ML071630241

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 Force

ML071630241
Person / Time
Site:	PROJ0690
Issue date:	06/22/2007
From:	Hoffman S 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

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 FORCE The 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 NRCs March 16, 2007, letter regarding Generic Aging Lessons Learned (GALL) Report aging management program (AMP) XI.E6 NEIs response to the NRC staffs March 16, 2007, letter regarding GALL Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, was discussed. NEI commented that the staffs 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 audits

a. Wolf Creek aging management audit Lessons 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 in scope 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 to provide 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 methodology and expectations for TLAAs. The staff clarified during the call that the staffs 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 projection to 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 RAIs NEI questioned why the NRC staff sent formal RAIs to Wolf Creek to request information 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 NRCs 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 be submitted 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 topics Environmental reviews - refurbishment The NRC staff indicated that a future applicant approached the NRC staff to discuss whether 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 areas regarding refurbishment are designated as Category 2 issues in the Generic Environmental Impact Statement and would require plant-specific evaluation in the applicants 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 participation Mr. Rich Janati, Chief of the Division of Nuclear Safety, Pennsylvania Bureau of Radiation Protection, 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 Manager License Renewal Branch B Division of License Renewal Office of Nuclear Reactor Regulation Project No. 690

Enclosures:

As stated cc w/encls: See next page

ML071630241 DOCUMENT NAME:C:\\FileNet\\ML071630241.wpd OFFICE PM:RLRB:DLR LA:DLR BC:RLRC:DLR BC:REBB:DLR BC:RLRB:DLR NAME SHoffman IKing KChang RFranovich Brogers for RAuluck DATE 06/20/07 06/20/07 06/20/07 06/21/07 06/22/07 List of Participants for the Telephone Conference Call and Meeting Held Between the U.S. Nuclear Regulatory Commission Staff and the Nuclear Energy Institute April 25, 2007 PARTICIPANTS AFFILIATIONS Samson Lee U.S. Nuclear Regulatory Commission (NRC)

Kenneth Chang NRC Louise Lund NRC Stephen Hoffman NRC Eric Benner NRC Jennifer Davis NRC Roy Matthew NRC Zhian Li NRC Jim Davis NRC Dave Wrona NRC Drew Stuyvenberg NRC Linh Tran NRC K. Robert Hsu NRC John Fair NRC James Medoff NRC Farideh Saba NRC Veronica Rodriguez NRC Yeon-Ki Chung NRC Duc Nguyen NRC James Ross Nuclear Energy Institute Mike Detamore PPL Susquehanna Dave Flyte PPL Susquehanna Jeff Welk PPL Susquehanna Dave Kunsemiller FENOC Steve Dort FENOC Roger Rucker FENOC Alan Cox Entergy Eric Blocher Strategic Teaming and Resource Sharing (STARS)

Paul Crawley STARS Chalmer Myer Southern Nuclear Company Al Fulvio Exelon Fred Polaski Exelon Gene Eckholt NMC - Prairie Island Tom Snow Dominion Mike Heath Progress Energy Ron Neilski Nine Mile Point PARTICIPANTS AFFILIATIONS Mike Semmler Duke Bob Vincent Palisades Lorrie Bell Wolf Creek Ken Putnam Duane Arnold Massoud Tefezzoli AREVA Kathryn Sutton Morgan Lewis Rich Janati Pennsylvania Bureau of Radiation Protection Steven Dolley Platts Nuclear Deann Raleigh Scientech Teleconference Agenda Between the U.S. NRC Staff and the Nuclear Energy Institute April 25, 2007 Topic Lead

1. Response to NRCs Mar. 16, 2007, letter regarding NEI GALL aging management program XI.E6.

2. License renewal implementation/Post-approval renewal NEI/NRC inspection procedure (IP-71003)

3. Lessons learned from recent safety review audits

a. Wolf Creek aging management audit NEI

b. Review of time-limited aging analyses NEI c.

Environmental audit requests for additional information NEI

4. New topics Environmental reviews - refurbishment NRC

5. Public participation All

Note to Nuclear Energy Institute, from S. Hoffman, dated June 22, 2007

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 FORCE DISTRIBUTION:

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Nuclear Energy Institute Project No. 690 cc:

Ms. Christine S. Salembier, Commissioner State Liaison Officer Department of Public Service 112 State St., Drawer 20 Montipelier, VT 05620-2601 Mr. Gordon A. Clefton Nuclear Energy Institute 1776 I St., N.W., Suite 400 Washington, DC 20006-3708 Mr. Frederick W. Polaski Manager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348 Mr. David Lochbaum Union of Concerned Scientists 1707 H St., NW, Suite 600 Washington, DC 20006-3919 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 Ave., SE Washington, DC 20003 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 Robert A. Vincent Licensing Lead - License Renewal Project Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Lorrie Bell, Project Manager Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Roger Stewart Progress Energy Carolinas, Inc.

3581 West Entrance Road RNP A9 Hartsville, SC 29550 Michael H. Crowthers, Supervisor Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street (GENPL4)

Allentown, PA 18101-1179