ML20035G231
| ML20035G231 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/1993 |
| From: | Mizuno G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Rajender Auluck NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20034D458 | List: |
| References | |
| FRN-58FR15303, RULE-PR-50 AE55-1-010, AE55-1-10, NUDOCS 9304270026 | |
| Download: ML20035G231 (4) | |
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March 10, 1993 Note to:
Raj Auluck, RES From:
Geary S. Mizuno, OGC
SUBJECT:
INSERT TO MAINTENANCE RULE ENVIRONMENTAL ASSESSMENT Attached please find OGC's proposed inserts to Environmental Assessment for the proposed amendment to the Maintenance Rule.
A I indicated at our 10:00 AM meeting today, I believe that OGC had previously provided significant guidance to RES regarding'the inadequacies of the EA.
If these changes are made, and the discussion in the Federal Register notice is conformed to the OGC inserts for the EA, then OGC will be in a position to concur.
cc:
M. Malsch S. Treby I
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9304270026 930415 PDR PR 50 SOFR15303 PDR
OGC DRAFT March 10, 1993 INSERT TO ENVIRONMENTAL ASSESSMENT ON MAINTENANCE RULE AMENDMENT 1.
On page 1, "Necd for the Action," second paragraph, delete t last sentence.
Add a third paragraph which states:
The Commission is now proposing to change the required per refueling..ge ance performance evaluations to onc E frequencyofrg (not to exceed 24 months).
Evaluation of data collected'over the period of a i
refueling outage will provide a substantially better basis for detecting problems in degraded performance of SSCs and weaknesses in maintenance practices.
Evaluations conducted on a refueling cycle basis would also consider and integrate data available only during refueling outages with the data available during operations; under the existing requirements this may noT occur depending upon whether the annual assessment coincided with the refueling outage.
Furthermore, evaluationg g[cgc,ta cumulated over the period of a da refueling... g as opposed to the shorter annual perioDJ required by the rule, will provide a more meaningful basis for the recognition and interpretation of trends.
The Commission also believes that the proposed change I
would be less disruptive of the licensee's activities a NO more conducive to effective maintenance, since any adjustments to the maintenance program required by the results of the evaluations under 50.65(a) (3)(hpuld be implemented at the beginning of a refueling cycle.
Und63 the existing rule, adjustments stemming from the 50.65(a)(3) annual evaluations could be implemented at any time throughout the refueling cycle, depending on when the annual evaluation is required.
It is simpler and easier to implement a maintenance program where the changes are coordinated with the refueling cycle outage so that in any given cycle there is only one maintenance regime.
The Commission believes that its regulatory requirements should be adjusted to minimize unnecessary burdens on the licensee, where there is no significant adverse impact on the level of public safety.
The rece>0r amendment to 10 CFR 50.71(e), which lengthens the time for submitting FSAR updates to once every refueling cyc LE 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 I
1
on safety.
It also reflects the Commission's view that refueling cycles are an appropriate period for cumulating, and integrating data, which NRC requirements should be j
integrated with.
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2.
On page 2, under " Alternatives Considered," delete the entir E discussion, and substitute the following:
The Commission determined-that there are two reasonable 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 coordinated with the refueling outage.
- Second, corrective action to maintenance would not be coordinat&D with the refueling cycle, which is thought to have benefits in administrative efficiency and quality of maintenance implementation.
Moreover, there is no j
environmental advantage to the existing requirement as compared with the proposed change.
The second alternative is viewed as undesirable because adopting a specific time period, e.g.,
every 18 months, or every two years, would have the same objections as thE existing requirement for an annual evaluation.
There would be no environmental advantage with the second alternative as compared with the proposed change.
Accordingly, the Commission finds that there are no oth ER 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," delete the discussion, and substitute the following:
i The proposed amendment changes the period for performin(L the evaluations of licensee maintenance activities required by 10 g{g gge.65(a)(3) from annually to once every refueling ___,, not to exceed 24 months.
The proposed change does not require any change to nuclear power plant design or require any modifications to a
a plant's SSCs.
Nor does the proposed rule change the scope of the maintenance rule or affect the nature of t4E activities to be performed, e.g., monitoring, correctiv E action, and assessments of compliance.
The proposed ru L g 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 i
information gathered during refueling outages and allow the licensee to efficiently integrate this activity witM refueling.
The requirement for an annual evaluation waS i
adopted to assure periodic evaluations by the licensee, i
but the exact interval of twelve months was never deemeb by the Commission to be required by safety considerations.
The proposed extension should not resu Ct in any significant or discernable reduction in the effectiveness of a licensee's maintenance program; rather, the change would increase the meaningfulness anD quality of the maintenance evaluations.
For these t
reasons, the Commission finds that the proposed amendmeart will not result in any significant increase in either t tnE I
probability of occurrence of an accident or the consequences of an accident, and therefore concludes thatt l
there will be no significant effect on the environment a result of the proposed amendment.
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