ML20205Q150

Comment on Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear Plant License Renewal. Safety Sys Functional Insps & Configuration Mgt Programs Support Renewal Basis as Opposed to Relicensing Process

ML20205Q150
Person / Time
Site:	Monticello, Kewaunee, Seabrook, Surry, 05000000, Shoreham
Issue date:	10/28/1988
From:	Steinhardt C WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-88-142, FRN-53FR32919, FRN-55FR29043, RTR-NUREG-1317, RULE-PR-50 53FR32919-00029, 53FR32919-29, AD04-1-058, AD4-1, AD4-1-58, NUDOCS 8811090111
Download: ML20205Q150 (4)

Text

e NRC-88-142 WPSC (414) 4331599 TELECOPiER 1414) 4331297 EASYLINK 62891993

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WISCONSIC PUBLIC SERVICE CORPORATION l 'E l 600 Nerth Adams e P.O. Boa 19002 e Green Bay, WI 543o7 9002

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October 28, 1988 Secretary of the Commission U. S. Nuclear Regulatory Comission Washington, D.C. 20555 Attention: Docketing and Service Branch Docket 50 305 Operating License DPR-43 Kenunee Nuclear Power Plant NUREG-1317 (Draft), "Regulatory Options for Nuclear Plant License Renewal" We have reviewed the subject advanced Notice of Propose.d Rulemakina and the NUMARC comments and position paper on the topic dated October 28,1988.

Wisconsin Public Service Corporation endorses the NUMARC position and coments n 1 offers the supplemental information for your consideration.

Section 2 of NUREG-1317 reaches two appropriate conclusions. First, since operating plants are undergoing continual safety reviews as part of the normal NRC function, the relicensing or license extension process should concentrate on the plant aging aspects. Second, past history demonstrates that plant-specific and industry operating data identifies those critical components susceptible to age-related degradation a.ed can be utilized to identify the operating, refur-bishment, and replacement practices necessary to insure continued plant safety.

The,e conclusions only restate the current practice of reviewing plant design features and plant practices to insure incorporation of appropriate tech-nological advances, industry experience, and plant specific operating experience.

As such, plant operational philosophy and maintenance practices become an integral part of the review process. This aspect is presently recognized through the emphasis placed on the SALP program and NRC perfarmance indicator program.

Of the two major topics discussed in Section 3 of NUREG-1317, the topic dealing with an appropriate licensing design basis for life extansion is easiest to resolve. The conclusione. Of Section 2 recognize maintaining an appropriate licensing design basis to insure the public health and safety is currently an ongoing process and practice. Section 2 also states (r. 2-4) "the largest drawback of this approach is its dependence on an wtJated and an often tirnes 8811090111 081020 PDR PR 50 53FR32919 PDR D S( l

Secretary of the Commission October 28, 1988 Page 2 poorly recorded licensing basis". This statement can easily be misinterpreted.

The licensing basis is neither "outdated" nor "poorly recorded" as noted by the NUMAR coments. The original design bases for plants designed in the late 1960's and early 1970's may, in fact, be poorly recorded when the design docu-mentation chain is evaluated utili.ing current audit philosophy and practice.

Prior to development of the present network of codes and standards, sound engineering judgment was applied to design but the design inputs were not documented in exhaustive detail. The industry has recognized this situation and is actively pursuing resolution through the combination of Safet3 System Functional Inspecticas (SSFI's) and Configurstion Management (CM) programs.

SSFI's document the original and current design and licensing bases of a safety system to ensure the system is operating within its design intent and licensing envelope. The CM system and inservice inspection program will then maintain the

' safety system within these bounds. These programs support the renewal basis as opposed to the relicensing process.

] The second technological topic, assessing and predicting the ?ffects of aging

that are significant to plant safety, has two fundamentally different approaches presented. The first approach (option A of section 3.1.2 and 3.2.2) is to iden-tify the safety-significant (i.e., critical) coinponents and structures and uti-i lize industry, plant, and design experience and criteria to determine the i specific degradation considerations, stressor monitoring techniques, and tech-niques for estimating residual life span. The alternative approach (option B of section 3.1.2 and 3.2.2) is to prepare a ."RA which explicitly takes into account plant aging and "integrates all plant systems into a framework providing information on com7enent importance, system performance, and overall safety on a plant-specific basis" (see Section 3.1.2, 2nd para.). The first approach is that used for the pilot PLEX projects at Surry and Monticello and the Residual Life Assessmer.t Project (RLAP) conducted at INEL under an NRC contract. These projects identified the components and stressors and provided insights into monitoring, maintenance, and refurbishing requirements necessary for continued safe plant eperation. The second (PRA) approach uses the assigned probability of failure method to generate the PRA and identify all risk-significant com-ponents. The same detailed analysis is then conducted is in the first approach so that the PRA expresses the effects of agina in terms of changes in failure probability, system availability, and risk. The d, aft NUREG recognizes two problems with this second approach; (1) there is not sufficient actual failure data for passive components to allow meaningful statistical correlations, and (2) there is not a consistent correlation between aging and failure rate for active items. Conversely, what the data may be showing is for passive struc-tures, there is not an age-related degradation effect and the few indications identified may be construction deficiencies or outliers. For active components, the lack of correlation between age and failure rate based on national data bases such as LER's and NPRDS may indicate an effective incorporatinn of plant and industry experience into plant-specific maintenance programs.

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Secretary of the Commission October 28, 1988 Page 3 It seems clear that the Option A of critical component identification, stressor evaluation, and stress interdiction where indicated would be the most ettictive use of industry manpower as shown below:

Option A Option B Emphasizes preventicn Emphasizes mitigation Operates against actual plant Operates ageinst probabilitin aquipment and practices and calculational methods using assumed bases Concentrates resources on Concentrates resources on developing monitoring and maintenance analytical technology and refinement of analytical techniques. Monitoring and maintenance will still be per-formed in phase !!

Implements existing and near- Continues the search for the optimum term technologies to maintain a assignment of resources to achieve tha  ;

consistent licensing / design minimum risk envelope i

The issue of NEPA compliance (Section 4) is actually rather cleai-cut. The licensee should be able to demonstrate, based on the many years plant effluent data, the assumptions made in the Final Environmental Statement are still valid. NPDES (or the host state's equivalent) and the NRC/ EPA limits on radiological discharges are applied on an annual basis and are not a function of plant operating lifetime. The only foreseeable topic that will require addi-tional environmental analysis is in provisions for disposal of low level and high level (spent fuel) waste. The low level waste impact would be treated most efficiently at the Compact level. The question of additional spent fuel stcraoe onsite must be treated early givEn the current DOE progress toward a permanent repository and possible need for a second reposiMey due to life extensions.

Application of the backfit rule (10 CFR 50.109) will hinge to a large extent on the options chosen under the technical topics section. If the renewal basis is the license and plant design considerations in effect at the time of renewal (current licensing basis), backfit is not a special consideration; it is already in effect for post and future potential licensing considerations. If special requirements or code updates are mandated prior to license renewal, the backfit rule must be applied and benefit to the health and safety of the public demonstrated. Due to the potential magnitude of mandated plant modifications, they could be the controlling factor on the decision to apply for renewal or decommissioning.

Effective date of renewal (or non-revokeability) is another critical issue. The draft points out in section 5.5 that, if a license extension is granted possibly ten years prior to expiration date, the utility must have assurance the extension will still be valid at the expiration date. Industry experiences and develop-

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L., Secretary of the Comission L

October 28, 1988 Page 4 ments during this period could still be incorporated into the license under the

• l normal backfitting cor.siderations but a Seabrook/Shoreham situation could not be allowed to develop. l In sumary, Wisconsin Public Service Corporation comends the NRC on their early j involvement of the industry and tne public in development of the administrative  ;

and technical aspects of the contin.ted utilization of a vital natior.a1 resource  :

and looks forward to continued part'cipation in the regulatory development pro- f Cess. '

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l' Sincerely,  :

Wllku& l C. R. Steinhardt l Mcnager - Nuclear Power .

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cc - Mr. Robert Nelson, US NRC f IIS NRC, Region III j l

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