ML072950495

09/25/2007 Summary of Meeting Between the U.S. Nuclear Regulatory Commission Staff and the Nuclear Energy Institute License Renewal Task Force

ML072950495
Person / Time
Site:	PROJ0690
Issue date:	11/08/2007
From:	Rowley J NRC/NRR/ADRO/DLR
To:	Nuclear Energy Institute
Rowley J, NRR/DLR/RLRB, 415-4053
References
Download: ML072950495 (9)

Text

November 8, 2007

ORGANIZATION: Nuclear Energy Institute

SUMMARY

OF THE SEPTEMBER 25, 2007, LICENSE RENEWAL MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND THE NUCLEAR ENERGY INSTITUTE LICENSE RENEWAL TASK FORCE The U.S. Nuclear Regulatory Commission (NRC) staff and the Nuclear Energy Institute (NEI) License Renewal Task Force held a public meeting on September 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 participants attending the meeting. Enclosure 2 contains the agenda for the meeting. A summary of the discussions follows:

1. Scoping of structures and components credited for recovery from station blackout Guidance on license renewal scoping and screening for structures and components credited for compliance with the stations blackout rule (10 CFR 50.63) is contained in License Renewal Interim Staff Guidance (LR-ISG)-02, "Staff Guidance on Scoping of Equipment Relied on to Meet the Requirements of the Station Blackout (SBO) Rule (10 CFR 50.63) for License Renewal (10 CFR 54(a)(3))", dated April 1, 2002 (ADAMS Accession No. ML020920464) and the standard review plan for license renewal (NUREG-1800) in which LR-ISG-02 was subsequently incorporated. The NRC discussed its interpretation of ISG-2 guidance which indicates that the components and structures that serve as the scoping boundary should include the switchyard circuit breakers that connect the offsite power system transformers (startup transformers); the transformers themselves; the intervening overhead and underground circuits between the circuit breaker and transformer and transformer and onsite electrical distribution system; and the associated control circuits and structures. The NRC indicated that the word "typically" may be removed from ISG-2. The NRC indicated that staff would evaluate the plants with renewed licenses that did not conform to ISG-2 under the appropriate regulatory processes. NEI representatives proposed that the NRC consider each plant's design and already established interfaces with the transmission system operator. NEI and staff agreed to have a separate meeting to discuss the technical basis for the scoping boundary.

2. Metal fatigue time-limited aging analyses and cycle projections NRC clarified that the review and audit performed by the audit team did not represent a new position. The position and the staff's review procedure were stated in the SRP-LR (NUREG-1800) Revision 0, and updated in Revision 1, issued September 2005. The key sub-sections of SRP-LR were read, highlighting the issues of concern.

The acceptance criteria for TLAAs are described in 4.3.2.1, known as 10 CFR 54.21(c)(1)(i) - (iii). When applying the criteria to ASME Section III, Class 1 components, the acceptance criteria are further clarified in 4.3.2.1.1.1 - 4.3.2.1.1.3. It stated

that if (ii) is used, the CUF calculations have been reevaluated based on an increased number of assumed transients. If (iii) is used, the staff has evaluated a program (a GALL AMP) for monitoring and tracking the number of critical transients and determined that this program is an acceptable AMP (normally Fatigue Monitoring Program (FMP)). The staff, in some cases, accepted a slightly relaxed (iii) acceptance criterion. The staff found it acceptable for an applicant to provide a description of the AMP in sufficient detail for the staff to make a determination during the license renewal review and audit period with a commitment to implement the AMP by an acceptable date. Before the AMP is fully implemented, the applicant may perform the updated or revised fatigue analysis as part of the FMP. The staff's review procedures follow 4.3.3.1.1.1 - 4.3.3.1.1.3, which are consistent with 4.3.2.1. For environmental impact on fatigue (EAF), the staff verifies that the applicant has addressed the effects of the coolant environment on component fatigue life as AMPs are formulated in support of license renewal. One acceptable way to assess EAF on a sample of critical components is described in 4.3.3.2.

NRC staff responded to a question raised by Entergy on their recently submitted LRAs. There were no further questions. The issue and NRC's position and review procedures were fully understood and agreed to by NEI.

3. License renewal interim staff guidance (LR-ISG)

NEI will provide comments on the updated LR-ISG process and the LR-ISG on Generic Aging Lessons Learned Report, Aging Management Program XI.E6, issued for public comment the end of August 2007. The NRC and NEI will hold a meeting if necessary to discuss the comments.

4. Post-approval renewal inspection procedure (IP-71003) revision The NRC staff awaits NEI comments on the revision to IP-71003, which was sent to NEI by letter dated August 9, 2007 (ADAMS Accession No. ML071720222). Once NEI has commented on the draft, a public meeting will be scheduled to discuss the revision and the NRC's plans for post-approval renewal inspections.

5. Lessons learned from recent safety review audits

a. Level of detail for new aging management programs (AMPs) that are consistent with the Generic Aging Lessons Learned (GALL) Report The staff clarified previous discussions on this topic during the June 21, 2007, meeting. For new AMPs that are consistent with a GALL Report AMP without exception, the license renewal application does not need to address the ten elements of an acceptable AMP. Consistency with the GALL Report will be confirmed during the staff's onsite audit. If any exceptions are taken to the GALL Report AMP, the renewal application must address the exceptions. The renewal application needs to address all ten elements for new, plant-specific AMPs that are not consistent with the GALL Report.

b. New observations No new observations were discussed.

6. New topics

a. Cable tie wraps The NRC staff is evaluating this topic and will discuss it in a future meeting when it has completed its evaluation.

7. Public participation No member of the public chose to participate in the meeting.

/RA/ Jonathan Rowley, Acting Branch Chief Program Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation Project No. 690

Enclosures:

As stated cc w/encls: See next page

ML072950495 OFFICE LA:DLR BC:RPOB:DLR BC:RER1:DLR BC:RER2:DLR NAME SFigueroa JRowley KChang RAuluck DATE 10/24/07 10/24/07 11/07/07 11/08/07 ENCLOSURE 1 List of Participants License Renewal Meeting Between the NRC Staff and the Nuclear Energy Institute September 25, 2007 PARTICIPANTS AFFILIATIONS Samson Lee U.S. Nuclear Regulatory Commission (NRC) Jonathan Rowley NRC Raj Auluck NRC Rani Franovich NRC Eric Benner NRC Bill Rogers NRC Kenneth Chang NRC Dan Hoang NRC Yeon-Ki Chung NRC Peter Wen NRC George Wilson NRC Veronica Rodriguez NRC Duc Nguyen NRC Sheila Ray NRC Surinder Arora NRC Tommy Le NRC Perry Buckberg NRC On Yee NRC Farideh Saba NRC Qi Gan NRC Julie Keys Nuclear Energy Institute Dave Flyte PPL Susquehanna Michael Detamore PPL Susquehanna Dave Kunsemiller FENOC/Beaver Valley Garry Young Entergy Alan Cox Entergy Roger Stewart Progress Energy Mike Fallin Constellation Energy Ron Leski Constellation Energy Michael Semmier Duke Energy Lorrie Bell Wolf Creek Mauri Lemoncelli Morgan Lewis Gene Eckholt NMC/Prairie Island Ken Putnam FPL Duane Arnold Chalmer Myer SNC Cary Martin SNC Paul Crawley STARS/APS Eric Blocher STARS/COB Richard Schaller STARS/COB Daisy Ligon Noblis Ahmad Faramarzi Noblis 2 Dave Bremer NPPD/Cooper PARTICIPANTS AFFILIATIONS Ken Brune TVA Massoud Tafazzoli Areva Ali Fakhar PSEG Abbas Mostala Energy Northwest/CGS Don Warfel Exelon ENCLOSURE 2 Agenda U.S. NRC Staff and the Nuclear Energy Institute Quarterly Meeting September 25, 2007

Topic Lead 1. Scoping of structures and components credited for recovery from NRC station blackout

2. Metal fatigue time-limited aging analyses and cycle projections NRC

3. Interim staff guidance (ISG) Proposed ISG on aging management program XI.E6 NEI

4. Post-approval renewal inspection procedure (IP-71003) revision NRC

5. Lessons learned from recent review audits NRC/NEI

6. New topics NRC/NEI

7. Public participation All Letter to NEI from J. Rowley Dated November 8, 2007 DISTRIBUTION:

SUMMARY

OF THE SEPTEMBER 25, 2007, LICENSE RENEWAL MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND THE NUCLEAR ENERGY INSTITUTE LICENSE RENEWAL TASK FORCE HARD COPY: DLR RF E-MAIL: PUBLIC SSmith (srs3) SDuraiswamy RidsNrrDlr RidsNrrDlrRlra RidsNrrDlrRlrb RidsNrrDlrRlrc RidsNrrDlrReba RidsNrrDlrRebb RidsNrrDciCvib RidsNrrDciCpnb RidsNrrDraAfpb RidsNrrDeEmcb RidsNrrDeEeeb RidsNrrDssSbwb RidsNrrDssSbpb RidsNrrDssScvb RidsOgcMailCenter ------------- MModes, RI CJulian, RII LKozak JRowley Nuclear Energy Institute Project No. 690 cc: Ms. Christine S. Salembier, Commissioner State Liaison Officer Department of Public Service 112 State Street, Drawer 20 Montipelier, VT 05620-2601

Mr. Frederick W. Polaski Manager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348 Mr. Clifford I. Custer Project Manager, License Renewal FirstEnergy Nuclear Operating Company P.O. Box 4 Route 168 (Mail Stop SIM-2) Shippingport, PA 15077

Mr. Paul Gunter, Director Reactor Watchdog Project Nuclear Information & Resource Service 6930 Carroll Avenue, Suite 340 Takoma Park, MD 20912 Mr. Hugh Jackson Public Citizen's Critical Mass Energy & Environment Program 215 Pennsylvania Avenue, SE Washington, DC 20003 Mr. Chalmer Myer 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35201 Ms. Mary Olson Nuclear Information & Resource Service Southeast Office P.O. Box 7586 Asheville, NC 28802 Mr. Garry G. Young Manager, License Renewal Services 1448 SR 333, N-GSB-45 Russellville, AR 72802

Ms. Lorrie Bell, Project Manager Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Mr. Roger Stewart Progress Energy Carolinas, Inc.

3581 West Entrance Road RNP A9 Hartsville, SC 29550 Mr. Michael H. Crowthers, Supervisor Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street (GENPL4) Allentown, PA 18101-1179 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations 440 Hamilton Avenue White Plains, NY 10601