ML20216C538
| ML20216C538 | |
| Person / Time | |
|---|---|
| Issue date: | 03/09/1998 |
| From: | Balmain P NRC (Affiliation Not Assigned) |
| To: | Wen P NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9803160058 | |
| Download: ML20216C538 (4) | |
Text
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4 UNITED STATES g
j NUCLEAR REGULATORY COMMISSION o
e WASHINGTON, D.C. 20555 4001
%g March 9,1998 MEMORANDUM TO: Peter Wen, Project Manager Generic issues and Environmental Projects Branch Division of Reactor Program Management THROUGH:
Richard P. Corriea, Chief Reliability and Maintenance Section Quality Assurance, Vendor inspection and Maintenance Branch Division of Reactor Controls and Heman Factors FROM:
Peter Balmain, Operations Engineer q gjhg[
Reliability and Maintenance Section Quality Assurance, Vendor inspection and Maintenance Branch Division of Reactor Controls and Human Factors
SUBJECT:
SUMMARY
OF FEBRUARY 18,1998 MEETING BETWEEN THE NUCLEAR REGULATORY COMMISSION (NRC) AND THE NUCLEAR ENERGY INSTITUTE (NEI) ON MAINTENANCE RULE IMPLEMENTATION FOR DECOMMISSIONING STATUS PLANTS The NRC staff met with NEl representatives and severalindustry and licensee representatives to discuss the staff's initial assessment of NEl's industry white paper regarding 10 CFR 50.65 Maintenance Rule implementation for Shutdown Plants. dated August 26,1997. The primary purpose of the meeting was to determine potential approaches for the development and promulgation ofindustry guidcnce that would provide acceptable maintenance rule program guidance for licensees required to implement the maintenance rule at decommissioning status plants (i.e., plants where certifications specified by 10 CFR 50.82 (a)(1) have been submitted to the NRC). Prior to this meeting, results of the initial NRC staff review of the NEl white paper were documented in a January 29,1998 letter from the NRC to NEl (see attachment).
a The NRC stated in the meeting that industry guidance in this area would be beneficial and suggested that the most desirable format for the guidance would be in the form of a revision to the existing maintenance rule guidance document, NUMARC 93-01, " Industry Guideline for Mcnitoring the Effectiveness of Maintenance at Nuclear Pnwer Plants." Providing a revision or g
extension of NUMARC 93-01 would provide a preferable method to meet the regulation than the
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approach taken in the industry white paper which outlined specific portions of 10 CFR 50.65 that
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should not apply to shutdown planis in decommissioning status. NEl agreed that providing guidance for decommissioning status plants as a revision to NUMARC 93-01 would be an
. 3 acceptable approach and it would consider revising NUMARC 93-01 and communicating the
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results of this review to the NRC in the near future. The NRC also stated that the industry white paper referr'd to terms that were not clearly defined and recommended the use of established terms in subsequent submittals.
(({] { py An important topic discussed was the scoping of structures, systems and components for a maintenance rule program at decommissioning status plants. NEl suggested that scoping of j
stiuctures, systems, and components (SSCs) for deco.nmissioning status plants include a time deper. dent factor to account for the reduction of decay heat gerseration of spent fuel and stated a similar approach has been used for other requirements. The NRC stated it would consider j
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P. Wen March 9,1998 revising inspection guidance to account for changing conditions of decommissioning status plants. The NRC stated that in general the industry white paper consistently failed to describe what SCCs were required to be in scope and emphasized relatively broad functional descriptions of SSCs that should not be required. The NRC stated that scoping was plant specific and that the guidance presented in the industry white paper would not be acceptable as generic guidance.
The NRC discussed future actions and outlined a plan for conducting a maintenance rule workshop with NRC staff, NEl and industry subsequent to NEl's development of revised industry guidance. The purpose of thi; workshop would be to provide a forum to discuss the implementation of the guidance. The spring of 1998 was proposed as the target date for this workshop.
Additional discussions were then held at NEl's request pertaining to the NRC's proposed rule making to revise section (a)(3) of the maintenance rule regarding safety assessments. NEl proposed to develop and submit industry guidance positions to the NRC for consideration during the rule making activities. These positions would include expanding maintenance rule guidance relative to the rigor of risk assessments prior to taking equipment out of service and would also provide information for operating p! ant outage / refueling shutdown management requirements.
NEl suggested that a partial endorsement by the NRC of NUMARC 91-06, " Guidelines for Industry Actions to Assess Shutdown Management", would be more appropriate than endorsing this docun.3nt in its entirety. NElinformed the NRC that they would submit these comments to the NRC in April 1998.
In conclusion, the meeting was beneficial and provided a constructive dialogue between the NRC and stakeholders involved in the development of maintenance rule program implementation for l
decommissioning status plants. Fulfillment of the proposed future activities addressed during the meeting will continue to enrich this process.
Attachments:
l
- 1. NRC letter to NEl dated January 29,1998
- 2. Meeting Slide
- 3. Attendance List l
DISTRIBUTION l
Central File TMartin, AEOD BJorgensen, RGill PUBLIC DWheeler HCMB R/F WScott SCollins/FMiraglia FTalbot LSpessard MFairtile 6
RDudley FAstulewicz TEssig DOCUMENT NAME: G:\\ Final \\ MEET.NEI
- See previous concurrence To receive a cop; of thle document, Indicate in the boa: *C" = Copy without attachment / enclosure
- E* = Cony with attechment/ enclosure
- N* = No c.opy 0FFICE HOMB HOMB SC:HOMB BC:HOMB g
NAME PBalmain JWilcox RCorriea SBlack (1
DATE 03/05/98*
03/05/98*
03/05/98*
3/ p/98 0FFICIAL RECORD COPY
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UNITED STATES g
j NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 30806 4 001 49... g,o January 29, 1998
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Mr. Alan P. Nelson Senior Project Manager Nuclear Energy Institute 1776 i Street, NW - Fuite 400 Washington, DC 20(,06-3708
Dear Mr. Nelson:
In your letter to me of August 26,1997, the Nuclear Energy Institu;e (NEI) submitted a white paper, ~10 CFR 50.65 Maintenance Rule implementation for Shutdown Plants". The purpose of the white paper was to establish a basis for development of industry guidance related to the implementation of the Maintenance Rule for decommissioned plants.
The staff has reviewed the cubject document as requested. Although we recognize that industry guidance is needed and that NEl's input would serve as an important element in this process, the proposed approach would require an exemption from the requirements of 150.65(a)(1) and (b)(2). Specific /ly, NEl's letter states that the approval of this guidance would, in part, " Clarify that Section (b)(2) of the rule should not apply to shutdown plants."
1 However,150.65(a)(1) requires, in p;.+ that "For a nuclear power plant for which the licensee has submitted the certificatiuns specified in 150.82(a)(1), this section only shall apply to the extent that the licensee shall monitor the performancs or condition of all structures, systems, or components associated with the storage, control, and maintenance of spent fuelin a safe condition, in a manner sufficient to provide reasonable assurance that such structures, systems, and components are capable of fulfilling their intended function."
While we agree that industry may propose guidance with respect to the ocoulation of SSCs in a permanently shutdown plant that the licensee is required to monitor to ratisfy 150.65(a)(1), including the requisite process for such monitoring, we disagree with NEl's assertion that "Section (b)(2) of the rule should not apply to shutdown plants."
Therefore, we would encourage NEl to continue to work with industry to formulate an acceptable guidance document on this subject, focusing on those elements that are necessary to comply with 150.65 rather than emphasizing those aspects which need not be l
complied with. To that extent, any future guidance developed would have to incorporate a resolution to the fundamentalisst,es summarized above.
9' ATTACHMENT 1
r-e Mr. Alan P. Nelson Should you have any questions or need additionalinformation on this matter, please contact Bob Latta at (301) 415-1023 (e-mail: RML1@NRC. GOV) or Mort Fairtile at (301) 415-1442 (e-mail MBF@NRC. GOV).
Sinc ely, e
Soy our H. Weiss, Director Non Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Project No. 689 cc: See next page l
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Nuclear Energy Institute Project No. 68g cc:
Mr. Ralph Beedle.
Ms. Lynnette Hendricks, Director SeniorVice President Plant Support and Chief Nuclear Officer Nuclear Energy institute Nuclear Energy Institute Suite 400 Suite 400 1776 i Street, NW 1776 i Street. NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Programs Nuclear Energy in-stitute l
Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Licensing Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director i
Operations Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708
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0M Peter Wen, Project Manager l 301-415-2832NRR/DRPM/PGEB Duke Wheeler, Project Manager l 301-415-1444NPR/DRPM/PDND J. D. Wilcox, Sr. Operations Engineer l 301415-1262 NRR/DRCH/HQMB Wayne Scott, Sr. Operations Engineer l 301-415-1020 NRR/DRCH/HOM3 Suzanne Black, Branch Chief l 301-415-1017NRR/DRCH.
MB Frank X. Talbot, Operations Engineer l 301-415-3146NRR/DRCH/HQMB j
Morton Fairtile, Sr. Project Manager l 301-415-1442NRR/DRPM/PDND Alan Nelson, Sr. Project Manager l 202-739-8110NEl Tony Pietrangelo, Director Licensing l 202-739-8081NEl Biff Bradley, Sr. Project Manager l 202-739-8083NEl Doug Walters, Sr. Project Manager l 202-739-8093NEl Donald G. Goldsmith, Asst. System 847-746-2084 Commonwealth Edison - Zion Engineer Manager ext. 3842 Jim Carlson, Zion Expert Panel l 847-746-2804 Commonwealth Edison - Zion l ext. 2746 Chuck Sibwey, Maintenance Rule l 630-663-7916 Commonwealth Edison -
Coordinator l
M. Streka, Principal Engineer l 301-468-6925NUS Information Altheie Wyche, Licensing Engineer l 301-417-4458SERCH Licensing /Bechtel Mike Tschiltz, Sr. Regional Coordinator l 301-415-1733OEDO Bruce Jorgensen, Chief l 630-829-9615RGill/DNMS/DB Richard Dudley, Sr. Project Manager l 301-415-1116NRR/DRPM/PDND Rich Correia, Chief l 301-415-1009 NRR/DRCH/HQMB Steve Reckford, Engineer 410-495-2565 Baltimore Gas & Electric Calvert Cliffs Pete Balmain, Operations Engineer l 301-415-3697 NRR/DRCH/HQMB ATTACHMENT 3 e