ML20043B807
| ML20043B807 | |
| Person / Time | |
|---|---|
| Issue date: | 05/16/1990 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| FRN-55FR29043, REF-10CFR9.7 AD04-1-030, AD4-1, AD4-1-30, NUDOCS 9005310320 | |
| Download: ML20043B807 (95) | |
Text
-,n.
t, $ s ' S
.; \\
~
'l 4,$..
w y
o-q; 3
UNITED STATES OF AMERICA
(.
NUCLEAR REGULATORY COMMIS SI.
$16
Title:
nutnso a nestD xm.t a uctxst xtwem s,
3 s
.l u:q LOCBt10D:
RocKV2ttt, MARYtAND t@'
s;r lN Date:
xxy 26. 1990 s.g t
kh,
-d
- e i Pages:
n acts de;.
NIllR. GROSS.AND00,INC.
C O L' R T RTPORTER$ AND TRANSCRIBERS 1323 ?.hode Island Avenue, Northwest Washington, D.C.
20305 (202) 234-4433 9005310320 900516 PDR 10CFR PT9.7 PDC h
6
.__._i____________________.__.____________._________.._,.__________________.._______________________._________.______..._.._.____________
i DISCLAIMER
]
'l This is an unofficial transcript of a meeting of the United States Nuclear Regulatory commission held on May 16, 1990, in the commission's of fice at one White Flint North, Rockville, Maryland.
The meeting was
.i open to public attendance and observation.
This transcript 4
has not been reviewed, corrected or edited, and it may contain inaccuracies.
l The transcript is intended solely for general informational purposes.
As provided by 10 CFR 9.103, it is l.
not part of the formal or informal record of decision of
[
the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorise.
~
1 e
HEAL R. GROSS court titotttt$ AND TRANSCRillR$
1313 kHoD0 t$ LAND AVfNUI, N.W.
(202) 234-4433 wASNmotoN. 0.C. 20008
-(202) 232-6600
--t -
j
.d:
p n.'
3 s.o 4-i l
UNITED STATES OF AMERICA
(
- J NUCLEAR REGULATORY CONNISSION l,
bc BRIEFING ON PROPOSED RULE ON LICENSE RENEWAL L
PUBLIC MEETING Nuclear Regulatory Commission One White Flint North l
Rockville, Maryland Wednesday, May 16, 1990 3_J The Commission met in open
- session, pursuant to notice, at 2:00 p.m.,
Kenneth M.
- Carr, h
Chairman, presiding.
1 COMMISSIONERS PRESENT' KENNETH M. CARR, Chairman of the Commission THOMAS M. ROBERTS, Commissioner KENNETH C.
ROGERS, Commissioner JAMES R. CURTISS, Commissioner FORREST J. REMICK, Commissioner 1.
1
'.~ J l
NEAL R. GROSS 1323 Rhode Island Avenuo, N.W.
Washington, D.C.
20006 (202) 234-4433
[I' i:
.s c-E L:
STAFF SEATED'AT THE COMMISSION TABLE:
SAMUEL J. CHILK, Secretary WILLIAM C.
PARLER, General Counsel JAMES TAYLOR, Executive Director for Operations DR. THOMAS MURLEY, Director, NRR DR. WARREN MINNERS, Director, Division of Safety Issue Resolution, RES CLEMENS HELTEMES, Deputy Director, RES JAMES PARTLOW, Associate Director for Projects, NRR WILLIAM
1.
L I
NEAL R. GROSS L
1323 Rhode Island Avenue, N.W.
D.C.
20005 (202) 234-4433
c
\\
I i
4
.a L ci o
+
1 I
3 kI i J l
P-R-0-C-E-E-D-I-N-0-S 2
2:05 p.m.
j 3
CHAIRMAN CARR:
Good afternoon, ladies and 4
gentlemen.
5 The purpose of today's meeting is for the 6
NRC staff to brief the Commission on the proposed rule 7
on nuclear power plant license renewal.
The I
i 8
Commission was last briefed on the subject of license i
9 renewal on January the
- 30th, 1990 and provided 10 direction to the staff on a conceptual license renewal 11 rule and schedule.
Today, the staff plans to brief 12 the Commission on the proposed rulemaking and describe 13 how they have responded to commission direction.
l 14 There will be no vote taken at this 15 meeting.
However, the staff has requested Commission 16 approval of the proposed rulemaking package for a 90 17 day comment period and the Commission is expected to 18 vote shortly following the meeting.
2 19 Copies of the slide presentation are 20 available at the entrance to the meeting room.
I 21 Do any of my fellow Commissioners have any 22 opening comments?
23 If not. Mr.' Taylor, please proceed.
24 MR. TAYLOR:
Good afternoon.
With me at 25 the table today are from the Office of Research, Jack i
m i._ _
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
h r
s 0
l l.
,o 4
t 1
1 Heltenes, Warren Minners and Karl Kniel; and to my l
2 left Tom Murley, Jim Partlow and Bill Travers from the 3
Office of NRR.
[
4 On May the 9th we submitted to. the commission for publication approval this proposed rule s
6 on license renewal.
This rulemaking has been one of
[
3 7
the highest priority tasks within the staff in recent I
8 months.
We're continuing to meet the schedule which
{
9 we reviewed with the commission in January, i
10 The conceptual framework for this rule 11 which was discussed with the commission in January has I
i 12 been the subject of substantial further werk by the 13 staff in making up this proposed rulemaking.
The main j
14 precepts of the conceptual approach are intact, but 15 there's been considerable-aberration and change.in 10 specific provisions and wording of the proposed rule.
{
17 It also reflects the guidance in the Commission's 18 staff requirements memorandum which you issued to us, l
?
19
- Further, the staff has analyzed and 1
20 considered in detail the public comments received at a
l L
21 and after the November 1989 workshop.
The staff is L
22 currently reviewing supporting technical documents r
L L
23 submitted by the industry.
It is having initial L
l 24 discussions with the two lead plants, Yankee-Rowe and 25 Monticello.
We have also had the benefit of review by r-NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433 1
t li
1 4
i g.
i l'
5 i
1J 1
the ACRS.
2 This overall rulemaking effort has 3
continued to be led by the Office of
- Research, t
4 although it has been very much a
cross an-5 interoffice' cooperative effort with extensive i
6 participation by Office of General Counsel and the NRR 7
and I appreciate all who have worked on it.
8 With those words of introduction. I'll now 9
ask Mr. Heltenes to continue.
10 MR. HELTEMES:
Thank you, Chairman.
11 As EDO mentioned, this proposed rule 12 reflects a number of important inputs, the guidance 13 and comments from the Commission, technical and 3-,
"~"
14 procedural suggestions from the public workshop in 15 November, exter.sive input and assistance from NRR and l
16 OGC, reviews by the ACRS and CRGR, and insights gained 17 from the research aging program.
l 18 The rule was founded on two basic 19 principles, that the plant-specific licensing base is i
20 retained at renewal and carried forward without change l
21.
and that this licensing base, that is the current l-22 level of plant safety, is to be maintained f e e-the 23 renewal term.
24 Our presentation today will focus on the 25 changes since the conceptual rule discussed with the I
e _J NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
j
+
't 6
k 1
Commission in January and will cover in detail the i
2 principal issues that have been identified to date.
I 3
In particular, it will cover the identification of the 1
4 current licensing base, the structure of systems and 5
components subject to plant
- aging, the screening 6
process used to identify the value weight and account 7
or address aging mechanisms.
And I also would point 8'
out in the rulemaking package there is an overall 9
schedule that identifies the individual end items 10 associated with this rulemaking, when they will be 11 available for
- review, when they're expected to be 12 approved or issued in final form.
13 For example, work continues on the generic 14 enviroceestal document.
As the Chairman mentioned, 15 our schedule calls for a 90 day public comment period 10 on this proposed rule and for publication of a finer 17 rule in May 1991.
18 With that, let me turn over the briefing 19 to Warren Minners.
1 20 DOCTOR MINNERS:
Thank you, Jack.
21 (Slide)
On the first slide is an outline 22 of the presentation.
I would like to discuss the two 23 principles that Jack mentioned to bring out some l
24 points, some other key provisions of the rule.
- Then, 25 starting with slide 11, have some comments on other R
NEAL R.
GROSS 1323 Rhode Island Av'enue, N.W.
i Washington, D.C.
20005 (202) 234-4433
L Ve a 7
1 issues.
Finally we'll talk about some questions that 2
are outstanding that are presented at the end of the 3
statement of considerations.
And at the very end 4
discuss resources in schedule.
5 (Slide)
On the second. slide, we keep 6
repeating this, but these are luportant principles.
'1 7
As Jack
- said, the current licensing basis is r
8 considered to be adequate now except adequate now 9
for plants and except for aging is considered to be 10 adequate in the renewal tern and will be carried 11 forward.
So, we have no intention or are not going to 12 be required to make any new findings on the adequacy 13 of the current licensing basis and we hope to exclude
. = ~
i i
'~'
14 the adequacy of the current licensing basis from the 15 scope of the' proceedings on any license renewal.
16 The second principle is the aged 17 degradation and that's the focus of the license 18 renewal effort.
That's our concerno We have tried to l
l 19 focus that onto the systen structures and components i:
20 that are important to license renewal and the actions 21 required to control aging is going to be the basis for j
22 our finding in issuing a license to any plant that 23 requests renewal.
And the proceedings in a renewal 24 action will be limited to the age related issues.
25 (Slide) on the third slide, we have to I
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
[*.
i 8
l I
have a current licensing basis because all of the 2
plants are different and it's plant specific and 3
that's the only way to capture all of the requirements
'l 4-that are laid on a
plant.
But in addition to 5
5-requirements such as
- rules, orders and license 6
conditions, the licensee has made usually many 7
commitments in response to bulletins, generic letters, 8
enforcement actions.
These things have formed part of 9
the licensing basis.
l 10 In order to limit that
- set, we have 11 limited to those commitments that are on the docket, l
12 so they're documented and they're there for l
13 everybody.to see.
We have further limited it to those l
- -}
1 14 commitments which are in effect at the time of the 15 application because some of the bulletins are one time 16 things or when we have a short period of operation, 17 then they're no longer applicable.
Although 18 originally the FSAR really contained the licensing 19 basis of a plant, there have been many subsequent 20 modifications to that which are contained on the 21.
docket and that forms the licensing basis.
22 COMMISSIONER CURTISS:
Warren, what degree 23 of confidence do we have that the requirements that
-24 have been imposed 'and the commitments that the 25 licensee has entered into are actually contained on I
.l
.. J NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
y
,0.
L 9
l j. I-
.J 1
the docket?
We'll get into the question of the SEP 2
issues later on, but take that or USIs and GSIs, for o
3
- example, where we've had some recent discussion of 4
Just where the commitment is reflected and what the i
5 licensees are required to do.
Is there a high degree 6
of confidence that those commitments and requirements 7
that are important for this initiative will actually l
8 be. captured by reference to those contained on the 9
docket?
10 DOCTOR MINNERS:
- Well, let me play a
11 lawyer a littje bit here and Bill can correct me.
I 12 guess as far as requirements go,
- rules, orders and j
13 license conditions, I think that's fairly obvious.
I l
\\
14 guess what you're talking about is commitments.
15 COMMISSIONER CURTISS:
Commitments, right.
16 DOCTOR MINNERS:
And I think NRR is now j
17 going through an exercise to assure that the USIs and 18 generic issues have been or are being implemented.
19 And then there's a bulletin tracking system to see 20 that people have complied with bulletina.
So, I think 21 there's a high confidence or will be a high confidence 22 that the licensing basis is on the docket.
23 COMMISSIONER CURTISS:
Okay.
24 CHAIRMAN CARR:
Let me -- go ahead.
i, 25 COMMISSIONER REMICK:
It indicates that i-L-
l NEAL R. GROSS 1323 Rhode Isler<d Avenue, N.W.
Washington, 5.0, 20005 (202) 2"s4-4433 F
p e-4 3
10 1
the current licensing basis will be NRC requirements l
2 and licensing commitments on docket in effect at time l
3 of application.
How do you handle those things that 4
might come into effect between the time of application 5
and the time of issusace which could be sometime to a i
6 year or so?
How are those picked up?
e 7
DOCTOR MINNERSt I would say it's like an' 8
OL.
I think we have the same problem.
We now don't 9
require people to -- or standard plants to address the 10 USIs and 01s after a certain time.
We have a cutoff 11 date and you'll have to handle them on a
plant-12 specific basis if you want those people to change 13 their licensing basis after they've made an
' ~_j i
14 application.
15 COMMISSIONER REMICK:
But it's possible 16 somebody could make a commitment in that intervening 17 time.
Would that be automatically picked up then?
18 DOCTOR HINNERS:
Well, there will be new 19 requirements or there could be new requirements and 20 commitments af ter the application --
21 COMMISSIONER REMICK:
Right.
22 DOCTOR MINNERS:
-- and af ter the renehn 23 and we have a process for applying them.
If the 24 licensee commits to it, I guess it would be part of 25 the licensing basis, whenever he commits to it, at
.I 4
+
NEAL R. GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
d','
11 l
< J 1
that time become part of the licensing basis.
1 2
COMMISSIONER REMICK:
The thing that i
3 puzzled me was the fact.that we're talking about the e
4 current licensing basis would be that that existed at j
6 the time of application and why not at the time of i
6 renewal license issuance?
I think the intent was to 7
give some certainty to the applicants who come in.
8 They have to make economic decisions and I guess they 9
would like to know what they're applying for.
10 MR. PARTLOW:
Commissioner, I believe one 11 of the reasons that we felt that tht?'re compiling 12 this list of commitments is important is not for all l
13 of the commitments but to ensure that they've looked n-i i i
"~'
14 at those that have to do with their renewal process.
l 15 Are they sure they have down all the commitments that 16 have to do with the aging of systems and components 17 and so forth?
So, we want them to have that as the 18 basis for their application.
So I think that's why L
19 it's tied to the application daily.
l:
20 COMMISSIONER REMICK:
I have no problem i.
21 with that and maybe it's a trivial point, but it seems 1
l-22 to me that at the time that renewal license was 23 issued, we'd want the current licensing basis to be l
24 what it was at that moment and then people would have l
25 to keep it up.
The way it's stated, it's now at the r-l u -
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
l l
l 12
.r r
1 time of application and it seems to me that we should r
2 say something like, "At the time of application plus 3
anything introduced or accepted or committed in the 4
intervening time," or something like that.
It just 6
seems to me there's a period of time that night ba 6
lost there.
7 COMMISSIONER CURTISS:
Let me follow up on 8
that.
Is it necessary to fix the time for the CLB in 9
order for the applicant to present and apply its 10 screening methodology?
Is that the reason it's set in 11 time, that the screening methodology has to identify 12 those SSCs up front?
13 DOCTOR MINNERS:
Yes.
14 COMMISSIONER CURTISS:
That are then 15 subsequently going to be evaluated?
It seems to me 16 it's important to do it for that reason, but at the 17 same time I wonder if it doesn't create a disincentive L
18 for those licensees that just prior to application any 1
19 be negotiating with the staff over possible 20 commitments with an idea that if we put it off past i
21 the application, it's not part of the CLB and hence 22 part of this proceeding.
23 As I understood it, the reason for fixing 24 it at that point was that it was necessary to get 25 going on the screening methodology.
g
.a NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
~o e
13 p
J 1
COMMISSIONER REMICK And I can see that f
i 2
there might be a current licensing basis deadline for t
(
3 application purposes.
It seems to me that for current 4.
licensing basis at the time of the issuance of renewal 5
license, it should be what it is at that particular 6
moment in time.
l 7
MR. PARTLOW:
It will be.
8 COMMISSIONER REMICK:
That's somehow i
9 captured in the worda?
i 10 MR.
TRAVERS:
In
- fact, the current i
11 licensing basis continues to evolve through the time I
12 that the application is submitted well into the s-13 renewal period for whatever period of time that the 14 license is valid.
So, the clear intent is to --
"~
15 COMMISSIONER REMICK:
Okay.
Okay.
I 16 realice it's going to be after the issuance.
It's
?
17 that integral time between application that it seemed t:
18 to be not covered, but maybe it is.
Okay.
t 19 CHAIRMAN CARR:
Let me ask a more basic 20 question.
I think.
The current licensing basis 21 includes a lot of issues not formally imposed on the 22 licensee in terms of an enforceable document such as l'
L 23 commitments on the licensing docket.
Why is it 24 necessary to continue informal commitments never made L
25 part of the original license or given legal l
r-
.i.-
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
'i
.]
1
+
14 p_--
L-1 significance during the renewal term 7 2
DOCTOR MINNERS:
Well, my understanding of a
3 it is that the commitments are enforceable.
My 4
understanding is that we have enforced commitments.
5 We have thst's the way we have done business, 6
largely with our so-called informal guidance like reg.
i 7
guides and generic letters and other things and that's 8
the.way our regulatory process has gone for years and t
9 has seemed to work very well.
That's why we've done 10 it.
Bill could comment on whether commitments are 11 enforceable.
12 DOCTOR MURLEY:
If I could comment, even 13 though we may not have formally made a rule or an i
"~~
14
- order, once a
licensee commits to something and i
16 changes their
- FSAR, then it becomes my 16 understanding is it becomes enforceable.
So, it 17 is --
l 18 CHAIRMAN CARR:
Oh, if the FSAR's changed, 19 I'm not arguing with that
- point, but I
get the f
20 impression there are a lot of commitments out there 21 that haven't been whipped into the FSAR.
22 DOCTOR MINNERS:
They might not go down to l
23 that detail.
24 MR. PARTLOW:
That's correct.
25 DOCTOR MURLEY:
Generally, I would say my l
F-~
i NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
m I
-4 i
16 l
1 understanding is that once he makes a commitment, we i
2 have mechanisms in place to ensure that they are 3
enforceable commitments.
4 CHAIRMAN CARR:
So you'd be willing to
{
i 5
change this to just what's in the FSAR then?
)
6 MR. TAYLOR:
No.
1 7
CHAIRMAN CARR:
That's what I thought you 1
8 said.
9 DOCTOR MURLEY:
What's enforceable?
There 10 are other documents, and I have to think for a minute 11 what they are, but there are other documents besides 12 the FSAR which --
I 13 CHAIRMAN CARR:
Which are enforceable?
.I.-
14 MR. TAYLOR:
Yes, and they are formal and 15 they are in the docket.
-16 MR. HELTEMES:
Many of our documents are 17 not requirements in the sense of a bulletin.
They're 18 not required to implement the requested action.
But 19 when the licensee commits to a certain action, comes 20
- back, he makes a commitment, they are incorporated 21 into the licensing docket and we do inspect against 22 those commitments and I
believe take enforcement 23 action.
24 CHAIRMAN CARR:
So that legal grounds 25 there?
Counselor?
- s. _
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
t
}
o-4 e -
i 16 1
MR.
PARLER:
It seems to me it's a
2 situation that would have to be examined on a case by I
4 3
case basis.
Obviously, regulations are enforceable, 4
orders are enforceable, things in the FSAR are enforceable.
But if you just have something that is a 6
commitment, it might even be unilateral.
It might be 7
highly informal.
So, it's certainly questionable I
8 whether things like that could be enforceable.
9 on the other
- hand, if there's been a
i 10 formal exchange of correspondence, if the j
t
. 11 understanding of the licensee and the regulatory 12 agency are clear in that exchange and there is no 13 doubt tnat something is going to be done according to
.h
\\
~
14 a
certain
- schedule, and that is reflected in the 15 licensing file, the licensing document, I would think 16 that that would be an enforceable situation.
If it's 17 violated and civil penalties could be imposed against 18 it is another legal question which we need not get 19 into at this time.
l 20 MR. TAYLOR:
It really is the last part.
21 That is, it is in the docket and it is a commitment 22 and it is 23 COMMISSIONER-CURTISS:
Take a
tougher l
24 example.
The generic letters that we've sent out over 25 the years in many cases contain language at the very
(
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433 f
n l
+
a 17 1
end that
- says, "This isn't intended to impose any 2
requirement on you."
I take.it the distinction here 3
between identifying the requirements versus the 4
commitments is to in part capture whetever commitments i
5 a licensee might make in a generic letter that by its
?
6 very terms and within the four corners of the generic 7
letter says this isn't intended to impose any 8
requirements.
I 9
1 guess I
have sort of a
narrow 10 observation.
One, we need to make sure that if that's l
11 the kind of thing we intend to pick up here in trying 12 to drag the river or. all the requitenents that we want 13 to impose, that we have a legal basis for doing that, I
i 14 having said in the document itself that this doesn't 15 impose any requirements.
And two, if it has that 16 affect, it seems to me that it puts to bed the notion' 17 that we're not imposing requirements through generic 18 letters because we certainly are and we intend to 19 capture those here.
20 MR. PARLER:
Let me make one other point 21 that also relates to your earlier
- question, Mr.
22 Chairman.
23 The status of these various things as 24 requiremente, whatever their status has been in the 25 past, that would not be changed by this document.
l n
u
.J NEAL R.
GROSS r
1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433 i.
1 18 y
1 CHAIRMAN CARR:
Be continued into the 2
future.
i
-3 MR. PARLER:
Right, right.
4 CHAIRMAN CARR:
All right.
Let's proceed.
+
5 DOCTOR MINNERS:
So, the current 6
licensing -- so the adequacy of=the current licensing 7
basis as defined is something which is to be excluded 8
from individual relicensing considerations.
So, in 9
order to do that, we have tried to make the case l
10 generically in the statement of considerations for the l
11 adequacy of the current licensing basis.
There's also 12 a supplement of separate enclosure 2 to the Commission l'
13 paper which goes into more detail on the adequacy of 14 the basis and I'll discuss that a little later.
15 (Slide)
In the fourth slide, as we said, l
i l
16 the licensing basis is defined in the rule and also i
17 the licensing basis is required to be compiled by the 18 licensee.
The Commission asked us to see to l
19 discuss the reasons why, if any, the licensees or 20 applicants should be required to sub'mit it.
And we 21 thought about it and decided that since the adequacy 22 -
of the current licensing basis is not subject to the 23
- hearing, there was no need to have it submitted as l-24 part of the application.
But since the basis was 25 nesded for the screening process, that it should be f
NEAL R.
GROSS 1
1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
a 19
.I
. J' I
readily available for audit and inspection by 2
inspectors.
And "readily available" has the usual 3
term is that the inspector should not have to travel a 4
long distance to get it from the corporate offices.
5 It should be certainly within the site.somewhere.
6 COMMISSIONER ROGERS:
I still don't quite 7
understand why you don't want to require a complete 8
listing of the documents. -Not documents, a listing of
[
9 the documents in the CLB.
I just fail to --
]
10 DOCTOR MINNERS:
To be submitted?
11 COMMISSIONER ROGERS:
Yes.
Just a list of 12 the documents.
I'm not saying the documents.
You 13 don't need a truck to drive up to the door, but why
- i 14 are you so --
15 DOCTOR MINNERS:
- Well, we think it's 16 adequate if the listing and the compilation is 17 available for inspectors at the plant and we discussed 18 it and I think that's the conclusion we came to.
19 COMMISSIONER ROGERS:
But when this whole j.
20 business gets
- reviewed, it's not going to just be j
21 reviewed at the plant by inspectors, it will be 22 reviewed in some other way as well, will it not?
When 1
23 you make a decision to make a recommendation, there 24 will be a lot of people looking at this and if any 25 questions come up about any aspect of what's in that i
i.
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
,4, 20 i
3 i
b -
1 CLB, why don't you have a handy list.of the documents
]
2 that are included?
'1 3
DOCTOR MINNERS:
- Well, you-could have 4
that, but I think withont the actual licensing basis
-5 itself, it has limited usefulness.
j 6
CHAIRMAN CARR:
Well, my understanding is 7
the licensing basis is not going to be part of the 8
problem.
What you're looking at are those systems 9
that are subject to aging and that's the list you 10 really want.
11 DOCTOR MURLEY:
Commissioner, there is a 12 logical reason.
We are not intending to review the 13 current licensing basis.
14 COMMISSIONER ROGERS:
No, I understand.
15 DOCTOR MURLEY:
We want to make sure, 16 however, that the licensee does so that he picks up 17 any potentiel part of that licensing. basis that could 18 be impacted by aging factors.
So, it's important that 19 he have it and have it documented at his offices, but 20 we don't need to other than to assure ourselves 21 that he's looked at it, we don't need to review it 22 ourselves.
23 CHAIRMAN CARR:
It seems to me if the 24 screening methodology is going to be broad enough to 25 address all the systems, structures and components NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
.,y, 21 k
1 subject to age degradation, then we really don't need 2
the licensing basis.-
It's not critical that that 3
thing is there at all.
If we're really going to have 4
a broad enough look at.those systems that are going to
?
5 get subject to aging, why is it critical that the 6
licensing basis be reviewed?
7 DOCTOR MURLEY:
- Well, particularly for l
8 some of these older plants where in -- now, the first 9
plant was licensed in 1960.
The procedures in those i
10 days were not as rigorous and the records perhaps were i
11 not as complete as they are today and the
'12 requirements.
So, we thought it was important for=the 13 licensees to go back and check all those commitments g-
-f i
14 and have them to make sure ' that they do pick up 15 commitments they've made that may not be obvious in 16 some FSAR document or something like that.
17 CHAIRMAN CARR:
I guess I'm having trouble 18 trying to tie that into what's growing old in the 19 plant, except the commitment.
20 DOCTOR MURLEY:
There may be a safety 1
21
- issue, let's say.
All I've got is a hypothetical 22 example.
Under certain circumstances of operation, a 23 safety system may not function at full capacity.
So 1
24.
maybe there's a letter that's maybe 30 years old that 25 says, "Well, we won't operate in that particular mode,
(
l NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 L
(202) 234-4433
.y 7
,. ~
m
~
h j
3 -..,
i 22
)
.{L-j 1
so it's not a problem."
Well, it may not have gotten i
i 2
captured in an FSAR update because that's a
s 3
relatively --
you
- know, on a 30 year time scale, 4
that's a relatively recent system that we've had.-
5 Nonetheless, we want to make sure that the 6
licensees for these older plants in particular 30 back 7
and check their records to pick up those kinds of 8
commitments to make sure that they've got them and 9
refreshed their memories and are on file.
10 CHAIRMAN CARR:
So that's kind of separate 11 from plant aging or components that you're worried 12 about --
P 13 DOCTOR MURLEY:
We think it's necessary to
~~
14 do that, to make sure that they don't miss some aspect 15 that could be affected by aging.
16 CHAIRMAN CARR:
Sounds to me like that's a 17 today problem rather than a future aging. problem.
l 18 DOCTOR MURLEY:
To some extent
- well, 19 it's not a today problem, but --
20 MR.
PARTLOW:
I guess really what we're 21 saying, what we want from this plant for the next 20 22 years is a list of commitments on how they're going to 23 monitor the aging of that plant.
Some of those 24-commitments, they've already made in the past and may 25 or may not continue to be good for the next 20 years, t
i j
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
- m 3
23 E % I-J l,
But-that's one set of commitments and they need to go 2
back and look at this licensing basis to determine 3
what those are because that's sort of'the jumping off 4
point" from ' which they're going to make a new set of 5
commitments to look at the aging of components-that 6
didn't-get committed before.
7 COMMISSIONER ROGERS: '
It's not just the 8
- aging, though the aging is a very big part - of it.
=9 It.'s - also maintaining the current base, whatever-that 10 is.
And that could erode by aging, it could erode by 11 not aging, just turning something off and forgetting 12 to turn it back on again.
, - ?. -
13 CHAIRMAN CARR:
But we've agreed to only 14 look at those things that aro affected by aging 15 in this license renewal.
16=
COMMISSIONER ROGERS:
No, no.
We're 17 saying that they're going to continue. the current 18 licensing basis, whatever that i s i, 19 CHAIRMAN CARR:
But they're doing that, 20 today.
21 COMMISSIONER ROGERS:
Sure.
22 MR. HELTEMES:
Mr. Chairman, if I may, one.
23 of the reasons why the staff put as the first step of 24 the screening process the compilation of the current 25 licensing base is that it constitutes the acceptance 1.]
c J NEAL R.
GF0t: 3 1323 Rhode Island tvenue, N.W.
Washington, D.c 20005 (202) 234-4433
- i
+
l 24 1-criteria when the-licensee has to make;a determination 2-whether he has effective ' programs to control and to 3
monitor plant aging.
When he goes through each of-the 4
structures, systems and components, in terms of the 5
commitments in his. license, his licensing commitments, 6
he has to make a determination whether that program is 7
effective.
The term " effective" in this context means-
_8 that he can fulfill the commitments of his license.
9 And if_ he can, then it's effective.
If he cannot, 10 then he has to institute and identify a specific 11 program to cover that criteria.
Such things are 12-margins, for example, f -,
13 CHAIRMAN. CARR:
The muintenance rule.
I qg' 14 understand that.
15 Go ahead.
16 DOCTOR MINNERS:
The Commission also asked 17L us to provide an alternate means of ensuring the 18 current licensing basis is enforceable.
I believe the
.19 mechanism by which we have done that'is to incorporate 20 the licensing basis into and consider it to be part of 21 the licensing docket, so that it has an official, 22 enforceable status.
We expect to look at how this all 23 works on the lead plants.and possibly some revision to 24 the rule of reg.
-guides might result from our 25 experience there.
i NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
I Washington, D.C.
20005 l
(202) 234-4433
'L f
Ng 4.-.-
nsi 25 1
COMMISSIONER CURTISS:
Let me go back'to 2
my - earlier question here.-
If the CLB consists of
-3 those-requirements and commitments. that have been V,
. imposed or~ agreed-to by the licensee at the-tihecthat 4
4 5
the plant was-licensed or subsequently, and if-you 6
have a
high degree of'-
sfidence that t'. se:
7 commitments and requirements vw included in the 8
- docket, that is to say we're going to look to.the 9
docket.-as the source of those requirements and' i
10 commitments, I guess I'm confused here when you. say 11 there's a need then to incorporate those requirements 12 and commitments into and deem them part of the
. J- --
13 licensing docket.
Isn't that done already?
14 DOCTOR MINNERS:
I think we're just 15' reinforcing thathstatement.
16 MR.
TAYLOR:
It's the docket-for the
~
17 renewed license.
18 MR. HELTEMES:
The docket for the current 19-license would continue and constitute the docket for
'20 the renewed-license.
The renewed license is indeed a j
21 new license.
i 22 COMMISSIONER CURTISS:
I understand.
23-MR. HELTEMES:
And so these words are to l-24 incorporate the previous docket into the new license g
b
.25 in the legal sense.
L F~}
.iO NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
.t h,
Washington, D.C.
20005 (202) 234-4433 o
y
.4 ;,9 26' E
l-COMMISSIONER CURTISS:
But the old docket
-2 carries.over..
3 MR.
HELTEMES:
- Yes, that's what these-4, words are. intended to say, the old docket carries 5
over.
6 CHAIRMAN CARR:
Your intent is to continue 7
the existing license terms --
.8 MR. HELTEMES:
Yes, sir, without change.
9 CHAIRMAN CARR:
as part of the renewed 10 license?
11 MR. HELTEMES:
Yes, sir.
12' MR. TAYLOR:
Unless they are modified.
13 COMMISSIONER CURTISS:
Okay.
_I 14 understand.
15 DOCTOR MINNERS:
Okay.
So by doing all.
16 this, what we intend to do is to not have to go back 17 and make the reasonable assurance finding that we made 18 at the OL for eacii license.
In other words, we're 19 going to do it generically in the statement of 20 consideration.
21 In order to bolster our contention that 22 the current licensing' basis is adequate, the statement 23 of consideration discusses the process by which the 24 licensing basis is modified over the years to assure 25 that it maintains its adequacy.
A large part of that i
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
= _ __ _
. l -. ' * ^'. '
.i.
27 s
l-N 1
process is cur resolution and implementation to the 2
-USIs, generic safety issues, the systematic evaluation 3
program.
And I'd alsoinote that when the IPEs 'are-4
- done, that's also ' another way of, if the licensee 5
commits to changes, of modifying the licensing basis.
6-What is not-required is a finding that the 7-
. licensee complies with his licensing basis at the time.
8 of application.
That's a continuing. function.
We and' 9
the licensees have programs to assure the licensees 10 are always in compliance with their licensing basis.
11 So that's not an additional finding that's going to be-12 made.
13 The supplement to the statement of 14 consideration-which is called the foundation for p
15 adequacy of the current licensing basis, which, was-16 primarily. written by - NRR and follows in~ format the 17 standard review plan, the different technical areas, 18 describes for each technical area in more specific 19 terms how that technical area evolved over the years 20 an'd-what processes occurred to ensure and will ensure 21 that the adequacy of a
licensing basis would be 22 maintained and it gives some specific examples.
23 Therefore, it gives a more comprehensive 24-technical support for the generic finding that the 25 licensing basis is adequate and that the reasonable
- n
.l i.
.J NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
a
. w y&! n p.. ~ a -
.z 2B g
1 assurance findings made during at the OL will continue-
/
'2' to be true.
'31 The one ' point that ~ I'd like to bring up
~
c
-4 here because it.'s a question that we ask at the:end of 6
the-statement of consideration is site changes which-6 are not. required to be reported ~ 1n the same manner, 7-that plant changes are.
We have in theLp'ast'and are 8
intending to continue in the' future to rely on our 9
inspection process to pick up changes in off-site 10
- hazards, industrial
- plants, airports, population 11 changes and things like that.
12:
(Slide)
The second principle, on -slide y.,
13 7 --
1 i
"~^
14 COMMISSIONER CURTISS:
Warren, before you y
15 go on, is there any significance to this being a 16 supplement to' the statement of considerations rather 17 than a part of the statement itself?-
18 DOCTOR MINNERS:.
I think it was made a 19 supplement because it's so thick.
We didn't want to.
20-put it in the Federal Register.
21 COMMISSIONER CURTISS:
But it would-be 22 considered a part of the rule and the rulemakind 23 record for purposes of --
24 DOCTOR MINNERS:
Yes, it's reference and 25 will be available for people to see.
We' re ' really
'i NEAL R.
GROSS l
1323 Rhode Island Avenue, N.W.
l Washington,-D.C.
20005 l
(202) 234-4433
3
^
.. 6 T-1 29
- 1:
considering making it a NUREG report so it would be 2
easily distributed.
i0-3 The second ' principle, on-slide 7, is age M
L4 degradation.
Once again what 't e' re-trying to do is
'5 only look at-age degradation of th'ose systems that are 6
important to license renewal, : which are the usuali 7
safety-related syctems that are involved in design 8
basis events.
To that.-we have added the sys. ten-9 atructures and components that are required for'non--
10:
. design basis events such as ATWS, station blackout.
11 And I think also to be sure that we cover ourselves, 12' that rad waste systems are either under the first one.
a, -
13' or the second one,' depending on--how you want to read
%_} ~
.14 it.
15 Then,- an additional-set of components'are 16 those whose failure could prevent the safety functions 17 of the first two sets and the' fourth category.is the 18 post accident monitoring equipment-that was required 19' following TMI, which is identified in 50.49 and in 20-more detail in Reg. Guide 1.97.
- 21 N ow,
- we have excluded some time-related 22 changes from age degradation management.
These are, 23 emergency planning, plant physical security, operator 24 licensing and financial qualifications.
Our basis for 25 excluding these from systematic review at the time of
,i
'L'-
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
...m
-- f, ;.' s,1*
l' 4,-
30-D' r.
I application is because we think the current processes 2
are ongoing and the aging _ changes or the time related 3
changing 11n _th'ese areas are adequately taken care.of 4
and don't have to be addressed by the applicant.
5 (Slide)
So, on slide 8, the rule defines 6
aging mechanisms and age related degradation and again 7
'the current licensing basis.'
The important thing that 8
the rule specifies is an integrated plant assessment.
9 In response to the Commission's SRM, we tried to be as 10 specific as we could in this integrated plant 11_
assessment and the screening process.
It's a four
'12-step screening process.
What the applicant is 13 required to do is describe the method.
We have.not
} -," ~) :
been so specific as to limit the applicant.
There is-14 15 a great deal of flexibility and therefore applicants 16 are going to have to describe their method of exactly 17
-how they're going to do it.
Then they are required, 18 of course, to list the results of each screening step.
19 Important to' this also is credit for 20 established effective programs.
The utilities, we most of their components are well 21
- believe, have 22 managed and we're going to give credit for those 23 programs.
24 I would like to point out here that in as Jack
- said, in order to determine 25 order to 1
l_
u
.J NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
- n, : ;'9 ', e 31 s
1-whether.the programs are effective, you have to know 2
what the current licensing basis is of the component ~
3 that you're looking at. -
If:you have something which.
4 has a licensing basis with a minimum wall thickness 6
and you-have a-program for erosion and corrosion, you 6
have to know what the-thickness is now and what the thickness minimum could be and demonstrate that during 7
8 the life of - the plant or ~the inspection integral, 9'
whichever is applicable, that you can meet the minimum 10 wall thickness.
So you have to know what the current 11 licensing basis is to be able to demonstrate you have 12 an effective program.
13 And also, the last bullet here is if you n'-
l"1i-14-don't have an' effective program, then you ' have to 15
' propose one and it will be imposed on you - as a
16 licensing' condition as apprcpriate to address any age 17-related degradation.
18 Once again, for these additional programs, 19 you have to know what the current licensing basis is 20-to be able to develop the program.
So, the current 21 licensing basis is a very important thing to know.
22 COMMISSIONER REMICK:
- Warren, since you 23 mentioned definitions, just an editorial comment.
I-24 assume from the changes you made in the proposed rule 25 that you prefer to use the term " renewal tern" rather e._
t.
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433 l
nj f.},3,,. -. -
I
~
L:.-
l 32-l 1 --
than'" renewal period" and that SSC stands for systems, 2
structures and components rather than structures, u
.3 systems and components.
But in the rule itself, there 4
still are some inconsistencies.
I just throw it out.
Si I. assume for the changes you've made that you. are
- 6 trying to be consistent, but there are still some 7
inconsistencies.
8 COMMISSIONER ROBERTS:
I'm on page 24 of 9
the proposed rule.
I'm reading from the first 10 sentence of the T$rst full paragraph.
"The only 11 situation which a plant'. current licensing-basis may 12' be changed-in.a license renewal proceeding is when the 9.+
13 licensee asserts that it is impossible or ' fairly.
14 impractical for it to comply with its curscpt 15 licensing basis due to age related degradation."
16 --
Could you explain that?
17 CHAIRMAN CARR:
That's in the statement of 18 consideration.
19 COMMISSIONER ROBERTS:
All right.
I beg 20 your pardon, in the statement of considerations.
21 DOCTOR MINNERS:
Yes.
We're saying there 22 that we're not going to propose changes to the 23 licensing basis as part of the license renewal 24 proceedings, but a fi a p p l i c a n t may have to do that.
25 I'll go back to my overused corrosion example.
When C
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
y H f.G ; p,
,4 a
~.,
i 33
]
1~-
he first came;in for his 0 ?,,
he may'have _ proposed a i
2 corrosion allowance of a hunt an inch.
Okay?
And we-ft 3
looked at it and said, "It's accept able,". which does.-
4.
not mean that that's the minimum you-need and he may-5 have looked at 'it. and said, " Hey, all you need is a l
H 6
tenth of an inch, but the guy is offering La half-an 6
-7 inch.
Fine.
Okay by us," away we go.
8 Now, as he goes through 40 years of life i
4 9
or 20 years of life, he may have eroded.quite a bit of.
10 that away and he no' longer has a half-inch corrosion l
11 allowance left.
So, he now has to sharpen his pencil 12 and come back closer to the tenth of an inch which is
[
13 probably all that people really wanted in the first
. wq-14 place.
So, he may have to, et the time of-l 1
' application, change his licensing basis to be able to.
l t
l-.
16 demonstrate that the licensing basis, whatever it i s ',
1 17-can be maintained throughout the renewal period.
s-
-18 So, he puts some margin into his original l
19 OL which may no longer b'e available to him and he's 20 going to have to run close to his minimums in the 21 renewal term in some cases.
22 CHAIRMAN CARR:
But he's not meeting'his 23 current licensing basis anyway.
24 COMMISSIONER ROBERTS:
I was going to say 25 suppose there were no license renewal proceedings.
' 'a
.L.
NEAL R.
GROSS L
1323 Rhode Island Avenue, N.W.
l Washington, D.C.
20005 (202)~234-4433 a
J.,
+
p.
t,,
34
- 1, 1
Wouldn't he.be doing that anyway?
2 DOCTOR-MINNERS:
On, he's meeting his 3'
'licensingLbasis because he'said at the beginning, "I'm-4 going to give you a. h a l f-inch," which gives you 5
assurance.that at the end of=40 years I'll be above 6
the minimum.
Okay?
Now he's going to -start'out for' 7
another 20 or 40 year period.
Okay?
He-doesn't have 8
a half inch.
How does-he make a demonstration that 9
he's going to have-the minimum by the time he comes to 10-the end of the next operating period.
He can't do 11 that the same way he did it the first time because he 12 doesn't have that much left.
He's used up some of his 13 half-inch.
So he's going to have to go down and do 14-some analysis and say, "Look, I've - got-better test 15 data and I know this and I know that and-I only need a 16 quarter of an. inch or a tenth of an inch or whatever 17 it is."
18 MR. HELTEMES:-
If I may add a little bit 19 to the response, the principle, of course, of the 20 license renewal rulemaking is to address only age 21 degradation effects and that's one of the reasons.this 22.
sentence is here, is to say that we do not intend to 23 address any part of the current licensing base other 24 than age related effects and that the renewal 25 proceeding is not a place to start addressing current I-
.=
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 l
(202) 234-4433
i, j '}, f.., f s:
35 1
' licensing' basis-or changes to them other than where it 2
becomes impossible or very difficult to meet the' 3
current basis because then it has to be incorporated 4
- because it's part of age degradation.
5 To go on just a moment, if there are some 6
changes to the' current licensing base that are not-age L
7 related_in the proper time, quite frankly, to address 8
those would be outside the renewal application, before 9
or after.
10 COMMISSIONER ROBERTS:
All right.
11 CHAIRMAN CARR:
Okay.
Let's proceed'.
12 COMMISSIONER REMICK:
Excuse me, Mr.-
s 13 Chairman.
g 3 q.
~
14 CHAIRMAN CARR:
Sure.
15 COMMISSIONER REMICK:
I had a question I 16 was going to' ask later, but because-of.something you 17
-said,
- Warren, it seems that I
should ask it.now 18 because you. talked about a
licensee meeting his 19-licensing basis.
What's the difference between 20.
licensing basis and design basis?
21 DOCTOR MINNERS:.
It could be the same, it 22 could be quite different.
I mean, he may have a 23 design besi.4 1or his equipment and, as I say, he may 24 have come in with something with more margin in it.
25 And he said, hey, I've in fact, in the GE plants,
,t NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 l
(202) 234-4433 I
.y..,f,i l-
.y1 i[
36 l~
1
-their design basis for relief valve capacity would 2
Provide more release. valve capscity then-the licensing' 3
basis. is.
And they want that extra margin so -that 4
they know they never get below the licensing basis an'd 5
have to restrict plant operation.
6 So a lot of vendors will put more meat 7
into their design than the licensing basis, so they're 8
sure'they don't bump up against the licensing basis.
9 COMMISSIONER REMICK:
I guess I thought 10 what you were going to answer and I thought was the 11 different design basis is basically what you 12 redesigned it for, and that's where that quarter of an 13 inch you were referring to.
I thought you-were going
.(7-,
14 to come back and say whether he meets his design. basis 15 without licensing basis.
We're talking about the 16 design basis plus any commitments, orders, all those 17 things beyond that.
That was my what I thought.
18 But when you used licensing basis in where I thought
.19 you'd say design basis, I'm not clear, or unsure that 20 that definition's correct.
21 MR. PARTLOW:
The design basis is a lot 22-
- bigger, a
lot more of information like level o f-23 detail.
24 The licensing basis is that portion of 25 that whole design basis that has been committed to.
M' c -
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433 m:
- e...,.. [= --
r 37
,)1-1-
That's one way of looking at it.
2 COMMISSIONER REMICK:
I guess I would have 3
thought the other way around.
I would have thought 4
,the licensing basis incorporated the design basis plus 5
commitments, orders, other things that we've added.
6 CHAIRMAN CARR:
What his answer said was-7 the licensing basis is a requirement, and the design 8
basis has got margin in it.
9 That's what you said.
10 MR. PARTLOW:
That's right, 11 COMMISSIONER REMICK:- Could be, yes.
12 COMMISSIONER ROGERS:
Well, I'll bite.
He 13 said that.
He also said that-licensing. basis. and fL_j
.14 design basis could be the same.
And so I'm a'little 15 puzzled-there with your margin question.
16 DOCTOR MINNERS:
If you have a design 17 basis accident --
18 MR. TAYLOR:
I think we need to get back 19 to you on that, because during the current license the 20-license covers the design, and then there are things 21 that come up where it is within our requirements for
'22 him to make design-changes.
And they, then, become 23 part of the design.
That's what we've got --
24 COMMISSIONER ROGERS:
What I'm a little-25 puzzled about is just the example.
I mean, I don't 7_
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 l
(202) 234-4433
sv 38 Le n bi want:to pursue it too far, but-it seemed to me that 2
what'you were saying is that our requirement
---you
'3 were saying, well, suppose : our. requirement is a tenth' 4'
of an inch when it was designed for a half inch and-5 over the course of time. there's an erosion down to 6
something less than a half inch, but they;still could 7
demonstrate that within the renewal period they still 8
wouldn' t come below the tenth inch.
9
- Well, that-all sounds fine.
But now 10 what's the tenth of an. inch?
If it was designed for a 11 half inch and built to a half inch, our requirement is 12 the tenth
- inch, where is that?
Is that in the 13 licensing, basis or'in the design basis?
I mean, in 14-what you're talking about here.
'It doesn't seem to me
' ~ ~ ~
15 that it's in either one of them.
16 CH AIRM AN CARR:
Sounds like it'll be in 17 the plant life extension license.
18 DOCTOR MINNERS:
It might not be in either 19 one, because the licensee might not tell us what the 20' design basis was.
He might just come in with ' a 21 licensing basis of a half an inch and our guys look at 22 it and say, " Hey, that's acceptable.
Okay, we accept 23 it."
24 CHAIRMAN CARR:
I would suggest if they're 25 not interchangeable we ought to define them and be I-t._
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
q )-
o l
l')W,_
', 4
( j.'~
39!
E t; -
1-very careful howLwe use them.
l
'2
. COMMISSIONER ROGERS:
I think so.-
I-think-1 3.
it's a point'here.
u-4 MR. TAYLOR:
I think there's a point'here.
~
5, That's why I'd like to come ba'ck..to you with a better 6
separation of those definitions, because --
7 COMMISSIONER ROGERS:
If. we just. accept' 8
- the --li' censing basis as the design-basis and the. design 9'
basis has the margin in it, then that-licensing basis 10 is what they're going to have to continue, -not 11 something else. DOCTOR MINNERS:
That's correct.
That's s
13 correct.
3., :
.i 14~
COMMISSIONER ROGERS:
So: I' think we have 151
-to-b'e very clear on this.-
16 MR.
HELTEMES:
We intend that the 17 licensing
- basis, with all
.of
'its
- margins, be
-18 continued.
r i
19 MR. TAYLOR:
We'll come back.
20 CHAIRMAN CARR:
Okay.
Let's proceed.
21 DOCTOR. MINNERS:
Okay.
We got through
{
22 slide 8, I think.
23' (Slide)
Let's go on to slide 9,
which 24-lists the screening' steps.
And I'd rather have you 25 look at slide 9A, which is in a flow diagram logic y
e.
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
2000S (202) 234-4433
t p
h;
- T.v a .s
t (l '
40 i
o p Ed
-1 form, which is I think easier to explain but harder to-f l
2 put on a. screen..
.., 1 3
At the top of 9A are the four different J
4 types of systems, structures, and components that are J
5' important to license renewal.
And,these can either be 6
determined by compiling your licensing basis, and then 7
you'll have all of these items', or you can just take-8 everything in the plant and dump-it into those_ hoppers 9
and screen everything and then you'll be sure,that you 10 have everything in the current licensing-basis, 11' whichever way licensees wish to.do it.
12-The first screening is to go through and
-13 see whether the item performs a safety function or-its
[
.j- -,
Q".
14 failure could affect the safety function of another
'15 item.
And if it has -no effect. on safety, obviously-no 16 further action is required.
If it does. have an 17 effect, then it - goes through the. next-' screen to see
.18 whether there's an established - ef fective program for t
19 controlling the aging degradation of this i t e m.-
And 20 as I mentioned before and. Jack talked about is-this h
21 is, again, where the current licensing basis comes in, L
22 because you have to know what the licensing basis is 23 to be able to determine whether the program is an 24 effective program.
25 If there is such a program, no further AL
. LJ NEAL R.
GROSS i
L 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 L
(202) 234-4433
?
1.
g
', }f
'e r 41-I-
'l' action.
If not, then you ~go down andD thei next eee k
2 screen of whether the degradation would be 3.
significant..
And once again, it's compared' to the 4.
current licensing basis, and you have to know. the.- licensing basis to be able to determine - whether 'the 6
degradation is significant or insignificant.
'If it's 7
not significant, no further acti'on.
And if it is
~
8 significant and you don't have a-program for it, then s,
9 you have to describe and provide the basis for action 10 to manage age-related degradation, and once again you l
11 have to use the licensing basis here to know what kind 12 of.a program you have to have to be'sure that' you.
l 13.
don't violate!the licensing basis ~.
),
14-So I guess the point I'm trying to make is t
15 that' throughout.the screening process from front to 16
. bottom the licensing basis is-an integral part of it.
c 17 CHAIRMAN CARR:.
Looks like you've got two-l 4
(
18 thirds of the maintenance rule right here.
19 DOCTOR MINNERS:
Glad you said that and 20 not me.
21 COMMISSIONER REMICK:
I couldn't. help but 1
22 be pleased with that chart.
I thought it was very 23 helpful in understanding what would take a. lot of 24 words to say.
I wish"all of our regulations kind of 25 followed that process, and Jim reminded me of the job 1.
d NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433 4
.n
g 9
y,s, v,..
~
-t 42
,1 iJ' 1,
being ~ done at the. Center of Nuclear Waste Regulatory 2
' Analysis-on Part 60 and thought maybe this'was a part-3 of'that.for Part 54.
It's a start for it.
I thought 4
it was very helpful.
4
'S DOCTOR MINNERS:
(Slide)
Well, on slide-o 6
10 -- so, the rule has been constructed to be directed 7
towards the required NRC-finding, which is to be 8
limited to age-related degradation, and it's only 9
addressing those systems, structures, and components.
i 10
~important ' to - license renewal as we define them.
And
~
'I 11 it's to find that the actions have been or will-. be 12 taken with respect to age-related degradation such l
13~
that there is a
reasonable assurance that' the I"
14-activities can - be conducted in accordance with the.
-l 1
15 current licensing basis.
And that's.the finding-that
.l
~i 16 has to be made prior to issuing a renewed license, j
!j 17.
Now at the risk-of generating more i
18 questions, although the adequacy.
of -the current
- j 19-licensing basis is going to be excluded from the
.l.;
20 proceedings, obviously, as I've indicated, the current l
21 licensing basis is not, because the, completeness and 22 the accuracy of the current licensing basis is very
-23 important in the screening process, as I illustrated.
4 24 So I would presume that in a proceeding, people could 25.
question the completeness and accuracy of the current i
5 j'
u_
q
\\
l --
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-44~33 7,
./
~
t.
43 L:
1 licensing basis by questioning the screening
'2 process, and I don't see any way to get rid of that 3
kind of a questioning.
~4' COMMISSIONER CURTISS:
Let me pursue that 6
.to make sure I understand'what you're saying.
In the 6
proceeding, one could question whether you found. alli 7
of the commitments or requirements 7 In.other words, 8
whether everything that's in the docket -- whether the
,9 docket
-captures all of the commitments and y
-10 requirements?
I guess an intervenor could point
.t o 11 commitments or requirements that they've found that 12 are outside of the docket and say it's not true to say 13 that the-docket contains all of
- them, or whether
['\\
14 you've scrubbed the docket in a sufficient manner to
~ ~ "
15 capture all the commitments and requirements.
But.the 16 question of the adequacy or sufficiency of those 17.
requirements or those commitments on particular' issues 18 remains a non-litigable issue.
Is that the way you 19-understand it?
20 DOCTOR MINNERS:
Yes, sir.
21 COMMISSIONER CURTISS:
Okay.
22 DOCTOR MINNERS:
-(Slide)
On slide 11, I'd 23 like to discuss some of the other issues associated 24 with this rule, the first of which is PRA.
I' 25 We had at first thought about requiring a i., l -
NEAL R.
GLOSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
y g.
c-.-.,
i 44-
. gM
.1 '
1 screening process using PRA, but-we have decided that 2
that's not-appropriate.
And the rule is silent on use 3
of PRA in -_that way, but we-discuss it in the 800 as a 4
possible method that - would supplement deterministic:
5' screening methods, and it's purely at the licensee's
- 6
' option 'whether ' he wants to use it or not.
And oft 7
course, the-rule requires licensees to describe.their 8
screening
- method, so they would have _to describe 9
however they use PRA.
10 And our basis for not requiring is that 11 the aging data and models are not very mature, and we 12 don't think that reliability of a PRA with aging in-it 13 is high enough to be something-that we would put all 14 our faith in..
But of course, the process may nature 15 and bec'ome better and it may be=more appropriate'later 16 on and people can use it.
17' Also related to PRA is plants are going to 18 be doing PRAs as 'part of 'their IPE.
And the SRM 19 addressed the question of IPE and requested the staff 20 not to confuse people _ with license. renewal. and IPE.
21 And so, we have eliminated most of-the discussion of 22 IPE, except to make a simple statement that we expect 23 that all plants will have completed a plant specific, 24 PRA as part of the IPE program.
And this is presented, 25 in the context of bolstering the adequacy of ~ the iy 1-NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
t Washington, D.C.
20005 (202) 234-4433
[:. idi' 45 T-3.
1.-
-current licensing basis that we're doing=the IPE.
And 2
if we need any more changes to the licensing brasis.
1 3
the IPE may' identify them, 4
CHAIRMAN? CaRR:
We really expect that o r.
5-do we understand that?
6 DOCTOR MINNERS:.
I think the word is --
7 CHAIRMAN-CARR:
You' used the word-
-8
" expect."
9 DOCTOR MINNERS:
I'll defer to Doctor 10 Murley, because I think that's his word, " expect.'"
ll CHAIRMAN CARR:
If they do a PRA as part 12 of th'e IPE, 'that's just their ' business.
We -don't 13 require that.
So we understand they're all going to l-14 do PRAs, though.
15 DOCTOR MINNERS:
But they are. required --
16 COMMISSIONER ROBERTS:
You can bet they 17 all are.
18 DOCTOR MINNERS:
But they are required to
'19 do PRAs.
It's not a voluntary action.
They are-20 required to do IPEs, that's what I meant.
21 CHAIRMAN CARR:
Okay.
22 COMMISSIONER ROBERTS:
They're all going 23 to do a PRA.
24 DOCTOR MINNERS:
Okay.
Pardon me, you're 25 right.
}
.. a NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
f.;
]
k h, j.,:7. J '
L g (.i ' <
t b
46 i pl9-1 CHAIRMAN-CARR:-
All-I wanted to do was
.[
+
2 make.sure that it's. understood, rather than expected.
3-DOCTOR MINNERS:
Okay.
4 The next issue is backfit, which the' SRM-i 5
had some directions which we think we've followed.
I 6.
think in-my discussions with OGC, the legal theory is
.7 the backfit rule does not apply to the Part 54 8-rulemaking, nor does it apply to a license. renewal 9-proceeding.-
Although the backfit rule doesn.'t apply 10 to the rulemaking, we have done a regulatory analysis
-11 which looks at the benefits and costs of-our proposed-12 rulemaking and some alternatives, and it comes to the 13
- conclusion that what we're doing is cost effective.
l-g, t_i_
14 When it comes time for an - applicant to
~
15 have his application reviewed, we will not apply a l
16 cost benefit test to any age-related requirements that 17 are needed for adequate safety, nor will we apply a 18 cost benefit test to any age-related requirements that' 19 are needed to maintain compliance with the current 20-licensing basis.
'21 COMMISSIONER CURTISS:
.On those
- two, 22 before you go on, on page 45 of the statement of 23 considerations you indicated that for those two P
24 instances where the backfit rule would not apply, 25 quote, "the staff need not prepare a separate document
- 1 1~
L,_
1 NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
s
.i
+
- w
.r..'
mb' 47-
'L 1
1-xplaining the basis for 4 this conclusion," right in e
2 the middle of the page there.
3-
~What's the reason for not documenting the 4
basis for the staff's conclusion that'a'backfit or-a j
k 5
particular-change-is-either necessary for adequate 6
safety;or to maintain the CLB and hence not subject to 7.
the cost. benefit analysis?
There must be's reason to-8 reach that conclusion.
9 DOCTOR MINNERS.
Well, I think it would-be q
10 a burden on the staff, because there's going-to be a l
j 11-lot of age-related requirements.
And it would be t
12 quite a burden on the staff to go down and explain-for tsv 13-each one of these things, and rather repetitious, of
- l. 3 14' why we think they're either adequate safety or 15 compliance.
And I guess it's presumptive that we're 16-going to follow our own policies and only omit cost 17 benefit analysis for those two classes of 18 requirements.
L
-19 MR. PARLER:
I think it's a question, Mr.
20' Chairman, of how many times you have to document.,
21 CHAIRMAN CARR:
-Yes.
22 MR. PARLER:
Presumably the compliance or i
23 the adequate protection exemptions to the backfit rule l
24 would
- apply, because you'd have to make the l,
25 improvements in order to pass an age-degradation I~l
.a p
NEAL R.
GROSS l
1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
p 48 h."
l n
$" J l
muster.
And I would assume that would be explained in
~2 the. safety evaluation' report.
3 CHAIRMAN CARR:
That's'the way I read-this
~
4 is it was --
5 COMMISSIONER CUS.TISS:
Somewhere in the--
6 document there is --
7 CHAIRMAN CARR:
A
, separate document 8
wouldn't be required, but it would be in the safety 9
evaluation report.
10 COMMISSIONER CURTISS:
Okay, emphasis on 11-separate.
12-DOCTOR MURLEY:
Commissioner, the
-t 13 following sentence on that page was meant to mean that.
"1 i 14 we would document it in the SEI.
15 COMMISSIONER CURTISS:
Somewhere in the 16 licensing proceeding you would be able to go back and 17 find the basis for the staff's conclusion.
Okay, I's 18 comfortable with that.
19 DOCTOR MINNERS:'
Okay.
But we will do 20 cost benefit tests for age-related things that would 21 go beyond the current licensing basis.
And of course, 22 the backfit rule would apply to any non-age-related 23 changes in the current licensing basis which we hope 24' in the context of a renewal application there aren't 25 any of those things.
}
' i
.. ~
NEAL R.
GROSS l
1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
m q
m,,. ;, ~.,
.p
!:t' 49 1,
And - not noted on here, but o n c e' a g a i n,
2 once the license is issued the backfit rule then comes 3-in-in full force, which is like he had in OL. 'And we 4
don't believe that any change in the backfit-rule is
-6; necessary to. implement - this process.
So we haven't 6
made any conforming changes to 51.01.
7 (Slide)
On slide 13 'is a' discussion ~ of 8
the scope of the proceedings, which is kind-of-
- 9 repetitious.
I guess, we're,j us t' s aying again we're 10 trying to limit the proceedings to age-related 11 degradations of systems, structures, and components 12-
_important to-license renewal and we' re excluding the-g -,
13-adequacy of the CLB in any-changes to the CLB which.
14 are not related to license renewal.
16 (Slide) on slide 14, decommissioning.
16 Obviously, if a
plant gets a
license renewal' it 17 doesn't have to decommission and we hadn't thought 18 about that too much when we wrote the decommissioning 19 rule.
So we're making conforming changes to 50.64 20 which requires.that licensees notify the NRC of their 21 program to fund decommissioning and-this is due five 22 years before any operating-license expires.
But it's 23 being.evised to say that if an applicant has made a 24 sufficient application for renewal at least five years 25 ahead
( his expiration date he doesn't have to make I
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
q Washington, D.C.
20005 (202) 234-4433
't s
f
, i.:, _., f. :, '. ' -
q 'o
- 50 fJ 1
this notification that was required by 50.54,
~
2 Also in; a decommissioning plan or an
- 3 application',t o terminate-his
- license, h e' is. now 4
required one year before OL expiration.
But; we are
. 5 saying that if you' re - in the application - proceeding 6
and have-your application in and we've reviewed it, 7
don't havoi.to do anything.
But if we deny the 8
- renewal, the decommissioning plan has. to be in one 9
year after-the denial.
10 CHAIRMAN CARR:
If you deny the renewal 11
. and he has made a
timely
- renewal, his license is.
12 expired and we're still looking at-it, so-he's 13 operating.
Now we come up and deny the renewal.
Are 3?) !
. 14 we going to require him to shut down that day?
15 DOCTOR MINNERS:
Yes, sir.
Yes.
16 CRAIRMAN CARR:
Okay.
I just want to make 17 sure that's what we're doing.
He no longer has-an 18 operating license.
19 DOCTOR MINNERS:
No longer-has an-
' 20 operating license.
21 CHAIRMAN CARR:
So he'll have a license to 22 hold and continue to decommission, but not operate; 23 MR.
PARLER:
If-you say that he has to
'24 stop operating in that day, I would assume that would
'25 mean that the existing license would have already r-L.
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
~
y, j
n o
51 1
expiref --
2 CHAIRMAN CARR:
Oh, it expired while we 3
were still --
because his time has run 4
MR. PARLER:
5 out.
If he has an existing license that hasn't i
6 expired and you deny the renewal, he can still operate 7
until the existing license --
8 CHAIRMAN CARR:
Oh, yes.
But I'm saying 9
if we didn't get our work done, he's operating beyond 10 his license because of the timely application and we 11 then deny it, he doesn't have a year to operate while 12 he's getting in his --
r 13 DOCTOR MINNERS:
No.
3-decommissioning plan.
~
14 CHAIRMAN CARR:
15 What he's really got is a
year to get his t
16 decommissioning plan after he shuts down that day.
17 DOCTOR MINNERS:
But I would expect that a l
l 18 denial could also contain an extension of operation if we thought that that was a thing that 19 that was l-L l
20 ought to be allowed.
21 CHAIRMAN CARR:
That's not a denial then.
22 DOCTOR MINNERS:
- Well, it might say you l
23 can operate another 30 days or something like that.
24 MR.
PARLER:
I think what he's thinking 25 about is a regulatory order of some kind that would i
I J
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
if l
t:
h'..'\\..*.,*
p 52 i
1 i
'JfJ l
provide for orderly termination of the operation --
2 DOCTOR MINNERS:
Right, that's right.
j 3
MR. PARLER:
-- because of the failure to f
4 grant a timely renewal.
t h
5 CHAIRMAN CARR Okay.
6 DOCTOR MINNERS:
I mean, you might be in 7
some critical operating period where the power is 8
needed and we'd say, okay, we'll give you another 30 9
days or something.
10 MR. TAYLOR:
We're hoping to avoid that.
l 11 MR.
PARLER:
That would have to be 12 carefully looked at.
13 CHAIRMAN CARR I started to say
- yes, 33 j
j 1
"~"
14 that'll get a little scrutiny on that.
15 MR, TAYLOR:
Yes, it will, i
16 DOCTOR MINNERS:
I hear that legal advice.
17 MR. TAYLOR:
Our object is to avoid that
)
18 by getting early submissions.
39 CHAIRMAN CARR:
Our object is to not have 20 one of those things where it expires while we're still
'21 looking at it.
22 MR. TAYLOR:
That is correct.
23 DOCTOR -MINNERS:
(Slide)
On slide 15 I
j 24 just war 2t to mentien that we also are making a small 25 chenge to Part 51 in the environmental area.
At the i
NEAL R.
GROSS 3323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
- q,,,,*
',l 4'
53 1
moment, Part 51 requires us to write an environmental t
1 2
impact statement if we renew a license, and we are i
3 changing this-to allow an environmental assessment to l
4 be written.
But of course, if the assessment does not 5
show insignificant
- impact, then an environmental 6
impact statement would have to be written.
But we 7
would allow an environmental assessment.
8 COMMISSIONER CURTISS:
On that point, I
l 9
gather from the SECY paper that there's a difference l
10 of views between the staff and General Counsel on 11 whether to proceed with this change to Part 51 at this 12 point, versus subsequently, after we prepare the GED 13 and make the corresponding changes to Part 51.
7-
"~~
14 MR.
PARLER:
There is a
difference, 15 Commissioner, but it's nothing-major.
It's simply a 10 difference of perspective from our point of view 17 compared to theirs.
18 On the one hand, the staff would prefer to 19 make this proposed change now in order to alert the 20 future users as to what the rule of the game will be 21 in this particular area.
22 One the other hand, from our perspective, 23 if there is a generic environmental study underway, 24 and if as the paper indicated in the future changes 25 have to be made to Part 51, it would seem that this h
e _
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
+ -
l t
64 i
q.
I could be left to that stage and we could tell the 2
users what our intent was.
But it's of no great 3
consequence to me, because in any
- event, as Mr.
4 Minners has
- said, if the environmental assessment that the 5
indicates that there would be 6
environmental impacts would,not be insignificant, 7
there would be en environmental impact statement 8
prepared in any event.
9 Strictly speaking, however, the change is 10 not simply a procedural change as the paper suggests, l
11 because if you label something environmental 12 assessment, environmental statement, the difference in 13 the labels have different consequences.
But the i
i U --'
14 difference is no significant difference.
+
15 COMMISSIONER CURTISS:
Aside from just 16 advising the licensees that this is something that 17 we're thinking about, in there any other advantage to 18 doing it now versus later?
19 MR. TAYLOR:
No, that's --
L 20 COMMISSIONER CURTISS:
That's the only L
21 one?
22 MR. TAYLOR:
That's the principal --
23 MR. PARLER:
But of course, the advice to 24-licensees now would be less than completely reliable, p
25 because if the assessment indicates that you have-to 1-r-
u..-
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
f'o y
l a
i i
65 e
I have a statement, you have a statement-in any event.
2 So the licensee would not know that until he found 3
out.
g 4
DOCTOR MINNERS:
I'm not so sure how 5
useful en environmental assessment.
would be to 6
licensees.
It would seem to me hard to write an 7'
assessment for a continued operation of another.20 i
8 years and come to the conclusion that there's 9
insignificant impact.
i 10 MR. PARLER:
I agree with that, 11 COMMISSIONER CURTISS:
Okay..
12 MR. PARLER:
That's part of our problem.
13 DOCTOR MINNERS:
(Slide)
On slide 16, we 7 --
14 address the questions that are at the end of the 15 statement of considerations.
And our purpose in this 16 whole rulemsking is to try to get all of the issues 17 out for public comment.
In this case, I think that 18 more is better than less, so that at the end of the 19 comment period we can make any changes that might be 20 appropriate and have a basis for making those changes.
21 If we omit things, then we might have to go out for 22 another public comment period if something new comes 23 up.
So these questions are intended to try to cover 24 some areas to be sure that everything is addressed.
25 The first issue is whether any equipment I
,l r._
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
o I
)
n..,
i r
56 o
i L t I-b.ld :J 1
or topics other than the ones that we have identified, i
g 2
emergency
- planning, physical
- security, et
- cetera, 3
should be excluded from aging management review.
4 The second question is kind of the 5
converse of
- that, whether any equipment or topics e
l 6
should be added to the review requirement.
At the e
7 moment, site hazards and population are not part of p-ir 8
the screening process.
So that's an example of-one.
9 The last issue or the last question is 10 going toward the adequacy cf the current licensing 11 basis.
There's no problem with issues that are
.t 12 resolved and implemented.
They're part of the cutrent g, -
13 licensing basis.
There's no problem with issues that i
i 14 are as yet unresolved that are in our process, because 15 part of our process is we look at an issue when it's
(
. 16 identified and say,
" Hey, do we have to take any 17 action now to provide adequate protection?"
And all 18 of the issues that are being in the resolution process 1
L 19 have had that inspection and we've decided to take 20 whatever actions we have to take.
In most cases, 1
21 none.
In a few, we have.
22 So, but what is kind of in the middle are l
23 issues which are resolved which are yet unisplemented.
24 And in the SOC, we believe that there is reasonable 25 assurance that the health and safety of the public is I
c J-NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
k Washington, D.C.
20005 (202) 234-4433 w
- m
}
[
=
l
[
[,
57-il. -
1 protected, because we know that these issues are going
{
F 2
to be implemented and we have told licensees what we 3
want done.
So we don't have a problem with it.
4 But we want to bring up the question of l
5 whether maybe these should be removed from that 6
reasonable assurance price status and possibly then 7
would be open for the questioning'in the proceedings.
i 8
So there might be some -- there are some USIs, generic 9
safety
- issues, and some SEP lesson learned issues i
10 which are not yet implemented.
So also what is 1
11 possible is as these issues do get implemented we 12 could revise the rule to bring these issues into the
-i 13 reasonable assurance finding.
i 14 COMMISSIONER CURTISS:
Let me follow up on 15 that.
Take ~the SEP issues that you've identified 16 here.
Is the concern here that we've resolved those
?
17 issues?
We took the old plants, beginning with the l
18-first 11.
We've identified where those plants didn't 19 meet the requirements in the early '80s.
And we have f
20 identified issues that if you went to the docket you 21 could find out how each of those 11 plants had 22 addressed or would address those issues?
23 DOCTOR MINNERS:
No, I think it's got to 24 be more the concern ' of we' re screening those issues 25 now to see which ones which we think are significant I
1 J-NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 3
(202) 234-4433
E i,;.,.
1 58
>I 11 1
issues, an?. we're going to put those into the generic 2
issue process.
And if those get resolved, they would L
3.
be unimplemented.
I don't think it's the concern of I
4 the plants that were reviewed under SEP.
It's these 5
issues which were lessons learned from the SEP program 6-which we haven't quite decided what to do with.
7 MR.
HELTEMES:
They apply to the other 8
plants of the same vintage, perhaps.
And what is 9
ongoing now within NRR is they're looking at those to 10 see if those lessons learned have been implemented by 11 any other mechanism.
12 COMMISSIONER CURTISS:
It's all in the 11.
13 We're comfortable with the 11 that were looked at.
>t 14 Other than those, it's the same vintage plants that if 15 you went to the docket it wouldn't be clear how those j
l l
16 SEP issues were resolved?
17 MR. HELTEMES:
We're trying to see if it
-l 18 is clear, to the extent to which it is clear, and 19 we're trying to see the residual where it is not L
20 clear, where the lessons learned may apply to those 21
- plants, i
22 MR.
TRAVERS:
Perhaps I can give you a l
23 sense of the numbers of issues that are involved.
The l
l 24 SEP lessons learned issues totalled some 27 issues I
i l
25 that were found to be generally applicable to-older l
C u.m NEAL R. GROSS 1323 Rhode Island Avenue, N.W.
l.
Washington, D.C.
20005 (202) 234-4433
p i
69 e
{-
l'-
1 plantn.
And we're in the process of evaluating those j
2 issues to see where and how they've either been 3
resolved or are being resolved in existing programs, 4
ongoing programs or programs that have been completed.
5 And what we've found is the overwhelming
't 6
majority of those issues, 23 of them to be precise, 7
appear at this time in our preliminary efforts to be 1
8 resolved through other programs that have been ongoing-.
9 or completed.
10 And now we're looking at four issues to 11 determine whether or not some additional actions need 12 to be taken, perhaps prioritized in a generic issue 13 program or a generic letter or something developed as 14 a result of our looking at those, for older plants.
15 COMMISSIONER CURTISS:
For the issues that 16 have not been resolved, the four that you've looked at 17 here and for the USIs and the GSIs, if you go through 18 and you identify unresolved issues for specific 19
- plants, how would those be treated in plant life 20 extension?
You suggested there'd be a possibility 21 that those would be contestable issues in the 22 proceeding.
23 DOCTOR MINNERS:
No, I think -- well, 1 24 guess anybody could bring up any issues.
But I think l
25 we would-say that our process has taken care of those 1
I.)
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
p L
4 i
60 1
and they should not be addressed in the licensing 2
procedures, because we have a procedure --
3 CHAIRMAN CARR Be no different in the 4
31st year than there was in the 39th year.
6 MR. TAYLOR:
And of course, we'll try to 6
clean them up in the process.
7 COMMISSIONER CURTISS:
Okay.
8 DOCTOR MURLEY:
We plan to treat it like 9
any other generic issue that's unresolved.
10 COMMISSIONER CURTISS:
Okay.
That was my 11 question.
12 MR. HELTEMES:
Becomes a compliance issue.
13 The inspection program will assure that the commitment' 14 of the licensee is properly and effectively carried t
16 out.
16 DOCTOR MINNERE:
I think he was talking 17 about unresolved issues.
18 MR. HELTEMES:
Resolved but unimplemented
-19 is what --
20 DOCTOR MINNERS:
Unresolved or 21 unimplemented?
22 COMMISSIONER CURTISS:
For the four 23 unresolved SEp issues.
24 DOCTOR MURLEY:
We intend to treat that as 25 a
generic issue to see whether it, in
- fact, is NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
p 1
(
61 I
applicable.
Is there a generic solution?
And if so, 4
2 is it applicable to that plant?
- Because, it's not y
3 obvious.
i 4
COMMISSIONER CURTISS:
- Okay, I
5 understand.
6 COMMISSIONER REMICK:
When do you expect 7
that effort will be completed?
y 1
i 8
MR. TRAVERS:
Our effort to preliminarily 9
go through the list to determine which have been 10
- resolved, in our view, is almost done.
Within a 11 matter of a couple of weeks, I expect that effort to 12 be completed.
13 Further efforts to determine whether or 14 not to put the remaining issues into the generic issue 15 hopper and prioritize them would be accomplished c
16 within several months, I would expect.
17 MR.
TAYLOR:
We can keep the Commission 18 informed of that.
19 COMMISSIONER REMICK:
Fine.
L 20 DOCTOR MINNERS:
(Slide)
Let's go to the 21 last slide, 17.
I'd like to discuss resources and 22 schedules.
23 The Commission asked us in the SRM to l
24 apply all of the resources necessary to implement this 25 rule.
And so far, I think we have adequate resources, c
r; e
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
,v.
62 I
kJ' 1
I know Research has added some more resources to do 2
the Part 51 rulemaking, and I understand that NRR is 1
3 staffing up also in their area.
So as far as 4
resources go at the moment, I think everybody's happy.
5 We also had the question about the 6
schedule, and the overall I guess, maybe for you 7
the bad news is that the overall schedule is not 8
changed.
W still are on a schedule to have the Part 9
54 rule issued May of
- 1991, before the first 10 applicant comes ab.
And we got that to the EDO on 11 April 30th on schedule, and he got it to you on the 12 3rd of May, which was about two weeks ahead of'the May
)
13 14th scheduled date.
So we're a little ahead of 14 schedule on the rule.
15 We hope to reschedule to publish the rule 16 in the rederal Reg / ster on the 29th of June.
And so 17 therefore, we need some time to go through the 18 mechanism.
We have to go and get some of these l
19 enclosures published so that they're available for the 20 public if they're requested.
We need to give this to l
21 OMB to look at.
So if we had an approved rule and l
22 accompanying documents, we could probably do it in a 23 month and possibly three weeks.
So somewhere around 24 the first of June is when we think we need approval so 1
25 that we can meet our 6/29 date.
l I
l
?
NEAL R.
GROSS l.
1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
63 1
The Part 51 rule is also scheduled 2
unchanged for its final.
We've had a little slippage 3
on some of the intermediate milestones.
I think we're 4
catching up on that.
We're not behind on any of the 5
major milestones, some of the interin milestones.
As 6
I
- said, we're applying more resources to that, so 7
we'll be there.
8 And I might note that the-draf t of the 9
Part 51 rule is scheduled to be published also in May 10 of '91 at the same time that the final rule is, Part 11-54.
12 We were urged to try to accelerate the 13 schedule for the standard review' plan and reg guide, l' i
' - ~ '
14 and we don't believe that we can do that.
We believe l
15 that we have a tight but meetable schedule and we l
l' 16 think it will work out, because this material will be 17 issued in December before the rule is issued and L
18 applicants wil.1 then have a chance to have a pretty 10 good idea of what we're' thinking of.
It ought to be 20 pretty near final form at that time.
21 We were also asked to look at the schedule 22 for industry technical reports, and we think that's a 1
23 very optimistic schedule and certainly couldn't be 24 accelerated.
The last technical report is scheduled I
25 to be submitted in August of this year, and our last i-s.
NEAL H.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433 i
64 1
SER is scheduled for September of '91, which seems to 2
be after the first application.
But these are not 3
necessary or critical to the leed plant reviews.
They 4
are basically doing this technical work themselves, 5
and in a lot of cases I think are probably out in 6
front of these industry reports.
And these would be 7
more useful later on when the bulk of applications 8
come in and we can get down to a kind of a generic 9
review of these things.
10 We would expect that we would we 11 anticipate that we revisit the rule after our 12 experience with the lead plants, also the SRp and the 13 reg guides and the question of current licensing basis
_y-
- s 14 and those kind of things.
We would use the lead plant 15 experience to see if any changes would be appropriate.
16 Unless there are further questions, that 17 completes my presentation.
18 CHAIRMAN CARR:
Commissioner Rogers?
19 Excuse me, Commissioner Remick?
20 COMMISSIONER REMICK:
Thank you.
21 First.
I want to commend the staff for 22 maintaining the schedule and urge that you continue to 23 do so.
24 Most of my questions have been answered 25 during the discussion, but in the statement of bi e _J NEAL R.
GROSS 4
1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
u
[
jf
...i' c
o i
l 66
{
I__-
'l considerations you refer to an average plant i
i 2
expenditure of about 197.600 person hours per -- for
,o+
3 the analytical and paperwork burden of this.
I o
[
4 couldn't find it in your regulatory analysis.
Is it 5
discussed in there how that was arrived at?
6 DOCTOR MINNERS:
We'd have to go find --
7 COMMISSIONER REMICK:
Okay.
You can get 8
back to me.
I was just curicon how it -- not 198.000 9
or 197,000, but 197,600, 10 CHAIRMAN CARR:
Take a little off for--
i 11 took a little vacation.
12 DOCTOR MINNERS:
Could you give me a page 13 reference for that, sir?
" '_j f
14 COMMISSIONER REMICK:
It's in the i
16 statement of considerations.
i 16 DOCTOR MINNERS:
Okay, we can find it.
17 COMMISSIONER REMICK:
Page 8 of the SECY i
-18 paper, I believe, and page 75 of enclosure 1, I think.
19 DOCTOR MINNERS:
Thank you.
20 CHAIRMAN CARR:
Sounded like 100 man 21 years.
22 COMMISSIONER REMICK:
What's that?
23 CHAIRMAN CARR:
Sounded like 100 man years 24 is what it sounded like.
25 COMMISSIONER REMICK:
Oh, yes.
That's I
.: J NEAL R. GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433 P
y
- ... +.
4 66 1
right.
Came to the same conclusion.
2 The other question, at any time, did we 3
amend the license or accept the commitment for a plant 4
on the basis that it would only operate for another 22 i
6 years to the end of its 40 year license or anything 6
like that?'
Have we ever?
And if so, how will we 7
handle those type of things in this license renewal 8
consideration?
9 DOCTOR MURLEY:
The answer is we may well
'10 have.
I mean I can't say, but there are some things 11 that are time dependent in our regulations, like the 12 pressurized thermal shock rule.
It could very well be y-13 that they have asked us for some relief on capsules or 14 something like numbers of capsules or timing of 15 capsules that we may have made a decision on with-16 regard to timing, th'e expectation of a fixed term.
17 Now, the reason I'm hesitant is we know we 18-can find that information out.
We just haven't done 19 it yet.
But insofar as there are those kinds of 20 things, we will need to know those when we look for I
21 the current licensing basis.
22 COMMISSIONER REMICK:
Do you think in the L
23 document we have people will logically think of that L
24 when they're going through this process?
In other u
25 words, will licensees logically include that type of IR
- J NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 i
(202) 234-4433 1
\\
. *4 L
67 F
I 1
situation?
2 DOCTOR MURLEY:
I think what we're going J
i 3
9 have to do is a special task to think of those 4
cases that may have come up just like that and then l
5 have a dialogue with the industry to do that.
I think 6
it's a very good idea.
7 DOCTOR MINNERS:
I don't know if this is 8 --
exactly what you're considering, but in the proposed 9
rule -- sir?
10 CHAIRMAN CARR:
No, go ahead.
11 DOCTOR MINNERS:
In the proposed Rule i
12 54.21(b), it discusses exemptions which was of concern i
13 to us which says if you've got an exemption, you have 14 to go review that exemption to see if it was based on
"'~
15 some assumed service life and is still applicable for L
16 the renewal --
l 17 COMMISSIONER RENICE:
Well, that certainly
.P
-18 would catch exemptions, but there might have been yes.
There might have been 19 others that we decide 20 something exempted on that basis, but there might have 21 been other --
22 DOCTOR MINNERS:
Well, also when they go 23 through their affected program analysis, they would
~
24 have to look and see if they have an effective program 25 and demonstrate that's an effective program for the a
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
7o.,-
i-
- 68 1
{J'
-renewal term as well as for --
l 1
2 CRAIRMAN CARR:
Plants are a
lot more 3
likely to be tracking that then we are, I would think.
i 4-COMMISSIONER REMICK:
I hope.
That's all j
t 5
I have.
i G
CRAIRMAN CARR:
Cornissioner Roberts?
i 7
COMMISSIONER ROBERTS:
Well, no questions, 8
just an observation.
This is a terribly important 9
issue and a very complex one and I think you're doing 10 an excellent job with the proposed rule and we look 11 forward to a comment from the public and interested l
12 parties.
13 CHAIRMAN CARR:
Commissioner Rogers't 4
y 14 COMMISSIONER ROGERS:
Well, I would second
'~
15 that.
I think staff's been doing an excellent job 16 here.
17 Just how do these steps that the lead
'18 plants have been using in this process compare to your 19 screening methodology?
Are they following something 20 close to that?
21 DOCTOR MINNERS:
- Similar, but not
=;
22 identical.
23 MR. TRAVERS:
Commissioner.
I'd like to 24 speak to that.
We've taken a look at Yankee-Rowe's i
25 methodology report to date.
We expect a methodology q-L-
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Nashington, D.C.
20005 (202) 234-4433
.I l
.s
>,a-
)
!~
69 l
[-
{
i 1
report in June for Monticello, the second hot plant.
i 2
Their screening methodology is quite close to what the i
3 rule states and we expect it's going to be quite close 4
to the NUMARC methodology that's being put together f
5 ultimately.
Some differences, but we expect that 6
those will be worked out.
i 7
COMMISSIONER ROGERS:
Good.
That's all I 8
have.
9 CHAIRMAN CARR:
Commissioner Curtiss?
10 COMMISSIONER CURTISS:
I don't have any 11 further questions.
I just want to commend the staff 12 for getting the paper up here early.
They've done a 3,
13 remarkable job.
1 I
" ~ ~ '
14 CHAIRMAN CARR:
I've got a
couple of 15 questions.
16
- One, on page 24 of the statement of 17 consideration, the same page that Commissioner Roberts
[
18 mentioned, the last sentence in paragraph 2 of that 19 page, it says, "Such licensee-initiated changes in the 20 current licensing basis would be subject to challenge l
21 in a hearing "
It appeared to me that if the licensee 22 opts to take a
little margin out but he's still 23 adequately safe and meets the adequate safety margin, l
1 24 why do we have to have a hearing if we've got adequate 25 protection and all he's done is remove margin above
.1
)
NEAl, R.
GROSS 1323 Rhode Island Avenue, N.W.
i Washington, D.C.
20005 (202) 234-4433
i e4,.,-.-
1 70 s
1 adequate protection?
1 L
2 MR.
PARLER:
This doesn't say that you 3
have to have a hearing. Mr. Chairman.
It says it's j
4 subject to challenge.
Some interested party who say s
5 be an intervenor in the proceeding may not agree that a'
6 there's adequate
- margin, may not agree with the j
i s
7 licensee, may not agree with the staff.
That's what 8
that sentence is about.
9 CHAIRMAN CARR:
So, it wouldn't i
10 necessarily mean he got a hearing?
j 11 MR.
PARLER:
It means they have an 12 opportunity to challenge it.
q 13 COMMISSIONER ROBERTS:
Challenge it, not
\\'
.p - ;!
14 necessarily a hearing.
~
15 CHAIRMAN CARR:
Okay.
The second one is 16 on page 40 of the statement of considerations, I'm 17 concerned that we've got something in there that will 18 cause us some problems when you say the last sentence 19 in the first paragraph, talking about a sufficient l
20 renewal application.
If somebody's going to challenge 1
us on the sufficiency because you go back and ask then 1
21 I guess I'm really 22 some questions, is there any 23 curious as to why you have to specify a sufficient l'
24 application.
25 DOCTOR MINNERS:
Well, the extreme example 1
c]
.. J NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
y, h;'
r
..g.,.,.
i 6 -
i 71 1
F$-
I where somebody would send in a postcard and say, "I
c'
\\
-l 2
want to renew my license."
3 CHAIRMAN CARR:
Well, but you're putting 4
out a guide on what constitutes what you want in the
)
6 application, right?
6 DOCTOR MINNERS:
And that would define 7
sufficient.
?
the 8
MR.
PARLER:
The timely renewal 9
benefits of the timely renewal document we get comes I
10 from the Administrative Procedure Act and the 11 adjective that you are talking about stems from the t
t 12-requirements in that act, 13 CHAIRMAN CARR:
Yes, I gathered that.from
$1 14 the staff.
15 MR. PARLER:
That sentence would be overly stringent just to make sure that we didn't get 16 17 something frivolous so that by filing something 18 without any foundation at all, the applicant could get 19 the benefit of the time or renewal provision of the 20.
law.
21 CHAIRMAN CARR:
Okay.
So you don't think l
22 we'll get in an argument over the sufficiency?
~
23 MR. PARLER:
I would never sit here and 24 tell you that you'll never get in an argument.
25 CHAIRMAN CARR:
I was trying to keep from r
r NEAL H. GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
p o
g
, =.
72
]
J l
getting into an argument.
/,
2 MR.
PARLER:
- Well, our colloquy just t.
3 helped minimize what the disastrous result might be if 4
somebody tried to make a mountain out of a molehill.
5 CHAIRMAN CARR Well, I too would like to 6
thank the staff for the briefing.
As you know, this 7
item is has been tops on my priority list.
I think 8
it's the most important thing we're doing right now 9
for the country because if we can't renew the licenses 10 for that 20 percent of the power that's out there and 11 there's nobody building new plants of any kind, why 12 the country is going to be in trouble.
So it's 13 important that we be able to get our work done.
" ~j 14 It appears that all the offices, Research, 15 NRR and OGC, have worked closely together to come to 16 the proposed license renewal rule on schedule and I 17 commend you for this and I also commend the EDO, who I 18 know Jerked a
few tight knots to make sure that 19 happened.
But I appreciate that and I know there's a 20 lot of hard work that went into it.
21 I'll be looking forward to receiving 22 comments on the proposed rule and urge you to 23 carefully consider such comments as well as any
.24 further information gained from the aging research 25 program in developing the finni rule, r _.
NEAL H.
GROSS f
1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
3.....
f 73 I
+ -...
1 Any of my fellow Commissioners have any 2
additional comments?
3 Well done, gentlemen.
4 (Whereupon, at 3:33 p.m.,
the above-6 entitled matter was adjourned.)
6 7
8 9
10
'll 12 13 I
t.,_.-
34 15 16 17 18 19 20 21 22 23 24 25 NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433
1 i
- n s f.,-
7.-
j i
l CERTIFICATE OF TRANSCRIBER j
This is to certify that the attached events of a meeting i
i of the United States Nuclear Regulatory Commission entitledt I
TITLE OF MEETINGt BRI'EFING ON PROPOSED RULE ON LICENSE RENEk'AL
)
i PLACE OF MEETINGt ROCKVILLE, MARYLAND DATE OF MEETINGt MAY 16. 1990 were transcribed'by me. I further certify that said transcription 1
is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
Ltb
- -i < m. f j
g u.
Reporter's name:
Peter Lynch 1
1 1
1
?
k NEAL R. GROSS
.0Utf RfD0ttft$ AND TRANSCRitth$
1333 RN000 ISLAND AYINUI, N.W.
(909) #34 4433 WASNW470N,D.C. 2000$
(202) 232 0600 t
s.
n.
4 COMMISSION BRIEFING
~
f.
PROPOSED RULE ON NUCLEAR POWER PLANT LICENSE RENEWAL l
i I
i i
WARREN MINNERS, DIRECTOR i
DIVISION OF SAFETY ISSUE RESOLUTION OFFICE OF NUCLEAR. REGULATORY RESEARCH i
MAY.16,1990 r
G L
l.
v.
OUTLINE OF PRESENTATION i
i o
TWO PRINCIPLES OF APPROACH i
o KEY RULE PROVISIONS k
o ISSUES i
o QUESTIONS o
SCHEDULE -
9 l
I 1
I
~.
TWO PRINCIPLES y.
o CURRENT LICENSING BASES i
ADEQUATE FOR RENEWAL TERM,- EXCEFF AGING CARRIED FORWARD NO NEW FINDINGS, NOT IN SCOPE OF PROCEEDINGS o
AGE-RELATED DEGRADATION MANAGEMENT FOR. SYSTEMS, STRUCTURES, & COMPONENTS l
IMPORTANT TO LICENSE RENEWAL l
FINDING BECOMES BASIS FOR LICENSE RENEWAL l
PROCEEDINGS LIMITED TO THIS ISSUE l
2
,., ~ _
.. ~
. - -....~..
T i
CURRENT LICENSING BASES i
o PLANT-SPECIFIC i
o NRC REQUIREMENTS & LICENSEE COMMITMENTS ON DOCKET.IN EFFECT AT TIME OF APPLICATION ORIGINAL SUBSEQUENT i
4
.i o
RULE, STATEMENT OF CONSIDERATIONS a
I SUPPLEMENT TO SOC ON FOUNDATION FOR ADEQUACY
- NEW SINCE 1/90 I
3 i
i
_k2
~
-CLB 1 RULE o
CLB DEFINED INLRULE
"]'
o COMPILATION BY. LICENSEE i
J NOT SUBMITTED TO NRC*
BUT AVAILABLE FOR AUDIT USED:IN SCREENING PROCESS o
o CLB BECOMES A PART OF RENEWED LICENSE l
INCORPORATED INTO AND DEEMED PART OF LICENSING DOCKET o
REASONABLE ASSURANCE MNDING [50.57-(a)] NEED NOT-BE MADE ANEW i
CHANGE SINCE 1/90~
1 1
4' 1
?
'j
_....,n
_. ~.,
,,J_
~ ? 'T "
1,
- ~
.t
' 6 T.
~'b.'.
., i
I
. o PROCESS FOR EVOLVING LICENSING BASES 1
1 o
COMPLIANCE FINDING NOT REQUIRED.
1 a
l i
LICENSEE. PROGRAMS a
NRC REGULATORY. OVERSIGHT l
o n
+
5 1
a
.--=.a-..
y.
,3~
~
CLB - FOUNDATION FOR - ADEQUACY o
SUPPLEMENT TO SOC *
-DESCRIBES EVOLUTION OF LICENSING BASES IN.
o MAJOR SAFETY ISSUE AREAS-PROCESSES THAT HAVE ENSURED CONTINUED ADEQUACY OF OLDER PLANTS SUPPORTS GENERIC FINDING THAT REASONABLE o
ASSURANCE FINDINGS FOR OLs CONTINUE TO. BE TRUE o
SITE CHANGES:
HAZkRDS, DEMOGRAPHY NEW SINCE 1/90
~
6
)
w c; x u; ; '
~
- ~~ m t
=
AGE-DEGRADATION MANAGEMENT FOR SYSTEMS, STRUCTURES, AND COMPONENTS o
IMPORTANT TO LICENSE RENEWAL DEFINED AS:
SAFETY-RELATED SSCs FOR DESIGN BASIS EVENTS SSCs IN SAFETY ANALYSES NEEDED TO MEET'CLB SSCs WHOSE FAILURE COULD PREVENT ACCOMPLISHMENT OF SAFETYt FUNCTIONS POST-ACCIDENT MONITORING: EQUIPMENT BUT CLB PROVISIONS ARE ADEQUATE FOR; TIME-o RELATED CHANGES AFFECTING EMERGENCY PLANNING, SECURITY, OPERATOR LICENSING,:AND FINANCIAL QUALIFICATIONS 7:
p-
~
- y 3;s. l h.*
AGING MANAGEMENT - RULE o
DEFINITIONS 1
~
o INTEGRATED PLANT ASSESSMENT 1
SCREENING PROCESS STEPS SPECIFIED*
APPLICANT TO DESCRIBE METHOD:FOR EACH L
STEP a
o CREDIT FOR ESTABLISHED EFFECTIVE PROGRAMS.
o LICENSE CONDITIONS AS NEEDED TO ' ADDRESS AGE-
)
RELATED -DEGRADATION i
.i NEW SINCE 1/90 1
I i
8 t
y
.- i
--=-J--
~ - - ~-
~?
c--
~
v
~
SCREENING - STEPS *
(1) IDENTIFY & LIST ALL SSCs IMPORTANT.TO LICENSE-RENEWAL (2) IDENTIFY & LIST CONSTITUENT ELEMENTS (STRUCTURES & COMPONENTS) OF SSCs FROM. STEP:(1)
THAT ARE NEEDED FORLSAFETY FUNCTION (3) IDENTIFY & LIST STRUCTURES & COMPONENTS FROM.
(2) THAT ARE SUBJECT TO ESTABLISHED EFFECTIVE PROGRAMS-(4) DESCRIBE ACTIONS FOR STRUCTURES & COMPONENTS FROM STEP (2) THAT -ARE NOT COVERED BY PROGRAMS OF STEP (3); SHOW ADEQUACY REFINED SINCE 1/90 9
- 3..
w
)
- Q.
~
34.21(a)(1):
- y.
543(a)(l) 543(*)(2) -
543(a)(3)
. 343(eli4i :
- / l9 g
g' SSCs usedin a safety Nonsafety-retaled SSCs M soddert 4
M We satis
.r o
1 I-I SSCsimportart tolicense renewal
. Does the structure or component s
54 n ie> m or
. Does failure of the strudeae U.
orcomponent produde a system EYO I
l l
y Yes l l No e
N is thees an estabilshed No furtheradlon l
54.21(e)(3) eWedive program for the structure orcompeaent?
i No l IYes Does detailed evaluellen inscase that degradation No further adlon
-l l
5f.21(e)(4)
- ce tre structure or -
componentis l
wilh respect to CLB7.
I
..Yes, [
l No l
i KNK2 ribe and provide d
the basis teTadion No tuveeradlon 6
o i
R O
Figure 3.1 ' Integrated plant assessment for identifying o
y structures and components for aging management.
o
.i 3
M u,
.+
w-
_n,
, ~+
<s---ne--
-n
-m-
~ N,.e
~.
=
w r
9
~
,Im -.,Aty r+,..
,w---g a
, c ~y, w e eN.v-,+,--m es m-e
.w,
,,_. -.s w-
....g, c
w u-.
- or
..a.
~
REQUIRED NRC FINDING j
o WITH RESPECT TO AGE-RELATED DEGRADATION:
o 1
l FOR SSCs-IMPORTANT TO' LICENSE RENEWAL i
ACTIONS TAKEN OR TO BE TAKEN GIVE i
a REASONABLE ASSURANCE THAT ACTIVITIES CAN BE CONDUCTED IN-ACCORDANCE WITH CLB i
a l
10
'~
i.
- 1. _
g.
~^
~ ' '
O
=.
~
1 PROBABILISTIC RISK ASSESSMENT
- 1 o
SCREENING.AND AGING MANAGEMENT APPROACHES-MAY INCLUDE PRA AS SUPPLEMENT TO.. DETERMINISTIC METHODS AT LICENSEE OPTION
{
o AGING DATA AND MODELS NOT DEVELOPED y
INCREASED USE OF PRA ~MAY BECOME-APPROPRIATE AS AGING RESEARCH' PROGRESSES CHANGE SINCE 1/90
?
l 11 l
q
_~.
. - -H
(. _
^
I' d T. :
BACKFIT-o PART 54 RULEMAKING NOT SUBJECT a
o o
NO COST-BENEFIT TEST FOR AGING. MANAGEMENT REQUIREMENTS NEEDED:
1 FOR ADEQUATE' SAFETY q
TO MAINTAIN CLB o
COST-BENEFIT TEST FOR AGING MANAGEMENT REQUIREMENTS -THAT GO BEYOND CLB
]
i o
BACKFIT RULE APPLIES TO NON-AGE-RELATED CHANGES IN CLB o
NO CHANGE IN BACKFIT RULE
[
12t j
. a
_m w.
. t
,g,
.x t
n i
SCOPE OF PROCEEDINGS o
LIMITED TO ACTIONS TO MANAGE -AGE-RELATED i
DEGRADATION OF SSCs IMPORTANT TO LICENSE
' RENEWAL o
NOT IN SCOPE:
ADEQUACY OF1CLB j
~b CLB CHANGES NOT RELATED TO LICENSE i
RENEWAL
'l 13 s
b
.hm+-w
.a*
{.9h,,
w.
w.
m*'e,w, g-%
q.
,,-h.
syg-,e
--w
,p**.E,4,,s-
.nri g _
,,.-g-g_
f.
n w
~
~~ V 2
h T
DECOMMISSIONING i
o NOTIFICATION-[50.54 (hb)]:
1 DUE.5 YR BEFORE OL EXPIRATION, BUT RENEWAL 1 d
APPLICANTS FILING. AT LEAST 5 YR: AHEADiARE-EXCUSED i
DECOMMISSIONING. PLAN [50.82 (a)]:
l o
I DUE 1.YR BEFORE OL EXPIRATION, BUT TIMELY RENEWAL APPLICANTS MAY POSTPONE TO 1 YR' j
'(MAX.) AFTER DENIAL OF RENEWAL-t i
i l
- 1 14 il
..~.-.
. _ _ = _, _ _ _ - _ _ _ _ _ - _ _ _ _
e
~
. s ;;
~
's
'~'.
- II,
~
l ENVIRONMENTAL IMPACT 4PART 51)
- l i
~)
o SUPPLEMENT TO EIS MAY BE EA OR -EIS l
WITHOUT PART 51 CHANGE EIS WOULD BE REQUIRED 1
EIS WOULD STILL BE REQUIRED IF EA DOES NOT SHOW INSIGNIFICANT IMPACT 1
i 4
CHANGE SINCE 1/90 J
15
.i
.-_y
~.
._.,.<,.._,.i.~_.w,.,.-
y,
-.,.~..,.w..,,,s,
a
~
TV
^
-0 OUESTIONS IN SOC 1.
ANY. EQUIPMENT OR TOPICS TO BE XCLUDED.
FROM AGING-MANAGEMENT REVIEW?
2.
ANY EQUIPMENT OR TOPICS INVOLVING CHANGES-OVER TIME TO BE: ADDED TO REVIEW REQUIREMENTS?
E.G.,. SITE -HAZARDS, DEMOGRAPHY?
3.
SHOULD RESOLVED, UNIMPLEMENTED ISSUES BE REMOVED FROM REASONABLE ASSURANCE FINDING [50.57(a)]?
USIs, GSIs, SEP " LESSONS LEARNED"?
16
^_
y..f
=
SCHEDULE OVERALL ' SCHEDULE 7NOT CHANGED.
o FINAL RULE"PART 54 5/91 i
FINAL RULE PART 51 4/92 o
STANDARD -REVIEW PLAN, REG. GUIDE l
i ISSUANCE.FOR COMMENT BEFORE FINAL RULE L
o INDUSTRY: TECHNICAL REPORTS i
l o
REVISIT RULE, SRP/RG AFI'ER LEAD PLANTS EXPERIENCE 3
17-
- ~
Tl Mi n,.b ] :
l l 1"933.SSWWA4YdhWWWWWWWWA%%WWWWWWW>fi @Whgggggggyyyy 4
q i.
f P.At!SMITTAl. 'TO: >M Document Control Desk, 016 Phillips.
~ ADVANCED COPY TO:
The Public Document Room
/
s g1 o
f22 M/ 96 5l DATE:-
[$
.FROM:
SECY Correspondence & Records Branch 3,
.i Attached are copies of a. Commission meeting transcript and related meeting
)
document (s). They are being forwarded for entry on the Daily. Accession-t.ist and
-j placement in the Public Document Room.
No other distribution is requested or
- j
'l 1
required.
' Meeting
Title:
' d > $ / > A M-MM s -
A l
NC - >
M w,A h
Meeting.0 ate:
f//4./ 9 o Open I Closed 1
I I
b E
Item Description *:-
Copies Advanced DCS
<[t
- s-to POR
. C3 L
tis '
4 t-L
- 1. TRANSCRIPT 1
'l
?!O hj/A a n l
L, l
/
t l-2*
L t
t ii
.y 1
t 3.
2
.2
'f l.. 22 H
t 4.
e l1 L
g e
1 t
b --
3 g i-k 3-l' 3
5.
c E
l-
~.
e u
r-y-
~
J-1
- 5:
C&R Branch files the original-transcript, with attachments, withcut SECY
.5
- PDR:is advanced one. copy of each document, two of each SECY paper.
[
j papers.
p2, j
l' 3!
A / AR.
"r kkkk