ML20247N232
| ML20247N232 | |
| Person / Time | |
|---|---|
| Issue date: | 05/11/1998 |
| From: | Tracy G NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Thompson H NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 9805270084 | |
| Download: ML20247N232 (9) | |
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0 4 %,,9 May 11, 1998 MEMORANDUM TO: Hugh L. Thompson, Jr.
Deputy Executive Director for Regulatory Programs
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FROM:
Glenn M. Tracy, Chief g])g, g//g Regional Operations and Program Management Section, OEDO
SUBJECT:
SUMMARY
OF MARCH 30,1998, PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE ON MUTUAL ITEMS OF INTEREST On March 30,1998, senior managers of the Nuclear Energy Institute (NEI) met with senior managers of the Nuclear Regulatory Commission (NRC) at the NRC's offices at One White Flint North in Rockville, MD. The purpose of the meeting was to provide an opportunity for the senior managers of both organizations to discuss items of current interest to the nuclear industry. provides a summary of the meeting and Attachment 2 is a list of meeting attendees.
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SUMMARY
OF NRC/NEl SENIOR MANAGEMENT MEETING MARCH 30,1998 1.
DSI-13: Role of Industry Several topics associated with industry-based solutions which could potentially reduce resource requirements were raised by the participants. A brief summary of each area follows:
a.
Severe Accident Management NEl stated that there did not appear to be a firm understano.ng of the NRC's expectations and that, in the industry's view, an initially voluntary program to address severe accident issues had now apparently become more regulatory-process oriented. The NRC staff noted that the transition from regulatory-based emergency operating procedures into severe accident guidance or "best practice" was not clear in all cases. There appeared to be a difference of opinion, stemming from NRC's January 28.1998 letter on this subject. NEl noted that the industry and NRC appeared to be diverging on this issue regarding the need for regulatory oversight in this area and claimed that there was a lack of focus on the desired outcome or end-result. Discussion of the issue was closed upon agreement that NEl would send a letter to NRR outlining their specific concems and that any follow up meeting should focus on the criteria to be used in judging successful Severe Accident Management implementation.
b.
Risk-informed in-Service inspection (ISI) versus Al. ARA j
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NEl claimed that the industry was frustrated with the apparent lack of progress by NRC in approving changes to ISI program requirements, noting the existence of at least five submittats by licensees within the agency. Claiming the identification of few flaws during ISls by the industry to date, NEl stated that the use of the PRA implementation plan and risk-informed, experience-based decision-making by the agency was not apparent. The NRC staff noted that the pilot plant submittals by the industry had been delayed several times, and the pilot plants had changed. The NRC staff discussed the activities required for the agency's detailed evaluation of the issue, the current schedule, approval process, and l
public comment period. After a brief discussion on the importance of balancing the contribution to overall risk by certain piping as compared to the radiation i
exposure from inspection, both sides agreed to the need for a follow up meeting j
to further discuss the issue, the evaluation process, and the best approach to effectively address the issue in the future.
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2 c.
Schedule for risk-informed pilot The NRC staff raised their concem over the industry's delays in the risk-informed pilot program and their application of risk insights. NEl responded that industry was concemed over the potential jeopardy and vulnerability the licensees faced in pursuing these initiatives. Concems included: the scope of future regulatory -
requirements resulting from participation in the program and the consumption of licensee resources with a potential for little to no benefit. These concems have ultimately resulted in a decision that the activity is potentially "not worth the effort."
Both NRC and NEl again agreed that there was a need for a follow up meeting on this topic. NEl agreed to take the lead for scheduling this meeting.
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d.
10CFR50.55a proposed rule NEl noted that the industry saw the adoption of the ASME Code differently than the NRC and did not agree with the apparent legal analysis of the backfit considerations of the issue by the agency. NEl stated that NRC's approach would undo 80% of the performance demonstration initiative (PDl) the industry had already undertaken and that the modifications and limitations to be placed on the code were unreasonable. NEl was concerned with the Statement of Considerations, which, in their opinion, did not fully consider and give credit for existing industry results. NRC stated that the legal analysis demonstrated that the revision was not a backfit and that there existed a provision for updating 10CFR50.55a. NRC stated that they did not agree with ASME in all cases and that the agency took exception to certain aspects of the ASME code where NRC concems were not addressed in the technicaljustification of the code and a strong technical argument for th6 ASME position did not exist. NEl requested a copy of the associated legal analysis and NRC agreed to see if it could place that document in the PDR and provide it to NEl. NRC agreed to pursue the PDI issues raised by NEl during the meeting.
e.
10CFR50.54(a) Quality Assurance NEl raised this topic, stating that the issue, which started as a Regulatory Review Group item and a petition to NRC in 1995, was lingering without action within NRC during the last three years. The NRC staff stated that the petition would be dispositioned in a few weeks and that NEl would have the results of the agency's activities upon receipt of direction from the Commission. Both NRC and NEl agreed that the lack of communication in this area was disappointing.
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50.54(q) Emergency Plan NEl highlighted that the rules and guidance regarding what constituted a change in the Emergency Preparedness Program and the need for prior NRC approval required clarification. NEl stated that the industry believed the plans contained superfluous information and that certain changes by the industry should be allowed without prior NRC approval. NEl commented that they had learned that
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3 the promulgation of NRC inspector guidance in this area was imminent and that the completion of that action without prior communication or promulgation to the industry was inappropriate. NRR agreed to pursue the issue and ensure that the industry and the public were aware of the content of any future guidance in this area.
g.
. Voluntary Commitments and Initiatives NRC staff raised a concem regarding the lack of obligation by the industry to follow commitments developed during NRC review of topical reports without a sponsor, identified customer or lead plant. NRR raised the issue of expending significant resources in the review and development of SERs associated with certain topical reports with little benefit, due to the apparent lack'of ownership or licensee comrnitment to the results.. Examples cited included the submittal of topicals by certain owners' groups, where the licensees fell short of committing to the topicals. NRR questioned the expenditure of NRC resources on these activities without a lead plant. NEl acknowledged the existence of this issue and was willing to try to influence the owners' groups to identify a lead plant. NRC stated that they would identify the outlying topicals and communicate those issues to NEL h.
Summary in summary, NEl stated that many issues in the area of industry initiatives lacked consensus standards. They stated that both the industry and regulator have attempted to embark upon a process which has all too often taken too long, l
resulting in the fading of corporate memories, changing standards and an overall lack of consistency in the long-term approach. As a whole, NEl was disappointed in the timeliness and resolution of many of these issues. NRC staff acknowledged the comment and responded with the hopes that Commission guidance on DSI-13 and future communication and workshops with the industry would help to develop an agreed-upon approach to achieve a reasonable regulatory position in similar cases in the future.
2.
Licensee Performance Assessment NEl raised a concern regarding what they perceived to be a lack of an ability to comment and participate in the development of the new reactor assessment process.
They questioned the value of the nublic comment period if the NRC staff had already made up its mind. NRC participants assured the NEl representatives that both they and the industry would have ample opportunity to express their views and comments on the new assessment process in the near future, as well as any changes to the Plant issues Matrix (PIM) and its use. AEOD stated that they had held meetings with INPO to discuss the use of the WANO indicators and INPO performance index and that the dialogue in this area continued. NRC reiterated the agency's desire for comment and input on the staff's proposal by the industry, NEl, the public and all of NRC's stakeholder.
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3.
10CFR50.59 and FSAR Updates NEl noted that the SRM from the Commission had just been isscxi to the staff. NEl stated that the current verification and validation efforts by the indushr were not addressing the " completeness" of the FSARs and questioned what action NRC proposed to take in October 1998 when the current enforcement discrction on FSAR accuracy expired. _ NEl discussed the variations in the content of FSARs across the industry, the varying implementation of the FSAR update process by both the industry and the regulator, and the need to redefine the scope of 10CFR50 59. NEl highlighted the need to extend the use of enforcement discretion upon implementation of any new rule or guidance in this area in order to minimize the impact upon the industry. NRC stated that there did not appear to be a great deal of benefit from the removal of information.from the FSARs and that continued communication between NEl and NRR in the area of scope.
was necessary. NEl agreed to pursue a meeting to discuss the scope issue with the appropriate NRC staff.
4.
Maintenance Rule Revision NEl stated that they were working with the task force on the second revision to NUMARC (NEI) 93-01 and hoped to have the final draft of NUMARC (NEI) 93-01 to the NRC by the end of April 1998. They hoped that this document would provide further guidance on the adequacy of assessments for the removal of equipment for maintenance. NEl expressed their hopes to work with the NRC staff to finalize the document.
5.
License Renewal NEl described their recent meeting with approximately 60 Chief Executive Officers (CEOs) and Chief Nuclear Officers (CNOs) on the topic of license renewal and their desire to finalize guidance in this area for the industry on the best way to proceed. They believed they had already experienced one "fals,e start" in this process and did not desire another. NEl expressed their view that the industry did not have enough certainty from NRC regarding the adequacy of the current licensing basis to support license renewal.
Upon questioning by NRR in this area, both NRC and NEl agreed that there needed to
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be better communication between the lead industry officials and SES-level NRC
- managers in discussing the review process that is to be used in license renewal. The process to be used needed to be understandable and should continue to develop from lessons-learned, similar to the development of the maintenance rule process.
6.
NEl Role in the Operator Licensing Examination Process NRC led a discussion on the current issues associated with the results from the recently modified operator licensing process. NRC highlighted the need for both the agency's and industry's oversight of the adequacy of examinations, adequacy cf operator knowledge and self-assessment of the operator requalification programs. NEl stated that they would look into the issue, but acknowledged that one of the major issues included the cost of the modified program for the small single-unit licensees. Both sides agreed 1
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5 that they would wait until the issuance of the rule and then discuss the issues among themselves and INPO.
7.
Proposed Year 2000 Generic Letter NRC staff highlighted the significance of the Year 2000 computer issue and the level of attention which the issue has received, including the NRC Chairman, NRC OlG, FERC, DOE and GAO. The NRC staff noted that the Senate had recently held hearings on the issue, highlighting its potential effect on the nation's grid. NRC discussed the recent identification of one reactor licensee who claimed to be behind schedule in its preparations toward addressing tha issue.
8.
Air Operated Valve (AOV) Issues AEOD staff discussed the preliminary results of an evaluation of AOV programs at seven sites. They noted that several vulnerabilities had been identified, and at one plant,50%
of the sample of valves tested in systems considered most risk-significant failed. AEOD stated that they had met with AOV user groups and noted that the draft report of th'e evaluation would be available in late June or July 1998. NRC staff expressed the desire for the industry to address this issue. NRC staff highlighted the success of the GL 89-10 motor-operated valve (MOV) program and desired a process which would allow the industry and NRC to work together to resolve these important AOV issues.
9.
NRC Audits of Commitment Tracking NRC discussed their audits of licensee commitment tracking and stated that their activities would be completed by June 1998. NRC stated that they would communicate the results of the audits to the licensees and NEl.
NRC/NEl SENIOR MANAGER MEETING LIST OF ATTENDEES March 30,1998 NAME ORGANIZATION Joe Callan NRC Hugh Thompson,..
NRC Tim Martin NRC Ashok Thadani NRC Lawrence Chandler NRC Mal Knapp NRC Jim Lieberman NRC Jack Roe NRC Brian Sheron NRC Frank Miraglia NRC Peter Wen NRC Bruce Boger NRC Glenn Tracy NRC Sam Collins NRC Carl Paperiello NRC Cathy Sumner NE!
Robert Evans NEl David Modeen NEl Tony Pietrangelo NEl Ralph Beedle NEl Stephen Floyd NEl James Davis NEl Lynnette Hendricks NEl Adrian Meymer NEl
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cc:
Mr. Ralph Beedle Senior Vice President and Chief Nuclear Officer Nuclear Energy Institute 1776 l Street, NW Suite 400 Washington, DC 20006-3708 Mr. Alex Marion, Director Programs Nuclear Energy institute 17761 Street, NW Suite 400 Washington, DC 20006-3708 Mr. James Davis, Director Operations Nuclear Energy Institute 1776 l Street, NW Suite 400 Washington, DC 20006-3708 Mr. Tony Pietrangelo, Director Licensing Nuclear Energy Institute 1776 l Street, NW Suite 400 Washington, DC 20006-3708 Mr. Steve Floyd, Director Regulatory Reform and Strategy Nuclear Energy institute 1776 i Street, NW Suite 400 Washington, DC 20006-3708 t
Mr. Dave Modeen, Director Engineering Nuclear Energy Institute 1776 l Street, NW Suite 400 Washington, DC 20006-3708 Mr. Robert Bishop, General Counsel Nuclear Energy institute 1776 i Street, NW Suite 400 Washington, DC 20006-3708 Ms. Lynette Hendricks, Director Plant Support Nuclear Energy Institute 1776 l Street, NW Suite 400 Washington, DC 20006-3708
May 11, 1998 l
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MEMORANDUM TO: Hugh L. Thompson, Jr.
Deputy Executive Director for Regulatory Programs FROM:
Glenn M. Tracy, Chief ORIGilitist9F0 Ff Regional Operations and Program Management Section, OEDO
SUBJECT:
SUMMARY
OF MARCH 30,1998, PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE ON MUTUAL ITEMS OF INTEREST l
On March 30,1998, senior managers of the Nuclear Energy Institute (NEI) met with senior managers of the Nuclear Regulatory Commission (NRC) at the NRC's offices at One White Flint North in Rockville, MD. The purpose of the meeting was to provide an opportunity for the senior managers of both organizations to discuss items of current interest to the nuclear industry. provides a summary of the meeting and Attachment 2 is a list of meeting attendees.
Attachments:
As stated cc w/ attachments:
See next page DISTRIBUTION Central Files PDR EDO R/F DEDR R/F DEDE R/F GTracy JCallan SCollins Attendees i
DOCUMENT NAME: g:\\nei330mt.wpd IM T't receive a copy of this document, indicate in the tpx: *
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NAME GTracy* fh lj}htNM V HLTh&7riphon LJCMidn l
DATE 4/30/98 i hV' 5/ 1 /98 5/ / t /98 5// / /98 5/
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OFFICIAL RECORD COPY
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