ML20155C278

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Summary of 981021 Meeting with NEI in Rockville,Md to Discuss NEI Comments, on Draft Commission Paper Entitled, Combined License Review Process
ML20155C278
Person / Time
Issue date: 10/27/1998
From: Joshua Wilson
NRC (Affiliation Not Assigned)
To:
NRC (Affiliation Not Assigned)
References
PROJECT-689 NUDOCS 9811020172
Download: ML20155C278 (15)


Text

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October 27, 1998 ORGANIZATION: NUCLEAR ENERGY INSTITUTE

SUBJECT:

MEETING ON COMBINED LICENSE REVIEW PROCESS l The subject meeting was held on October 21,1998, in the Rockville Maryland office of the Nuclear Regulatory Commission (NRC), between representatives of the NRC staff and the Nuclear Energy Institute (NEI). A list of the meeting attendees is provided in Attachment 1 and NEl's presentation handout is provided in Attachment 2.

The purpose of the meeting was to discuss NEl's comments, dated September 8,1998, on a draft Commission paper entitled," Combined License Review Process." The NRC requested comments on this paper in a Federal Register notice (63 FR 25528), dated May 8,1998.

Mr. Marion of NEl began the meeting by emphasizing the importance of NRC and NEl continuing to discuss issues associated with the combined license (COL) review process 1 because the viability of the nuclear option in the U.S. depends on the stability and predictability l of the COL review process. Mr. Marion also stated that NEl plans to assemble a " lessons- i learned" group of industry representatives with experience in the reactor licensing process to facilitate future interactions with the NRC. The staff asked NEl to clarify some of its comments and stated that it would address the comments submitted on September 8th in the final version  !

of the paper on the COL review process. The staff also stated that it would hold future public l meetings on the additionalissues identified in Section 5 of NEl's comments, as resources l permit.

original signed by:

Jerry N. Wilson, Senior Policy Analyst License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation t<

Project No. 689 I Attachments: As stated I N n, O cc w/ attachment: See next page DISTRIBUTION:

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JNWilson DOCUMENT NAME: G:\ WILSON \NEl-MTG.WPD MQ" b-Q QWG"G b To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" l

= Copy with attachmentjenclosure "N" = No copy OFFICE LA A PA:PDLR:DRPM 6 D:PDLR:DRPM l NAME / JNWilsG2 CLGrime(/k l DATE // /98 /#/ 27/9W C) Io /2.? /98 W OFFDAL RECORD COPY l

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NUCLEAR ENERGY INSTITUTE (NEI)

Project No. 689 cc:

Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy Institute Suite 400 l Suite 400 1776 I Street, NW 1776 i Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 l

Mr. Alex Marion, Director Mr. Charles B. Brinkman, Manager Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineering, Inc.

Suite 400 12300 Twinbrook Parkway, Suite 330 1776 i Street, NW Rockville, MD 20852 Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director ,

Licensing Nuclear Energy institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparuto, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation l P.O. Box 355 l

Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 17761 Street, NW

Washington, DC 20006-3708

1.

i COMBINED LICENSE REVIEW PROCESS ATTENDANCE LIST OCTOBER 21,1998 ~

NAME ORGANIZATION JERRY N. WILSON NRR/PDLR/DRPM ALEX MARION NEl l STEVE FRANTZ MORGAN, LEWIS & BOCKlUS LLP MIKE SCHOPPMAN NEl BRIAN MCINTYRE WESTINGHOUSE TED QUAY NRR/PDST/DRPM GEARY S. MlZUNO NRC/OGC l DAVID STELLFOX MCGRAW-HILL ROBERT WEISMAN NRC/OGC l

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l Attachment

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l MEETING WITH XRC OX .

! COMBINED LICENSE (COL) i PROCESS ,

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October 21,1998 i ":

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AGENDA

! = Neec for streamlinec process

= NEI comment letter on c raft NRC paper on COL review process j (9/8/98)

= Ac.ditional COL issues i

2 i

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l l Need For Streamlined Process l

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= Market Factors i

Predictability, certainty, timeliness l . 3 to 5 year construction + licensing period i = Other Factors l . Lessons learned - DC rulemakings i . Lessons learned - intemational ALWR projects 4 .FOAKE j . COL line item in update ofNRC " tasking memo" I

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  • l NEl Comment Letter

= ITAAC for programmatic issues

= General c arifying comments

! = Content of t:ae generic COL l = Duration of t: 1 ECOL i

= Ac citional issues l

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ITAAC for Programmatic issues l = ITAAC should not apply to programs I . Purpose ofITAAC relates to hardware I

j . 52.97 language directed at "the facility" j . Legislative history focused on " constructed plant" i

i - Use other means to ensure adequacy of programs

) . Regulations require programs l . Programs will be described in the COL ,

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. Programs will be inspected & enforceable ,

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{ = Programmatic ITAAC are a disincentive

. Too subjective l . Reduce viability of Part 52 5

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l l General Clarifying Comments

= COL applicants can use the DC PRA l = Verify ITAAC ay using Part 50 QA program

= System classification c eficiencies in most cases will not affect ITAAC

= ESP ho c ers need not update emergency alan l

= All construction specs do not need to 3e

! available at COL issuance i

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i Content of the Generic COL

= COL should use the standard Part 50 l

4 License Concition for startup tests l = COL saould include effective c ates for:

. Technical Specifications j . Security Plan & Safeguarc s Plan  ;

l . Financial Protection l

l . Other operational programs i

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l Duration of the COL l = 40-year duration of operation in 52.83 is i .

l appropriate i

! = Neither EPAct nor AEA explicitly discuss l COL duration l

= COL is a Combined CP + OL

. OLs allow operation for 40 years l

l . OLs need not account for construction period 3

. Therefore, COL may allow operation for 40 years i

l = Seek confirmatory legislation to eliminate I

ambiguity 8

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Additional Issues i

i l = Tae scope of tae draft COL paper is l _imited l

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= Taere are several adc itional issues I

. Time is available now to discuss them l . E tilize " institutional memory"

. Resolution would rec.uce uncertainty for

potential COL applicants 4

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, Partial List of Additional Issues l

= Form & content of EP ITAAC I . Scope (hardware only vs. hardware + program)

! . Identify EP issues that warrant ITAAC l . Identify language for EP ITAAC i

= Construction Inspection & ITAAC Verification j . Timing / content of notices of successful completion (52.99) 1

. Binding nature of 52.99 notices

. Supporting documentation

. SAYGO process for Tier 2 i

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l Additional Issues (continued) l = Role of PRA

. Scope of activities affected (e.g., change process) i j . Update frequency

- Lessons-learned rulemaking for Part 52 l . Modify change process (52.63) l . Modify FSAR requirements (52.79)

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. Other changes to reflect DC rulemakings

= Standardized programs

. Scope of programs subject to standardization j . Content of standardized programs j . Process for approving standardized programs ,

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Additional Issues (continued)

= Form & content of plant-specific DCDs i

j . Scope (standardized plant vs. standardized + site-specific)

! . Format (Tier 2*, standardized, plant-specific)

= Guidance for Tier 2 change process l . What is a " severe accident" issue?

. What constitutes a " credible" accident or malfunction? .

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! . What constitutes a " substantial" increase in consequences?

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