ML20035H639
| ML20035H639 | |
| Person / Time | |
|---|---|
| Issue date: | 04/23/1993 |
| From: | Shewmon P Advisory Committee on Reactor Safeguards |
| To: | Selin I, The Chairman NRC COMMISSION (OCM) |
| References | |
| FRN-59FR46574 ACRS-R-1515, AF05-1-013, AF5-1, AF5-1-13, NUDOCS 9305060137 | |
| Download: ML20035H639 (2) | |
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'o UNITED STATES 8'
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NUCLEAR REGULATORY COMMISSION ACRSR-1515
WASHINGT ON, D. C. 20555
&g April 23, 1993 The Honorable Ivan Selin Chairman U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
Dear Chairman Selin:
SUBJECT:
SECY-93-049, IMPLEMENTATION OF 10 CFR PART 54, REQUIREMENTS F3R RENEWAL OF OPERATING LICENSES FOR NUCLEAR POWER PLANTS During the 395th and 396th meetings of the Advisory Committee on Reactor Safeguards, March 11-12 and April 15-17, 1993, we discussed with the NRC staff its proposal in SECY-93-049 for implementing the License Renewal Rule.
During our April meeting, we also heard from representatives of NUMARC on this matter.
We had the benefit of the documents referenced.
In a number of our past reports, we provided comments and recommendations on various aspects of the License Renewal Rule including our recommendation that this rule and the Maintenance Rule be better ' integrated in the interest of long-term coherence of the regulatory process.
We have also commented that the operational phase reliability assurance program required of applicants licensed under 10 CFR Part 52 needs to be integrated with these two rules.
Additionally, we have strongly opposed the staff's proposals to use license renewal as a means of dealing with such issues as electrical cable qualification and mechanical component fatigue life on the occasion of a plant's 40th birthday, when, in iact, these issues potentially affect presently operating plants that may or may.not seek license renewal.
We continue to support these views.
The staff's recent efforts to develop an approach to facilitate a more effective and efficient license renewal' process that would rely heavily on use of the requirements of the Maintenance Rule appear to have the potential for making significant improvements in this process.
However, we believe further dialogue between the staff and the industry on this matter is needed so that the many subtle issues involved in this approach are fully explored.
As we understand the present situation, the Commission's major concern is whether (1) the.present License Renewal Rule can be legally construed to accommodate the staff's proposal in SECY 049 or (2) there is a need to revise or formally interpret the existing rule and its accompanying statements of consideration to j
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The Honorable Ivan Selin 2
April 23, 1993 s
r accurately reflect the course of action proposed by the staff.
From a policy point of view, we believe that this Commission's thinking on the formulation of the ultimate implementation of the License Renewal Rule needs to be documented by a policy statement, interpretive rulemaking, or a revision to the rule and its statements of consideration.
Based on our discussions with the staff and NUMARC, it appears that the needed time is available to revise the rule without significantly impacting licensees' schedules for making decisions regarding license renewal.
i Sincerely, Usu Paul Shewmon Chairman
References:
1.
SECY-93-049, dated March 1, 1993, for the Commissioners, from James M.
- Taylor, Executive Director for Operations, NRC,
Subject:
Implementation of 10 CFR Part 54, Requirements for Renewal of Operating License for Nuclear Power Plants 2.
Report from David A. Ward, ACRS Chairman, to James M. Taylor, i
Executive Director for Operations, NRC,
Subject:
Proposed Guidance for Implementation of the Maintenance Rule, 10 CFR 50.56, October 15, 1992 3.
Report from David A. Ward, ACRS Chairman, to James M. Taylor, Executive Director for Operations, NRC,
Subject:
Proposed Regulatory Guide and Interin Standard Review Plan for License Renewal and a Related Branch Technical Position on Fatigue Evaluation Procedures, August 17, 1992
.