ML20035C350
| ML20035C350 | |
| Person / Time | |
|---|---|
| Issue date: | 03/26/1993 |
| From: | Moulton J Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9304070105 | |
| Download: ML20035C350 (13) | |
Text
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March 26, 1993 ORGANIZATION: Nuclear Management and Resources Council (NUMARC)
SUBJECT:
SUMMARY
OF PUBLIC MEETItE WITH NUMARC TO DISCUSS THE PROPO STAFF POSITIONS IN SECY-93-049 A meeting was held with NUMARC representatives on March 12, 1993, at the U.S.
Nuclear Regulatory Commission The staff also invited represen(NRC) offices located in Rockville, Maryland.
tatives from the Union of Concerned Scientists, Nuclear Information and Resource Service, National Resources Defense Council, and the Public Citizen Litigation Group to participate, but they chose not to attend.
The objective of the meeting was to discuss the staff's positions contained in SECY-93-049, " Implementation of 10 CFR Part 54, Requirements for Renewal of Operating Licenses of Nuclear Power Plants," dated March 1,1993. A number of documents were distributed as handouts at this meeting.
These included the meeting slide package, SECY-93-049, staff responses to questions from Commissioner Curtiss on license r.iewal rule implementation dated March 3, 1993, the Office of the General Counsel's (0GC) Commission paper, " License Renewal and SECY 93-049," dated March 9,1993, and NUMARC's preliminary questions dated March 11, 1993.
Dr. William Travers, of the NRC, opened the meeting by summarizing the staff conclusions from a recent senior management review.
Dr. Travers explained that the staff determined that a rule change was not required, that the form of a renewed license would not affect the technical issues for license renewal, that the current licensing basis is to be carried over into the renewal period, and that fatigue and environmental qualification issues would be addressed as current issues for older plants and as license renewal issues for newer plants. Dr. Travers also explained the staff's belief that unique to license renewal (UTLR) must be interpreted broadly with provisions for dispositioning a majority of issues without extensive analyses.
Regarding NUMARC's industry reports, Dr. Travers stated that the staff did not intend to publish SERs but would include areas of technical agreement in the NRC's license renewal standard review plan the use of probablistic risk assessmen(SRP-LR). Finally, Dr. Travers discussed t (PRA) results in license renewal. He stated that PRA results can be used for safety insights but not to directly reduce the scope of license renewal reviews.
He further added that PRA results can be used in effective maintenance programs and thereby indirectly support dispositioning of license renewal issues.
Mr. William Russell, of the NRC, detailed the staff's approach for carrying out the rule-required integrated plant assessment (IPA). Mr. Russell summarized the initial important to license renewal (ITLR) scope and function i
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review required by the rule and concluded that these reviews were fairly
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i straightforward.
He characterized the next phase, the uniqueness review, as i
the hardest ooint in tM IPA. Mr. Russell explained that although a licensee y
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could attempt to screen out systems, structures, and components (SSCs) as not UTLR, the staff did not believe that many SSCs could easily be dispositioned this way because the argument would generally be a tough one to make.
Additionally, if future actions (such as periodic replacement) were relied on to make the not UTLR argument, the staff would require some level of regulatory commitment to ensure that these future actions were continued.
Mr. Russell explained that the staff believed a more appropriate dispositioning of SSCs was through the effective program review phase.
Finally, Mr. Russell explained how the effective program review phase could be used to take credit for maintenance rule implementation.
s NUMARC expressed concerns with the staff's intention to require future periodic replacement actions by technical specification or license condition.
NUMARC stated that such actions would be overly burdensome and did not appear consistent with current regulatory practices.
Additionally, NUMARC and others expressed concern over possible litigation stemming from the inconsistency between the rule statement of considerations (SOC) and portions of the staff's approach. Mr. Russell stated that ultimately the Commission would be making a decision and offered that these inconsistencies could be resolved by a notice and comment process, a policy statement, revised SOC, or even an OGC analysis.
Mr. Russell concluded the meeting by reiterating the staff's conclusion that a-rule change was not needed and stated that a rule change would be adverse to license renewal at this point.
In concluding remarks, NUMARC expressed that the fundamental principles of the staff's approach were sound. NUMARC also agreed that there was a risk involved with a rule change, but that they also i
see risk in no rule change if one is really needed.
A list of meeting attendees and the meeting slides are provided as Enclosure 1 and Enclosure 2 respectively. Copies of the remaining handouts can be obtained from the NRC Public Document Room.
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John P. Moulton, Project Manager Projects Section License Renewal and Environmental Review Project Directorate Associate Directorate for Advanced Reactors and License Renewal Office of Nuclear Reactor Regulation
Enclosures:
As stated cc: See next page DISTRIBUTION:
Central File PDR PDLR R/F TMurley/FMiraglia, 12G18 JPartlow, 12G18 WRussell, 12G18 WTravers, llH21 SNewberry, llF23 LLuther, 11F23 JMoulton, llF23 FAkstulewicz, llF23 OGC ACRS (10)
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\\3 93 1){/93 DOCUMENT NAME: MOULTON MEETI G RY v
I CC Mr. Robert Pollard Union of Concerned Scientists 1616 P Street, N.W.
Washington, D.C.
20036 Diane Curran, Esq.
Harmon, Curran, Gallagher and Spielberg 2001 S Street, N.W.
Suite 430 Washington, D.C.
20009 Mr. Michael Mariotte Nuclear Information and Resource Service 1424 16th Street, N.W.
Washington, D.C.
20036 Mr. Dan Richer Natural Resources Defense Council 1350 New York Ave, N.W.
Washington, D.C.
20005 Patti Goldman Public Citizen Litigation Group 2000 P Street, N.W.
Washington, D.C.
20036 9
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i LICENSE RENEWAL MEETING WITH Nuclear Management and Resources Council (NUMARC)
March 12, 1993 ATTENDANCE LIST HAME TITLE & AFFILIATION Steven A. Reynolds Technical Assistant, ADAR/NRC William D. Travers Deputy Director:ADAR:NRR' Scott Newberry Director:PDLR:NRR Raj Anand Project Manager /NRR:PDLR Rebecca Nease Sr. Project Manager /NRR:PDLR Thomas Hiltz Sr. Project Manager /NRR:PDLR P.T. Kuo Section Chief /NRR:PDLR Jeff Sharkey Sr. Operations Engineer /NRR:PDLR i
John Moulton Project Manager /NRR:PDLR Bill Russell Director:ADT:NRR Frank Akstulewicz Section Chief /NRR:PDLR j
Dennis Harrison DOE NE-42 David Lewis Shaw Pittman Janet Ecker Newman & Holtzinger Barth Doroshuk Baltimore Gas & Electric Co.
Lynn Connor STS Larry Gifford GE-Rockville, Maryland Tricia Heroux EPRI John Galembush Westinghouse Tim Matthews NUMARC Doug Walters NUMARC Robert Bishop NUMARC William Rasin NUMARC Ray NG NUMARC Joseph Gallo Gallo & Ross Eve Fotopoulos SERCH Licensing, Bechtel John Osborne Baltimore Gas & Electric Co.
David Tang Mechanical Engineer /NRR:PDLR 1
Jit Vora NRC:RES:DE:EMEB Janet Kennedy Tech. Assistant / Chairman's Office Myron Karman Legal' Asst /0CM/KR:NRC Jack Scarborough Tech. Asst /0CM/KR:NRC Geary Mizuno OGC/NRC Steve Crocket OCM/KR:NRC Bill Horin Winston & Strawn Deborah Staudinger B&WOG i
Ed Lane Energy Daily.
Ron Parkhill Sr. Mechanical Engineer /NRR:PDLR Debbie Jackson Mechanical Engineer /NRR:PDLR Jim Sniezek NRC/DEDR Steve Hoffman Sr. Project Manager /NRR:PDLR ENCLOSURE 1
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- LICENSE RE\\lEWAL March -12,1993-ENCLOSURE 2.
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L LICENSE RENEWAL - BACKGROUND l
COMMISSION BRIEFINGS ON THE STATUS h
OF LICENSE RENEWAL ACTIVITIES 1'
SENIOR MANAGEMENT REVIEW INITIATIVE l
l-SENIOR MANAGEMENT REVIEW MEETINGS 12/92 l
& 1/93 PUBLIC MEETING ON RESULTS OF 1/29/93 SENIOR MANAGEMENT REVIEW SECY-93-049: STAFF PROPOSALS 3/1/93 ACRS MEETING 3/11/93
- PUBLiC MEETING TO DISCUSS SECY-93-049 3/12/93 s-COMMISSION MEETING 3/15/93 3
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L LICENSE RENEWAL - STAFF CONCLUSIONS:
- 1. NO NEED TO CHANGE RULE.
- 2. THE FORM OF THE RENEWAL LICENSE L(NEW. LICENSE vs. AMENDMENT) DOES NOT l
AFFECT THE SCOPE OF THE TECHNICAL l
lSSUES REVIEWED OR THE: SAFETY EVALUATIONS REQUIRED.
- 3. THE CLB IS. CARRIED FORWARD INTO THE RENEWAL PERIOD & NRC's REGULATORY.
PROCESSES 1WILL PROVIDE ASSURANCE-THAT THE CLB WILL BE MAINTAINED THROUGH THE RENEWAL PERIOD.
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l_ICENSE RENEWAL - STAFF CONCLUSIONS 1
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- 4. FOR OLDER PLANTS, FATIGUE & EQ ISSUES l
WILL BE ADDRESSED AS A CURRENT
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GENERIC ISSUE, NOT AS PART OF THE L
LICENSE RENEWAL REVIEW.
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- 5. FOR NEWER PLANTS, FATIGUE & EQ ISSUES WILL HAVE TO BE ADDRESSED AS PART OF THE LICENSE RENEWAL REVIEW.
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LICENSE RENEWAL - STAFF CONCLUSIONS
- 6. ARD UTLR MUST BE INTERPRETED BROADLY, BUT THIS DOES NOT IVIPLY A MASSIVE AMOUNT OF PAPERWORK FROM APPLICANTS.
- 7. REVIEW P-ilLOSO 3-Y S ~~O CONSIDER BROAD RANGES OF PLANT STRUCTURES & COMPONENTS BUT HAVE MECHANISMS FOR DISPOSITIONING THE GREAT VIAJORITY OF ISSUES WITHOUT REQUIRING EXTENSIVE ANALYSES.
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LICENSE RENEWAL - STAFF CONCLUSIONS 8.
THERE IS NO NEED TO PUBLISH SERs ON THE
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INDUSTRY REPORTS. THE SRP-LR WILL BE REVISED TO INCLUDE AREAS OF TECHNICAL AGREEMENTS FROM irs, THEN PUBLISHED IN DRAFT FOR PUBLIC COMMENT.
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PRA RESULTS CAN BE USED FOR SAFETY INSIGHTS BUT NOT FOR DIRECTLY REDUCING THE SCOPE OF LICENSE RENEWAL REVIEWS.
l HOWEVER, PRA RESUL~S.CAN BE USED IN EFFECTIVE MAINTENANCE PROGR \\MS & WILL THEREBY INDIRECTLY SUPPORT DISPOSITIONING OF l
LICENSE RENEWAL ISSUES.
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FIGURE 1: INTEGRATED PLANT ASSESSMENT (IPA)
ALL PLANT EQUIP V ENT 54.21(a:u:1}: SCOPE REVIEW
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SL.21 (a)(2}: FUNCTIONAL REVIEW
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54.2- (a)(3): UNIQUENESS REVIEW
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FIGURE 2: UNIQUENESS REVIEW
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54.21(a)(3): UNIQUENESS REVIEW Not unique to
, is or could be unique license renewal 54.21(a)(5): EFFECTIVE REQUIRES EXPLICIT ID PROGRAM REVIEW AND EVALUATION BY
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APPLICANT AND FOUND ACCEPTABLE BY THE NRC (54.3)
FUTURE ACTIONS REQUIRED NO YES NO TECHNICAL SPECIFICATION PROGRAM NEEDED.
OR LICENSE CONDITION LIC. COND. OR TS (Few SCs)
PER 54.33(b) TO ENSURE NO ARDUTLR examnie: one.iime inspeciion
& TO MAINTAIN THE CLB of tanks little or no corrosion Example: Replacement at fixed intervals 7
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FIGURE 3: EFFECTIVE PROGRAM REVIEW
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54.21(a)(5): EFFECTIVE PROGRAM REVIEW i
~5%
Some SCs Most SCs
- EXISTING P'ROGRAM
- ACCEPTANCE CRITERIA IN ACCEPTABLE, BUT EXISTING TS OR REG. AND NO ACCEPTANCE INCLUDED IN MAINT. RULE CRITERIA IN TS Minimum information provided.
Additional information provided.
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Very few SCs
, Very few SCs
- NEW PROGRAM
- NO PROGRAM REQUIRED NEEDED Detailed information provided.
Detailed information provided.
- Must ensure CLB is maintained during renewal period 8
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