ML20042E075

Comments on Proposed Rule on Nuclear Power Plant License Renewal Presented During 360th ACRS Meeting on 900405-07. ACRS Surprised by Lack of Emphasis on Pressure Vessel Integrity During Briefings

ML20042E075
Person / Time
Issue date:	04/11/1990
From:	Michelson C Advisory Committee on Reactor Safeguards
To:	Carr K NRC COMMISSION (OCM)
References
FRN-55FR29043 ACRS-R-1390, AD04-1-087, AD4-1-87, NUDOCS 9004200034
Download: ML20042E075 (2)

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m mt.2t- /390 UNITED STATES NUCLEAR REGULATORY COMMISSION

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ADV180RY COMMITTEE ON HEACTOR SAFEOUARDS WASHINGTON, D, C. 20665 April 11, 1990 The Honorable.Kenneth M. Carr Chairman U.S. Nuclear Regulatory Commission Washington, D.C.

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SUBJECT:

PROPOSED RULE ON NUCLEAR POWER PIANT LICENSE RENEWAL During its 360th meeting, April 5-7, 1990,.the Advisory Committee on Reactor Safeguards reviewed the staff's proposed rule on nuclear plant license renewal.

This matter-was also discussed 1during a meeting of the Regulatory Policies and Practices Subcommittee.on--

March 26, 1990.

During these meetings we had the benefit.of I

discussions with representatives of'the NRC. staff, NUMARC, EPRI, Northern States Power Company, and Yankee' Atomic C ectric Company.

We also had the 'benefitT of the referenced-document and -its enclosures.

The decisive issues for license renewal and associated plant aging, and the_ potential for further aging during the. proposed: license-extension, should'~be addressed throughout the life-of a-plant.

Attention to aging phenomena,.and--the criteria ~for safe operation (adequate protection of the health and safety of the public),

should be the same just after as: just.before ' license' renewal.

There may be components or systems - which are ' not aging issues..

during the first forty years,_ but become so = later, and; which therefore may require special attention.;

j At the-time that ths forty year period.for aflicense was chosen, there was no special technical. rationale for its

choice, and no j

specific form of plant' aging becomes magically decisive-at forty.

1 The regulatory-job for license renewal.is.'to identify the aging elements of the plant, and ensure that they receive- :. timely attention during the extended license period.

i In that context, we were surprised by the11ack: of emphasis on-pressure vessel integrity during our briefings.- This is surely.one-of the driving technical issues for extended life,.and we assume that it will move to a more central position as the plans develop.

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9004200034 900411 l

PDR ACRS 0\\

R-1390 PDC

The Honorable Kenneth M. Carr 2-April 11, 1990 The staff proposes to use the." current licensing basis" of a plant as.the basis for license renewal,. but there seems to be some ambiguity about the interpretation of the term. 'The industry seems concerned that this may provide an opportunity to impose arbitrary new requirements.

It is important that this terminology. be clarified, so that any future conflicts of interpretation are minimized.

With these observations, we concur in the approach being proposed by the staff, which emphasizes attention to aging phenomena, avoids the temptation to treat license extensions as relicensing, and makes a timely start toward providing an integrated; policy. for dealing with aging phenomena.

Sincerely, Carlyle Michelson Chairman-

Reference:

Memorandum dated March 6,

1990 from Warren Minners, Office of Nuclear Regulatory Research, NRC, to Raymond - F.

Fraley, ACRS,.

Subject:

. Proposed Rule on. Nuclear Power Plant License-Renewal, w/ enclosures:

Draft Commission Paper, " Proposed Rule on Nuclear Power Plant License Renewal" 6

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