ML20137B568
| ML20137B568 | |
| Person / Time | |
|---|---|
| Issue date: | 03/20/1997 |
| From: | Hoffman S NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-690 NUDOCS 9703240004 | |
| Download: ML20137B568 (7) | |
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UNITED STATES p'
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NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 2055H001 March 20, 1997 ORGANIZATION: Nuclear Energy Institute (NEI) l
SUBJECT:
SUMMARY
OF M UTING WITH NEI.REGARDING THE NRC STAFF'S REGULATORY GUIDE AND NEI'S GUIDELINE FOR IMPLEMENTING THE LICENSE RENEWAL RULE On March 6,1997, representatives of NEI met with the Nuclear Regulatory Commission (NRC) staff in Rockville, Maryland to present views on proposed guidance for inclusion in the final version of either the NEI " Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - the License Renewal Rule," NEI 95-10, or the NRC staff's Regulatory Guide (RG), " Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Lfcenses." A list of meeting attendees is provided in Attachment 1.
NEI requested the meeting to obtain clarification of NRC staff positions contained in the staff's letter to NEI dated February 27, 1957. Following is a summary of staff clarifications provided at the meeting in response to NEI questions pertaining to parts of the letter.
The numbers, titles, and references that follow refer to the Enclosure to the February 27, 1997, letter.
1.
Creditina existina oroarams The elements of an aging management program (AMP) and cemonstration are delineated in NEI 95-10, Sections 4.2.1.2 and 4.2.1.3.
As stated in the staff's position, an applicant may make specific reference to a previous staff review and acceptance of each of the elements in lieu of providing the discussion in the renewal application. The elements need not be specifically addressed in the staff's acceptance document, but may be contained in the licensee's submittal previously evaluated by the staff.
If all elements are not addressed in the staff's previous review, an applicant would then provide the additional information in the renewal application for those elements.
Th' staff will review the adequacy of the proposed existing program for license renewal.
2.
Desian loads and acina manaaement orocram acceptance criteria (alert values)
For aging management programs that monitor a certain parameter and take i
corrective action when this measured parameter does not meet a specified k} \\
acceptance criterion, the application should describe the applicable I
!g acceptance criteria, current licensing basis (CLB) design loading conditions, en
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and parameter mea ured for all structures and components subject to aging V
management. The application should also discuss that this criterion is based on ensuring the structure or component intended function under all CLB design loads. Acceptance criteria need not be numerical values and details should be maintained onsite.
The same information should be provided for commodity groupings. However, the CLB design loading information is not needed if a gj'2M834*2o (U)KT' k r pU NRC FILE CENTER COPY &ss
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f i program does not permit structure or component degradation, such as a coating program to prevent corrosion that requires coating repair when coating degradation is detected. An applicant would not have to justify in the application acceptance criteria taken directly from the final safety analysis report (FSAR) or other documents incorporated by reference into the FSAR.
4.
" System" versus " component" level intended _ function The first paragraph of the staff's position stated that "For license renewal, the effects of aging on a component must be managed to ensure its availability to perform the component inter.ded function as designed when called upon."
With respect to "as designed," the required component design loadings that must be ensured may be derived from the system design loadings.
5.
"Ob.iective evidence" from operatina experience The rule does not explicitly require an applicant to provide operating experience for all existing programs. However, as stated in the stacements of consideration for the license renewal rule (56 FR 64963) and in NEI 95-10, Section 4.2.1.1, the applicant should assess plant and industry operating experience in performing its aging management review.
The application must demonstrate that the AMP will manage the effects of aging.
Providing operating experience in the application for the AMP supports the demonstration of program adequacy. A summary description of the experience should be provided in the application. This summary description should also include a discussion of any significant enhancements made in the program resulting from l
past corrective actions.
Detailed operating experience should be maintained onsite.
8.
Appendix C examples The _ intent of the regulatory guide is to establish the format and content of a license renewal application. The regulatory guide is not intended to establish the technical adequacy of aging management reviews and programs for specific components or structures. The staff recommends deleting the examples. However, the staff would consider leaving the examples in NEI 95-10 with caveats as examples of implementation of the NEI 95-10 process.
9.
Information for existina and new oroarams NEI asserted that all elements listed in NEI 95-10, Section 4.2.1.2 may not always be applicable. For example, NEI suggested that only one of the first two elements needs to be addressed as the first element addresses the prevention or mitigation of an aging effect and the second addresses management of an aging effect that is occurring. NEI indicated that its original intent was that these elements should be considered by an applicant establishing an AMP and were not intended to be necessary elements for every AMP. The staff expects that all AMPS contain these elements which should be addressed in the application.
If an applicant determines that certain
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.- elements are not applicable to a specific AMP, the applicant should discuss any non-applicable elements in its application.
Schedule NEI requested additional time to prepare the requested response to the staff's February 27, 1997, letter and obtain concurrence by its industry senior management steering group. The staff agreed to NEI's submittal of a letter containing the industry's working group response by the requested date of March 13, 1997, followed by a confirmation letter concurred on by senior management by March 20, 1997.
The next working level meeting between the NRC staff and NEI is scheduled for March 20, 1997. A meeting between NEI, industry senior management, and the Director, Office of Nuclear Reactor Regulation, will be scheduled after the staff has received and evaluated NEI's response to its February 27, 1997, letter.
a,_.
Stephen T. Hoffman, Senior Project Manager License Renewal Project Directorate Division of Reactor Program Management l
Office of Nuclear Reactor Regulation Project 690 l
l Attachments: As stated cc w/atts:
See next page
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i NUCLEAR ENERGY INSTITUTE (NEI) 1 i
Project No. 690 cc: Mr. Dennis Harrison i
U.S. Department of Energy NE-42 Washington, DC 20585 j
Mr. Douglas J. Walters Nuclear Energy Institute 1
l 1776 I Street, NW i
Suite 300 Washington, DC 20006 Mr. Richard P. Sedano, Commissioner State Liaison Officer
' State of Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, Vermont 05620-2601
p DISTRIBUTION w/ attachment:
'1Centrat' Filer:t PUBLIC PDLR R/F ACRS OED0 0-17-G21 E-Mail SCollins/FMiraglia/(SJC1/FJM)
RZimmerman (RPZ)
TMartin (TTM)
DMatthews (DBM)
SMeador (SAM)
RJohnson (REJ)
RCorreia (RPC)
RWessman (RHW)
JStrosnider (JRS2)
SDroggitis (SCD)
SPeterson (SRP)
Glainus (GCL) l JCraig (JWC1)
JVora (JPV)
BMorris (BMM)
JMoore/EHoller (JEM)/(EJH)
GMizuno (GSM) j GHolahan (GMH)
B5 heron (BWS)
MMalsch (MGM)
MMayfield (MEM2)
AMurphy (AJM1)
HBrammer (HLB)
LShao (LCS1)
GBagchi (GXB1)
MBiamonte (MAB)
PDLR (staff)
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- t ATTENDANCE LIST I
NRC MEETING WITH THE NUCLEAR ENERGY INSTITUTE 3
March 6. 1997 1
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HAME ORGANIZATION 1.
Steve Hoffman NRC/NRR/DRPM/PDLR 1
2.
David Masiero GPU Nuclear 3.
Doug Walters NEI 4.
Fred Polaski PECO Energy
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5.
R. D. Baker Southern Company 6.
Kathryn Sutton Winston & Strawn i
7.
Rick Buckley Entergy 8.
R. Paul Colaianni Duke Power Co.
9.
Alice Carson Bechtel Power
- 10. Ellen C. Ginsberg NEI i
- 11. David Roth Virginia Power
- 12. Tricia Heroux for EPRI i
- 13. Michael Henig Virginia Power
- 14. Barry Tilden BGE
- 15. Geary S. Mizuno NRC/0GC Rulemaking & Fuel Cycle
- 16. Paul Shemanski NRC/NRR/DRPM/PDLR j
- 17. Sam Lee NRC/NRR/DRPM/PDLR
- 18. P. T. Kuo NRC/NRR/DRPM/PDLR
- 19. Scott Newberry NRC/NRR/DRPM/PDLR
- 20. Scott Flanders NRC/NRR/DRPM/PDLR l,
- 21. Richard E. Johnson NRC/RES/DET/EMMEB
- 22. Don Eggett comed i.
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Attachment I
' elements are not applicable to a specific AMP, the applicant should discuss
-any non-applicable elements in its application.
Schedule NEI requested additional time to prepare the requested response to the staff's February 27, 1997, letter and obtain concurrence by its industry senior management steering group. The staff agreed to NEI's submittal of a letter containing the industry's working group response by the requested date of March 13, 1997, followed by a confirmation letter concurred on by senior management by March 20, 1997.
The next working level meeting between the NRC staff and NEI is scheduled for March 20, 1997. A meeting between NEI, industry senior management, and the Director, Office of Nuclear Reactor Regulation, will be scheduled after the staff has received and evaluated NEI's response to its February 27, 1997, letter.
Original signed by:
Stephen T. Hoffman, Senior Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Project 690 Attachments: As stated cc w/atts:
See next page DOCUMENT NAME: A:\\NEIO306.MTS Ta receive a copy of tNo document, andcate in the boa: *C* = Copy ht}out attechment/ enclosure "E" = Copy with attachment / enclosure
- N* = No copy 0FFICE SPM:PDLR g ?)- 6 SC:PDLR /)1//
D:PDL W NAME SHof fman: avl '
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SNew)dkry DATE 03/24 /97 03/ ?v/97 03/<Lp/97 0FFICIA RECORD COPY
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