?

ANSWER 3:

The concept is useful in that it allows an initial broad scope of plant equipment to be considered but provides the mechanism to quickly focus on equipment whose performance or condition eculd be negatively impacted by aging in the renewal term.

However, as currently written in 10 CFR 54 the definition does not allow the intended concept to be applied. The DOE proposed approach allows the emphasis to be placed on evaluating Systems Structures and Components (SSC) ITLR where performance or condition is not managed by programs that are part of one's CLB, that are not subject to the maintenance rule and replaced or refurbished, or that had not been previously j

evaluated for the extended period of operation and the evaluation had been found acceptable by the NRC.

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3 QUESTION 4:

For any proposed approach, what standard (e. g.,10 CFR 54.29) do you propose the NRC apply for issuing a renewed license?

ANSWER 4:

For any proposed approach, the standard (e.g.,10 CFR 54.29) should reflect the fundamental principles and regulatory process proposed and specifically reflect the information that must be submitted in a renewal application. The approach being proposed focuses on the identification of SSCs ITLR, identification of SSCs ITLR which may be subject to ARDUTLR, and management of age-related degradation determined to be unique to the extended terin of operation such that the CLB will be maintained. Therefore, the Department's i

approach would not require a change to the License Renewal Rule Standard. The standard provided in 954.29 (a), "Actf3.is have been identified and have been i

or will be taken with respect to age-related degradation unique to license renewal of SSCs Hoortant to license renewal, such that there is reasonable arsurance that the etivities authorized by the renewed license will be conducted in accordance with the current licensing basis, and that any changes made to the plant's current licensing basis in order to comply with this t

paragraph are otherwise in accord with the Act and the Commission's l

regulations." remains valid.

QUESTION 5:

How does the proposed approach consider existing licensee programs that help assure acceptable perfomance or condition of systems, structures and componen ts?

ANSWER L:

The definition of ARDUTLR has been modified to consider existing licensing programs by confirming that credit may be given to CLB activities, and refurbishment and replacement activities for Structures and Components (SCs) under the scope of the maintenance rule.

The following statement has been added to the definition of ARDUTLR:

A structure or component shall not be considered subject to age-related degradation unique to license renewal if its performance or condition to the extent set forth in the CLB is reasonably assured by programs that are part of the CLB.

Further, structures and components that are subject to the maintenance rule at 10 C.F.R. 50.65 shall not be considered to have age-related degradation unique to license renewal (i) l if they are subject to routine or one-time replacement or refurbishment such that the structures or components will not have a service life of more than forty years, or (ii) if they are regularly inspected or tested and are replaced or refurbished when establishsi performance or condition criteria are not met.

The first sentence of the proposed addition above is intended to make it clear that attivities prescribed by the CLB may be given credit in determining

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4 whether a structure or component is sabject to ARDUTLR. A licensee need not assume that regulations and technical specifications do not exist.

If regulatorily prescribed pragrams preclude a structure or component from experiencing ARDUTLR, the structure or component should be excluded from detailed Effective Program review.

The second sentence in the proposed addition above is intended to allow replaced and refurbished components to be excluded from detailed Effective Program review without further evaluation of degradation mechanisms, effects, or rate. Except in unusual circumstances (that might justify a waiver of the rule), components that are replaced or refurbished cannot experience degradation unique to license renewal, and their reliability and compliance with the CLB will be adequately assured, both in the current tem and the renewal term, by the maintenance rule.

The exclusion of replaced and refurbish *d components subject to the maintenance rule does not imply that no further ntivity is required to manage degradation. Rather, the exclusion signifies that the programs currently in place for such components, coupled with the maintenance rule coverage, are presumptively adequate.

QUESTION 6A:

How is the maintenance rule relied on in the proposed approach?

ANSWER 6A:

The changes to the definition of ARDUTLR discussed above also serve to reconcile the license renewal and maintenance rules. Like the license renewal rule, the maintenance rule is intended to provide reasonable assurance that SSCs will be capable of performing their intended functions, thereby preserving the CLB. With respect to replaced and refurbished structures and components, the maintenance rule should be considered adequate to prevent ARDUTLR and assure the availability and reliability to such structures and components. With the change above, the IPA would be focused on those components that deserve attention in a license renewal proceeding, i.e. on those components that may be expected to experience greater or different degradation during the period of extended operation.

QUESTION 68:

Does the scope of the license renewal rule need to be the same as that of the maintenance rule?

ANSWER 6B:

The scope of the two rules do not necessarily need to be the same. The scope of the license renewal rule encompasses those SSCs that have a controlling interest in safety, and whose functions need to be reasonably ensured cch that an adequate level of safety is maintained. The scope of the mdntenance rule includes those SSCs which have been traditionally identified as important to safety by also taking into account operations experience which will be ongoing. Together the two rules will provide reasonable assurance that SSCs which have a controlling interest in safety and those based on continued

5 operation that may challenge the traditional important to safety systems will continue to perform their function and maintain the CLB during the extended term of operation.

QUESTION 7:

How does the proposed approach reduce uncertainty and promote stability? If areas of uncertainty or inetability remain, how should they be addressed?

ANSWER 7:

PROMOTING STABILITY The proposed approach promotes stability by: (1) correcting the definition of ARDUTLR; and (2) allowing cruit for: CLB activities which provide reasonable assurance that the performance and condition of an SSC ITLR will be maintained during the extended term of operation, and refurbishment and replacement of SCs ITLR which are also under the scope of the Maintenance rule.

(1) Definition of ARDUTLR (1) The definition of ARDUTLR, contained in 954.3, has been modified as follows:

i Age-related degradation unique to license renewal is degradation--

(1) That (i) occurs during the tenn of the current operating license but whose effects are different in character or magnitude after the term of the current operating license (the period of extended operation) or (ii) occurs only during the period of extended operation; and (2) Whose effects have not been addressed for the period of extended operation in an evaluation found acceptable by the NRC.

A structure or component shall not be considered subject to age-related degradation unique to license renewal if its performance or condition to the extent set forth in the CLB is reasonably assured by programs that are part of the CLB.

Further, l

structure and components that are subject to the maintenance rule at 10 C.F.R. 50.65 shall not be considered to have age-related degradation unique to license renewal if they ('.) are subject to routine or one-time replacement or refurbishment such that the structures or components will not have a service life of more than forty years, or (ii) are regularly inspected or tested and are replaced or refurbished when established performance or condition criteria are not met.

The criteria contained in the definition of ARDUTLR, as written in the final license renewal rule, were each connected by the conjunction "or".

As a result, degradation is ARDUTLR if any of the three clauses were satisfied.

Thus, under the literal wording of the definition, any degradation that had not been explicitly identified and evaluated by the licensee and approved by the NRC for the renewal term is ARDUTLR, even if no different from degradation occurring during the initial licensing

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term. This would preclude screening out any components even if they could not possibly experience any degradation different in character or magnitude in the renewal term or unique to the renewal term. The grammatical flaw in the definition has been easily corrected by altering the conjunctions in and rearranging the definition as shown above.

l The wording in the second paragraph (the paragraph beginning with "whose l

effects...") provides an exception to the uniqueness classification when the age-related degradation in question has already been identified, evaluated, and accepted for the period of extended operation. The wording in the second paragraph has been slightly changed, partly to be grammatically correct and partly to cvoid an implication that degradation mechanisms must be identified. The appropriateness of addressing degradation by focusing on effects, rather 1

than on mechanisms, is discussed in the response to question 8.

(2) Credit for Reaulatorily Controlled Activities l

The basis for allowing credit to be taken for CLB activities which provide reasonable assurance that the performance and condition of an SSC ITLR will be maintained during the extended term of operation, and allowing credit to be taken for refurbishment and replacement of SCs ITLR which are also under the scope of the Maintenance rule is discussed in the response to question 5.

REDUCING UNCERTAINTY j

With regards to future activities (i.e., those activities which would impact the licensee's O&M costs during the stended tenn of operation), the proposed approach reduces uncertainty by: (1) reducing the level of detail contained in the FSAR Supplement to that which has been determined to be acceptable in the i

past, (2) reserving the use of Effective Programs to those SCs that may be expected to experience greater oi Jifferent degradation during the period of i

extended operation, and (3) deleting 10 CFR 54.21(a)(6)(ii) which would allow licensees to avoid committing to prescriptive acceptance criteria when such a degree of detail is unnecessary.

(I) Level of Detail Under the current rule, the entire IPA and all other elements of the application must be included in the Final Safety Analysis Report (FSAR) supplement. As a consequence, all the procedural descriptions and details provided in the IPA will become incorporated into the FSAR and subject to the review procedures set forth in 10 CFR 550.59. This approach is not consistent with NRC licensing practices. Requiring that the entire contents of a renewal application, including all the detail-specified in the IPA, be included FSAR is not a judicious practice.

It allows no discrimination in determining what information should be singled out for inclusion and centrol in the FSAR. This problem can be eliminated if the FSAR supplement and the IPA are decoupled. The proposed approach would still require that the IPA be submitted with as much information as is necessary to demonstrate that Effective Programs l

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will maintain the CLB, but that only the results and conclusions of the l

IPA, including descriptions of Effective Programs, be incorporated in the FSAR supplament. To accomplish this change, the introductory sentences of 10 CFR 554.21 were amended, original (e) has been changed to (f), and a new paragraph (e) has been added as follows:

Each application shall contain the following information:

(a) Integrated plant assessment (IPA).

The IPA must....

(e) FSAR supplement. The results and conclusions of the IPA, including a general description of Effective Programs specified in paragraph (a)(6) of this section, shall be incorporated into the Final Safety Analysis Report (FSAR) for the facility.

Certain conforming changes would also be required in 10 CFR fl 54.33 and 54.37. Currently, Section 54.33(d)~ imposes administrative and regulatory requirements variously on " programs and procedures reviewed i

and approved by the staff" or "previously approvea programs and procedures referenced in the renewal application or FSAR supplement."

Section 54.37 requires that all the lists in the IPA be updated annually.

(2) Effective Proarams By reserving the use of Effective Programs to those SCs that may be expected to experience greater or different degradation during the period of extended operation, the administrative burden placed on the licensee should be greatly reduced. Under the final license renewal rule, the majority of SCs ITLR and their associated maintenance activities could be subject to rigorous administrative controls which would ultimately defeat the purpose or the performance-based maintenance rule and result in uncontrolled operations and maintenance (0&M) costs.

(3) Level of Commitment Effective Programs are made more complicated and burdensome than may be necessary by the requirement that they contain acceptance criteria against which the need for corrective action will be evaluated. This requirement may force a licensee to describe in the IPA the specific details of its preventive maintenance procedures. As a result, the licensee's procedures may become subject to the rule's administrative and regulatory controls at a very detailed level, making it difficult for a licensee to adjust its maintenance procedures (in response to industry information or the results of monitoring under the maintenance rule, for example) and effectively eliminating flexibility otherwise accorded by the maintenance rule.

In the proposed approach, 10 CFR 54.21(a)(6)(ii) has been deleted. This deletion does not mean that specification of acceptance criteria is always unnecessary. The rule would still require a renewal applicant to demonstrate that its Effective Programs will be effective in maintaining the CLB during the

8 period of' extended operation; and if the specification of acceptance criteria is necessary to make this demonstration with respect to particular structures and components, such acceptance criteria would have to be provided.

QUESTION 8:

Would the proposed approach alter other aspects of the final license renewal rule, such as content or description of an effective program, contents of a license renewal application, or continuing reporting requirements?

ANSWER 8:

The proposed approach would result in changes to the definition of " Effective Program" and the requirements of an Effective Program described in 154.21 (a)(6)(i). Other changes to the 10 CFR 54 are being proposed and are discussed in the answer to question 7.

Changes to 10 CFR 54 which reduce uncertainty and promote stability include:

654.21 Contents of Application--

technical information, 654.33 Continuation of current licensing basis and conditions of renewed license, and 954.37 Additional record and record keeping requirements.

The basis for the changes to the definition of " Effective Program" and the requirements for an Effective Program follows.

The proposed approach allows a licensee to address ARDUTLR by either an evaluation of effects or mechanisms.

In some cases, inspections and surveillances focused on detecting and identifying specific degradation mechanisms, but in many cases ARDUTLR, can be effectively managed by monitoring and mitigating the effects of such degradation. With respect to many components, a licensee should be able to demonstrate that monitoring performance or condition is a sufficient and an i

effective means to detect degradation effects and identify the need for l

corrective action. Performance or condition monitoring is usually adequate because age-related degradation, and in parthalar degradation relevant to maintaining the CLB, manifests itself in a change in functional performance or condition.

The considerable experience with such programs and activities provides reasonable assurance that the structures and components covered by such programs wil' continue to perform their intended function. This focus on i

effects is consistent with recent recommendations of the NRC staff, who has i

made it clear that programs are effective if they mitigate the effects of ARDUTLR. Because of the importance of this position and the ambiguity of the l

current rule, the appropriate focus on effects should be confirmed in a rule change. Where performance or condition monitoring is sufficient to mitigate l

the effects of ARDUTLR, there should be no requirement or need either to identify or to evaluate degradation mechanisms.

To make the focus on effects clear, the definition of

• Effective Program" in 554.3 should be amended as follows:

Effective Program (EP) is a documented program to manage the effects of l

age-related degradation unique to license renewal in a manner reasonably assuring that a system, structure or component will continue to perform its required function or will not prevent the performance of a required I

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It is also recommended that f54.21(a)(6(i), requirements of an effective j

program be amended to:

E (i) Provide for the mitigation of the effects of age-related I

i degradation unique to license renewal for the SCr identified pursuant to i

2 paragraph (a)(3) of this section, by reasonably assuring for example the l

performance or condition of such SCs during the period of extended l

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operation in accordance with the CLB, QUESTION 9:

f Is the concept of " fundamental safety importance" as discussed in SECY 93-113 i

4 appropriate? Will the proposed approach result in the imposition of l

1 regulatory requirements for plant structures or components that are not of j

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" fundamental safety importance?"

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i ANSWER 9:

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The concept of " fundamental safety importance" may be a good one but the manner in which it is applied in SECY 93-113 is not logical. If what is i

really important are those SSCs which are of " fundamental safety importance" i

then the scope of review for Part 54 should be SSCs of " fundamental safety j

i importance" instead of SSCs ITLR.

In actuality, it does not really matter j

what term is given to characterize the scope; what is important is the l -

criteria which defines the scope. The criteria to define " fundamental safety importance" could just as well be the same criteria used to define "important j

to license renewal". What was provided in SECY 93-113 was an example of j

e criteria which could be used. Since the example criteria had not been fully j

l examined to determine what set of SSCs it would yield, the use of such j

criteria is premature.

j QUESTION 10:

Does the proposed approach incorporate consideration of "like-kind" i

replacement? If so, should the tem "like-kind" be interpreted with respect j

to structures and components which are replaced such that they will not experience a service life of greater than 40 years during the renewal tem?

l ANSWER 10:

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i Replacement of SCs has been incorporated into the proposed approach.

In the i

proposed approach, two forms of replacement are recognized. The first 1

involves routine or one-time replacement such that the component will not i

experience a service life of greater than 40 years, similar to the approach taken in SECY 93-113. The other form involves SCs which are regularly

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inspected or tested and are replaced or refurbished when established performance or condition criteria are not met.

Replacement in this case, j

means replacement with a component of equal or greater quality, subject to i

i controls established by 10 CFR 950.59.

Limiting replacement to identical "like-kind" substitutions is overly rt:;irictive and could induce licensees to i

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use original design components when better ones are available.

QUESTION 11:

How does the proposed approach consider refurbishment? What is a definition

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of refurbishment? How should guidelines be established to ensure that the

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concept of " refurbishment" is consistently applied in the implementation of 1

the proposed approach to license renewal?

j AltSWER 11:

The proposed approach considers refurbishment in the same manner as replacement (i.e., routine or one-time refurbishment such that a service life I

of greater than 40 years is not exceeded, or an SC which is regularly j

inspected or tested and refurbished when established perfomance or condition criteria are not met). The proposed approach does not offer a speciNc l

definition of refurbishment, it is assumed that each licensee will develop a i

set of criteria, pursuant to 654.21(a)(4) which will be utilized to assess the l

refurbishment program.

It is the methodology / criteria which would be approved l

by the NRC. Guidelines (i.e., methodology / criteria) should be developed based l

l on a mutual understanding and experience by the NRC and industry. Such guidelines should be contained in the Application and Format and Content l

Guidelines for License Renewal.

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2/11/94 WITS CONTROL:

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Janua y 14, 1994 NRR RECEIVED:

DAR:CRUTCHFIELD ACTION e'

NRR ROUTING:

MURLEY MIRAGLIA L

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FOR ADDITIONAL TIME OR DUE DATE CHANGES MUST BE APPROVED BY THE DEPUTY DIRECTOR OR THE ASSOCIATE DIRECTORS OF NRR.

IF YOU HAVE QUESTIONS CONCERNING EXTENSIONS CALL KEVIN B0HRER (3072).

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ACTION - Murley, NRR Cys:

Taylor

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UNITED STATES SnieZek

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IN RESPONSE, PLEASE Beckjord I

l January 12, 1994 REFER TO:

M931222 THiltz i

OF FICE OF THE SECRETARY MEMORANDUM TO:

James M. Taylor i

ExecutiveDirectorforOpehttions FROM:

Samuel J.

Chilk, Secretary})

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SUBJECT:

STAFF REQUIREMENTS - BRIEFfNC ON RESULTS OF LICENSE EXTENSION WORKSHOP AL D PROPOSED CHANGES TO LICENSE RENEWAL RULE (SECY-93-331), 10:00 A.M.,

WEDNESDAY, DECEMBER 22, 1993, COMMISSIONERS' CONFERENCE ROOM, ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND (OPEN TO PUBLIC ATTENDANCE) l The Commission was briefed by the NRC staff on the results of the license extension workshop and proposed changes to the license renewal rule.

l The Commission raised several questions concerning the definition of the term age-related degradation unique to license renewal (ARDUTLR) and whether or not it is needed in the rule.

The Commission also expressed interest in the responses to the eleven questions which appeared in the Federal Reaister notice of the workshop.

The staff should provide this information to the Commission.

449E9-(NRR)

(SECY Suspense:

2/11/94) 9400012 Althouch the license renewal rule will have some dependence on the maintenance rule, the Commission noted that the industry has a significant amount of experience with maintenance even though the rule is a recent introduction.

j When developing the statement of considerations to explain the j

rule, the language should be consistent between the statement of considerations and the rule, even to the extent of using the same language when referring to specific requirements.

In particular, the Commission requested that the staff carefully review the use of the terms SSC and SC throughout the proposed rule and l

statement of considerations to ensure consistent usage when each is appropriate.

I The Commission will provide further guidance to the staff in their votes and the subsequent SRM on SECY-93-331.

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The Chairman Commissioner Rogers Commissioner Remick Commissioner de Planque OGC i

OCA OIG Office Directors, Regions, ACRS, ACNW, ASLBP (via E-Mail)

PDR - Advance DCS - P1-24 i

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