ML20205Q623
| ML20205Q623 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/27/1988 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR32919, FRN-55FR29043, RTR-NUREG-1317, RULE-PR-50 53FR32919-00018, 53FR32919-18, AD04-1-047, AD4-1, AD4-1-47, NUDOCS 8811090298 | |
| Download: ML20205Q623 (6) | |
Text
DOCKET tw,',tSER Alabama Power Company O Ndl,[ ]
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October 27, 1988 Docket Nos. 50-349 50-364 Mr. Samuel J. Chilk Secretary of the Consission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTN Docketing and Service Branch Dear Mr. Chilkt Ret Comments in Response to NRC Advance Notice of of Proposed Rulemaking - Plant License Renewal (53 Federal Register 32,919 of August 29, 1988)
On Honday, August 29, 1988, the Nuclear Regulatory Commission ("NRC")
published in the Federal Register an aivance notice inviting public comments on a proposed rulemaking dealing with NUREG - 1317. "Regulatory Options for Nuclear Plant License Renewal". This advance notice, and the NUkEG document to which it referred, posed a series of questions sni policy options for public comment. The period for public comment expires on October 28, 1988.
Alabama Power Company has monitored the NUKARC NUPLEX Working Group efforts in the development of this rulemaking.
In accordance with the advance rulemaking request for public comments, Alabama Power Company hereby endorses the NUKARC NUPLEX Working Group comments to be provided to the NRC on October 28, 1988.
Alabama Power Company also encloses additional comments which are pertinent to this rulemaking. We appreciate the opportunity to express our views to the NRC on the NRC's Advance Notice of Proposed Rulemaking.
8811090290 001027 53 32919 D bt o
o Mr. Samuel J. Chilk October 27, 1988 U. S. Nuclear Regulatory Commission Page 2 If there are any questions, please ad31se.
Respectfully submitted.
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R. P. Mcdonald Enclosure cct Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford
ENCLOSURE Alabama Power Company Comments on NRC Advance Notice of Proposed Rulemaking Concerning License Renewal and on NUREG-1317, "Regulatory Options for Nuclear Plant License Renewal"
'ane Advance Notice invited the public to comment on the issues and option =
discussed in NUKEG-1317. "Regulatory Options for Nuclear Plant Licener Renewal" (June 1988). That Notice specifically requested a response to five questions posed both in the Notice and the NUREG and solicited comments on the regulatory options proposed in the NUREG.
Alabama Power Company is participating in industry efforts associated with license renewal which has included involvement with the NUMARC NUPLEX Working Group Effort. The working group is providing detailed comments to the license renewal issee to the NRC on October 28, 1988. Alabama Power Company has reviewed and hereby endorses the comments being provided by NUMARC.
There are five areas that Alabama Power Company considers essential for the feasibility of life extension and feels should be strongly emphasised.
These are as follows:
1.
Current Licensing Basist In NUREG-1317, the NRC provided three options that could be considered for license renewal. These options involve using the original licensing basis of the plant, using the licensing requirements for plants at the time a renewal application is submitted, or using a modified licensing basis that supplements, as necessary, the original licensing basis in safety significant areas. Question ? 't the Advance Notice asks for public comment on the "benefits of requiring the licensee to verify his original licensing design basis, as subsequently amended." The JUMARC comments support and Alabama Power Company strongly endorses the use of the licensing basis in effect at each individual facility at the time when a renewal application is submitted. That licensing basis is acceptable since the NRC constantly monitors safety issues, addresses them on a continuous basis, and requires modifications to operating plants as needed. Moreover, adequate documentation of current licensing bases is assured through the requirement to annually update FSARs and through each individual utility's 10 CFR 50, Appendir B configuration control program.
Both NRC and utility inspection programs currently exist to assure proper maintenance of the liccasing basis.
The purpose of these programs is to assure that the current licensing bases of operating plants are adequate, even though they might be different from the licensing standards for new plants.
Thus, a utility's licensing basis at the time of license renewal application can be expected to be adequately known, understood, and documented to serve as the foundation for the findings required by the Page 1 of 4
Enclosure Comments on Advance Notice Plant License Renewal Atomic Energy Act and the NRC regulations. Any additional licensing requirements to be imposed on tne facility at that time should be applied through the disciplined process of the Backfit Rule and should not be a part of this rulemaking.
2.
Scope of Reviewt As discussed above the lir.ensing bases and plant configuration are maintained current throutpout the life of the plant.
Therefore, a complete and through review of the plant's configuration need not be performed to assure compliance with the facility's entire licensing basis.
The review of ',he plant's configuration and licensing basis should focus only on those p'srtinent structures, systems, and components which are safety significant and which could experience age related degradation processes that might not be mitigated through routine monitoring, maintenance, and replacement during the extended operating plant lifetime.
3.
Timely Renewal Doctriner If a license renewal applicant submits an application in advance of the scheduled license erpiration date in order to allow NRC a reasonable period of time for consideration, the licensee should receive the benefit of the timely renewal doctrine.
Tha doctrine provides, under the Administrative Procedure Act and section 2.109 of the NRC regulations, that the continued operation of the facility must be permitted, absent any NRC enforcement action, until the licensee renewal requests have been acted upon by the NRC.
4.
Use of the Backfit Rule The "Backfit Rule" as set forth in the Commission regulations (10 CFR 50.109) is the procedural basis for the evaluation of new regulatory requirements including those potentially applicable to a facility for which license renewal is sought. The Backfit Rule specifically states that it applies to "the modification of or addition to systems, structures, components in design of a facility." Therefore, the BecVfit Rule should apply to any safety enhancement during the renewal period for the same reason it applied to the original period of operation. Refer to the NUMARC NUPLEX Working Group comments for a more detailed explanation of this position.
Page 2 of 4
cnelosure Comm..r;
'a Advance Notice Plant License Renewal 5.
Procedural Issuest Consistent with the NUMARC NUPLEX Working Group comments. Alabama Power Company believes that the issues of emergency planning, decommissioning, antitrust review, Price Anderson Act Coverage, and material alteration have little bearing on the license renewal issue.
Action relative to these $ssues should be fully finalized in the NUREG so that resources con be more efficiently directed toward resolution of the more substantive issues associated with license renewal policy. Refer to the NUMARC NUPLEX Working Group comments for a more detailed explanation of this position.
In addition to the NUMARC comments, Alabama Power Company provides the following comments:
1.
A question raised by the NRC in NUREC-1317 is "How should the NRC determine the design adequacy of a plant for continued operation over the renewal term?" One of the options the NRC has provided deals with strong emphasis on a probabilistic risk assessment (FRA) to address future plant aging. NUREG-1317 states that this option would involve the use of a PRA to address the followingt o
Identiff risk significant components and structures.
o Estimate effects of aging in terms of changes in system availability and risk.
o Demonstrate minimal increase in risk due to continued aging over the renewal term.
PRA is an effective tool for risk evaluation and management. However, the effect of aging on changes in system availability and risk cannot currently be evaluated with a reasonable degree of certainty given the present PRA state-of-the-art. Any output from such an exercise would have limited value. Therefore, the NUREG should not currently endorse use of PRA for such an estinate.
An option to address the effects of aging for some structures, systems, or componento whose aging is not mitigated through routine monitoring, maintenance, and replacement could be to develop a form of an industry wide experience data base including non-nuclear erperience much like the Seismic Qualification Utility Group's current efforts.
Such a data base could potentially demonstrate che adequacy of certain types of components (e.g. large motora) for extended plant life. Factors related to the 1
Page 3 of 4
Enclosure i
Comments on Advance Notice Plant License Renewal i
maintenance and performance history could also be addressed by such a data base. As a miniaun, a data base of this type could reduce the scope of the study requested for the renewal process.
2.
With regard to the technological issues, NUREC-1317 identifies two basic options available to compensate for any uncertainties related to plant aging. The first option (emphasis on plant maintenance, inspection, and reliability) would adequately protect the public health and safety. The second option (impose an additional level of protection in safety systems as a "defense in depth" approach) would require an additional level of i
protection beyond what is currently considered adequate. No justification has been provided as to why the NRC should require a level of protection l
l beyond that which is required through the current regulatory process.
Aging uncertainties are currently accounted for in the plant design basis i
and through the plant saintenance and inspection programs.
This is a proven, acceptable method which should be continued.
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