ML20044B922
| ML20044B922 | |
| Person / Time | |
|---|---|
| Issue date: | 03/03/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Curtiss NRC COMMISSION (OCM) |
| References | |
| NUDOCS 9303150009 | |
| Download: ML20044B922 (9) | |
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RELEASED TO THE PDR
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l NUCLEAR REGULATORY COMMISSid!4 * *
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Marcn 3.-1993 MEMORANDUM FOR:
Commissioner Curtiss t
FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
LICENSE RENEWAL RULE IMPLEMENTATION ISSUES 1
l Enclosed are the answers to questions concerning license renewal you posed in a memorandum dated February 9,1993..The answers reflect the staff's proposed approach for implementing the license renewal rule (10 CFR Part 54),
and have been coordinateu with the Office of the General Counsel. The staff's i
approach is fully described in the forthcoming SECY paper on which the staff will brief the Commission later this month.
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esM. Thor xecutive Director for Operations
Enclosure:
Questions and Answers cc: The Chairman Commissioner Rogers Commissioner Remick Commissioner de Planque SECY 0GC OCA OPA CONTACT:
R. Nease, NRR 504-3146 9303150009 930303
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I hest on 1.
Please discuss in detail what the staff sees as the impediments or cifficulties to applying the current license i
renewal rule in a manner that would permit the agency to find that structures and components are not subject to age-related i
degradation unique to license renewal in accordance with the l
t provisions of Paragraph 54.21(a)(3) of the rule if their performance and/or conditions are managed in an engoing manner in accordance with the provisions of the maintenance rule?'
answer.
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The rule prescribes an integrated plant assessment (IPA) which recuires i
identification among those structures and components (SCs) noted as important to license renewal (ITLR), of SCs that could be subject to age-related degradation unique to license renewal (ARDUTLR).
Since the rule defines ARDUTLR to include aging whose effects were neither explicitly evaluated by j
t the appli: ant nor approved by the NRC for the period of extended operation, the staff expects that most of these SCs could be subject to ARDUTLR.
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' During the staff's presentation, the staff stated that in order to eliminate structures and components under Paragraph 54.21(a)(3), license renewal applicants would have to explicitly address, at the cceponent level, individual age-related degradation mechanisms and cited the recuirements of 3 ara;raph 54.21(a)(4)(iii) as the basis for this position.
Paragraph 54.E(a)(4)(iii) requires that a renewal applicant describe ano ;ustify:
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"The technical criteria 10 be used in determining wnetter an SC is subject to age-related degradation unique to i
,ncense renewal "
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f ENCLOSURE i
Although some long-lived ITLR equipment might be identified by the applicant as not being subject to ARDUTLR, a demonstration that this equipment could not have ARDUTLR would require a detailed justification by structure-or component-specific inspection and/or analysis.
Relatively short-lived equipment that is replaced at a fixed interval could also be identified as aqt subject to ARDUTLR.
Such identification would, however, require an applicant to provide detailed SC-specific justification in the application. The staff expects that the justification for conclusions that such equipment has no ARDUTLR will be based on commitments for continuing licensee action to
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periodically replace equipment.
f.:. provided in 10 CFR 54.33(b), the staff can include license conditions and technical specifications as necessary to ensure that licensee actions will be continued so that equipment will not experience ARDUTLR.
In determining whether or not technical specifications or license conditions are necessary, the staff will consider such factors as safety l
r significance, the nature of administrative controls on commitments and changes to consitments, and reporting requirements.
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Question 2.
Please discuss in detail what the staff sees as the impediments or difficulties to applying the current license t
renewal rule in a manner that would permit the agency to find that structures and components are covered by an " effective program" in accordance with Paragraph 54.21(a)(5)(1) of the rule based solelv upon the fact that their performance and/or conditions are managed in accordance with the provisions of 2
i the maintenance rule?
Explain in more detail the basis for the staff's position that the maintenance rule, alone, is not sufficient basis upon which to conclude that a licensee has an
" effective program."
In this regard, explain why agency reliance on the actions that a licensee takes pursuant to the maintenance rule is acceptable for currently operating plants, even though not all structures and components covered under that rule are subject to technical specifications or other regulations, but would not be sufficient in the context of license renewal?
2During the staff's presentation, the staff indicated that licensee actions carried out pursuant to the maintenance rule, alone, may or may not, as a technical matter, constitute an effective program under the license renewal rule. At the conclusion of the presentation, it was unclear whether the staff believed that, as a legal matter, effective programs must also be specified by rule, technical specification, license condition, or docketed commitment. The staff was also unclear as to the level of specificity required in any or all of the foregoing to satisfy the requirements of the license renewal rule. The language of Paragraph 54.33(b), would seem to suggest that the agency has considerable discretion in specifying whether or not license conditions or technical specifications are " appropriate and necessary to address age-related degradation unique to license renewal."
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Answer.
The staff believes that actions carried out pursuant to the maintenance rule could, for many structures and components (SCs), provide a sufficient sr'a basis for demonstrating an " effective program" in accordance with 10 CFR 54.21(a)(5)(i) and 10 CFR 54.21(a)(6). However, in order to establish that such actions constitute an " effective program" for an SC, information on program specifics (e.g., performance or condition monitoring acceptance criteria) would need to be submitted in the license renewal application.
Rather tnan generic reliance on the maintenance rule (MR) to establish that an SC is subject to perfomance or condition monitoring and corrective action requirements, the license renewal rule (LRR) requires, at "54.21 Contents of application - technical information," that the application include information which describes programs determined to be " effective." This information must be reviewed for approval by the staff to support the agency findings, at 54.29(a), for issuance of a renewed license. This LRR requirement is substantively different from the MR requirement in that the MR does not involve issuance of an NRC license and does not require licensees to submit j
i information on their implementing programs for approval.
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The staff believes that 54.33(b) gives the agency the discretion to decide whether or not actions taken to manage &ge-related degradation unique to license renewal (ARDUTLR) should be subject to technical specifications or license conditions. Although the staff's proposed IPA approach recognizes that most SCs may alreaoy be subject to " effective" programs as a result, in part, of being directly subject to technical specifications or regulations, 4
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the approach also recognizes that other existing programs may also be cetermined to be " effective." The staff expects that most programs which are etermined to be " effective" but which are not already subject to technical specification or regulation, will not require impositicn of such requirements.
Accordingly, effective programs would be demonstrated by program comitments described in the application. Program comitments described in the application and relied upon to demonstrate an " effective program" would become subject to the change and reporting requirements of 54.33(d) and 54.37(c).
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Ouestion 3.
Regarding Paragraph 54.21(a)(6), what latitude does the agency have in determining acceptable levels of rigor and specificity in the showing required by this provision? Could a process.
for the development and use of acceptance criteria be presented and justified in the application in lieu of -
individual acceptance criteria for each SC [ structure and
'i component]?
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- Answer,
- l Paragraph 54.21(a)(6) requires that an effective program for addressing age-
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related oegradation unique to license renewal (ARDUTLR) must be described for -
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each SC identified in 54.21(a)(5)(i), and must be demonstrated to be effective in maintaining the current licensing basis. An effective program is one that (1) identifies and mitigates ARDUTLR, (2) hcs' acceptance criteria against '
which the need for corrective action will be evaluated, and (3) is implemented by facility procedures and reviewed by the onsite review committee. The staff j
believes it has considerable latitude regarding the rigor and specificity necessary to show that a program is effective in managing ARDUTLR. For.
instance, the staff is proposing that structures and components that are
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subject to ARDUTLR can be shown to be covered by an effactive program in groups rather than on a component-by-component basis. Additionally, although
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the rule requires tnat appropriate acceptance criteria be identified in the application, the rule also establishes a process for modifying acceptance
-j criteria as conditions change. The rule (10 CFR 54.33(d)) gives renewal
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licensees flexibility in making changes that do not decrease the effectiveness of their programs for managing aging.
The staff expects that upcoming activities with the Babcock and Wilcox Owners Group will be particularly useful in providing specific review issues, including methodology justifications, for evaluation.
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9 Question 4, The license renewal (LR) rule does not provide for the use of PRA (probabilistic risk assessment) in the IPA (integrated plant assessment) to screen out SSCs (systems, structures, and f
components) as not important to license renewal. To what extent, if at all, could PRA insights be employed to provide the basis for determining that an effective program is unnecessary in accurdance with the provisions of Paragraph 54.21(a)(5)(ii), or the appropriateness of acceptance criteria established pursuant to Paragraph 54.21(a)(6)(ii)?
Answer.
The LR rule does not provide for the use of PRA insights as justification that an effective program is not necessary nor does the LR rule provide for use of PRA insights as the basis for determining that specific acceptance criteria i
pursuant to paragraph 54.21(a)(6)(ii) are appropriate.
Specifically, PRA cannot be used as the basis to excuse the development of an effective program to ensure the CLB is maintained during the renewal term.
To the extent that risk insights were used to develop the specific criteria contained in the current licensing basis (e.g., Emergency Diesel Surveillance Testing), the i
license renewal rule would permit continued use of such criteria in a licensee's assessment.
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