ML20035G228
| ML20035G228 | |
| Person / Time | |
|---|---|
| Issue date: | 03/11/1993 |
| From: | Mizuno G NRC |
| To: | NRC |
| Shared Package | |
| ML20034D458 | List: |
| References | |
| FRN-58FR15303, RULE-PR-50 AE55-1-009, AE55-1-9, NUDOCS 9304270023 | |
| Download: ML20035G228 (5) | |
Text
OQC f
Pl1o/o)3 EDR#
From: Geary S. Mizuno (GSM)
To:
WN1:NSl:JXM2 Date: Thursday, March 11, 1993 11:50 am
Subject:
Environmental Assess Part 50.65 -Reply l
With respect to the EA, please make the following changes; with these changes OGC need not further review the EA:
On page 2 in third paragraph of "Need for the Action," modify to read:
...under the existing requirements this may not occur depending on whether the annual assessment coincides with the refueling outage."
On page 2 in fourth paragraph of "Need for the Action," nodify to read:
..is an example of where the Comission found that regulatory requirements can be..."
/ With respect to " Discussion" section of FR notice, I do not find that RES has made any change to the discusssion which reflects the revised EA inserts provided by OGC.
RES had agreed to make conforming changes.
Looking at the discussion, the sentences beginning with, "The Comission believes that the quantity and quality of data..." up to and including the sentence saying, "The change would provide more effective evaluations..." should be deleted, and the discussion beginning with the second sentence in "Need for Action" of the EA up to end of paragraph inserted in their place. When these conforming changes are made, OGC will be in a position to concur.
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%_v activities to allow them to be done once per refueling cycle basis provided 3._ g,
ta the interval between evaluations does not exceed 24 months.
Finding of No Significant Environmental Impact:
The Commission has deternined that, under the National Environmental i
Policy Act of 1969, as amended, and the Commission's regulations in Subpart A of 10 CFR Part 51, that this rule, if adopted, would not be a major Federal action that significantly affects the quality of the human environment a..d therefore an environmental impact statement is not required.
[ Tt; ::Mterin; ectivities regwired by the current r"la are intaaded to O
/ :n:ure ; centinuing high level cf cperetionabperformanca 2+ avisting nor1*ar-t^eer phnt:. No modification to the plant design is required as a result of t cv l fs the rule. The proposed change merely revises the frequency with which nuclear power plant licensees will evaluate.their performance and condition monitoring
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a c t i vi t i e s.b(Ma-MS;',N:pl ;;; nt et i v o ed vei ae i.he mended - ele (b uv p, W vi t nQ 0 SNS \\_
impact en the quelity ef the envirena. int
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The environmental assessment [nd the finding of no significant impact on/,1 hch this determination is basedh.s ailable for inspection at the NRC 7
gU7 Public Document Room, 2120 L Street NW. (Lower Level), Washington, DC.
Single copies of the environmental assessment Ed findings of
[
of icant impactffvailable from Joseph J. Mate, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone: (301) 492-3795.
5
i D hC 94W M T E 3-1 o "I 3 OGC DRAFT March 10, 1993 INSERT TO ENVIRONMENTAL ASSESSMENT ON MAINTENANCE RULE AMENDMENT 1.
On page 1, "Need for the Action," second paragraph, delete tyE last sentence.
Add a third paragraph which states:
The Commission is now proposing to change the required
,, frequency of 4
enance performance evaluations to oncE per refueling (not to exceed 24 months).
Evaluatio dpta collected over the period of a
' r~ '
basis for detecting problems in degraded performance of refueling b will provide a substantially better 1,
SSCs and weaknesses in maintenance practices.
N s Evaluations conducted on a refueling cycle basis would
\\x also consider and integrate data available only during
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refueling outages with the data available during
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operations; under the existing requirements this may noT
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occur depending upon whether the annual assessment N
coincidbd with the refueling outage.
Furthermore, evaluation g
data cumulated over the period of a refueling gg {g i
__ ge, as opposed to the shorter annual perioDJ 1
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required by the rule, will provide a more meaningful
} Q M { g basis for the recognition and interpretation of trends.
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The Commission also believes that the proposed change would be less disruptive of the licensee's activities a N O more conducive to effective maintenance, since any adjustments to the maintenance program required by the results of the evaluations under 50.65(a)(3)(hould be
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implemented at the beginning of a refueling cycle.
Und Gg 1c3 the existing rule, adjustments stemming from the 1
- 50. 65 (a) (3) annual evaluations could be implemented at any time throughout the refueling cycle, depending on
.'s when the annual evaluation is required.
It is simpler N
and easier to implement a maintenance program where the changes are coordinated with the refueling cycle outage 3 so that in any given cycle there is only one maintenance regime.
The Commission believes that its regulatory s\\ requirements should be adjusted to minimize unnecessary Nburdens on the licensee, where there is no significant j
adverse impact on the: level of public safety.
The rece>Cr amendment to 10 CFR 50.71(e), which lengthens the time for submitting FSAR updates to once every refueling cycle not to exceed 24 months, is an example of where regulatory requirements can be relaxed to integrate the with licensee activities without any significant impact g.--
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i on safety.
It also reflects the Commission 8s iew that 2
refueling cycles are an appropriate period foh cumulati G '
and integrating data, which NRC requirements should be j
integrated with.
2.
On page 2, under " Alternatives Considered," delete the entir &
discussion, and substitute the following:
The Commission determined that there are two reasonable 4
alternatives to the proposed amendment: (1) retain the existing requirement for annual assessments (the "no action" alternative), and (2) amend the period for performing maintenance assessments to some period other than once every refueling cycle.
As discussed above, the first alternative (keeping the existing requirement) is viewed as being undesirable because the quality and meaningfulness of annual evaluations would not be as high as evaluations which a N
coordinated with the refueling outage.
- Second,
/\\
bs
\\ corrective action to maintenance would not be coordinatfsD f
\\ with the refueling cycle, which is thought to have i
benefits in administrative efficiency and quality of maintenance implementation.
Moreover, there is no environmental advantage to the existing requirement as s
'N compared with the proposed change.
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The second alternative is viewed as undesirable because
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adopting a specific time period, e.g.,
every 18 months, or every two years, would have the same objections as tyg N
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existing requirement for an annual evaluation.
There i
s would be no environmental advantage with the second i
alternative as compared with the proposed change.
Accordingly, the Commission finds that there are no othER alternatives which address the problems with the annual assessment which are obviously superior from an environmental standpoint.
3.
On page 2. under " Environmental Impacts of the Action," dele"TE the discussion, and substitute the following s
The proposed zituendment changes the period for performing.
the evaluations'of licensee maintenance activities K required by 10 Cgg.65(a) (3) from annually to dnce proposed change does not require any chang
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every refueling ___
e, not to exceed 24 months.
x clear
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power plant design or require any modifications o
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plant's SSCs.
Nor does the proposed rule change the
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scope of the maintenance rule or affect the nature of t4E activities to be performed, e.g., monitoring, correctiv E action, and assessnents of compliance.
The proposed ru Lg change would only extend the time period for performing evaluations of the effectiveness of licensees' maintenance program from at least once a year to at learT' once every refueling cycle, not to exceed 24 months.
TME staff believes that the proposed extension of the allowable time in which to perform maintenance program evaluations will allow the licensee to consider information gathered during refueling outages and allow the licensee to efficiently integrate this activity with refueling.
The requirement for an annual evaluation waS adopted to assure periodic evaluations by the licensee, but the exact interval of twelve months was never deemed by the Commission to be required by safety considerations.
The proposed extension should not resuL.T in any significant or discernable reduction in the effectiveness of a licensee's maintenance program; rather, the change would increase the meaningfulness anb quality of the maintenance evaluations.
For these reasons, the Commission finds that the prcposed amendmeart will not result in any significant increase in either t t)E probability of occurrence of an accident or the consequences of an accident, and therefore concludes th or there will be no significant effect on the environment a result of the proposed amendment.
I;
.