ML20196E251

Summary of 981015 Meeting with NEI in NRC Offices Re Recommendations for Development of Direct Final Rule That Would Suppl 10CFR50.54(a).List of Attendees & Staff Presentation Encl

ML20196E251
Person / Time
Issue date:	11/30/1998
From:	Stewart Magruder NRC (Affiliation Not Assigned)
To:	Essig T NRC (Affiliation Not Assigned)
References
PROJECT-689 NUDOCS 9812030077
Download: ML20196E251 (11)

Text

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November 30, 1998 MEMORANDUM TO:

Thomas H. Essig, Acting Chief Generic issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation i

FROM:

Stewart L. Magruder, Project Manager Original Signed By:

i' Generic issues and Environmental Projects Branch l

Division of Reactor Program Management i

Office of Nuclear Reactor Regulation l

SUMMARY

OF MEETING HELD ON OCTOBER 15,1998, WITH NEl TO DISCUSS 10 CFR 50.54(a) RULEMAKING i

Members of the NRC staff met with representatives of the Nuclear Energy Institute (NEI) and other interested parties in the NRC offices on October 15,1998. The purpose of the meeting was to obtain recommendations for the development of a direct final rule that would sup' lement p

10 CFR 50.54(a) to permit an alternate and more expeditious approach for licensees to effect i

changes to their quality assurance programs. A list of attendees is included as Attachment 1.

The staff presented its concepts for the proposed direct final rule as shown in Attachment 2.

The initial criterion elicited the most discussion since it would permit adoption of a previously approved staff position as described in a safety evaluation report (SER) by another licensee without additional staff review. The staff position would include approval of a single altemative, up to, and including, a complete QA program description. Each alternative available for l

licensee adoption would be identified by the staff, possibly on a website. NEl and licensees indicated interest in this approach. The staff indicated that such positions are those most recently approved (i.e., since 1996) since prior staff positions generally do not have the benefit of an SER. The staff indicated willingness to provide an SER for other alternatives ifinterest was shown by licensees.

NEl and licensees present also indicated interest in the remaining five criteria, primarily those permitting organizational changes. No specific suggestions were offered by the invited participants.

The staff stated that its objective was to prepare the direct final rule for Commission consideration by the end of November. The staff requested that any suggestions from the industry be made available in a timely fashion.

Project No. 689 l

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November 30, 1998 MEMORANDUM TO:

Thomas H. Essig, Acting Chief Generic issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation MiWy M

FROM:

Stewart L. Magruder, Project Manager ;

Generic issues and Environmental Projects Branch

'd Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF MEETING HELD ON OCTOBER 15,1998, WITH NEl TO DISCUSS 10 CFR 50.54(a) RULEMAKING Members of the NRC staff met with representatives of the Nuclear Energy Institute (NEI) and other interested parties in the NRC offices on October 15,1998. The purpose of the meeting was to obtain recommendations for the development of a direct final rule that would supplement 10 CFR 50.54(a) to permit an alternate and more expeditious approach for licensees to effect changes to their quality assurance programs. A list of attendees is included as Attachment 1.

The staff presented its concepts for the proposed direct final rule as shown in Attachment 2.

The initial criterion elicited the most discussion since it would permit adoption of a previously approved staff position as described in a safety evaluation report (SER) by another licensee without additional staff review. The staff position would include approval of a single alternative, up to, and including, a complete QA program description. Each alternative available for licensee adoption would be identified by the staff, possibly on a website. NEl and licensees indicated interest in this approach. The staff indicated that such positions are those most recently approved (i.e., since 1996) since prior staff positions generally do not have the benefit of an SER. The staff indicated willingness to provide an SER for other alternatives if interest was shown by licensees.

NEl and licensees present also indicated interest in the remaining five criteria, primarily those permitting organizational changes. No specific suggestions were offered by the invited participants.

The staff stated that its objective was to prepare the direct final rule for Commission consideration by the end of November. The staff requested that any suggestions from the industry be made available in a timely fashion.

Project No. 689 Attachments: As stated cc w/att: See next page

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Distribution: Mtg. Summary w/ NEl Re 10 CFR 50.54(a) Dated Nnvomber 30. 1998 i

Hard Copy l

Docket File l

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SMagruder i

WHaass EMail SCollin',/FMiraglia BSheron.

RZimmerman JRoe DMatthews l'

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HTovmassian WHaass MSatorius, OE STreby, OGC GTracy, EDO i

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l LIST OF ATTENDEES Name Oraanization Tony Pietrangelo NEl Biff Bradley NEl Adrian Heymer NEl Terry Morton CP&L l

Robert Lawton USEC Robert Sheridan BECo Steve Warren Duke Charles Peterson MLB Roger Huston Licensing Support Services

,l Donald Chung Scientech Deann Raleigh SERCH/Bechtel Bob Gramm NRC/NRR Harry Tevmassian NRC/NRR

-Walter Haass NRC/NRR Lee Spessard NRC/NRR -

j Ken Heck NRC/NRR Suzanne Black NRC/NRR Stuart Treby '

NRC/OGC 1

Mark Satorius -

NRC/OE i

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l ATTACHMENT 1 l

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NRC-NEl l

Public Meeting on 50.54(a) Rulemaking Petition

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10/15/98 I

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i MEETING OBJECTIVES e

i NRC Staff to Present Concepts for Proposed i

l Implementation in Near Term Regarding the NEl l

Petition for Rulemaking (Direct Final Rule Concept)

Provide Opportunity for NEl, Licensees, and Other Interested Parties to Suggest input for Staff to l

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. Consider on the Direct Final Rule Approach L

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CURRENT STAFF THOUGHTS ON PETITION Licensee Flexibility to Make QAP Changes Without NRC Review Should be Expanded Considerably i

50.59 Change Control is Not Viewed to be Appropriate as QAP Changes Cannot be Readily J

Correlated with USQ Criterion Accept Principle That 50.54(a) Needs Revision, Envision Alternative Approach to Accomplish that Goal Pursue a Direct Final Rulemaking to Provide immediate Relief for all Licensees Pursue an Option that Could be Voluntarily Utilized by Licensees that Would Offer Further Relief Coupled with QAP Effectiveness Monitoring Voluntary Option to be Developed with Industry input Through Meetings and Workshops 3

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DIRECT FINAL RULEMAKING l

Will Partially Resolve NEl Petition Provide immediate Relief to All Licensees Identify set of Non-Controversial Criteria to include in 50.54(a) that Would Expand the Scope of QAP Changes that Could be Made Unilaterally without NRC Review, Such as:

1. Use of a QA provision approved by an NRC safety evaluation for another licensee provided that similar conditions exist hsnes: What population of precedents is available; How would precedents and conditions of use be tracked; precedents to be identified by staff (website)

2. Use of consensus standard newly endorsed by NRC laauns: Endorsement by RG to provide conditions,if any 4

l DIRECT FINAL RULEMAKING -continued

3. Elimination of QAP text provisions that duplicate commitments embodied in Reg. Guides and Standards issues: Direct correlation needs to be verified; greater burden on licensee staff to be familiar with guidance documents

4. Implement organizational changes that do not affect the required independence of the QA function issue.s: Need to maintain separation of performing and verifying activities unless suitably controlled; guidance for determining adequacy of independence l

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1 DIRECT FINAL RULEMAKING -continued i

5. Use of generic organizational and position titles issues: Position descript!9ns need to be provided per Criterion i v7 Appendix B

6. Use of generic organizational charts or descriptions to depict functional relationships Issues: Flow of authority and responsibilities for QA functions must be presented i

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i FUTURE ACTIONS i

1 Finalize SECY Paper to Obtain Commission Approval to Proceed with Staff Recommendations Issue Direct Final Rule and Companion Proposed 2

Rule and Seek Public Comments Should Significant Adverse Comment be Received, Direct Final Rule Will be withdrawn and Staff to Proceed with Standard Rulemaking Develop voluntary option rule predicated on interactions with stakeholders 7

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Nuclear Energy Institute 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 Suite 400 1776 I Street, NW

' 1776 i Street, NW Washington, DC 20006-3708

. Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director i

Programs Washington Operations l

Nuclear Energy Institute ABB-Combustion Engineering, Inc.

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

Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 i

Mr. Jim Davis, Director Operations Nuclear Energy institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 I

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