ML003751047
| ML003751047 | |
| Person / Time | |
|---|---|
| Site: | Boiling Water Reactor Owners Group |
| Issue date: | 09/13/2000 |
| From: | Pulsifer R NRC/NRR/DLPM |
| To: | |
| References | |
| Download: ML003751047 (62) | |
Text
NRC FORM 658 U.S. NUCLEAR REGULATORY COMMISSION (9-1999)
TRANSMITTAL OF MEETING HANDOUT MATERIALS FOR IMMEDIATE PLACEMENT IN THE PUBLIC DOMAIN This form is to be filled out (typed or hand-printed) by the person who announced the meeting (i.e., the person who issued the meeting notice). The completed form, and the attached copy of meeting handout materials, will be sent to the Document Control Desk on the same day of the meeting; under no circumstances will this be done later than the working day after the meeting.
Do not include proprietary materials.
DATE OF MEETING The attached document(s), which was/were handed out in this meeting, is/are to be placed in the public domain as soon as possible. The minutes of the meeting will be issued in the near future. Following are administrative details regarding this meeting:
Docket Number(s)
Q "
4i O Plant/Facility Name TAC Number(s) (if available)
Reference Meeting Notice g./.
Purpose of Meeting (copy from meeting notice) 4C-,
NAME OF PERSON WHO ISSUED MEETING NOTICE
[ILEL "OFFICE DIVISION BRANCH Distribution of this form and attachments:
Docket File/Central File PUBLIC NRC FORM 658 (9-1999)
PRINTED ON RECYCLED PAPER This form was designed using InForms
Presentation to NRC Management On Appendix R Committee BWROG EOC/NRC Management Meeting September 13,2000
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Background===
S.Appendix R Issues identified during FPFI's/Inspections
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D;WROG Committee formed in Fall 1997
.Multiple meetings with NRC Staff in '98, '99, & '00
- .* Letter to Commissioner Diaz 11/3/98
.Products have been delivered to NRC
,.. BWROG Guidance endorsed by PWRs BWROG NRC Meeting September 13, 2000 2
Progress to Date
.+ BWHOG Products delivered '991 to NRC SRV+IPS "Redundant" Shutdown Paths (Rev 11
-Subsequent submittal 7/20/2000
- Subsequent submittal [Pending]
r
- i Post-Fire Safe Shutdown Guidance Document
,.. Established Integrated approach for r
Industry under NEI.
September 13, 2000 BWROG NRC Meeting 3
Actions to Close i.. NRC issue SER on SRV + LPS Submittal
+. NRC, w/BWROG support, present results of SHV + LPS Issue & basis of Generic Guidance to ACRS - [Oct'O0)
.*.:. NRC concur that BWROG Guidance Document provides reasonable assurance of compliance with existing regulations S.: NRC continue "hold" on expansion of NRC Inspection criteria pending completion of NEI 00-01
- .. NEI finish work to complete & submit NEI 00-01
. NRC issue SER on NEI 00-01 September 13, 2000 BWROG NRC Meeting N
Issues Resolution Unresolved issues will be addressed
- Multiple Spurious failures = NEI CF ITF
- Issues determined to have high safety significance will be addressed BWROG NRC Meeting 5
September 13, 2UUU S.....................
Conclusion Provide SER on BWROG Position on SRV + LPS
- BWROG Guidance Document I is a solid regulatory compliance approach Continue "hold" on NRC expansion of Inspection criteria pending completion of NEI 00-01 SResolve open issues through integrated industry effort under NEI BWROG NRC Meeting September 13, 2000 6
Loose Parts Monitoring System Regulatory Relaxation Presentation for BWROG/NRC Management Meeting September 13, 2000 Washington, DC
Loose Parts Monitoring System Regulatory Relaxation BWROG Committee Participation:
I CP&L, ComEd, Detroit Edison, Entergy Operations, First Energy, Amergen-Clinton, NMPC, PECO Energy, PPL, PSE&G, SNC, Energy NW I None of the 8 non-participating utilities have Loose Parts Monitoring Systems BWROG/NRC Management Mtg.
September 13, 2000 2
Loose Parts Monitoring System Regulatory Relaxations Loose Parts Monitor Regulatory Requirements:
M 19 U.S. BWRs do not have requirements for this system 0 15 U.S.BWRs are currently required to maintain this system I RG1.133 I Technical Specification or TRM I FSAR commitments BWROG/NRC Management Mtg.
September 13, 2000 3
Loose Parts Monitoring System Regulatory Relaxations Loose Parts Monitor Elimination:
I BWROG LTR NEDC-32975P, "Regulatory Relaxation for BWR Loose Parts Monitoring Systems" transmitted to NRC on July 31, 2000 I Contains plant specific design information and experience summary I Operating experience does not demonstrate that LPM Systems provide safety benefits I Compared RG1.133 requirements/expectations to system operating history BWROG/NRC Management Mtg.
September 13, 2000 4
Loose Parts Monitoring System Regulatory Relaxations Key BWROG Findings 1,* Although loose parts have been detected by LPMs, none have involved a failed or weakened safety component I BWRs employ aggressive foreign material exclusion programs I A foreign object or loose part in the reactor coolant system has a tendency to migrate to a low-flow region and remain there Sentember 13, 2000 BWROG/NRC Management Mtq.
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Loose Parts Monitoring System Regulatory Relaxations Key BWROG
[ Based on effects idE Findings (Continued)
BWROG survey, potential detrimental ntified in RG1.133 have not occurred at any BWR None of the BWR PRAs rely on or address LPMs I Quantitative risk assessments cannot be made I Risk insights based on several hundred years of plant experience indicated the existence or non-existence of LPMs will have no affect on core damage or large early release frequencies BWROG/NRC Management Mtg.
September 13, 2000 6
Loose Parts Monitoring System Regulatory Relaxations LPM Cost Burden I Median annual maintenance cost is $45K I Includes a $10K allowance for an exposure of 1 "person Rem I Some BWRs will require system replacement within next few years I $500K per plant I Based on operating experience, the negligible safety benefits do not justify cost burden I Regulatory requirements for LPMs may be eliminated for all BWRS with no impact on safety BWROG/NRC Management Mtg.
7 September 13, 2000
Loose Parts Monitoring System Regulatory Relaxations NRC Review of LTR M BWROG requests timely review of NEDC 32975P 2 NRC commitment requested to support system removal in spring 2001 refueling outages BWROG/NRC Management Mtg.
September 13, 2000 8
BWROG RISK INITIATIVES Presentation for BWROG/NRC Management Meeting Washington, DC September 13' 2000 Greg Krueger (PECO Energy) 1
PURPOSE OF THE PRESENTATION
- Provide a status of on-going initiatives
"* Maintenance Rule
"* Industry Standards
"* Risk Informed Part 50 Option 2 Pilot
"* Risk Informed Technical Specifications 2
MAINTENANCE RULE m Provided a risk informed process plant work management personnel m Drafted a position for PRA personnel on issues such as evaluations using:
- Predetermination based on one time Analysis or periodic analysis
- Reduction in scope based on one time analysis 3
for
INDUSTRY STANDARDS m ASME full power standard
- Draft 12 finished public review
- Detailed comments received from NRC
- Working Group will consider options
- ANS standards on External Events and Low Power/Shutdown
- External events review in 2000
- BWROG position is that a quantitative low power/ shutdown standard is unnecessary 4
RISK INFORMED PART 50 OPTION 2 PILOT
"* Committee developed preliminary cost benefit information
"* Five systems considered for RISC 1-3 SGTS and LPCS selected
"* Multiple BOP systems considered for RISC 4-2 Feedwater selected 5
RISK INFORMED PART 50 OPTION 2 PILOT m Schedule impact for the lead plant:
- Two months delay over initial year-end schedule
- Original work considered only one system from RISC 1-3
- Additional system may cause additional delay
- Lead plant to be complete by mid-2001 6
RISK INFORMED TECHNICAL SPECIFICATIONS m Early 2000 tasks included:
- Develop a BWR 4 generic model for Initiative 1 (modified end states)
- Write a report for Initiative 1 submittal (using CEOG report as a model)
- Monitor Initiatives 2 and 3 (missed surveillances and flexible mode restraints) 7
RISK INFORMED TECHNICAL SPECIFICATIONS i Late 2000 tasks included:
- Develop "how to" report on the model for Initiatives 4 and 6 (AOTs and LCO 3.0.3)
- Investigate value of Initiative 8 (elimination of some Technical Specifications)
- Support Initiative 5 (Removal of some surveillance requirements to owner controlled program) 8
RISK INFORMED TECHNICAL SPECIFICATIONS m STATUS
- Model is completed and reviewed
- Initiative 1 report is drafted and reviewed
"° Final publication is on hold until after Initiative 3
"° Initiative 3 delayed to get all Owners' Groups to submit a generic position
"* BWROG generic table due early September
"* Initiative 2 submitted for NRC
- The "how to" report will start after Initiative 1 report is issued and should be done in 2000.
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EXPECTED 2001 TASKS
"* Expand the model to:
- Include low power in addition to Modes 3 and 4
- Include sensitivities for BWR 2/3 and 5/6
"* Continue work on remaining initiatives
"* Evaluate containment isolation valve AOT extension
"* Participation in NEI RITSWG 10
DC MOTOR METHODOLOGY Presentation for BWROG-NRC Management Meeting September 13, 2000 BWROG NRC Management Meeting 09/13/00 I
DC MOTOR METHODOLOGY PURPOSE OF PRESENTATION
"* Program Status
"* Results of August 30 BWROG-NRC Meeting 2
BWROG NRC Management Meeting 09/13/00
DC MOTOR METHODOLOGY BACKGROUND
"* Issue: Motor speed/output affected by stem load, supplied voltage and winding temperature.
"* Potential Im act:
- Longer MOV stroke times
- Lower motor output (torque), thus lower valve thrust BWROG NRC Management Meeting 3
09/13/00
DC MOTOR METHODOLOGY METHODOLOGY DEVELOPMENT
"* Methodology developed with vendor input.
"* Methodology provided to utilities.
"* Utility training conducted.
4 BWROG NRC Management Meeting 09/13/00
DC MOTOR METHODOLOGY RESULTS OF 8/30 BWROG-NRC MEETING
"* BWROG applauded for extensive effort in DCM methodology development.
"* Only NRC concern was small testing sample as basis for generic methodology validation.
"* No major comments from INEEL.
"* BWROG prefers Staff communication to industry to be via Information Notice vice Safety Evaluation (BWROG never requested SE).
Ao/1 i/An PW'Pf)C NRP NMnnn ement Meetinor 5
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DC MOTOR METHODOLOGY "RESULTS OF BWROG-NRC MEETING Limitorque likes methodology; committed to an endorsement NLT 20 October via a published Technical Update pending resolution of Peerless "motor curve" verification.
- Staff requested EOC update on status of BWROG Utility Implementation Schedule (Staff wants BWROG letter) 6 BWROG NRC Management Meeting 09/13/00
DC MOTOR METHODOLOGY
SUMMARY
"* BWROG pro-actively developed methodology.
"* BWROG methodology models INEEL test results.
"* Methodology provided to utilities & training performed.
"* Utilities being provided guidance for implementation.
BWROG NRC Management Meeting 09/13/00 7
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PASS, H2 Recombiner, H2/02 Monitors, Regulatory Relaxations Presentation for NRC/BWROG Management Meeting September 13, 2000 Washington, DC 7
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PASS, H2 Recombiner,H 2/0 2 Monitors,
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Regulatory Relaxations
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Committee Objective:
"* Eliminate unnecessary post-accident sampling and
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analysis requirements for BWRs
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- m Declassify H2/0 2 monitors to non-safety related
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- Eliminate requirements for H2 recombiners and Containment Air Dilution (CAD) systems or relax to
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non-safety
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m Update NRC Management 7'
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Licensing Topical Report to eliminate PASS requirements Will submit report to NRC in 4Q00 prior to completion of revised BWR Core Damage Assessment Procedure
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Regulatory Relaxations PASS Current Status/Schedule m Following NRC issuance of SERs regarding WOG and CEOG sample stations, BWROG is drafting
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PASS, H2 Recombiner, H 2/0 2 Monitors, Regulatory Relaxations H2 Recombiner, H2/02 Monitor, CAD System Current Status/Schedule m Deterministic evaluation not successful if core iodine release is in accordance with NUREG-1465
-Detonable gas mixture could occur
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Se6tembe/r 13/2000 BWRG E6C M(eting/
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PASS, H2 Recombiner, H 2/0 2 Monitors,
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H2 Recombiner, H2102 Monitor, CAD System 7/7 Current Status/Schedule (Continued)
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m BWROG will proceed with Licensing Topical Report asking for declassification to non-safety
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based on low probability of events leading to "high iodine concentrations
- Severe accident scenarios only
- Consistent with findings by NRC from risk
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~informing 10CFR50.44 program m Target submittal is 4QO0
/7 Se6tember 13,2/000
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Reportability of RCIC Loss of Function Presentation for BWROG/NRC Management Meeting September 13, 2000 I ---
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Presentation Objective
"* Describe current issues concerning RCIC reportability
"* Describe BWROG effort to evaluate the issue
"* Request NRC action to achieve resolution BWROG/NRC Management Meeting 4
4 September 13, 2000 2
A A
Background
"* A BWR utility recently received a level 4 non cited violation for failure to report RCIC unavailability in accordance with 10 CFR 50.72 4
and 50.73 S*
Several BWR owners have responded to inquiries from NRC inspectors by reporting RCIC unavailability
"* Some BWRs report RCIC unavailability; some do not September 13, 2000 BWROG/NRC Management Meeting 3
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BWROG Evaluation BWROG/NRC Management Meeting 4
4 September 13, 2000
"* BWROG is preparing a white paper explaining why RCIC unavailability is not reportable under 10 CFR 50.72 and 50.73
"* RCIC is a risk-significant system which is adequately controlled by the Maintenance Rule
RCIC Design Function
+ RCIC plays a significant role in the SBO scenario September 13, 2000 BWROG/NRC Management Meeting 5
I 6
September 13, 2000 RCIC Design Function Summary
- RCIC is designed to mitigate Anticipated Operational Occurrences and not Design Basis Accidents BWROG/NRC Management Meeting
U Requested NRC Action
- Defer NRC action to resolve the issue pending review of the BWROG white paper currently scheduled for submittal October 2000 BWROG/NRC Management Meeting IIVA 4
September 13, 2000 7
Flu en ce Methodology Presentation for BWROG/NRC Management Meeting September 13, 2000
Fluence Methodology Purpose of Presentation Discuss concerns regarding recent NRC actions with respect to fluence calculational methodology Gain an understanding of NRC undocumented generic BWR fluence concern 2
BWROG/NRC Management Meeting September 13, 2000
Fluence Methodology Industry Perspective Fluence Methodology is a generic issue for which individual licensees' submittals on P-T curves, power uprates, and capsule deferrals should not be delayed No established near term safety significance Not cost-effective to revise fluence methodology (on a site by site basis) to conform to draft RG
$1OOK to $125K per unit 3
BWROG/NRC Management Meeting September 13, 2000
Fluence Methodology Industry Perspective (Continued)
Potential cost to BWR fleet could be approx. $4.4 Million Given that there are no established safety issues, individual licensee efforts are not warranted The industry desires a cost effective resolution 4
BWROG/NRC Management Meeting September 13, 2000
Fluence Methodology
Background
NRC requesting that BWRs comply with draft RG-1053 fluence methodology for:
Revised P-T curves Dresden: required to use end-of-life fluence, but only valid for 1 fuel cycle (no questions asked for Quad Cities)
Limerick: approved with same interim requirement Power Uprates Browns Ferry: TVA elected not to challenge NRC approach BWRVIP capsule deferral Septemoer 1., zvuV
(1 D'%ATTC)(W\\TTC' NA-Ann Pmpnt Meeting b
Fluence Methodology Current Approaches GE submitted fluence Licensing Topical Report (LTR) for NRC review and approval in August 2000 Includes good agreement with benchmark as required by draft RG Addresses uncertainties as required by RG Expected to resolve NRC concerns for fluence calculations performed by GE BWRVIP is going to address fluence in 2001 as part of Integrated Surveillance Program (ISP) 6 BWROG/NRC Management Meeting September 13, 2000
Fluence Methodology Position Summary Interim fluence methodology restrictions are not necessary Current NRC approach is not cost effective Request NRC support for Complete review of GE LTR on fluence calculations by year end Accept P-T curves and power uprates with no restrictions Grant deferral of capsule removal (with technical justification)
BWROG/NRC Management Meeting September 13, 2000 7
BWR Vessel and Internals Project (BWRVIP) Status Report by Carl Terry, BWRVIP Chairman Niagara Mohawk September 13, 2000 NRC Offices Rockville, MD NRC-9/13/2000 1
BWRVIP !
Assessment Geoge Vanderheyden CornEd Executive Chair Rich Ciemiewicz PECO Energy Tech Chair Bob Carter EPRI Task Mgr NRC-9/13/2000 Ir B
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BWRVIP Organization Carl Terry NMPC Chairman Joe Hagan PECO Energy Vice Chairman ispection Mitigation Repair ill Eaton Lewis Sumner George Jo ntergy SNC PPL xecutive Chair Executive Chair Executive arl Larsen John Wilson Bruce Mc[
T Yankee AmerGen SNC ech Chair Tech Chair Tech Chai reg Selby Raj Pathania Ken Wolfe PRI EPRI EPRI ask Mgr Task Mgr Task Mgr Jack Dillich NPPD BWRVIP Liaison to EPRI Nuclear Power Council 2
)nes Chair
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Integration Harry Salmon NYPA Executive Chair Vaughn Wagoner CP&L Tech Chair Tom Mulford EPRI Task Mgr BWRVIP m
K NRC-9/13/2000 BWRVIP BWRVIP Key 2000 Activities
- Support NRC review and closure on all BWRVIP guidelines Support NRC review of I&E guidelines license renewal appendices Support NRC review of BWR Integrated Surveillance Program (ISP) Plan and produce implementation plan 0
Submit fracture toughness and crack growth evaluations of irradiated stainless steel Coordinate assessment of BWRVIP implementation similar to steam generator assessments Continue complementary BWRVIP and NRC RES work on weldability of irradiated material Continue transition to a maintenance mode I
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BWRVIP Direction in 2000
- Expect closure with NRC on BWRVIP base program guidelines in 2000 BWRVIP transition to a maintenance mode Executive oversight and timely response to industry issues will be maintained continue NRC interaction collection and dissemination of plant inspection data and experience utility implementation assessments implementation, training and assistance program maintenance based on industry experience Streamlined BWRVIP organizational structure will be implemented for 2001 and beyond NRC-9/13/2000 BWRVIP-I 4
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BWRVIP Organizational Structure for 2001 and Beyond BWRVIP Utility Executive Committee I
BWRVIP Maintenance Mode Transition Organization Chairman Vice Chairman V ic Chairma Assessment Commit Executive Chairman Technical Chairman EPRI Task Manager NRC-9/13/2000 ttee Mitigation Committee Intec Executive Chairman Exec Technical Chairman Tech EPRI Task Manager EPR Utility Member as BWRVIP Liaison to EPRI Nuclear Power Council
,ration Oversight
- utive Chairman nical Chairman I Task Manager BWRVIP 5
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BWRVIP Summary
- BWRVIP base program guidelines have been submitted to NRC
- Need to continue close coordination to obtain NRC approval of submitted products.
Concentrated NRC effort requested on:
License renewal appendices Revised GL 88-01 inspection schedules (BWRVIP-75)"
Inspection relief for HWC (BWRVIP-62)
RPV I&E guidelines (BWRVIP-74)
Integrated Surveillance Program (BWRVIP-78)
- BWRVIP issuance of final documents for utility implementation tied to completion/resolution of NRC review NRC-9/13/2000 BWRVIP K
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m4 Tech Spec Instrument Uncertainties Presentation for BWROG/NRC Management September 13, 2000 Washington, DC Meeting S
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Tech Spec Instrument Uncertainties BWROG Committee Objective
"* Proactively resolve NRC concerns with respect to Tech Spec instrument uncertainties
"* Provide guidance for BWRs to manage mS instrument uncertainty to assure that plant safety is maintained J
September 13, 2000 BWROG NRC Meeting 2
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Tech Spec Instrument Uncertainties Presentation Objective m Describe program to NRC management and present preliminary evaluation results SIM
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.I September 13, 2000 BWROG NRC Meeting 3
Tech Spec Instrument Uncertainties Resolution Approach "m "Screen" BWR Standard Tech Spec Surveillance Requirements to eliminate need for consideration of instrument uncertainties "m Qualitative assessment only "m NRC approved industry standard (ASME etc) m "m EOP variables
"* For all other surveillances, margin in BWR safety analyses are compared to.!
instrument uncertainties September 13 2000IBWROGJRCJMeetingI September 13, 2000 BWROG NRC Meeting 4
Tech Spec Instrument Uncertainties Evaluation Results m For non-RG 1.105 parameters, BWR safety analysis margin is sufficient such that no additional instrument uncertainty evaluations are warranted m
m For RG 1.105 parameters, less than 10% of the setpoint evaluations are
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warranted
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'I BWROG NRC Meeting I,
5 September 13, 2000