ML20205Q666

Comment on Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear Plant License Renewal. Endorses NUMARC Nuplex Working Group Comments,Including Use of Licensing Basis at Facility When Renewal Application Submitted

ML20205Q666
Person / Time
Site:	Hatch, Vogtle, 05000000
Issue date:	10/27/1988
From:	Mcdonald R GEORGIA POWER CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR32919, FRN-55FR29043, RTR-NUREG-1317, RULE-PR-50 53FR32919-00017, 53FR32919-17, AD04-1-046, AD4-1, AD4-1-46, NUDOCS 8811090311
Download: ML20205Q666 (6)

Text

- _ _ _ _ _ _ _ _ _ _ _ ._ .-

<J;lt!ff; DOCKET NUMBER nn /7

, . w v.: x a ee 4 a inca PROPOSED RULE m 60 l:'u5:i.$atu F4 Mh .

nr a sw; a 3m: f l

R. R ucconsid 5

' 8 5*'

Em ue m nes am tww owaws --

.t, - -

a? f,f r October 27, 1988 i

Mr. Samuel J. Chilk Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTN: Docketing and Service Branch PLANT HATCH - UNITC 1 AND 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 PLANT V0GTLE - UNITS 1 AND 2 NRC DOCKETS 50-424, 50-425 OPERATING LICENSE NPF-68 CONSTRUCTION PERMIT CPPR-109 COMMENTS IN RESPONSE TO NRC ADVANCE NOTICE OF PROPOSED RULEMAKING - PLANT LICENSE RENEWAL (53 FEDERAL REGISTER 32,919 0F AUGUST 23, 1988) a 3

Gentlemen:

On Monday, August 29, 1988, the Nuclear Regulatory Consission ("NRC")

published in the Federal Register an advance notice inviting public comments on a proposed rulemaking dealing with NUREG - 1317, "Regulatory Options for Nuclear Plant License Renewal". This advance notice, and the NUREG document to which it referred, posed a series of questions and policy options for public consent. The period for public comment expires on October 28, 1998.

Georgia Power Company has monitored the NUMARC NUPLEX Working Group efforts in the development of this rulemaking. In accordsnee with the advance rulemaking request for public comments, Georgia Power Company hereby endorses the NUMARC NUPLEX Working Group comments to be provided to the NRC on October 28, 1988.

Georgia 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.

8811090311 881027 PDR PR 50 53FR32919 PDR D5/c

', a

'. f{i Mr. Samuel J. Chilk October 27, 1988 U. S. Nuclear Regulatory Consission Page 2 If there are any questions, please advise. __

s

Sincerely,

' /

R. P. Mcdonald Enclosure 1 c Georgia Power Company Mr. P. D. Rice, Vice f resident and Vogtle Project Director Mr. G. Boekhold, Jr. , General Manager - Plant Vogtle Mr. L. T. G3 cwa, Manastr Hatch Engineering and Licenstag Mr. J. P. Kane, Manager Vogtle Engineering and Licensing

CO-NORMS

! U. S. Nuclear Regulatory Cosaission, Washington, D.C.

j Mr. J. B. Hopkins, Licensing Project Manager - Vestle Mr. L. P. Crocker, Licensing Project Manager - Hatch

! U. S. Nuclear Regulatory Casaission, Region II

, Dr. J. N. Grace, Regional Administrator j Mr. J. F. Rogge, Senior Resident Inspector, Operations - Vogele j Mr. J. E. Menning, Senior Resident Inspector - Hatch 5

2 f

l 1

l I

l i

j 1

l l

---

n ., .-- --_,-. -.---, ,- - n ~,,,-.-.- --.-- ,- - .

ENCLOSUR" Georgia Power Company Comments on NRC Advance Notice of Proposed Rulemaking

, Concerning License Renewal and on NUREG-1317, "Regulatory Options for Nuclear Plant License Renewal" The Advaace Notice invited the public to consent on the issues and opaions discussud in NUREG-1317 "Regulatory Options for Nuclear Plant License Renewal" (June 1988). That Notice specifically requested a response to five questions posed both in the Notice and the NURIG and solicited comments on the regulatory options proposed in the NUREG. ,

)

Georgia 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 l renewal issue to the NRC on October 28, 1988. Georgia Power Company has '

reviewed and hereby endorses the comments being provided by NUMARC.

There are five areas that Georgia Power Company considers essential for the feasibility of life extension and feels should be strongly emphasized. 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 renawal application is submitted, or using a modified licensing basis that supplements, as necessary, the original licensing basis in safety significant areas. Question 3 of the Advance Notice asks for public consent on the "benefits of requiring the licensee to verify his original licensing design basis, as subsequently amended." The NUMARC consents support and Georgia 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 acnitors 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 CTR 50, Appendir B confaguration control program.  ;

1 Both NRC and utility inspection prograss currently exist to assure proper  ;

maintenance of the licensing 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 r plants. Thus, a utility's licensing basis at the time of license renewal i application can be erpected to be adequately known, understood, and documented to serve as the foundation for the findings required by the 1

I Page 1 of 4

l Raelosure Coenents on Advance Notice -

Plant License Renewal  :

Atomic Energy Act and the NRC regulations. Any additional licensing .

requirements to be imposed on the 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 Reviews  ;

l As discussed above the licensing bases and plant configuration are l' asintained current throughout the life of the plant. Therefore, a complete and through review of the plant's configuration need not be i performed to assure compliance with the facility's entire licensing basis. The review of the plant's configuration and licensing basis should i focus only on those pertinent structures, systems, and components which t are safety significant and which could experience age related degradation  ;

processes that might not be attigated through routine monitoring, i maintenance, and replacen nt during the estended operating plant lifetime. [

3. Timely Renaul Doetr.tne If a license renewsti applicant submits an application in advance of the i scheduled license expiration date in order to allow NRC a reasonable l period of time for consideration, the licensee should receive the benefit i of the timely renewal doctrine. The doctrine provides, under the i Administrative Procedure Act and section 2.109 of the NRC regulations, [

that the continued operation of the facility must be permitted, absent any l NRC enforcement action, until the Itcensee renewal requests have been l acted upon by the NRC. l

4. Use of the Backfit Rulet The "Backfit Rule" as set forth in the Cmission regulations f (10 CFR 50.109) is the procedural basis for the evaluation of new I 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 L systems, structures, components in design of a facility." Therefore, the Backfit Rule should apply to any safety enhancement during the renewal l perios 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. [

l i

L l

i Page 2 of 4

Enclosure Commer a on Advance Notice Plant .ucense Renewal

5. Procedural Issuest Consistent with the NUMARC NUPLEX Working Group comments, Georgia Power Company believes that the issues of energency planning, decossissioning,

antitrust review, Price Anderson Act Coverage, and saterial alteration have little bearing on the license renewal issue. Action relative to these issues should be fully finalized in the NUREG so that resources can be more efficiently directed toward resolution of the more substantive issues associated with license renewal policy. RefeJ to the NUMARC NUPLEX Working Group consents for a more detailed explanation of this position.

In addition to the NUMARC consents, Georgia Power Company provides the

, following comments:

1. A question raised by the NRC in NUREG-1317 is "How should the NRC determine the design adequacy of a plant for continue.1 operation over the I renewal ters?" One of the options the NRC has provided deals with strong emphasis on a probabilistic risk assessment (PRA) to address future plant aging. NUREG-1317 states that this option would involve the use of a PRA to address the followingt o Identify risk significant components and structures.

1 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 agies on changes in systen availability and risk cannot j 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 estimate.

An option to address the effects of aging for some structures, systems, or components whose aging is not mitigated through routine monitoring, i

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 the adequacy of certain types of components (e.g. large motors) for extended plant life. Factors related to the l

l 1

) Page 3 of 4 l

i 1

l e (

Esclosure I

Comments on Advance Notice Plant License Renewal ,

t maintenance and performance history could also be addressed by such a data base. As a minimus, a data base of this type could reduce the scope of ,

the study requested for the renewal process. c

2. With regard to the technological issues, NUREG-1317 identifies two basic options available to compensate for any uncertainties related to plant t aging. The first option (emphasis on plant saintenance, inspection, and l reliability) would adequately protect the public health and safety. The  :

second option (impose an additional level of protection in safety systems I

, as a "defense in depth" approsch) would require an additional level of  !

1 protection beyond what is currently considered adequate. No justification l has been provided as to why the NitC should require a level of protection l i beyond that which is required through the current regulatory process.

! Aging uncertainties are currently accounted for in the plant design basis 1 and through the plant maintenance and inspection programs. This to a .

proven, acceptable method .hich should be continued. [

i I

I

. r

! l l

l 1

l l

i i

1 3

5 j

i I

I j

1 j Page 4 of 4 i

i

-__. -- _-- - - , . - - - - .-_ -