ML20206G098

Summary of 990414 Meeting with Industry Licensing Action Task Force Meeting in Rockville,Md Re Minor TS Changes & Preliminary Feedback from Industry on Revs to NRC Request for Addl Info.List of Attendees Encl

ML20206G098
Person / Time
Issue date:	04/30/1999
From:	Black S NRC (Affiliation Not Assigned)
To:	Zwolinski J NRC (Affiliation Not Assigned)
References
NUDOCS 9905070062
Download: ML20206G098 (12)

Text

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April p0,.1999-MEMORANDUM TO: John A. Zwolinski, Director:

Division of Licensing Project Management Office of Nuclear Reactor. Regulation FROM: Suzanne C.' Black, Deputy Director -

Division of Licensing Project Management

' Office of Nuclear Reactor Regulation ,

l .

SUMMARY

.OF APRIL 14,1999 NRC/ INDUSTRY LICENSING ACTION TASK FORCE MEETING '

' The U.S. Nuclear Regulatory Commission (NRC) held a meeting with representatives from the -

nuclear industry on April 14,1999, at NRC Headquarters in Rockville,- Maryland. Attachment 1 lists the attendees at the meeting; Attachment 2 contains a copy of the material presented at the meeting; and Attachment 3 contains a list of action items from the meeting.

. The meeting was held between members of the NRC and Industry Licensing Action Task Force.

The fo9owing topics were discussed: (1) minor Technical Specification changes, (2) preliminary -

feedback from the industry on revisions to the NRC request for additional information (RAl) process, and (3) dividing the NRC/ industry Licensing Action Task Force into teams focusing on -

various broad topics.

The next meeting of the NRC/ Industry Licensing Action Task Force is planned for sometime in June 1999.

Attachments: As stated cc w/atts: See next page E fi U M E R g e p v -

DISTRIBUTION Hard Copy E-Mail

-. Central File S. Collins /R. Zimmerman W. Reckley R. Dennig PUBLIC B. Sheron (BWS) M. Cheok W. Beckner PD 3-1 r/f. J. Zwolinski S. Lee L.Raghavan J. Zimmerman S. Black M. Rubin R. Bachman i OGC J. Moore R. Lobel

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ACRS S. Peterson M. Tschiltz

. B. Wetzel T. Harris B. Wetzel Q (W(' m '(96 m

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NAME- BWetzel /pl/ THarris Jd> GDick UA SBlack "$b L' U DATE 9 / 8 /99 9 /Af/99 4 /30 /9f " ' t.// ,9/99 O

OFFICIAL RECORD COPY -

9905070062 990430 PDR ORG NRRA PDR

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. April 30, 1999 5 MEMORANDUM TO: John A. Zwolinski, Director Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM: Suzanne C. Black, Deputy Director Division of Licensing Project Management i Office of Nuclear Reactor Regulation I

SUMMARY

OF APRIL 14,1999, NRC/ INDUSTRY LICENSING ACTION TASK FORCE MEETING The U.S. Nuclear Regulatory Commission (NRC) held a meeting with representatives from the nuclear industry on April 14,1999, at NRC Headquarters in Rockville, Maryland. Attachment i lists the attendees at the meeting; Attachment 2 contains a copy of the material presented at the meeting; and Attachment 3 contains a list of action items from the meeting.

' The meeting was held between members of the NRC and Industry Licensing Action Task Force.

The following topics were discussed: (1) minor Technical Specification changes, (2) preliminary feedback from the industry on revisions to the NRC request for additional information (RAI) process, and (3) dividing the NRC/ Industry Licensing Action Task Force into teams focusing on various broad topics.

The next meeting of the NL ndustry Licensing Action Task Force is planned for sometime in June 1999.

Attachments: As stated cc w/atts: See next page DISTRIBUTION Hard Copy E M ail

' Central File S. Collins /R. Zimmerman - W. Reckley R. Dennig PUBLIC B. Sheron (BWS) M. Cheok W. Beckner PD 3-1 r/f J. Zwolinski S. Lee L.Raghavan J. Zimmerman- S. Black M. Rubin R. Bachman OGC. J. Moore R.Lobel ACRS S. Peterson M. Tschiltz B. Wetzel. T. Harris B. Wetzel DOCUMENT NAME: G:\ REGION 3\PD3-1\WPDOCS\PTBEACH\MTS44199 OFFICE PM:PD3-1 l LA:PD3-1 lE (A)SC:PDh1( E DD:DLPM l Ih NAME BWetzel A3L/ THarris Jatk GDick 4,A\; SBlack db DATE 9/8/99  %/M/99 4 /E /9s "' t// #A/99 OFFICIAL RECORD COPY

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, ra uau g i UNITED STATES s

2 j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20056-0001 i

\,*****J April 30, 1999 l

MEMORANDUM TO: John A. Zwolinski, Director Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM: Suzanne C. Black, Deputy Director b Division of Licensing Project Management Office of Nuclear Reactor Regulation l

SUMMARY

OF APRIL 14,1999, NRC/ INDUSTRY LICENSING ACTION TASK FORCE MEETING The U.S. Nuclear Regulatory Commission (NRC) held a meeting with representatives from the nuclear industry on April 14,1999, at NRC Headquarters in Rockville, Maryland. Attachment i lists the attendees at the meeting; Attachment 2 contains a copy of the material presented at the meeting; and Attachment 3 contains a list of action items from the meeting.

The meeting was held between members of the NRC and Industry Licensing Action Task Force.

The following topics were discussed: (1) minor Technical Specification changes, (2) preliminary feedback from the industry on revisions to the NRC request for additional Information (RAI) process, and (3) dividing the NRC/ industry Licensing Action Task Force into teams focusing on various broad topics.

The next meeting of the NRC/ industry Licensing Action Task Force is planned for sometime in June 1999.

Attachments: As stated cc w/atts: See next page

cc: Mr. Ralph Beedle Mr. Jim Fisicaro, Manager Senior Vice President Nuclear Assessment and issues and Chief Nuclear Officer Duke Energy Corporation Nuclear Energy Institute 526 South Church Street l 1776 l Street, NW, Suite 400 Charlotte, North Carolina 28201-1006 Washington, DC 20006-3708 Mr. Alex Marion, Director Programs l

Nuclear Energy institute 1776 l Street, NW, Suite 400 i

)

Washington, DC 20006-3708 Mr. Jim Davis, Director Operations Nuclear Energy institute 1776 i Street, NW., Suite 400 Washington, DC 20006-3708 Mr. Tony Pietrangelo, Director Licensing ,

Nuclear Energy Institute k 1776 l Street, NW., Suite 400 i Washington, DC 20006-3708 Mr. Steve Floyd, Director Regulatory Reform and Strategy Nuclear Energy Institute 1776 l Street, NW., Suite 400 Washington, DC 20006-3708 Mr. Dave Modeen, Director ,

Engineering Nuclear Energy Institute 1776 l Street, NW., Suite 400 Washington, DC 20006-3708 Mr. Scott Peterson, Senior Director ,

Communications 1 Nuclear Energy Institute I 1776 I Street, NW., Suite 400

- Washington, DC 20006-3708 Ms. Lynette Hendricks, Director Plant Support -

Nuclear Energy Institute 1776 i Street, NW., Suite 400 q l

! Washington, DC 20006-3708 1 l

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NRC/ INDUSTRY LICENSING ACTION TASK FORCE MEETING LIST _OEAIIENDEES Aoril 14.1999 NAME ORGANIZATION Suzanne Black NRC/NRR/DLPM Beth Wetzel NRC/NRR/DLPM William Beckner NRC/NRR/TSB Bob Dennig NRC/NRRTTSB Jake Zimmerman NRC/NRR/DLPM Donald Woodlan TU Electric Mike Schoppman NEl Alex Marlon NEl l Al Passwater Ameren UE l James Fisicaro Duke Energy l Joe Kelly FTl Roger Hustos Licensing Support Services Everett Perkins Entergy Jim Kelly PP&L John Osborne BGE Charles Brinkman ABB E.J. Weinkam FPL Brian McIntyre Westinghouse Dale Wuokko FENOC

M. Callahan GSL Assoc.

Colleen Amoruso NUS Info. Services Nancy Chapman SERCH/Bechtel Bill Reckley NRC/NRR/DLPM L.Raghavan NRC/NRR/DLPM Richard Bachman NRC/OGC A.K. Kranik APS Attachment 1

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1 NEI PROPOSAL ON " MINOR TECH SPEC CHANGES" 1

TECHNICAL SPECIFICATION CORRECTION I PROPOSED DEFINITION: A Tech Spec " correction" is not a change. A " change" to the Tech i Specs affects the functional requirements of an LCO,  !

+ surveillance requirsment, action statement, limiting safety system setting, or safety limit. A correction modifies words in the Tech Specs to correct minor editorial errors and inaccurate l statements.

PURPOSE: To avoid unnecessary Operating License amendments.

PROPOSED PROCESS: May be handled like changes to the Tech Spec BASES (further definition is pending).

MINOR TECH SPEC CHANGE PURPOSE: Avoid administrative exercises, plant transients, and plant staff diversions from necessary activities due to the discovery of non.

substantive Tech Spec errors. Not a mechanism for avoiding Tech Spec requirements.

BACKGROUND:

1) Current process for correcting Tech Spec errors involves enforcement discretion and possibility of exigent or emergency Tech Spec changes.

2) Tech Specs are followed from time of discovery until NOED approved.

3) Frequently results in significant administrative efforts in a short time.

4) Frequently results in plant operators expeditiously preparing for plant shutdown to meet Tech Spec that may have been in error for some timo.

5) Little value added from NOED process for these errors.

Attachment 2 er w.w e m m .w...w.,,..w . p_... ,

1 MINOR TECH SPEC CHANGE PROPOSED DEFINITION (4/14/99) 1 A Minor Technical Specification change is one that corrects editorial or 1 I

administrative errors or technicalinconsistencies that, when discovered, result in the plant being placed in an action statement requiring a functionally unnecessary shutdown or other unnecessary plant evolution. Minor Technical Specification changes are non. substantive changes to the licensing basis for the plant and may correct the text of LCOs, Action Statements, or Surveillance Requirements as long as the Technical Specification functional requirements are not altered. ,

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MINOR TECH SPEC CHANGE PROPOSED PROCESS

1) A licensee will notify appropriate NRR personnel of the need for a Minor Technical Specification Change by telephone within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the identification of the need. The notification will provide a preliminary justification of the classification af the change as minor.

2) The licensee will submit an amendment request to NRR within 31 days of the identification date in accordance with the process for a normal Technical Specification change. The application willinclude written justification of the classification of the change as minor.

NRR would give initial approval of the classification of the change as minor after the initial notification. NRR would process the amendment request as a normal Technical Specification change and provide final approval of the classification of the change. .

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l BASIC QUESTIONS:

i o What if issue becomes or is generic in nature?

i o What if within the 31 days prior to submittal, the issue becomes l more safety significant?

o Better definition of minor Tech Spec change needed with some  !

examples which give it tangibility.  !

l o Policy change - will a Commission Paper be needed? i i

o How it's handled if when it's submitted the NRC does not agree l with classification as Minor Tech Spec change - enforcement?

NOED7 Emergency or exigent amendment?

o Used for discovered deficiencies only or pre-planned Tech Spec l changes too?

o internal NRC handling. ,

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• amount of documentation of "NOED lite" l

• Time period for issuance of amendment i

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INITIAL RAI COMMENTS i

TYPICAL CONCERNS IN THE PAST (written RAIs):

. Too many "information only" questions

. Requests for information already submitted

. No regulatory basis for the RAI

. Backfitimplications POSITIVE TREND AFTER PUBLICATION OF OL

. Too early to make final conclusions

. Industry comments on OL 803 (due NEI 4/30/99)

. Industry feedback on impact of OL 803 on the licensing process (due NEI 8/1/99)

CURRENT INDUSTRY FEEDBACK

. Continue to encourage early communications

. Continue to encourage resolution of reviewer questions by telecon

. Receiving fewer formal RAIletters

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. Need work control process to coordinate RAI activity among NRC Branches .

. Need work control process to coordinate licensee due dates for RAI responses

. Consider establishing a "backfit checklist" applicable to potential RAIs

. Explore the idea _of resolving questions via a draft SER with blanks (for select licensirg actions)

m DRAFT SUGGESTIONS FOR AUGMENTING NRR OFFICE LETTER 803, SECTION 4.3, " REQUESTS FOR ADDITIONAL INFORMATION (RAPS)"

4.3.1 states that:

• Questions included in the formal RAI should ask for information that is required to make the regulatory finding. Each question should explicitly state the regulatory basis for asking the licensee for the information."

This section could be expanded to include a set of principles to guide NRC project managers and reviewers in satisfying the OL guidance. Information of the type listed below is not explicitly documented in RAls, and would aid the NRC staffin verifying that no portion of a formal RAI represented a plant specific backfit. It would also enable the Project Directorate to document that no plant specific backfits have been identified by the RAI:

1. Does the RAI use acceptance criteria more stringent than those contained in either the Standard Review Plan (SRP), or the plant's licensing basis, to take positions more stringent then those specified?

2. Does the RAI imply or suggest that a position in excess of already applicable staff positions is the only way for the staff to be satisfied?

3. Does the RAI apply an SRP to an operating plant after the license has been granted that has not been specifically approved for operating plant implementation?

4. Does the RAI promulgate staff proposed positions with regard to technical matters not related to the changes proposed by the licensee?

5. Does the RAI propose a plant specific Regulatory Guide provision?

6. Does the RAI expand on, add to or modify a generically approved Regulatory Guide, SRP, or regulation such that the position taken is more demanding or conservative than intended in the generic positions of the Regulatory Guide, .

SRP, or regulation?

7. Does the RAI contain statements to the licensee directing or suggesting a voluntary specific action to satisfy staff positions that are not a part of already approved applicable regulatory staff positions?

The formal RAI should inform the licensee of the results of NRC's backfit review and request that the licensee either concur with the review or specifically identify any backfits that the NRC may have missed.

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LATF Issue Teams l

Communications & Poliev l (Jim Fisicaro, Brian McIntyre, Charlie Brinkman, Alex Marion)

1. Use of NRC precedents

2. Informaltelecons

3. Initialissuance of documents (e.g., SERs) in draft form l

4. Increase communications between licensees and NRC (OL 803) ~

5. Industry provide feedback on NRR licensing process trends; factor into OL 803

6. Coordinate comments on OL 803 (short term) i

7. NRC paper on the generic communications process (3/30/99)

8. NRC management oversight when reviewers are reassigned

9. 000 factors associated with licensing reviews l

Tech Soec Change Process (Al Passwater, Pedro Salas, Don Woodlan, Dale Wuokko, Harold Chernoff)

1. Simplified process for minor Tech Spec changes (short term)

2. Guidance for Bases changes

3. Generic Tech Spec changes

4. Precedent Tech Spec changes Licensing Submittals (other than Tech Soecs)

(Angie Krainik, Chip Perkins, John Osborne)

1. Code exemptions / relief requests (streamlining approval) 2.10 CFR 50.12 exemption approval

3. QA/ Security / Emergency Plan changes

4. Licensee consistency of submittals on similar issues

5. Submittal que.lity factors

6. NRC acceptance of precedent (once a submittalis approved, subsequent reviews of similar submittals from other licensees should be expedited)

7. Topicalreports

, 8. Mandatory reports to be submitted (review value added) .

Reauests for AdditionalInformation (Roger Walker, Pete Kokolakis, Jim Kenny, Mike Schoppman)

1. Monitor progress made thus far in RAI area

2. Consistent application of Backfit Rule to RAls

3. Integrated reviews and RAIs

4. Support Projects in the review & screening of RAIs

5. Explore value of draft safety evaluations in RAI process

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ACTION ITEMS AS A RESULT OFTHE. MEETING )

l NRC:

. .o - Determine if we can make internal memo re corrections to TS publicly available for LATF.

o Provide feedback on new proposed definition of Minor TS Changes.

1 o Give LATF some examples of Minor TS Changes (particularly those that were not NOEDs, )

but were exigent or emergency TS changes),

o Provide feedback on pronosed Section 4.3 to be added to OL 803 (backfit guidance for RAls).'

o Give LATF definition of "predecisional."

o Give LATF feedback on issue Teams list, particularly if any items need to be added.

o Assign NRC counterparts to issue Teams.

o Consider adding guidance in OL C M regarding OGC review (when it's required).

Industry; o Will look at revision to 50.72 and 50.73 for i.npact on timing of Minor TS Change notification 1 process. 1 o Provide lead plant for Minor TS Changes.

o . Will wc k on wording of proposed 3.0.x. generic TS.

o Will providQ ATF comments on OL 803 for next meeting, o - Will assign a schedule to issue Teams list.

o Revise Minor TS Change definition to include TS problems other than those requiring shutdown. -

o Work on wording of 3.0.x generic TS Bases section.

o Agreed to review '97, '98, '99 NOEDs for more examples of minoi TS changes, o Provide mechanism for publicizing availability of TS 3.0.x, Attachment 3

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