ML20198G389

Summary of 981210 Meeting with Nuclear Industry in Rockville,Md Re Continued Discussions of Ongoing Solutions to Process Problems Identified During Recent Nrc/Industry Meetings & Workshops.List of Attendees Encl

ML20198G389
Person / Time
Issue date:	12/23/1998
From:	Bill Dean NRC (Affiliation Not Assigned)
To:	Zwolinski J NRC (Affiliation Not Assigned)
References
NUDOCS 9812290068
Download: ML20198G389 (17)

Text

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December 23, 1998 MEMORANDUM TO: John A. Zwolinski, Acting Director Division of Reactor Projects -l/II Office of Nuclear Reactor Regulation FROM:

William M. Dean, Director Original signed by:

Millstone Project Directorate Division of Reactor Projects - l/ll Office of Nuclear Reactor Regulation

SUMMARY

OF DECEMBER 10,1998, NRC/ INDUSTRY LICENSING ACTION TASK FORCE MEETING The U.S. Nuclear Regulatory Commission (NRC) held a meeting with representatives from the nuclear industry on December 10,1998, at NRC Headquarters in Rockville, Maryland. lists the attendees at the meeting; Attachment 2 contains a copy of the material presented at the meeting; and Attachment 3 contains a list of action items as a result of the meeting.

The purpose of the meeting was to continue discussions of ongoing solutions to process problems identified during the recent NRC/ industry meetings and workshops.

The next planned meeting of the NRC/ Industry Licensing Action Task Force (LATF)is scheduled for January 13,1999.

Attachments: As stated cc w/att: See next page Distribution:

See next page I

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,, app 9812290068 981223 PDR ORG NRRA PDR To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy 1J OFFICE PM:P,D%$)

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December 23, 1998

.....f MEMORANDUM TO: John A. Zwolinski, Acting Director Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation 1

FROM:

William M. Dean, Director Millstone Project Directorate Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation

SUMMARY

OF DECEMBER 10,1998, NRC/ INDUSTRY LICENSING ACTION TASK FORCE MEETING The U.S. Nuclear Regulatory Commission (NRC) held a meeting with representatives from the nuclear industry on December 10,1998, at NRC Headquarters in Rockville, Maryland. lists the attendees at the meeting; Attachment 2 contains a copy of the material presented at the meeting; and Attachment 3 contains a list of action items as a result of the meeting.

The purpose of the meeting was to continue discussions of ongoing solutions to process problems identified during the recent NRC/ industry meetings and workshops.

The next planned meeting of the NRC/ Industry Licensing Action Task Force (LATF)is scheduled for January 13,1999.

Attachments: As stated cc w/att: See next page i

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MEETING

SUMMARY

DATED December 23, 1998 l

l HARD COPY Docket File L

PUBLIC PD 11-2 Rdg.

J. Zimmerman OGC ACRS E-MAIL S. Collins /R. Zimmerman (SJC1/RPZ) i B. Boger (BAB2)

' J.-Zwolinski H. Berkow T. Martin (e-mail to SLM3)

W. Dean J. Moore S. Peterson M. Gamberoni S. Wetzel W. Reckley T. Fredette M. Check M. Rubin R.Lobel M. Tschiltz (MDT)

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Distribution for Memo dated December 23, 1998

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cc: Mr. Ralph Beedle Mr. Jim Fisicaro, Manager Senior Vice President Nuclear Assessment and issues and Chief Nuclear Officer Duke Energy Corporation NutJear Energy institute 526 South Church Street 1776 l Street, NW, Suite 400 Charlotte, North Carolina 28201-1006

. Washington, DC 20006-3708 Mr. Alex Marion, Director Programs Nuclear Energy Institute 1776 i Street, NW, Suite 400 Washington, DC 20006-3708 Mr. Jim Davis, Director Operations l

Nuclear Energy Institute 1776 i Street, NW., Suite 400 Washington, DC 20006-3708 Mr. Tony Pietrangelo, Director Licensing Nuclear Energy Institute 1776 l Street, NW., Suite 400 Washington, DC 20006-3708 Mr. Steve Floyd, Director Regulatory Reform and Strategy Nuclear Energy Institute 1770 l Street, NW., Suite 400 Washington, DC 20006-3708 Mr. Dave Modeen, Director Engineering Nuclear Energy Institute 1776 l Street, NW., Suite 400 Washington, DC 20006-3708 Mr. Scott Peterson Senior Director Communications Nuclear Energy Institute 1776 i Street, NW., Suite 400 Washington, DC 20006-3708 Ms. Lynette Hendricks, Director Plant Support Nuclear Energy Institute 1776 i Street, NW., Suite 400 Washington, DC 20006-3708 i

NRC/ INDUSTRY LICENSING ACTION TASK FORCE MEETING LIST OF ATTENDEES December 10.1998 l

NAME ORGANIZATION John Zwolinski NRC/NRR/DRPE William Dean NRC/NRR/DRPE Jake Zimmerman NRC/NRR/DRPE Sheri Peterson NRC/NRR/ADT Beth Wetzel NRC/NRR/DRPW Bill Reckley NRC/NRR/DRPW Mike Cheok NRC/NRR/DSSA Richard Lobel NRC/NRR/DSSA Mike Schoppman NEl James Fisicaro Duke-Energy Pete Kokolakis NYPA John Osborne BG&E Joe Kelly FTl

)

Brian McIntyre Westinghouse Electric Co.

Perry Robinson Winston & Strawn I

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ATTACHMENT 2 i

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AGENDA FOR NRC/ INDUSTRY LICENSING ACTION TASK FORCE MEETING - 12/10/98 1:30 PM OPENING REMARKS (BILL DEAN / JIM FISICARO) 1:35 PM DISCUSSION OF PROPOSED CHANGES TO OFFICE LETTER 803 ON PROCESSING LICENSE AMENDMENTS (SHERI PETERSON/ BILL RECKLEY) 2:30 PM RECENT CHANGES TO GUIDANCE ON NOTICES OF ENFORCEMENT DISCRETION (LAKSHMINARAS RAGHAVEN) 2:40 PM DISCUSSION OF ENTERGY/NRC WORKSHOP ON IMPROVING LICENSE SUBMITTAL QUALITY (MIKE SCHOPPMAN) 3:00 PM LICENSE AMENDMENTTHRESHOLD(NEI) 3:15 PM REVIEW OF IDENTIFIED ISSUES FROM JULY WORKSHOP (BILL DEAN /ALEX MARION) 3:25 PM WRAP UP/ FUTURE MEETINGS

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initial " License Amendment Tatsk Force" Comments on Draft Rev to Office Letter 803

1. GOOD POINTS Overall good attempt to address industry concerns Work plan concept Allowance for only one review by each technical branch Moving in direction of more opsn communications e

Demonstrate that staff is attempting to understand impacts on licensees Concept of goals for routine & complex amendment completion times a

ll. COMMENTS SCHEDULING e

= Needs to demonstrate tte complete picture

• real time vs. calendar time review time projections

= Provide for NRC management tracking including feedback to licensees j

e OGC

= Threshold for OGC involvement o Define review responsibilities

= Timing of OGC review should be reflected in schedule i

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• COMMUNICATIONS

= Minimize predecisionalinformation

= Binning of submittals

= Specific feedback (acceptance review; work plan; technical review)

= Project manager & technical branch feedback on licensee performance PRECEDENT

= Posting of information

= Consistent application of precedent

= Keep "same subject" reviewers

= Legal significance of SER e.

MANAGEMENT /PM OVERSIGHT

= Define management roles & responsibilities

= Consistent guidelines for reviewers

= Minimize handoffs

= Use and oversight of contractors

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i RAls e

= Communicate proposed questions (avoid receiving " wrong rock")

= Management oversight is key to consistency

= Goal should be zero RAls RISK-INFORMED LICENSING ACTIONS e

= Clarifydefinition

= Need more detail on process Ill. IMPLEMENTATION Trial use of draft Guide e

Need opportunity for NEl to obtain detailed industry comment industry comment letter to NRC first Quarter 1999 e

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Issues from July ANS Workshop 1.

Submittal Quality NRC expectations NRC acceptance review Standardize Attributes of a good submittal Workshops 2.

Threshold / Process Issues Minor changes Elevation of concerns to management Repeat submittals Generic applicability 3.

Communications early/ frequent /proactive formal / informal 4.

Scheduling Priority Track progress 5.

Information Resources 6.

RAls NRC staff consistency NRC management involvement Documented basis

. ~ Advance communications Goal one round per technical branch 7.

Documentation Telecons Letters SERs l_

8.

Commitment Management J

Action Item List (for licensing submittals and processes)

ACTION SOURCE STATUS

1. NEI provide information to NRC about the NEI NRC/NEI meeting 10/5/98 on RAIs COMPLETE Licensing Issues Workshop held in New Orleans.

Tony Pietrangelo (NEI) briefed the workshop i

attendees on the license amendment effort.

2. NEI explore the establishment of an industry task NRC/NEI meeting 10/5/98 on RAls COMPLETE. License Amendment Task force to interface with NRC staff.

Force (LATF) formed in November 1998.

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3. NEI develop guidance on the format and content NRC/NEI meeting 10/5/98 on RAls Under consideration by LATF.

oflicense amendment submittals.

4. NEI communicate near term improvements NRC/NEI meeting 10/5/98 on RAls Under consideration by LATF.

relative to the importance of communication, identifying p eviously approved submittals, and importance of conversion to iSTS.

5. Compare the prioritized NEI action item list from NRC/LATF meeting 11/12/98 Draft NEI list prepared for 12/10/98 LATF the ANS NRC/ Industry Licensing Manager's maeting.

t Workshop with NRC's list of action items from that Workshop.

6. NRC revise the guidance on Tech Spec review NRC/LATF meeting 11/12/98 See NRC draft revision (Dec.1998) procedures in NRR Office letter 803.

7. NEI coordinate industry feedback to NRR on use NRC/LATF meeting 11/12/98 LATF to review revised guidance at of revised guidance in Office Letter 803 relative to internal meeting 12/10/98. Also on agenda RAls.

for NRC/LATF meeting during the afternoon of 12/10/98.

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8. NEI prepare suggestions for long. term NRC/LATF meeting 11/12/98 LATF to discuss at internal meeting improvements to the RAI process.

12/10/98.

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Actien It:m List-(far licensing submittals end process =)

9. LATF develop proposed " threshold" for license NRC/LATF meeting 11/12/98 LATF to review a "strawman" process for amendments that would be an entry point for

" minor Tech Spec changes" at internal possible " dual-track" process.

meeting 12/10/98. Also on agenda for NRC/LATF meeting during the afternoon of 12/10/98.

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10. LATF consider options for compiling licensing NRC/LATF meeting 11/12/98 LATF to review information from submittal " fundamentals" and examples of quality Entergy/NRC Workshop on licensing issues for distribution to licensees. NRC staff processes and submittals that was held at examples of typical problems they have seen in past-Waterford on 12/1-2/98.

submittals.

11. NEI explore Entergy/NRC workshop in early NRC/LATF meeting 11/12/98 COMPLETE. NEl attended the second December to see if any synergy with LATF activities.

day of the workshop. See action item 10.

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12. NRC/LATF meet in December 1998 to focus on NRC/LATF meeting 11/12/98 PENDING. NRC/LATF meeting scheduled '

revised RAI guidance, review items on priority list, for 12/10/98.

and explore long-term improvements to license amendment process.

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4 NRC/NEl LICENSING INTERFACE MEETING ISSUES ISSUE POSSIBLE RESOLUTION I. Communications -

1. RAI Effectiveness (A major issue that was spread Work with Industry on clarifying and streamlining the RAI process throughout issues raised)

2. Communicate prior to submittals Philosophy change needed by NRC to define "what" needs to be submitted /use of draft mat'l

3. Utility provide feedback on PM and Tech Staff NRC feedback should be informal unless chronic Focus of Performance; utilities should be on NRR's performance, not indwiduals; NRC l

should formalize its feedback in cover letter if chronic

4. Issue SERs, irs, etc. In draft form for review Legal issue - precludes issuance of draft material in such matters; OGC would need to be involved II. Licensing Submittels and Expectations (Arthur Andersen is currently reviewing NRC's process in this area)

1. Industry endeavor lo improve consistent submittals on Industry initiative needed to expand " sharing"- some use of search similar issues engines already exists

2. Communicate prior to submittals with technical reviewers (See 1.2 above)

3. Publish expectations for review process / hold reviewers NRC should work with NEl to better define this issue and how to I

and management accountable for " requirements" achieve (formal approach to above issue 11.2)

(standards)

4. Change process to allow licensees to make " simple" Advocation of a 50.59 like process for TS - would need a changes substantial change to current processes

6. NEI/ industry publish examples of good submittals May be some industry benefit to this effort

7. Perform acceptance reviews and provide early feedback Revisit existing guidance and determine if needs to be reemphasized or redesigned

8. Only respond to violations with safety significance OE currently working on changing Level IV response i

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2 NRC/NEl LICENSING INTERFACE MEETING ISSUES ISSUE POSSIBLE RESOLUTION

9. Globally accept one plant's accepted change across Given lack of standardization, this is only applicable in certain j

industry situations - topical reports / joint submittals are a method to do this

10. Re-review routine reporting requirements Cooperative review between NRC and industry to identify redundancies / areas for reductions

11. Is OGC review needed; can there be a graded OGC Legal issue - look into ways to eliminate or " grade" OGC review on review process (not needed for certain situations; certain issues; may want to do a "value-added" review of OGC's accelerated in others).

contribution to the process (Arthur Andersen initiative in process)

IIL Licensing Restart issues After Prolonged Outages

1. NRC should make timely determination on A review of MC 0350 guidance may be warranted to determine if implementation of MC 0350 and communicate what the some guidance can be provided to formalize these issues process is in a public forum

2. Licenses provide timely restart action plan Revise 0350 guidance to formalize this requirement

3. Review criteria for MC 0350 implementation to Review 0350 to see if it artificially delays implementation of determine if it affects timeliness of commencing process activities to correct problems

4. NRC and licensee should conduct " consensus" meeting Though it generally happens in effect over time, review MC 0350 to to discuss restart process, identify restart scope, jointly see if these should be clearly incorporated as a requirement define issues and discuss issue closure criteria / process

5. Expand NRC Restart Panel authority to include oversight Review MC 0350 and work with senior managers to determine if of all regulatory issues affecting plant should alter guidance, giving Restart Panel broader authonty

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6. Examine make-up bf Restart Panel to ensure HQ With impending reorganization, may be worthwhile to review MC participation and communications with HQ managers is 0350 guidance in this area and ensure HQ is appropriately appropriate represented

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NRC/NEl LICENSING INTERFACE MEETING ISSUES IV. Notice of Enforcement Discretion (Currently under review by staff-new guidance in draft)

ISSUE PROPOSED RESOLUTION

1. Clarify and improve definition of USQ applicability to Will require stakeholder input; delete reference to USO in NOEDs guidance, clarify Admin Letter 95-05 items 3 and 6, Section E; Revise IM Part 9900

2. Eliminate or clarify "line item improvement" or "Impicved Look at current draft guidance and how it approaches this issue STS" as acceptance criteria for NOED

3. Establish mechanism / guidance on pre-notification'of Establish framework for how NRC will handle pre-notification and a potential need for NOED preliminary view of licensee's technical adequacy V. l..L,.4 Ion of Risk-Informed Decision Making / Using PRA in Licensing Decisions j

There were a number of issues raised in the use of risk-informed decision making. Rich Barrett indicated a number of initiatives are currently in place that are intended to address these issues. However, he noted that it may be worthwhile to form a industry task group or working group, with the vendors, similar to what the Tech Spec Branch has established.

VI. Prioritization of Licensing Work

1. Need to establish consistency among OGC, DRPE/W, Establish prioritization scheme for entire scope of NRC's work Tech Staff, and Licensee

2. License actions and activities should be " forecasted";

Look into a more formalized process of determining expected work with industry on mutual prioritization license actions on a periodic basis (Admin Letter or scheduling i

meetings are possibilities)

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't NRC/NEl LICENSING INTERFACE MEETING ISSUES VII. Standard Technical Specifications The Technical Specifications Branch has an active Technical Specification Task Force that meets periodically with applicable vendors to discuss pertment issues. The issues raised at the conference have all been taken under advisement by this Task Force and are under review.

li Our efforts indicated some synergy with the PRA Branch, and they are pait@i;..g in a funi-.

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.y (Nc;;.74mr SM) with i

applicable owner's groups to discuss an overall integration of risk into STS. The PRA branch is also considering instituting a i

similar effort with Industry to promote better communication on risk-informed initiatives.

Vill. Commitment Management This is another area under active review by NRC and NEI. Some of the key issues raised included defining h i.;iiim.r. having

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a graded approach, eliminate recent use of Appendix C heense cor.ditions, allowing licens ses to concur on commitments identified by NRC in SERs, and ensuring a clear delineation between a commitment and corrective actions.

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e ACTIONS ITEMS AS A RESULT OF THE MEETING 1)

NRC will combine action item iists into one list and forward to NEl. NRC/NEl will schedule a conference call to discuss the combined list.

2)

NEl will provide NRC with a copy of the LATF Mission Statement.

3)

NEl will coordinate inoustry feedback on the option of using Orders as a vehicle for processing minor Technical Specification changes when prompt tumaround is necessary to support plant operating schedules.

4)

NEl will schedule LATF meeting for 1/12/99. NRC/NEl will schedule NRC/LATF meeting for the aftemoon of 1/13/99.

5)

NRC will issue letter to industry on revised NOED policy.

6)

NRC willissue revised " Guide for Processing License Amendments"(NRR Office Letter 803). NEl will coordinate industry feedback to NRC.

7)

NRC will provide NEl/PDR with an advance / final copy of a new Administrative Letter on processing Technical Specification changes in those situations where non-conservative values or incorrect actions are identified. In advance of the NRC/LATF meeting l

scheduled for 1/13/99, LATF provide "strawman" proposal for long term simplification of the regulatory process for making minor Technical Specification changes.

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