ML20199E509
| ML20199E509 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1998 |
| From: | Charemagne Grimes NRC (Affiliation Not Assigned) |
| To: | Walters D NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| PROJECT-690 TAC-M92972, NUDOCS 9802020175 | |
| Download: ML20199E509 (8) | |
Text
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UNITED STATES p
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j NUCLEAR REGULATOHY COMMISSION 2
WASHINGTON, D.C. 20666 0001
% g,o January 29, 1998 Mr. Douglas J. Walters Nuclear Energy Institute 1776 i Street, NW
' Suite 400 Washington, DC 20006-3708
SUBJECT:
GENERIC SAFETY ISSUES RELATED TO LICENSE RENEWAL (TAC NO.
M92972)
Daar Mr. Walters:
In letter dated October 21,1996, the NuJear Energy Institute (NEI) provided the results of an industry review of unresolved safety issues (USIs) and generic safety issues (GSis) (collectively referred to herein as GSts) applicable to license renewal. The NRC tracks GSIs in NUREG-0933, 'A Prioritization of Generic Safety issues," which is updated periodically. The NRC staff reviewed (1) the criteria NEl used for performing the review and (2) the list of GSis identified by NEl as appbable to license renewal. On the basis of this review and further evaluation of the NUREG-0933 generic issues process, the staff has determined that the appropriate criteria for reviewing GSis differs from those proposed by NEl. This letter responds to your October 21 letter and transmits the staffs guidance for performing the GSI review.
The staff has determined that allissues listed in NUREG-0933, Appendix B, with the following Safety Priority / Status classifications should be reviewed to identify any generic concerns that may be related to the effects of aging or time-limited aging analyses for systems, structures, or components within tiie scope of the license renewal rule:
USl High priority Medium priority Note 1:
"Possible Resolution Identified for Evaluation" Note 2:
" Resolution Available (Documented in NUREG, NRC Memorandum, SER
[ safety evaluation report], or equivalent)"
These criteria are consistent, with one exception, with the staffs guidance in draft Branch Technical Position PDLR 3.0-1 (BTP), which is found in the September 1997 working draft of the standard review plan for license renewal. The evaluation of GSis classified as Note 4,
" Issue to be Prioritized in the Future," has been eliminated. Until the staff completes its j
prioritization process for Note 4 issues and documents the results in NUREG-0933, the full scope of Note 4 issues and the determination of whether safety concerns exist that warrant
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further pursuit (i.e., High or Medium priority) are not known. During the review of its application, an applicant should monitor updates to NUREG-0933 to identify any Note 4 issues that are p g ci o subsequently prioritized and that meet the criteria for review specified above.
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Mr. Douglas J. Walters The criteria proposed by NEl in its October 21 letter did not include evaluation of the Note 2 issues for license renewal. For Note 2 issues, although the NRC may have developed a proposed resolution, action by the NRC to implement that resolution is not complete. Until final implementation requirements are promulgated, those Note 2 GSIs which contain aging issues should be evaluated for license renewal.
The staff's criteria implement the Commission's position, as discussed in the statements of consideration (SOC) for the amended license renewal rule (60 FR 22484), that a renewal applicant must evaluate aging issues associated with unrero!ved GSIs. However, the Commission also clearly stated that an aging management review involving an issue being addressed by the NRC as a GSI shNid not delay the issuance of a renewed license pending resolution of the issue. Four approaches were given in the SOC for addressing unresolved GSis, which the BTP also discusses. Application of the preceding criteria assures that all applicable unresolved GSIs are evaluated. The Low priority GSIs listed in NUREG-0933 need not be reviewed because, as stated in the Introduction to NUREG-0933, these issues have been eliminated from further pursuit by the staff because the generic issues prioritization process has determined that there is little or no prospect of safety improvements. However, the NRC staff does periodically review existing Low priority GSIs to determine whether there is any new information that would necessitate reassessment of the original prioritization evaluations.
NEl has provided guidance for reviewing GSIs in Section 1.5 of its " Industry Guideline for implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule,"
NEl 95-10, Revision 0, which the staff proposed to endorse in its Draft Regulatory Guide, DG-1047, " Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses." The staff has developed the additional guidance contained in, which updates and expands on the guidance found in NEi 95-10 and the BTP.
The staff willincorporate the revised guidance into the next revision of the BTP. NElis requested to consider incorporating the Enclosure 1 guidance into NEl 95-10 To illustrate the application of the criteria contained in Enclosure 1, the staff reviewed NUREG-0933, updcted through Supplement 21, December 1996, to identify GSis involving potential aging effects that should be evaluated in a license renewal application. The results of the staff's review are provided in Enclosure 2. An applicant is expected to apply the criteria contained in Enclosure 1 when preparing its application to review the version of NUREG-0933 in effect to identify GSIs needing evaluation.
Mr. Douglas J. Walters,
NEl is requested to review the enclosures and inform the staff in writing of its intent regarding incorporating the Enclosure 1 guidance into NEl 95-10 and whether it agrees with the staff's application of the criteria to identify the GSIs listed in Enclosure 2.
If there are any questions, please contact Stephen Hoffman of my staff at 301-415-3245.
Sincerely,
)
Christopher I Grimes, Project Director License Renewal Project Directorate Division of Reactor Program Management j
Office of Nuclear Reactor Regulation t
Project No. 690
Enclosures:
As stated cc: w/ encl: See next page B. Doroshuk, BGE R. Gill, Duke l
C. Pierce, SNC 4
NUCLEAR ENERGY INSTITUTE (NEI)
I Project No. 690 cc:
Mr. Dennis Harrison U.S. Department of Energy NE-42 Washington, DC 20585 Mr. Richard P. Sedano, Commissioner State Liaison Onicer i
State of Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, Vsrmont 05620-2601 l:
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e:
Evaluation of USis and GSis for License Renewal Additional Guidance for NEl 95-10. Section 1.5. Revision 0 Insert Line 9 issues designated as unresolved safety issues (USis) and generic safety issues (GSIs) are identified in the NRC program for the resolution of generic issues desenbed in NUREG-0933, "A Prioritization of Generic Safety issues." Appendix B to NUREG-0933 contains a listing of those i
issues that are applicable to operating and future plants. For license renewal, an applicant should evaluate allissues identified in NUREG-0933, Appendix B, with a Safety Priority / Status of USl, High, Medium, and Notes 1 and 2. The version of NUREG-0933 fn 's current on the date 6 months before the date of the application should be used for prepaw.g the renewal application.
During the review of its application, an applicant should continue to review updates to NUREG-0933, Appendix B, to identify new issues added to NUREG 0933 that meet the preceding criteria and issues originally classified as Note 4, " Issue to be Prioritized in the Future " that are subsequently prioritized and that meet the preceding criteria for evaluation. An applicant should a
supplement its application to evaluate any new applicable issues identified up to 6 months j
before the anticipated date for issuing a renewed license.
Those issues that involve aging effects or time-limited aging evaluations for systems, structures, or components within the scope of license renewal should be specifically evaluated in th* " ense renewal application, if, during the preparation or review of the application, the appi. ant or the NRC staff identifies an issue with a " Low" or " Drop" priority that involves potential aging effects and has specific applicability to the applicant's plant, the applicant should evaluate the issue in its application.
Ins _ ert Line 31 Normally, if resolution of a USI or GSI has been achieved before issuance of the renewed license, the first approach listed above, to incorporate implementation of that resolution into the apphation, should be followed.
9 Safety issues Reauiring Review for License Renewal SAFETY ISSUE PRIORilY/
TITLE STATUS i
GSI 23 High Reactor Coolant Pump Seal Failurca GSI 78 Medium Monitoring of Fatigue Transient Limits for
[ Reactor Coolant System]
GSI 166 -
Note 1 Adequacy of Fatigue ;.ife of Metal Components GSI 168 Note 1 Environmental Qualification of Electrical Equipment GSI 173.A Note 2 Spent Fuel Storage Pool: Operating Facilities 4
Mr. Douglas J. Walters NEl is requested to review the enclosures and inform the staff in writing of its intent regarding incorporating the Enclosure 1 guidance into NEl 95-10 and whether it agrees with the staff's application of the criteria to identify the GSis listed in Enclosure 2.
If there are any questions, please contact Stephen Hoffman of my staff at 301-415-3245.
Sincerely, Original signed by:
Christopher I. Grimes, Project Director License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation
+
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Project No. 690
Enclosures:
As stated cc: w/ encl: See next page B. Doroshuk, BGE
- R. Gill, Duke C. Pierce, SNC DOCUMENT NAME: A:\\GS17.SH (S. Hoffman/ AVL Disk #2) *See previous Concurrenca 1/!
g M' f
Tm receive a cop f of this document, Indicate in the box: "C= a Copy without endosurep/lg's Copy with endosures "N" a No copy
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M OFCICE TECH. EC). l N PM:PDLR<.,14 E SC:PDLR {Jl V D:PDLR
,l 6 (A)D:DRP4 OGC' l5 NAME RSanders*
S. Hoffrn(n%h P. T. Kuo' C. Grime ( TM J. Roe f(
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DATE 01107/98 01/ 7 /98 01/ WI98 01/9 /98 W !
01/R/98 ()
01/}3/98 U/
OFFICE GRES # d'/ l ADT:NRR l
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NAME MU*
B. Sheron
- DATE 01///3/98 01/27/98 OFFICIAL RECORD COPY
o HARD COPY Docket File PUBLIC PDLR R/F OED0 RIV Coordinator. 0-17G21 E-Mall w/ encl.
S. Collins /F. Miraglia (SJC1/FJM)
R. Zimmerman (RPZ)
J. Roe (JWR)
D. Matthews (DBM)
S. Meador (SAM)
OPA R. Correia (RPC)
R. Wessman (RHW)
J. Strosnider (JRS2)
S. Droggitis (SCD)
S. Peterson (SRP)
G. Lainas (GCL)
B. Morris (BMM)
J. Moore (JEM)
G. Mizuno (GSM)
G. Holahan (GMH)
S. Newberry (SFN)
- 8. Sheron (BWS)
M. Mayfield (MEM2)
A.-Murphy (AJM1)
H. Brammer (HLB)
L, Shao (LCS1)
G. Bagchi (GXB1)
S. Shaeffer (SMS)
J. Vora (JPV)
C. Craig (CMC 1)
F. Coffman (FDC)
J. Calvo (JAC7)
R.
Emrit (RCE)
PDLR Staff 1