ML20199H611
| ML20199H611 | |
| Person / Time | |
|---|---|
| Issue date: | 01/20/1998 |
| From: | Bill Dean NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Thompson H NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 9802050084 | |
| Download: ML20199H611 (9) | |
Text
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20$$5 0001 N...., *#
January 20, 1998 l
i MEMORANDUM T0:
Hugh L. Thompson, Jr.
Deputy Executive Director for Regulatory Programs l
FROM:
William M. Dean, Chief Regional Operations and Program Management Staff. OEDO SUBJECi.
SUMMARY
OF DECEMBER 18, 1997, PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE ON MUTUAL ITEMS OF INTEREST On December 18, 1997, senior mangers of the Nuclear Energy Institute (NEI) met with senior managers of the Nuclear Regulatory Commission (NRC) at the NRC's offices at One White Flint North in Rockville, MD. The purpose of the public meeting was to provide an opportunity for the senior m6nagers of both organizations to discuss items of current interest to the nuclear industry. provides a summary of the meeting and Attachment 2 is a list of meeting attendees.
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Mr. Ralph Beedle Ms. Lynette Hendricks. Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy Institute 1776 I Street. NW. Suite 400 1776 I Street. NW Suite 400 Washington, DC 20006-3708
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Mr. James Davis, Director Operations Nuclear Energy Institute 1776 I Street. NW Suite 400 Washington, DC 20006-3708 Mr. Tony Pietrangelo. Director Licensing Nuclear Energy Institute 1776 I Street. NW Suite 400 Washington, DC 20006-3708 Mr. Steve Floyd. Director Regulatory Reform and Strategy Nuclear Energy Institute 1776 I Stree*, NW Suite 400 Washington. DC 20006-3708 Mr. Dave Modeen. Director Engineering Nuclear Energy Institute 1776 I Street. NW Suite 400 Washington. DC 20006-3708 Mr. Robert Bishop. General Counsel Nuclear Energy Institute 1776 I Street. NW Suite 400 Washington. DC 20006-3708
January 20, 1998 MEMORANDUM T0:
Hugh L. Thompson, Jr.
Deputy Executive Director for Regulatory Programs FROM:
William M. Dean, Chief Regional Operations and CA:G!NAL StGNED BY Program Management Staff. OEDO I
SUBJECT:
SUMMARY
OF DECEMBER 18. 1997. PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE ON MUTUAL ITEMS OF INTEREST On December 18, 1997, senior mangers of the Nuclear Energy Institute (NEI) met with senior managers of the Nuclear Regt'latory Commission (NRC) at the NRC's offices at One White Flint North in Rockville. MD. The purpose of the prolic meeting wa#, to provide an opportunity for the senior managers of both organizatias to discuss items of current interest to the nuclear industry. provides a summary of the meeting and Attachment 2 is a list of meeting attendees.
Attachments:
As stated cc w/ attachments:
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SUMMARY
OF NRC/NEI SENIOR MANAGER MEETING DECEMBER 18. 1997
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EC_ Enforcement Process NEI noted that they had recently met with representatives from the Office of g
Enforcement and expressed that the meeting was very positive and that it hoped to continue with periodic meetings. The main issues they raised were:
O industry concerns with the NRC's characterization of issues as low safety significance but high regulatory significance:
that the NRC consider using an approach similar to the Federal Aviation Administration (FAA):
the industry needs a better understanding of how the agency intends to enforce against performance-based rules that issuing an order to licensees to confirm schedules for dealing with Thermo-Lag is an inordinate way to solve the problem.
The EDO noted that it is important for the NRC to act decisively on problems that are precursors of more safety significant problems.
The emphasis on issues of regulatory significance is needed for just this reason.
Examples of such issues include: repeat events, problem identification, and corrective action. The NRC addressed the FAA issue by noting that FAA's threshold for taking enforcement action is similar in description to the level of problems that would warrant the NRC to order a plant to be shut down.
With respect to tha Thermo-Lag issue, it was noted that this was currently before the Commission, which prevented the NRC from engaging in discussion on this topic.
Safety Goal Pilot Proiect NEI noted that they are in the process of identifying items that industry believes would be easy to remedy and requested that the NRC form a team to follow the project.
NEI stated that they expect to identify 20-30 rules and regulations that may need to be modified as a result of this pilot program.
The NRC noted that similar pilot efforts in the past have suffered from too many interactions between the NRC and NEI. resulting in frequent changes in the guidance. The focus needs to be on ensuring quality of the products is both high and consistent.
t NRC Assessment Process NEI reiterated the message transmitted in its letter of November 14, 1997, that the NRC communicate with the industry early on as to what the process and performance indicators will be.
NEI has formed an industry task force to follow this issue and NEI noted that it is also developing guidance on what constitutes a good Performance Indicator prograni.
Steam Gen:rator Issues Development of a formal industry position has been undertaken and the associated guidance document, NEI 97-06, has been distributed.
NEI stated it will mail copies to the NRC staff.
The objectives of this document are to:
provide a clear commitment to EPRI guidelines, a more unified industry approach, and more performance based focus on maintaining steam generator tube integrity. The NRC statf had not seen the NEI document at the time of the meeting.
NEI believed it is technically in agreement with the NRC but some details may remain to be resolved.
The NRC stated a generic letter and regulatory guide are already under development and therefore it may be too late to incorporate the NEI document.
However, the NEI guidance may represent an alternate method of completing what is described in the regulatory guide.
NEI requested a follow up meeting with NRR in the February 1998 time frame.
Fire Protection NEI provided a summary of their recent activities in the fire protection area including: a November meeting with the staff, a presentation to ACRS, and a letter to the EDO. The staff stated the rule making plan is under development. NEI stated the rule is not necessary from a safety perspective and it is concerned that many of the old issues that have been dealt with over time may be lost. The DEDR stated we will include NEI's letter to the EDO in a forthcoming Commission paper on Fire Protection issues so the Commission will be fully abreast of the industry views.
Reactor Vessel Internals Database NEI stated that EPRI has conducted an industry survey to create a reactor pressure vessel industry databsse.
Though not necessarily a cost issue, there are questions about control of t:ie data and how the NRC intends to use its own Reactor Vessel Integrity Database.
NEI also stated there is a need to alleviate over-conservatisms that exist.
NRR believes the database should be g
maintained by the industry.
NRR and NEI agreed to interact on what can be
i done for data validation and to discuss differences in each of the databases and how they might be addressed, if needed.
Source Term NRC is delaying its schedule for rebaselining and reviewing submittals from the two pilot plants. The NRC noted there is a resource problem-in doing this in parallei with the AP600 reviews.
NEI stated this was a problem for the pilot plants and interaction between the NRC and the licensees was needed to
-address this issue.
Reaulatory Process NEI raised the issue of how a change to a Branch Technical Position relative to a specitic license amendment would be communicated to other licensees. NEI offered to act as a conduit to assist in this area.
NRC stated it is not yet ready to comit to this change in direction. The NRC noted that it generally issues an IN for an issue at one plant that potentially has generic implications.
IEEE 603 NRC has received adverse comments on pursuing a direct final rule to codify IEEE_603 and so is changing to the normal rulemaking process. NEI also noted that the~
sed for a 30 day extension to the review period for NUREG 1559
' Draft adard Environmental Review Plan." The staff indicated they were reluctant to extend the 120 day comment period as it would adversely impact follow on activities associated with license renewal.
Licensina Issues NEI asked whether the NRC's time frame for revising 10CFR50.59 has changed.
NRC noted that it hoped to move forward to the Commission papers related to FSAR and 10CFR50.59 improvements by the end of December. However, this may be delayed to address Commission comments following a recent briefing on the
-subject. The NRC stated they have received four NEI documents in association with this issue and these are currently being reviewed by the staff and considered in the packages being prepared.
NRC stated they will continue to meet with NEI on these issues. NEI stated they had just met with each of the Commissioners on this subject and had received some good insights.
NEI stated it will send some additional suggested changes on the scoping issue.
NEI stated the comments on the FSAR update are due soon and NRC and NEI will continue to meet on this issue. NEI is holding a workshop in January 1998 to determine how well licensees are updating the FSAR.
The-NRC staff stated they
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agreed with much of the NEI feedback but need to deal with the rulemaking process. NEI stated they do not believe rule making is necessary.
They are concerned about interim guidance causing difficulties like the NUREG 1606 issue did with 10CFR50.59. Also NEI believes there is a desire to jump ahead without taking care of criteria needs, such as risk informed content.
Anoendix B Vendor Insoections The NRC offered that NEI may want to take the initiative to help licensees undertake some vendor inspections.
Paper audits are not very beneficial but detailed technical audits of vendor activities would be a very beneficial proactive action.
Such an action may negate the need for a generic letter.
NEI stated they would look at this issue. They did note that they have a robust fuel group in EPRI that is in the middle of commercial issues.
NEI agreed to follow-up with the NRC staff on this issue.
Sianificant Control Manioulations The NRC staff stated it is reassessing the requirements for control manipulations for obtaining an operator license.
This issue has caused some l
plants to manipulate power levels just for training purposes. The NRC staff stated it would be interested in NEI input relative to a proposed rule change.
NEI agreed to follow-up with the NRC staff on this issue.
Year 2000 Issues The NRC staff stated the NEI guidance document (NEI 97-07) is good but it is not binding on the licensees.
The NRC is looking for some commitment from licensees to avoid the need for the NRC to issue generic communications. The NRC stated the NEI guidance is not written as regulatory guidance but rather as management guidance on how to assess and correct issues.
NEI stated that the NRC should issue generic communication if it believes it is necessary.
Risk Informed Initiatives The NRC staff stated it needed advance notice of what initiatives are going to be proposed, the schedule, and the resource impacts in order to address the myriad of activities being undertaken by industry in this area. NEI stated it is looking at a plan for implementation of a "living" PRA.
Comunications NEI gave some examples of how daily reports on the web site are being referenced by the media as " reports". NEI stated this is a powerful tool that gives access to a lot of information and care should be taken to ensure its
6 accuracy, One example given as a potential problem was when a plant is
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projecting a return to power and this information is made public. Such information on the web can give an economic advantage to competitors. The NRC stated that it needs to continue to work on its communications but that the l
industry also needs to communicate effectively with its stakeholders so that I
the NRC is not relied upon as the only source of information.
No further topics were discussed and the meeting adjourned at 11:00 a.m.
i
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NRC/NEI SENIOR MANAGER MEETING-LIST OF ATTENDEES DECEMBER 18, 1997 NME ORGANIZATION Joe Callan NRC Hugh Thompson, Jr.
.NRC Tim Martin NRC Ashok Thadani NRC Lawrence Chandler NRC Mal Knapp NRC Jim Lieberman NRC William Kane NRC Brian Sheron NRC David Matthews NRC Mark Satorious NRC Bill Dean NRC Glenn Tracy' NRC Mel Leach NRC
' Stewart 1Magruder NRC
- NEI
-James Davis NEI Alax Marion NEI Tony Pietrangelo NEI Steve Floyd NEI David Modeen NEI-Robert Evans-NEI Bob-Bishop
-NEI Lynette Hendricks NEI Nancy Chapman SERCH/Bechtel Jenny Weil McGraw Hill
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