ML071630241
| ML071630241 | |
| Person / Time | |
|---|---|
| Site: | PROJ0690 |
| Issue date: | 06/22/2007 |
| From: | Hoffman S T NRC/NRR/ADRO/DLR/RLRB |
| To: | Nuclear Energy Institute |
| Hoffman, S T, NRR, 415-3245 | |
| References | |
| Download: ML071630241 (10) | |
Text
June 22, 2007 ORGANIZATION: Nuclear Energy Institute
SUBJECT:
SUMMARY
OF THE LICENSE RENEWAL TELEPHONE CONFERENCE CALL AND MEETING HELD BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND THE NUCLEAR ENERGY INSTITUTE LICENSE RENEWAL TASK FORCEThe U.S. Nuclear Regulatory Commission (NRC) staff and the Nuclear Energy Institute (NEI)License Renewal Task Force held a public telephone conference call and meeting on April 25, 2007, to discuss generic license renewal topics, lessons learned from the audit process, and license renewal process improvements. Enclosure 1 provides a listing of the conference call participants. Enclosure 2 contains the agenda for the conference call. A summary of the discussions follows:1.Response to NRC's March 16, 2007, letter regarding Generic Aging Lessons Learned(GALL) Report aging management program (AMP) XI.E6NEI's response to the NRC staff's March 16, 2007, letter regarding GALL Report AMPXI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," was discussed. NEI commented that the staff's response to its white paper regarding the AMP was along the line of its expectation. However, NEI is concerned about aging management for cable connections in active components and the sample size of cable connections. The staff requested that NEI submit its concern in writing. NEI asked when the staff would issue the draft interim staff guidance (ISG) for public comments. The staff responded that the draft ISG was in concurrence phase and should be issued in the near future. 2.License renewal implementation/post-approval renewal inspection procedure (IP-71003)The NRC staff is continuing development of the Regulatory Issue Summary for 10 CFR 54.37(b) and update of IP-71003. The status of these documents will be discussed during the next meeting. The staff plans to make the draft inspection procedure public and discuss it with NEI and interested stakeholders before finalizing the procedure.3.Lessons learned from recent safety review auditsa.Wolf Creek aging management auditLessons learned from the recent safety review audits at Wolf Creek were discussed. One item discussed was an underground medium-voltage cable issue. This underground cable was not within the scope of license renewal. The staff indicated that all components associated with restoration of station blackout (SBO) recovery path, including the circuit breaker in the switchyard, should be included in the scope of license renewal. The underground medium-voltage cable from the circuit breaker to the disconnect switch should have been in scope of GALL Report AMP XI.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." NEI felt that circuit breakers in the switchyard do not need to be inscope and suggested that the staff and industry meet to discuss the scoping issue of SBO restoration paths.GALL AMP XI.S8, "Protective Coating Monitoring and Maintenance Program" serves toprovide an AMP to ensure operability of post-accident systems that rely on water recycled through the containment sump/drain system. Protective coatings inside containment applied to steel surfaces also serve to prevent or minimize loss of material due to corrosion. However, the GALL Report line items suggest the use of ASME Code Section XI, Subsection IWE, as the AMP for steel elements inside containment. The staff has concluded that until a change is made to the GALL Report, applicants who reference an AMP that is consistent with GALL have a program that is acceptable to the staff.b.Review of time-limited aging analyses (TLAAs)There is a perception in the industry that NRC staff has changed its review methodologyand expectations for TLAAs. The staff clarified during the call that the staff's TLAA review methodology has been consistent and has not changed recently. However, when the review moved from a headquarters review with requests for additional information (RAIs) to the audit team, additional material was available onsite for the audit team and the review could be more thorough and detailed as compared to previously. The review of TLAAs is always based on some combination of acceptable demonstrations for the TLAA as described in 10 CFR 54.21(c)(i), (ii), and (iii).The concern revealed by recent TLAA audits is related to cycle counting and projectionto the end of the extended period of operation (i.e., 60 years). The projection is based on previous years of operation without considering the potential of increased cycling due to system and component aging. As a result, licensees have reduced transients substantially, some down to zero cycles in 60 years. The projected cycles have been used to calculate the 60-year projection of the cumulative usage factor. The staff indicated that reduction of projected cycles to zero is not acceptable. Because of the complexity of the issue, NEI requested that the staff arrange a meeting in the near future to discuss the issue further. The meeting was subsequently held on May 24, 2007.c.Environmental audit RAIsNEI questioned why the NRC staff sent formal RAIs to Wolf Creek to requestinformation and documents that had been made available to the NRC staff at the environmental site audit. Also, NEI questioned why the NRC staff sent RAIs to Wolf Creek to request that the information and documents made available to the staff during the audit be submitted under oath or affirmation. NEI expressed concern that these actions represent a shift in the NRC's approach to gathering information for the environmental review and place an additional burden on applicants. The NRC staff indicated that the NRC staff would continue to refine its approach to obtaining information and would work with future applicants to develop the most effective approach and minimize the regulatory burden. The staff also indicated that applicants could reduce the number of RAIs by providing information in the environmental reports consistent with the guidance discussed at the March workshop. Further, the staff indicated that sending RAIs and requiring that information besubmitted under oath or affirmation made the environmental review process more consistent with the license renewal safety review process. It was decided that a separate meeting should be scheduled to discuss the environmental review process for obtaining information and documents. The meeting was subsequently held on May 31, 2007.4.New topicsEnvironmental reviews - refurbishment The NRC staff indicated that a future applicant approached the NRC staff to discusswhether a planned steam generator replacement constituted a refurbishment activity as outlined in NRC guidance documents. The NRC staff indicated evaluation of steam generator replacement as a refurbishment activity would be appropriate if the applicant planned to undertake the activity in anticipation of license renewal. Several other potential applicants expressed an interest in discussing refurbishment. The NRC staff summarized existing guidance on refurbishment. Several impact areasregarding refurbishment are designated as Category 2 issues in the Generic Environmental Impact Statement and would require plant-specific evaluation in the applicant's environmental report. The applicant indicated that its plans to replace steam generators will be discussed in the environmental report along with an environmental impact evaluation.
However, the applicant does not plan to identify steam generator replacement as a refurbishment activity. The staff indicated that the steam generator replacement, described in that manner, would probably be reviewed as refurbishment. An additional future applicant indicated that it would be addressing steam generator replacement as a refurbishment issue.5.Public participationMr. Rich Janati, Chief of the Division of Nuclear Safety, Pennsylvania Bureau of RadiationProtection, and Administrator, Appalachian Compact Commission, commented that the NRC should evaluate steam generator replacement as a refurbishment activity. He also commented that NRC environmental reviews should address groundwater monitoring programs./RA/Stephen T. Hoffman, Senior Project ManagerLicense Renewal Branch B Division of License Renewal Office of Nuclear Reactor RegulationProject No. 690
Enclosures:
As statedcc w/encls: See next page
ML071630241DOCUMENT NAME:C:\FileNet\ML071630241.wpdOFFICEPM:RLRB:DLRLA:DLRBC:RLRC:DLRBC:REBB:DLRBC:RLRB:DLRNAMESHoffmanIKingKChangRFranovichBrogers for RAuluckDATE06/20/0706/20/0706/20/0706/21/0706/22/07 List of Participants for the Telephone Conference Call and Meeting Held Between the U.S. Nuclear Regulatory Commission Staffand the Nuclear Energy InstituteApril 25, 2007PARTICIPANTSAFFILIATIONSSamson LeeU.S. Nuclear Regulatory Commission (NRC)Kenneth ChangNRC Louise LundNRC Stephen HoffmanNRC Eric BennerNRC Jennifer Davis NRC Roy MatthewNRC Zhian LiNRC Jim DavisNRC Dave WronaNRC Drew StuyvenbergNRC Linh TranNRC K. Robert HsuNRC John FairNRC James MedoffNRC Farideh SabaNRC Veronica RodriguezNRC Yeon-Ki ChungNRC Duc NguyenNRC James RossNuclear Energy InstituteMike DetamorePPL Susquehanna Dave FlytePPL Susquehanna Jeff WelkPPL Susquehanna Dave KunsemillerFENOC Steve DortFENOC Roger RuckerFENOC Alan CoxEntergy Eric BlocherStrategic Teaming and Resource Sharing (STARS)
Paul CrawleySTARS Chalmer MyerSouthern Nuclear Company Al FulvioExelon Fred PolaskiExelon Gene EckholtNMC - Prairie Island Tom SnowDominion Mike HeathProgress Energy Ron NeilskiNine Mile Point PARTICIPANTSAFFILIATIONSMike SemmlerDukeBob VincentPalisades Lorrie BellWolf Creek Ken PutnamDuane Arnold Massoud TefezzoliAREVA Kathryn SuttonMorgan Lewis Rich JanatiPennsylvania Bureau of Radiation Protection Steven DolleyPlatts Nuclear Deann RaleighScientech Teleconference AgendaBetween the U.S. NRC Staff and the Nuclear Energy InstituteApril 25, 2007 Topic Lead 1.Response to NRC's Mar. 16, 2007, letter regardingNEIGALL aging management program XI.E6.2.License renewal implementation/Post-approval renewalNEI/NRCinspection procedure (IP-71003)3.Lessons learned from recent safety review auditsa.Wolf Creek aging management auditNEIb.Review of time-limited aging analysesNEI c.Environmental audit requests for additional informationNEI4.New topicsEnvironmental reviews - refurbishmentNRC5.Public participationAll Note to Nuclear Energy Institute, from S. Hoffman, dated June 22, 2007
SUBJECT:
SUMMARY
OF THE LICENSE RENEWAL TELEPHONE CONFERENCE CALL AND MEETING HELD BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND THE NUCLEAR ENERGY INSTITUTE LICENSE RENEWAL TASK FORCEDISTRIBUTION:HARD COPY DLR RFE-MAIL:PUBLICSSmith (srs3)
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Nuclear Energy Institute Project No. 690
cc:Ms. Christine S. Salembier, CommissionerState Liaison Officer Department of Public Service 112 State St., Drawer 20 Montipelier, VT 05620-2601Mr. Gordon A. CleftonNuclear Energy Institute 1776 I St., N.W., Suite 400 Washington, DC 20006-3708Mr. Frederick W. PolaskiManager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348Mr. David LochbaumUnion of Concerned Scientists 1707 H St., NW, Suite 600 Washington, DC 20006-3919Mr. Clifford I. CusterProject Manager, License Renewal FirstEnergy Nuclear Operating Company P.O. Box 4 Route 168 (Mail Stop SIM-2)
Shippingport, PA 15077Mr. Paul Gunter, DirectorReactor Watchdog Project Nuclear Information & Resource Service 6930 Carroll Avenue, Suite 340 Takoma Park, MD 20912Mr. Hugh JacksonPublic Citizen's Critical Mass Energy &
Environment Program 215 Pennsylvania Ave., SE Washington, DC 20003Mary OlsonNuclear Information & Resource Service Southeast Office P.O. Box 7586 Asheville, NC 28802 Mr. Garry G. YoungManager, License Renewal Services 1448 SR 333, N-GSB-45 Russellville, AR 72802Robert A. VincentLicensing Lead - License Renewal Project Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043Lorrie Bell, Project ManagerWolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839Roger StewartProgress Energy Carolinas, Inc.
3581 West Entrance Road RNP A9 Hartsville, SC 29550Michael H. Crowthers, Supervisor Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street (GENPL4)
Allentown, PA 18101-1179