ML051100051

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Attachment 6 - NRC Handout: Slides from April 7, 2005, NEI-04-01 Public Meeting
ML051100051
Person / Time
Site: Nuclear Energy Institute
Issue date: 04/07/2005
From: Joseph Colaccino
NRC/NRR/DRIP/RNRP
To: Bell R
Nuclear Energy Institute
Colaccino,Joseph,NRR/DRIP/RNRP,415-2753
References
NEI 04-01
Download: ML051100051 (9)
v • d • e


Text

NRC Review of NEI 04-01, Revision D:

Draft Industry Guideline for Combined License Applicants Under 10 CFR Part 52

_,R REG&

NRC/NEI Public Meeting April 7, 2005 1

\,Opening Remarks: NEI 04-01 and Operational Program Review Public Meetings

  • NEI 04-01 NRC providing preliminary comments during public meetings

. Behind NEI's "strawman" schedule of February 2005 NRC plans to provide 1st round comments in June Competing priorities will delay the discussion of certain issues

  • Some sections of NEI 04-01 may not need to be discussed at this time
  • COLOPR Four of fourteen operational programs identified in May 14, 2001, NEI letter remain to be discussed after today's meeting
  • Consistent themes developing in the completion of NRC's work:

- Availability of operational program document before fuel load

- Implementation schedule of operational, program 2

Agenda

  • Section 4.3.9.7: FSAR Chapter 7 - Instrumentation and Controls
  • Section 4.5: Report on Departures from the Generic DCD
  • Section 5: Pre-COL Phase Activities
  • Section 6: Change Control for COL Application Information
  • Section 4.3.9.17: FSAR Chapter 17 - Quality Assurance
  • NEI Presentation on Operational Program Implementation
  • NRC Initial Thoughts on the Information Needed to Evaluate a COL Operational Program During the COL Application Review
  • New Operational Program Review Examples

- Quality Assurance, Maintenance Rule (incorporated into discussion of Section 4.3.9.17) 3 Preliminary Comments and Questions Section 4.3.9.7: FSAR Chapter 7 - Instrumentation and Controls c Guidance for COL Applicants on Design Implementation of Digital Instrumentation and Control Systems in Nuclear Power Plants See separate handout Draft comments to support this meeting sent to NEI by letter dated March 16, 2005 (Accession # ML050750083)

- Includes draft of NUREG-0800, Chapter 7 (Revision 4 issued June 1997) 4

+ s Preliminary Comments and Questions Section 4.5: Report on Departures from the Generic DCD

  • This section acceptable, but cannot comment on proposed rule for Part 52
  • Be aware that the timing of reports in AP1 000 proposed rule has been changed.

5

  • Preliminary Comments j :1and Questions Section 5: Pre-COL Phase Activities No preliminary comments in following sections:
  • Applicant Programs Required in the Pre-COL Phase (Section 5.1)
  • Engineering Design Verification (Section 5.2)
  • Pre-COL ITAAC Related Activities (Section 5.3)

Coordination of ITAAC-Related Activities with NRC (Section 5.3.1)

C Completion of ITAAC Prior to Issuance (Section 5.3.2)

  • Required Records and Reporting to NRC (Section 5.4)

- Record keeping (Section 5.4.1)

Discussed in conjunction with quality assurance

  • Design Reliability Assurance Program (Section 5.1.3) 6

It Preliminary Comments and Questions Section 5: Pre-COL Phase Activities (continued)

Design/Construction Quality Assurance Program and Part 21 Program (Section 5.1.1)

  • Section 5.1.1 states that "In addition to certain design activities, seismic investigations at the site would be included in pre-application work ... subject to QA requirements."
  • Believe that other site investigation activities could be subject to QA in addition to seismic investigations 7

.% °Preliminary Comments and Questions Section 5: Pre-COL Phase Activities (continued)

Construction/Operating License Fitness for Duty Programs:

10 CFR Part 26 (Section 5.1.2)

  • Section 5.1.2.1 states that "The detailed description of FFD program is neither required . . ."
  • Believe that the program should be described in FSAR 8

REOL, Alk Preliminary Comments and Questions Section 5: Pre-COL Phase Activities (continued)

Required Records and Reporting to NRC (Section 5.4)

Reports and Updates to NRC (Section 5.4.2)

  • Section 5.4.2 states that "These reports are required annually. . . "
  • this requirement has been changed in the proposed rule for AP1 000 9

Preliminary Comments and Questions Section 6: Change Control for COL Application Information No preliminary comments in following sections:

a Plant-Specific Exemptions from Tier 1 Information (Section 6.1)

  • Plant-Specific Departures from Tier 2 Information (Section 6.2)

, Plant-Specific Exemptions from Tier 2 Information (Section 6.2. 1)

  • Post Application Change Process (Section 6.5) 10

Preliminary Comments

// and Questions Section 6: Change Control for COL App. Information (continued)

Special Change Processes for Plant-Specific Departures from Tier 2 (Section 6.2.2)

  • Concerns with the proposed special change process for severe accident resolutions 11 Preliminary Comments and Questions Section 6: Change Control for COL App.lnformation (continued)

Departures from Generic Technical Specifications and Other Operational Requirements (Section 6.3)

  • Discussion in the statements of consideration for AP1 000 design certification rule (Section VIII.C) is a clearer explanation of the change process for operational requirements
  • Concerned with the proposal for a single exemption with multiple examples 12

IC, Preliminary B Comments and Questions Section 6: Change Control for COL App.lnformation (continued)

Changes in Approved Early Site Permit Information (Section 6.4)

Discussion Topics

  • GENERAL
  • RESOLVED ISSUES
  • MAJOR FEDERAL ACTION
  • CHANGES AND NEW INFORMATION
  • ENVIRONMENTAL REVIEW STANDARD
  • EXAMPLES AND OTHER ENVIRONMENTAL STATUTES 13 Preliminary Comments and Questions Section 6: Change Control for COL App.lnformation (continued)

Changes in Approved Emergency Planning Information (Section 6.4.3)

  • 10 CFR Part 52 - Proposed rule (§ 52.39, Finality of early site permit determinations)
  • General - Update and correct ESP emergency planning information, and discuss whether new (or additional) information changes the bases for compliance with applicable requirements
  • Subject to Litigation - New (or additional) information which materially affects the Commission's ESP determination, or is needed to correct ESP inaccuracies 14

COL Operational Program Comments on NEI 04-01 Section 4.3.9.17: FSAR Chapter 17, Quality Assurance

  • Develop new Standard Review Plan Sections 17.1-3, to provide updated guidance for meeting the requirements in Appendix B of 10 CFR Part 50
  • Discussion of operational reliability assurance program in Section 4.3.9.17 not linked with Sections 4.3.9.19 and 4.3.9.16 15 Oft) RE s COL Operational Program New Examples Maintenance Rule Operational Program
  • Revise Standard Review Plan Section 17.4, Reliability Assurance Program, to address Maintenance Rule. (17.4 currently provides D-RAP and O-RAP guidance.)

16

R§E, Status of Operational V g X Program Discussions 0'* -P in NRC/NEI Public Meetings Operational Program (05/14/01 NEI Letter) Meeting Date FollowuD U Emergency Planning N/A No E Quality Assurance 04/07/05 U Radiation Protection 03/03/05 ' Yes U Fitness for Duty 03/03/05 Yes U Licensed Operator U Containment Leak Rate Testing U Inservice Inspection and Inservice Testing 02/02/05 No U Physical Security 03/03/052 Yes a Fire Protection 02/02/05 No a Access Authorization 03/03/05 Yes U Training U Reportability 03/03105 3 U Maintenance Rule 04/07/05 U Equipment Qualification Notes: 1) Separate public meetings underway with NEI on content of FSAR Chapter 12; 2) NEI to form separate task force on security design ITAAC; 3) NEI provided view of reportability operational program but NRC has not presented Its view.

17 OF REI,

Background

NEI 04-01 and COL OPR Public Meeting Summaries Public Meeting Date(s) Meeting Summary Date Accession #

November 9, 2004 December 17, 2004 ML043240352 December 8, 2004 February 4, 2004 ML050110448 February 2, 2005 March 3, 2005 ML050540427 March 3-4, 2005 March 15, 2005*

March 18, 2005** April 4, 2005 ML050940075 April 7, 2005

  • Duke Power Corporation public meeting on planning for a COL application
    • NEI Public Meeting discussing the radiation protection operational program 18
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