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NRC Section XI Report - February 2001

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Presented By: Wally Norris, United States Nuclear Regulatory Commission

NRC Report
Section XI
February 2001

1. Amendment to 10 CFR 50.55a

The proposed amendment to § 50.55a is scheduled to be published in September 2001. The amendment would endorse the 1997 Addenda, 1998 Edition, 1999 Addenda, and 2000 Addenda of Section III, Section XI, and OM Code. The scheduled date has slipped approximately 6 months from the previously announced date due to cancellation of the assistance contract at Idaho National Engineering Laboratory (INEL). The contract was canceled because of the potential of conflict of interest related to management of INEL by Bechtel. Hence, the staff has reallocated resources to complete the rulemaking in-house.

2. ASME Code Cases

The NRC has received the letter from John Ferguson to William Travers dated January 12, 2001. NRC staff met with the Office of the Federal Register (OFR) on January 30, 2001, to discuss the legal concerns raised by the NRC’s Office of General Counsel (OGC) relative to the Code Case endorsement process. The OFR approved the staff plan to continue to endorse Code Cases in regulatory guides with an accompanying administrative change to 10 CFR 50.55a. A meeting is being scheduled to brief the EDO. Hence, a publication date is not yet available. The staff plans to endorse Code Cases through Supplement 10 to the 1998 Edition.

3. Standards Coordination Meeting with ASME

Representatives of the ASME and NRC staff are meeting on the morning of February 21, 2001, to discuss ASME concerns relative to endorsement of the Code and Code Cases. Items on the draft agenda included: (1) NRC rulemaking process and endorsement of new edition and addenda; (2) NRC regulatory guide process and endorsement of new Code Cases; (3) Footnote 6 to 10 CFR 50.55a; (4) ASME process for issuing new editions, addenda, and Code Case supplements; (5) incorporation of Code Cases into ASME Code; and (6) potential enhancements to NRC and ASME processes to facilitate NRC endorsements.

4. PRA Standard

The staff has been working with the ASME and the other stakeholders to reach a consensus on a standard for PRAs. The ASME Standards document will help define the quality of PRAs to be used in applications to satisfy risk-informed regulations. Use of this Standard will diminish the need for staff review of PRAs, and provide uniformity and consistency of staff review when it is determined that a detailed review is necessary. The ASME standard (Revision 12) was published for a 60-day public comment period on June 14, 2000. On August 14, the staff sent extensive comments on the PRA standard to the ASME. A task group consisting of 4 NRC staff members and 5 industry representatives was formed to evaluate the principles and objectives for the PRA standard and to identify critical technical issues. The task group met on September 19 and 20 and the results were presented to a senior management group of executives from ASME, USNRC and the nuclear industry on September 21. The task group has continued to redefine some objectives, high level requirements as well as supporting requirements for each of the PRA elements to be included in the PRA Standard. The Task Group met during the week of January 15, 2001, to finalize the supporting requirements and ensure that clear criteria are provided for each requirement. The Task Group meetings went very well, and the NRC staff Task Group members were pleased with the efforts relative to the development of criteria and guidance. The draft document was distributed to the working group for review during the week of January 29, 2001.

5. Standards Development Organizations (SDOs) Meeting

A meeting was held on January 17, 2001, between the NRC, eight SDOs (including ASME, represented by John Ferguson), NEI, DOE, NIST, and other interested parties. This was the fourth semi-annual meeting. These meetings are held to foster better communication between the NRC and SDOs on matters of standards policy. A key item raised at this meeting was the need for this body to coordinate development of risk-informing and performance-based guidelines for the SDOs as the nuclear industry proceeds with risk-based efforts.

6. Regulatory Information Conference (RIC)

The NRC staff is in the process of considering the responses to the on-line survey (stakeholders were invited to complete the form by November 15, 2000). The responses will be used in developing the RIC which will be held March 12, 13, and 14, 2001, at the Capital Hilton Hotel, 16th and K Streets, NW, Washington, DC. Please note that both hotel registration and on-line registration for the conference opened on January 1, 2001.

7. Industry Initiatives

In response to the SRM issued on May 27, 1999, to SECY-99-063, "The Use by Industry of Voluntary Initiatives in the Regulatory Process," and to stakeholders' comments, the staff, working with stakeholders, developed proposed guidelines for including industry initiatives in the regulatory process. The proposed guidelines were transmitted to the Commission on May 30, 2000 (SECY-00-0116, "Industry Initiatives in the Regulatory Process"). On June 28, 2000, the Commission approved the staff’s recommendation to issue the proposed guidelines for public comment. The guidelines were published in the Federal Register on August 31, 2000 (Volume 65, Number 170, Pages 53050-53058) for public comment (45-day). The final version of the guidelines is scheduled to be provided to the Commission for review prior to issuance on June 29, 2001.

8. Risk-informing Technical Requirements of 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities"

The NRC staff has released to the public a draft version of its review guidelines for the South Texas Plant (STP) Nuclear Operating Company request for exemptions from numerous special treatment requirements in 10 CFR Parts 21 and 50 (http://www.nrc.gov/NRC/REACTOR/RISK50/treatment_modifications). The purpose for releasing the draft guidelines, titled "Review Guidelines for STP Exemption Request and Baseline Acceptance Criteria for RIP50 Option 2," is to facilitate discussion of the issues at several public forums. The draft guidelines represent a "work in progress" and are subject to change on the basis of stakeholder input. These guidelines will also serve as the starting point for the development of acceptance criteria for licensees who choose to adopt the staff's risk-informed changes to the special treatment requirements published in an Advanced Notice of Proposed Rulemaking on March 3, 2000 (risk-informed Part 50, Option 2).

Note that this is a draft document which is subject to change and does not yet represent official NRC positions. For further information, you may contact Tom Bergman, NRC/NRR, by telephone at (301) 415-1021, or by email at tab@nrc.gov.

An agency policy paper SECY-98-300, "Options for Risk-informed Revisions to 10 CFR Part 50 - "Domestic Licensing of Production and Utilization Facilities," identifies three options for risk-informed modifications to 10 CFR Part 50. Option 3 from SECY-98-300, is discussed on http://nrc-part50.sandia.gov/. Option 3 involves a study of risk-informed changes to specific requirements in the body of the regulations, including general design criteria. The details of the plan for risk-informing the technical requirements of 10 CFR Part 50 are specified in policy paper SECY-99-264, "Proposed Staff Plan For Risk-informing Technical Requirements in 10 CFR Part 50." SECY 00-0086 - "Status Report on Risk-Informing the Technical Requirements of 10 CFR Part 50 (Option 3)," is also available on this website. This SECY provides the first status report on the work done to date by the staff to study risk-informing the technical requirements of 10 CFR part 50, as described in SECY-99-264 (Option 3), and informs the Commission of the staff's intent to expedite completion of its recommendations for risk-informed changes to certain parts of 10 CFR 50.44 ("Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors").

SECY-00-0198 - "Status Report on Study of Risk-Informed Changes to the Technical Requirements of 10 CFR Part 50 (Option 3) and Recommendations on Risk-Informed Changes to 10 CFR 50.44 (Combustible Gas Control)," provides the second status report on the staff's study of possible risk-informed changes to the technical requirements of 10 CFR Part 50, provides the staff's recommendations for risk-informed changes to 10 CFR 50.44 ("Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors"), and provides policy issues for Commission decision.

9. License Renewal Activities

In August 2000, the NRC staff issued three improved license renewal guidance documents for public comment: NUREG-1801, "Generic Aging Lessons Learned (GALL) report," NUREG-1800, "Standard Review Plan for License Renewal" (SRP-LR), and a draft of Regulatory Guide 1.188, "Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses," which proposes to endorse a revised industry guide, NEI 95-10. These documents are designed to streamline the license renewal review process by providing clear guidance for license renewal applicants and the NRC staff in preparing and reviewing license renewal applications. Two applications for license renewal have been approved (Calvert Cliffs and Oconee) and three applications are under review (Arkansas Nuclear One, Unit 1, Edwin I. Hatch, and Turkey Point).

The GALL report systematically catalogs aging effects on structures and components; identifies the relevant existing plant programs; and evaluates the existing programs against the attributes considered necessary for an aging management program to be acceptable for license renewal. The GALL report also provides guidance for the augmentation of existing plant programs, including those based on codes and standards, to support license renewal. The GALL report provides credit for ASME section XI inspection where it was determined to be an effective aging management program and also provides specific recommendations where ASME section XI inspections may need to be enhanced to support license renewal. The revised SRP-LR allows an applicant to reference the GALL report to preclude further NRC staff evaluation if the plant's existing programs meet the criteria described in the GALL report. During the renewal review process, the NRC staff will focus primarily on existing programs that should be augmented or new programs developed specifically for license renewal.

The NRC staff has been actively participating in the ASME special working group for plant life extension (SWG-PLEX). The NRC staff attended meetings, provided license renewal status updates, and reviewed products from the working group. The SWG-PLEX provided public comments on the improved license renewal guidance mentioned above. The NRC staff will continue to participate with the SWG-PLEX in the development of improved guidelines for license renewal and aging management.

The NRC staff is developing responses to all of the public comments on the improved renewal guidance and is scheduled to present proposed final guidance to the ACRS in February 2001. Submittal to the Commission for approval is scheduled for April 2001. Information relative to license renewal can be found at http://www.nrc.gov/NRC/REACTOR/LR/index.html.

10. Revised Reactor Oversight Process

On June 28, 2000, SECY-00-0146, "Status of Risk-based Performance Indicator Development and Related Initiatives," was transmitted to the Commission to provide the Commission with a status report on the development of risk-based performance indicators (RBPIs) and related initiatives in support of the Reactor Oversight Process (ROP). A white paper ("Development of Risk-Based Performance Indicators: Program Overview) on the development of RBPIs was issued for comment in March 2000. The purpose of this white paper was to provide an overview of the current efforts to develop RBPIs. The ACRS was briefed on the RBPI white paper on April 5, 2000. The ACRS concluded that the RBPI development is very important for the successful transition to risk-informed regulation and recommended that the agency assign a high priority and adequate resources to this program. The ACRS also recommended that the staff should work with the industry to ensure that licensee reporting of reliability data becomes an industry self-imposed requirement of the Equipment Performance and Information Exchange (EPIX) database. A public meeting with external stakeholders was held on April 28, 2000, to discuss their comments on the overall concept and technical approach outlined in the RBPI development white paper. The NRC staff is developing Phase-1 RBPIs using the overall concept described in the RBPI white paper. Monthly working session meetings are held for the NRC staff to solicit feedback regarding initial implementation of the revised reactor oversight process.

11. Risk-Informed Inservice Testing

On April 27, 2000, the licensee for Sequoyah submitted a limited scope RI-IST relief request. The Sequoyah RI-IST relief request addresses 80 valves in each of the two units, in ten different systems, and would extend the test intervals for these valves from quarterly to once each refueling cycle. A set of Request for Additional Information (RAIs) have been prepared and discussed with the licensee. The submittal is on hold pending discussions between the NRC and the licensee concerning the type and amount of information that is required to complete the review.

The staff is also reviewing a RI-IST topical report from the B&W Owners Group (received in August 2000). This topical report applies the ASME RI-IST categorization code case, OMN-3, to air-operated valves at Davis Besse, the B&WOG lead plant for RI-IST. This topical report was also developed in conjunction with the Joint Owners Group (JOG) AOV Program. Davis Besse submitted a licensing action on September 11, 2000, which proposes an alternative to 10 CFR 50.55a(f) to implement the B&W Owners Group methodology for AOVs. A public meeting was held at the NRC on January 25, 2001. Representatives from the B&WOG and Davis-Besse discussed specifics of the risk-informed AOV program. The staff, the B&WOG, and Davis-Besse are working to resolve the remaining open items.

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