ML031970065
| ML031970065 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 07/21/2003 |
| From: | Joseph Sebrosky NRC/NRR/NRLPO |
| To: | Nuclear Energy Institute |
| Sebrosky J M, NRR/DRIP/RNRP, 415-1132 | |
| Shared Package | |
| ML031970037 | List: |
| References | |
| Download: ML031970065 (12) | |
Text
July 21, 2003ORGANIZATION:Nuclear Energy Institute (NEI)
SUBJECT:
SUMMARY
OF MEETING HELD ON MAY 22, 2003, TO DISCUSSINSPECTIONS, TESTS, ANALYSES AND ACCEPTANCE CRITERIA (ITAAC) FOR OPERATIONAL PROGRAMS AND 10 CFR PART 52 COMBINED LICENSE (COL) ISSUESThe Nuclear Regulatory Commission (NRC) held a public meeting with NEI on May 22, 2003, atNRC Headquarters to discuss ITAAC for operational programs (programmatic ITAAC) and 10 CFR Part 52 combined license (COL) issues. A list of attendees is provided as . The meeting agenda is provided as Attachment 2. Handouts were provided during the meeting by both the staff and NEI. The handouts can beaccessed through the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML031420814. This system provides text and image files of NRC's public documents. If you do not have access to ADAMS or if there are problems in accessing the handouts located in ADAMS, contact the NRC Public Document Room (PDR) reference staff at 1-800-397-4209, 301-415-4737, or by e-mail to pdr@nrc.gov
.Highlights From Programmatic ITAAC Portion of the MeetingAttachment 3 contains a description of the programmatic ITAAC issue and the staff's proposalto address the Commission's staff requirements memorandum (SRM) of September 11, 2002.
The staff and NEI disagreed on the interpretation of the second paragraph of the Commission's September 11, 2002, SRM which states the following:Although the NRC inspection process does not replace a particular ITAAC, anITAAC for a program should not be necessary if the program and its implementation are fully described in the application and found to be acceptable by the NRC at the COL stage. The burden is on the applicant to provide the necessary and sufficient information for approval of the COL without ITAAC.The staff and NEI disagreed on what constitutes a "fully described" program. NEI stated that aCOL application need only describe operational programs with the level of detail equivalent to what is provided in existing final safety analysis reports with respect to such programs. The staff believed that additional information regarding the implementation of the program would have to be furnished.To address the issue, the staff and NEI agreed to pick a program listed in Footnote 2 ofAttachment 3 to be used to develop guidance to implement the Commission's SRM regarding programmatic ITAAC. The staff and NEI would then independently develop guidelines for the level of programmatic information that would be needed in order to issue a COL without ITAAC for that program. The information would be provided to each organization at least 10 days in advance of a public meeting to discuss the issue. The staff and NEI agreed to target mid-July for the next meeting on the issue. Subsequent to the meeting, the fire protection program wasidentified as the candidate program, and the mid-July meeting was canceled in favor of an August 25, 2003, workshop.Highlights From the COL Portion of the MeetingIn their handouts NEI provided a revised list of COL process and construction inspectionprogram (CIP) general discussion topics. NEI stated that they expect a business decision in the 2005 time frame on whether or not to pursue a COL application. NEI stated that if a COL application was pursued the time frame for a letter of intent could be submitted in late 2005 and the COL application itself could be submitted in mid-calendar year 2006. NEI stated that its overarching goal regarding COL and CIP issues was to support new plant business decisions by 2005. NEI stated that the first eight items identified in their list would require near-term interactions inorder to support new plant business decisions by 2005. For the majority of the eight issues, the staff and NEI have already begun discussions. NEI questioned the staff regarding COL-5, "Establish a common understanding with NRC regarding the 10 CFR Part 52.103 ITAAChearing process.
" The staff agreed to provide feedback to NEI regarding their proposal for the52.103 hearing process. NEI
's comments in this area are contained in Section 6,"Preoperational Finding Process and Hearing Opportunity," of their letter datedNovember 20, 2001. The NRC did not provide a full set of comments in this area because some of the issues associated with how the hearing will be conducted will be determined by the presiding officer in a COL proceeding./RA/Joseph M. Sebrosky, Senior Project ManagerNew Reactor Licensing Section New, Research and Test Reactors Program Division of Regulatory Improvement Programs, NRRProject No. 689
Enclosures:
As stated cc w/encls: See next page
ML031970037-Pkg.OFFICEPM:RNRP(A)SC:RNRPNAMEJSebroskyJWilliamsDATE7/18/037/18/03 Combination List:cc:Mr. Charles BrinkmanWestinghouse Electric Co.
Washington Operations 12300 Twinbrook Pkwy., Suite 330 Rockville, MD 20852Mr. David Lochbaum, Nuclear Safety EngineerUnion of Concerned Scientists 1707 H Street, NW, Suite 600 Washington, DC 20006-3919Dr. Gail H. MarcusU.S. Department of Energy Office of Nuclear Energy, Science
& Technology NE-1, Room 5A-143 1000 Independence Avenue, SW Washington, DC 20585Mr. Paul GunterNuclear Information & Resource Service
1424 16 th Street, NW, Suite 404Washington, DC 20036Mr. James RiccioGreenpeace 702 H Street, NW, Suite 300 Washington, DC 20001Mr. Ron SimardNuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708Mr. George Alan ZinkeProject Manager Nuclear Business Development Entergy Nuclear M-ECH-683 1340 Echelon Parkway Jackson, MS 39213Mr. Thomas P. MillerU.S. Department of Energy NE-20, Rm. A286 Headquarters-Germantown 19901 Germantown Road Germantown, MD 20874-1290Ms. Marilyn KrayVice President, Special Projects Exelon Generation 200 Exelon Way, KSA3-E Kennett Square, PA 19348Mr. Laurence ParmeManager, GT-MHR Safety &
Licensing General Atomics Company P.O. Box 85608 San Diego, CA 92186-5608Mr. Joseph D. HegnerLead Engineer - Licensing Dominion Generation Early Site Permitting Project 5000 Dominion Boulevard Glen Allen, VA 23060 Mr. Edward L. QuinnMDM Services Corporations Utility Operations Division 28202 Cabot Road, Suite 205 Laguna Nigual, CA 92677Lynn Connor Doc-Search Associates 2211 sw 1 ST Ave - #1502Portland, OR 97201Mr. Ed Rodwell, ManagerPWR Design Certification Electric Power Research
Institute 3412 Hillview Avenue Palo Alto, CA 94304-1395Mr. Paul LeventhalNuclear Control Institute 1000 Connecticut Avenue, NW Suite 410 Washington, DC 20036Mr. James F. Mallay, DirectorRegulatory Affairs FRAMATOME, ANP 3315 Old Forest Road Lynchburg, VA 24501 Patricia CampbellWinston & Strawn 1400 L St., NW Washington, DC 20005Mr. W. Edward CumminsAP600 and AP1000 Projects Westinghouse Electric Company P.O. Box 355 Pittsburgh, PA 15230-0355Mr. Kelly R. Fletcher, ManagerBusiness Development and Advanced Technologies GE Nuclear Energy 175 Curtner Avenue, MC 784 San Jose, CA 95125Mr. Jack W. RoeSCIENTECH, INC.
910 Clopper Road Gaithersburg, MD 20878Mr. Stephen P. FrantzMorgan, Lewis, & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004Mr. Gary Wright, ManagerOffice of Nuclear Facility Safety Illinois Department of Nuclear Safety 1035 Outer Park Drive Springfield, IL 62704Mr. David RitterResearch Associate on Nuclear Energy Public Citizens Critical Mass Energy and Environmental Program 215 Pennsylvania Avenue, SE Washington, DC 20003Mr. Tom Clements6703 Gude Avenue Takoma Park, MD 20912Mr. Horace R. Hall, Commercial ManagerNuclear Business Team UCAR Carbon Company, Inc.
P.O. Box 2170 Clarksburg, West Virginia 26302-2170Mr. James BlythCanadian Nuclear Safety Commission 280 Slater Street, Station B P.O. Box 1046 Ottawa, Ontario
K1P 5S9Atambir RaoProject Manager, ESBWR GE Nuclear Energy 175 Curtner Avenue, MC 365 San Jose, CA 95125 USAMr. Edward F. Sproat, IIIVice President - Int
'l ProjectsExelon Generation 200 Exelon Way Kennett Square, PA 19348Mr. Vince LangmanLicensing Manager Atomic Energy of Canada Limited 2251 Speakman Drive Mississauga, Ontario Canada L5K 1B2Dr. Regis A. MatzieSenior Vice President and Chief Technology Officer Westinghouse Electric Company 2000 Day Hill Road Windsor, CT 06095-0500Mr. Ed Wallace, General ManagerProjects PBMR Pty LTD PO Box 9396 Centurion 0046 Republic of South Africa Distribution for Meeting Summary dated July 21, 2003Hard CopyRNRP R/FPUBLIC JSebrosky JWilliamsE-Mail:PUBLIC SCollins WBorchardt BSheron DMatthews RNRP Group DE Branch Chiefs DE Section Chiefs
OGC ACRS/ACNW JLyons MKotzalas AThadani FEltawila JIsom JBlake RGardner CPaulk GMizuno RWeisman JMoore BSmith, OGC KBarber, OGC DBarss BMusico NIqmbal PQualls TKenyon DCoe MEl-Zeftway MeetingWith the Nuclear Energy InstituteMay 22, 2003Attendance List NRC NEIJames LyonsNRR/NRLPORuss BellMarsha GamberoniNRR/NRLPORon Simard Joe SebroskyNRR/NRLPO Jerry WilsonNRR/NRLPOOther Interested AttendeesNaeem IqbalNRR/DSSA/SPLBMike BourgeoisEntergyDan BarssNRR/DIPM/IEHBMarilyn KrayExelon Bruce MusicoNRR/DIPM/IEHBJoe HegnerDominion Tom KenyonNRR/DRIP/RLEPLarry DrbalBlack and Veatch Jose CalvoNRR/DE/EEIBLane HaySerch Bechtel Matt ChiramalNRR/DE/EEIBPatricia CampbellWinston and Strawn Janice MooreOGCCharles BrinkmanWestinghouse Geary MizunoOGCBob CowardMPR Kathryn BarberOGCJ. Alan BeardGE Nuclear Energy Brooke SmithOGCShinichi HayaduneEnergy USAMark SmithUSEC Jack RoeScientech Ryaji ImasakiToshiba K. KitamuraToshiba Deann RaleighLIS, ScientechAttachment 1 AgendaMay 22, 2003 Meetingwith NEI9:00 Introductory CommentsNEI/NRC9:10Discussion of response to staff requirementsmemorandum (SRM) dated September 11, 2002, regarding programmatic ITAAC (The ADAMS Accession Number for the SRM is ML022540755.
Additional background is contained in attachment 2 to the announcement.)
NRC9:30 Discussion of programmatic ITAAC responseNRC/NEI10:30Identification and plans for addressing 10 CFR Part 52combined license (COL) issuesNRC/NEI11:45 Public Comment11:55Summary 12:00AdjournAttachment 2 1 A principal issue for these categories is what constitutes a "fully described
" program.2 The following programs may fall into Category C or D depending on the informationprovided at the time of the COL: fire protection, radiation protection, security, fitness for duty, training, access authorization, reportability, licensed operator training.Attachment 3Background Material for Programmatic Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC)Description of the Issue In SECY-02-0067, "Inspections, Tests, Analyses, and Acceptance Criteria for OperationalPrograms (Programmatic ITAAC)," the staff requested Commission approval for its position thatcombined licenses (COLs) for a nuclear power plant submitted in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 52 Subpart Ccontain ITAAC for operational programs required by regulations such as training and emergency planning (ADAMS Accession Number ML020700641). The Commission provided its response in a September 11, 2002, staff requirements memorandum (ADAMS Accession Number ML022540755).Discussion Topics The staff would like to discuss a response to the staff requirements memorandum (SRM)including a discussion of the following option. A draft standard review plan (SRP) Section 14.3, Appendix E, "Programmatic ITAAC
" would be developed for guidance. The staff is consideringcategorizing the 14 programs that it listed in SECY-02-0067 in the following manner as part of this guidance:Category A:Programmatic ITAAC are required. A program that falls into this category isemergency planning.Category B:Programmatic ITAAC are not necessary because hardware-related ITAACaddress the results to which the program is directed. Examples of programs that may fall into this category are equipment qualification, quality assurance, and containment leak rate testing.Category C:An ITAAC for a program or elements of the program is not necessary becausethe program and its implementation can be fully described 1 in the application andfound to be acceptable at the COL stage.
2Category D:An ITAAC for a program or elements of the program is necessary because theprogram and its implementation cannot be fully described 1 in the application. That is, the COL applicant cannot provide the necessary and sufficient programmatic information for approval of the COL without ITAAC.
2Category E:An ITAAC for a program is not necessary because ITAAC will be dispositionedprior to fuel load and the program is not required to be implemented until after fuel load. Examples of programs that may fall into this category include the inservice inspection and inservice testing programs, and the maintenance rule program.