ML20138J359

Summary of 970422 Meeting W/Nei in Rockville,Md to Discuss Development of Final NRC RG, Standard Format & Content for Applications to Renew Nuclear Power Plant Operating Licenses

ML20138J359
Person / Time
Issue date:	05/06/1997
From:	Hoffman S NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
PROJECT-690, TASK-*****, TASK-RE NUDOCS 9705080173
Download: ML20138J359 (17)

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UNITED STATES j

j NUCLEAR REGULATORY COMMISSION o

't WASHINGTON, D.C, 20555 4 001 May 6, 1997 ORGANIZATION: Nuclear Energy Institute

SUMMARY

OF MANAGEMENT MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) ON THE DEVELOPMENT OF THE FINAL REGULATORY GUIDE FOR IMPLEMENTING THE LICENSE RENEWAL RULE On April 22, 1997, NEI's License Renewal Working Group met with the Nuclear Regulatory Commission (NRC) management and staff in Rockville, Maryland, to discuss the development of the final NRC Regulatory Guide (RG), " Standard 4

Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses." The draft RG, DG-1047, proposes to endorse NEI's, " Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," NEI 95-10, if found acceptable by the NRC. A list of meeting attendees is provided in Attachment 1.

NRC handouts at the meeting are contained in Attachments 2 and 3.

Status of Reaulatory Guide and NEI 95-10 Development Senior management and staff from NEI, licensees, and NRC Office of Nuclear Reactor Regulation discussed the status of final RG development and presented positions on associated issues.

Significant policy and implementation issues were raised by the industry during the public comment period on the draft RG and NEI 95-10. Attempts were made to disposition the issues associated with the comments in correspondence and in working level meetings.

Views presented at the meeting clarified positions but NRC and industry positions still appeared to differ on the implementation aspects of significant issues.

In order to proceed with license renewal reviews and development of implementation guidance for the rule. the NRC staff is considering an option that maintains the RG in draft form and uses the draft RG guidance to perform plant-specific and owners group reviews which would be the focus of the staff's efforts.

The staff would incorporate positions established and i

implementation guidance into the next working draft of the license renewal standard review plan (SRP) scheduled to be available in September 1997.

With this approach, experience gained from the trial use of the draft RG and plant-4 i

specific and owners group technical reviews would be incorporated into the final RG. The staff would continue to interact with NEI to develop the final RG during this time but with a lower priority.

NEI indicated that it could support this approach or the continued development of a final RG.

The final RG is currently scheduled to be issued in September 1997.

Due to the time expended interacting with industry to disposition selected issues, the current schedule is no longer achievable and the NRC staff will inform the Commission of the change in schedule. A Commission paper and briefing are j

scheduled for June 1997.

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9705080173 970506 PDR REVGP ERGNUMRC PDR

. Following is a summary of the positions presented at the meeting on significant issues:

Creditina Existina Proarams for Aoina Manaaement The NRC staff's position is that the rule requires an applicant to demonstrate the adequacy of its aging management programs, whether they are new, modified, or existing.

References to previous staff reviews are acceptable and the staff would limit the depth of the reviews, as appropriate.

NEI indicated that programs required by regulations or subject to regulatory oversight are part of the current licensing basis (CLB) that will carry forward into the period of extended operation and that an applicant's demonstration need only j

be identification of the programs and linking them to the regulatory i

requirement.

NEI indicated that if current programs are not acceptable, they j

should be of concern today and that review for license renewal is not 1

necessary.

The staff responded that the Commission, when amending the license l

renewal rule in 1995, indicated that it did not have reasonable assurance that the effects of aging will be adequately managed for the period of extended operation for all passive, long-lived comper.ents subject to an aging management review. Therefore, the license renewal rule requires a demonstration of the adequacy of aging management programs, regardless of whether they are new or existing.

This will result in the review of current programs for adequacy to manage the effects of aging during the period of extended operation.

System vs. Comoonent Level Aoina Manaaement Component Failure Detection as Aoino Manaaement i

The NRC staff indicated that the effects of aging on a component must be managed to ensure its availability to perform the component intended function as desinued when called upon.

NEI agrees that aging management is at the compont., level ivt that an evaluation of the component's function is needed only to ensure that the system's intended function is maintained.

Component degradation or failure is acceptable if the system level intended function can be maintained.

The staff's position is that detection of degradation or failure under normal operating conditions may not ensure that the component can perform its intended function under CLB design conditions (e.g., a seismic event).

Failure detection, such as leakage detection from a fluid system component, is not acceptable as the sole aging management program.

Reasonable assurance is required that unacceptable degradation is not expected to occur based on credited aging management programs. However, absolute assurance that degradation or failure will never occur cannot be guaranteed and is not required by the staff.

The staff will consider failure detection programs that are credited as defense in depth for aging management programs that provide reasonable assurance that the effects of aging will be managed.

j Operatina Experience as Ob.iective Evidence of Proaram Effectiveness The NRC staff expects the application to describe operating experience for existing aging management programs.

The information would include a

1 discussion of the effectiveness of the program, significant events, and

. corrective actions that the staff could verify during an inspection, if

.l needed. NEI indicated that providing operating experience is not a l

requirement of the rule and is concerned with how extensive a review the staff I

will require of operating history. The staff indicated that it will be difficult to make a finding on the adequacy of an existing program without j

knowledge of the operating experience.

Environmental Issues i

The NRC staff provided a summary of current activities and issues associated with development of guidance for preparing the license renewal environmental report supplement (Attachment 2).

Closina Remarks The NRC staff ind;cated that it is important that progress be made in implementing the license renewal rule. At the request of the staff, NEI stated that it would submit a proposed revision of NEI 95-10 reflecting its understanding of the views expressed at the meeting. A meeting will also be arranged between the staff and NEI to present views on the guidance for the format and content of a license renewal application and final safety analysis report supplement.

NEI indicated its willingness to continue interactions with the staff in developing implementation guidance.

[

n-Stephen T. Hoffman, Senior Project Manager j

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

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j NUCLEAR ENERGY INSTITUTE (NEI)

Project No.

690 l

cc: Mr. Dennis Harrison U.S. Department of Energy NE-42 Washington, DC 20585 Mr. Douglas J. Walters Nuclear Energy. Institute 1776 I Street, NW Suite 300 i

Washington, DC 20006 Mr. Richard P. Sedano, Commissioner State Liaison Officer State of. Vermont Department of Public Service 112 State Street Drawer 20 l

Montpelier, Vermont 05620-2601 1

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t ATTENDANCE LIST I

NRC MEETING WITH THE NUCLEAR ENERGY INSTITUTE April 22. 1997 HMiE ORGANIZATION 1.

Steve Hoffman NRC/NRR/DRPM/PDLR 2.

Tim Martin NRC/NRR/DRPM i

3.

Sam Collins NRC/NRR 4.

Scott Newberry NRC/NRR/DSSA 5.

Chris Grimes NRC/NRR 6.

Sam Lee NRC/NRR/DRPM/PDLR i

7.

P. T. Kuo NRC/NRR/DRPM/PDLR 4

8.

John B. Cotton PECO Energy 9.

Robert E. Denton Baltimore Gas & Elec.

10. Mike Tuckman Duke Power

11. Doug Walters NEI i

12. Ralph Beedle NEI

13. Louis Long Southern Nuclear 4

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14. Charles R. Pierce Southern Nuclear

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15. Don Eggett Comed

16. Jon Hornbuckle Southern Nuclear

17. Greg Robison Duke Power Co.

18. Bob Borsum FTI

19. Tricia Heroux for EPRI

20. Roger Newton WEPCo/WOG

21. Kathryn Sutton Winston & Strawn

22. Marylee Slosson NRC/NRR/DRPM

23. Terry Pickens Northern States Power Co.

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24. David Lewis Shaw Pittman

25. Fred Polaski PECO Energy

26. Michael Henig Virginia Power l

27. David Roth Virginia Power i

28. Sill MacKay Entergy i

29. Dan Stenger Winston & Strawn i

30. Tony Pietrangelo NEI

31. Charles Meyer Westinghouse /WOG i

32. Jit Vora NRC/RES/DET

33. Bob Prato NRC/NRR/DRPM/PDLR i

34. Scott Flanders NRC/NRR/DRPM/PDLR i

35. Claudia Craig NRC/NRR/DRPM/PGEB i

36. Francis Akstulewicz NRC/NRR/DRPM/PGEB

37. Janice Moore NRC/0GC i

38. Raj Anand NRC/NRR/DRPM/PDLR 1

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NRC-NEl MANAGEMENT MEETING APRIL 22,1997 l

NEl IMPLEMENTATION GUIDELINE / REGULATORY GUIDE DEVELOPMENT 4

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AGENDA Introduction Status of Regulatory Guide and NEl 9510 Development Presentation of Significant issues e

NRC Positions NEl Positions e

NEl Topics Closing Remarks

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i REGULATORY GUIDE /NEl 95-10 STATUS l

e Aug.1996: Draft RG endorsing NEl 95-10, Rev. O, published for public comment Demonstration program tested implementation of Draft RG and NEl 95-10, Rev. 0 e

Significant comments on Draft RG received from NEl, industry, and DOE Jan.21,1997, meeting: Proposed revision of NEl 95-10 received reflecting NEl/ industry e

comments j

e Jan.30,1997, meeting & Feb. 27,1997, letter: staff cannot review revision Significant deviations from previous positions Eliminates guidance incorporated during development of Rev. 0 Feb. 20 and Mar. 6,1997, working level meetings: clarification of positions e

Feb. 27 letter provided staff positions on significant topics e

NEl response to staff positions provided in Mar.14 & Apr. 7,1997, letters - still e

significant disagreement i

Additional NEl 95-10 topics yet to be completed o

Content of application and FSAR supplement, others i:

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REGULATORY GUIDE /NEl 95-10 STATUS-i Schedule Final RG scheduled for Sept.1997 riot achievable Schedule is indeterminate with current process Must inform Commission of any change in schedule and approach i

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CREDITING EXISTING PROGRAMS FOR AGING MANAGEMENT e

Staff:

Applicant must justify the adequacy of any aging management programs for renewal, including existing programs Applicant may reference previous staff reviews and staff may limit the depth of review, as appropriate e

NEl:

Some existing programs are required by regulation or subject to regulatory oversight Justification is a description " linking the regulatory requirement or oversight mechanism with the program and aging effect" Such existing programs "are adequate because they are part of the CLB that carries forward" Elements of such existing programs need not be rejustified for renewal

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SYSTEM-VS. COMPONENT LEVEL AGING MANAGEMENT

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e Staff:

Effects of aging on a component must be menaged to ensure its availability to i

perform the component intended function as designed when called upon. In this way, all system level intended functions including redundancy, diversity, and defense-in-depth consistent with the plant's CLB will be maintained.

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NEl:

Evaluate component function only to ensure system intended function maintained. Allow component degradation / failure if system intended function maintained.

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COMPONENT FAILURE DETECTION AS AGlNG MANAGEMENT e

Staff:

A program based solely on detection of component failure is not an acceptable aging management program for license renewal For an aging management program that monitors component degradation, the acceptance criteria should ensure th::t corrective actions would be taken in a timely manner such that the structure and component intended function will be maintained for renewal under CLB design conditions e

NEl:

Component failure does not imply that the component intended function cannot be performed - concept should consider linkage to system function "we do not interpret the rule as precluding degradation or failure" For some cases, " limited degradation or actual component failure will neither be a violation of any license condition nor impact the capability of a component to satisfy its component intended functions (as linked to the system function)"

OPERATING EXPERIENCE AS OBJECTIVE EVIDENCE _

_OF PROGRAM EFFECTIVENESS Staff:

Applicant should provide operating experience, including past corrective actions that have provided feedback as program enhancements or new programs, as

" objective evidence" to be considered in evaluating the effectiveness of the aging management programs for renewal e

NEl:

"lU]se of operating experience is an optional enhancement that assists the licensee in the efficient development of its integrated plant assessment" 5

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ENVIRONMENTAL ISSUES FOR LICENSE RENEWAL Generic Environmental impact Statement (GEIS) addressed environmental impacts for

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license renewal t

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GEIS formed the basis of revised Part 51 rule i

in support of revised Part 51, Environmental Standard Review Plan (ESRP) and Regulatory e

Guide (RG) being developed 1

Draft ESRP to be released for public comment 8/97 i

Draft RG to be released for public comment 7/97 i

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ENVIRONMENTAL ISSUES FOR LICENSE RENEWAL (continued)

BGE Environmental Report template process e

Establish format and content for ER such that it would be accepted for review Issues being discussed include:

Severe Accident Mitigation Alternatives (SAMAs)

High level waste transportation New and significant information Mitigation measures Electric shock hazard Senior Management Meeting to discuss template process (similar to technical side) e NEl interaction with RES on RG Discussed same issues as with BGE, including electromagnetic frequencies Addressing issues through BGE template and guidance development process e

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.. discussion of the effectiveness of the program, significant events, and corrective actions that the staff could verify during an inspection, if needed. NEI indicated that providing operating experience is not a requirement of the rule and is concerned with how extensive a review the staff will require of operating history. The staff indicated that it will be difficult to make a finding on the adequacy of an existing program without knowledge of the operating experience.

Environmental Issues The NRC staff provided a summary of current activities and issues associated with development of guidance for preparing the license renewal environmental report supplement-(Attachment 2).

Closina Remarks The NRC staff indicated that it is important that progress be made in implementing the license renewal rule. At the request of the staff, NEI stated that it would submit a proposed revision of NEI 95-10 reflecting its understanding of the views expressed at the meeting. A meeting will also be arranged between the staff and NEI to present views on the guidance for the format and content of a license renewal application and final safety analysis report supplement. NEI indicated its willingness to continue interactions 4

l with the staff in developing implementation guidance.

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 t

Attachments: As stated cc w/atts: See next page DOCUMENT NAME: A:\\NEIO422.MTS To r:c:Jue a copy of this document,inecate in the leox: "C" = Copy Mhdut attachment / enclosure

• E' s Copy with attschment/ enclosure "N" = No copy 0FFICE SPM:PDLR N //- E AD:PDLR !/ V l

l NAME SHoffmanfavi PTKun i

DATE Q57f/97 q$76 /97 0FFICIAL RECORD COPY