ML083240461
| ML083240461 | |
| Person / Time | |
|---|---|
| Site: | Boiling Water Reactor Owners Group |
| Issue date: | 11/26/2008 |
| From: | Michelle Honcharik NRC/NRR/DPR/PSPB |
| To: | Rosenberg S NRC/NRR/DPR/PSPB |
| Michelle Honcharik, 415-1774 | |
| Shared Package | |
| ML083260102 | List: |
| References | |
| TAC MB5757 | |
| Download: ML083240461 (9) | |
Text
November 26, 2008 MEMORANDUM TO:
Stacey L. Rosenberg, Chief Special Projects Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation FROM:
Michelle C. Honcharik, Senior Project Manager /RA/
Special Projects Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF NOVEMBER 5, 2008, OPEN MEETING WITH THE BOILING WATER REACTOR (BWR) OWNERS' GROUP (BWROG)
WITH SENIOR MANAGEMENT (TAC NO. MB5757)
On November 5, 2008, a Category 2 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of the BWROG at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to develop common understanding between the Office of Nuclear Reactor Regulation (NRR) senior management and the BWROG executive members of topics discussed and reach agreement and common understanding of any actions assigned and associated due dates.
Members of the public were in attendance. Public Meeting Feedback forms were not received.
Introductions
A complete list of attendees is enclosed. The BWROG handouts are available in the Agencywide Documents Access and Management System as ML083260470.
Opening Remarks Mr. Bruce Boger (NRC), Associate Director for Operating Reactor Oversight and Licensing, welcomed the group. He explained NRC has focused on timeliness of Topical Report (TR) reviews, including reducing backlog, improving efficiency, maintaining schedules, and working to understand impact of delays on industry schedules. Currently, there are 43 TRs submitted for NRC review. Mr. Boger stressed the use of pre-submittal meetings to achieve alignment.
Mr. Rich Anderson (FPL Energy), BWROG Executive Chairman, provided an overview of the BWROG mission, organization, leadership, and industry interactions. In addition, Mr. Anderson stressed the value of the Consolidated Line Item Improvement Process (CLIIP) and encouraged continued NRC support of this program.
Mr. Anderson also provided a brief summary of the division of responsibility between the BWROG and the BWR Vessel Internals Program (BWRVIP). Mr. Libra included that the executives on the oversight committees are common between the two but different Chair and Vice Chairs.
Schedule/Process Review of Selected Submittals Mr. Doug Coleman (Energy Northwest (ENW)), BWROG General Chairman, provided a current status of BWROG TR submittals. The following TR reviews were reported as on schedule by the BWROG:
NEDO-33349 Revision 1, "BWR Application to Regulatory Guide 1.97 Revision 4,"
NEDC-33178P, Revision 0, General Electric Methodology for Development of Reactor Pressure-Temperature Curves, and NEDE-33213P, "ODYSY Application for Stability Licensing Calculations Including Option I-D and II Long Term Solutions."
The following two TR reviews were reported as delayed schedule by the BWROG:
RITS 4a/6b and NEDC-33347P, "Containment Overpressure Credit for Net Positive Suction Head (NPSH)."
Ms. Stacey Rosenberg (NRC), Special Projects Branch Chief, questioned how NEDC-33178P could be considered on schedule when it had exceeded the two-year review period.
Ms. Rosenberg commented that in the future, the NRC and industry need to set a new schedule when delays occur and not continue to work without a defined scheduled. Mr. Coleman (ENW) stated that the BWROG would work with the NRC staff on setting new schedules.
Mr. Jack Grobe (NRC), Associate Director for Engineering and Safety Systems, questioned how many times the BWROG receives multiple Requests for Additional Information (RAIs) and what do they think are the reasons?
Mr. Coleman (ENW) responded that the BWROG feels they usually do receive multiple rounds of RAIs and the reason can vary including: lack of alignment with staff, change in reviewers, and poor quality of original submittals and responses, etc. The BWROG has been holding RAI response teleconferences with NRC staff to ensure that the BWROG responses will meet the mark.
The BWROG's target date to submit the TRs RITs 4a/6b has been moved to May 2009. They are awaiting NRC review of the PWROG TR since the same resources can be used to address the BWROG TR. During the meeting there was some confusion as to what the May 2009 date represented - whether this date was the RAI issuance for the PWROG TR or the draft safety evaluation (SE). It was confirmed after the meeting that the May 2009 date is the target date for issuance of the draft SE of the PWROG TR.
NEDC-33347P was reported as delayed. The final RAIs were expected by November 7 in order to support a December BWROG committee meeting for review. Ms. Michelle Honcharik (NRC),
Senior Project Manager, reported that draft RAIs for containment overpressure were sent to the BWROG Project Manager on November 5, with final RAIs issued by November 26, in time to support the BWROG meeting.
Review of Industry Issues Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems.
Mr. Anderson (FPL) provided an update on BWROG efforts to support the industry in addressing GL 2008-01. The Gas Accumulation Team (GAT) has coordinated the industry response to the GL. The GAT is made up of industry leaders including the BWROG and PWROG Chairmen and NEI. The BWROG has created several products to assist utilities in addressing the GL response. In addition the BWROG and PWROG have collaborated on several common products. The next major step will be to conduct a decision-making analysis to evaluate the existing suction-side void criteria. Another industry workshop is tentatively scheduled for Spring 2009.
Mr. Grobe (NRC) asked if the industry 9-month letters were complete in their responses to GL 2008-01. Mr. Rich Anderson (FPL Energy) indicated that not all stations were able to complete all actions as indicated in the 3-month response letters. Mr. Jared Wermiel (NRC),
Division of Safety Systems Deputy Director, indicated that his staff is reviewing the responses and would be providing a briefing to Mr. Grobe on the level of completion shortly.
BWR Emergency Core Cooling System (ECCS) Suction Strainers Mr. Rick Libra (Exelon), BWROG Executive Vice Chairman, provided an update on the BWROG activities on ECCS Suction Strainers. The NRC staff has identified differences in treatment of containment strainer/sump clogging technical issues for BWRs and PWRs. These differences, first discussed in an internal white paper, were subsequently documented in a letter to the BWROG dated April 10, 2008. The BWROG is implementing a three-year plan to address these issues.
The BWROG has held several management and technical staff meetings with the NRC staff since the June 4, 2008, management meeting. The BWROG has funding in place for the following projects in 2008, which are already underway:
Assessment of Fuel Blockage Assessment of BWROG URG (NEDO-32686-A) vs. NEI 04-07 Evaluation of Design-Basis Accident (DBA) Qualification of Coatings & Debris Guidelines for containment walkdowns Mr. Libra reviewed the resolution logic plan with the NRC staff which focuses on debris source terms, head loss correlations, downstream effects of debris including fuel and components.
Mr. Libra also provided a preview of proposed future activities including:
Downstream Effects: Adaption of WCAP-16406 for BWRs Testing for impacts on fuel (blockage and chemical effects) if required Surveys of industry practices Debris Source Term - finalization and application Downstream Effects on components Strainer head loss correlations The BWROG expects to continue periodic meetings with the NRC staff and share results of activities (first will be containment walkdown guidelines). In addition, the BWROG is soliciting commitments from members on implementation of the walkdown guideline and timeframe.
Mr. James Wiggins (NRC), Office of Nuclear Reactor Regulation Deputy Director, questioned if the BWROG is able to obtain, and if so are they using, information from international tests.
Mr. Coleman (ENW) replied the BWROG has obtained some of the reports and they are using them during the evaluations. Mr. Wiggins commented that both sides need to keep the communication open to ensure that we all have the same set of data. Mr. Grobe stated that the BWROG and NRC staffs need to address this information during their meetings.
Motor Operated Valve (MOV) Magnesium Rotor Failures Mr. Anderson (FPL Enery) provided insights on current BWROG Valve Technical Resolution Group (VTRG) efforts to address concerns with MOV magnesium rotor failures. The VTRG has drafted guidelines for its members and plans to issue them in January 2009. Guidelines include:
MOV prioritization method and associated schedule Borescope inspection criteria Motor disassembly instructions and inspection criteria Equipment qualification considerations Installation of motor inspection ports Spare part requirements for motor disassembly Mr. Grobe (NRC) questioned how this issue began within the BWROG. Mr. Anderson (FPL Energy) explained that a plant raised the issue to the BWROG and the VTRG committee took action to develop a plan to resolve. Mr. Grobe (NRC) asked if the PWRs were addressing the issue and was the BWROG working with the PWROG. Mr. Libra indicated the BWROG had shared the intent of its efforts with the PWROG.
Ms. Michele Evans (NRC), Division of Component Integrity Director, commented that the NRC was working on a similar effort and had shared information with the Licensing Action Task Force (LATF), but they were unaware of the BWROG's efforts until today. Mr. Grobe wanted to avoid duplicate efforts and asked if there was a better way to communicate current activities.
Mr. Ken McCall (GEH), BWROG Program Manager, explained that the BWROG has over 40 technical committees currently underway and that an external website is available which has an executive summary of the activities of each committee and a listing of contacts for information (www.bwrog.org, select "Committee Exec Summaries"). Mr. Grobe suggested that the BWROG periodically provide a brief summary of technical committee activities to the NRC.
Review of NRC Concerns The MOV magnesium rotor failure concerns were already discussed during the BWROG presentation.
Topical Report Working Group Update Ms. Honcharik (NRC) commented that the last meeting in October went well, during which all the comments on LIC-500 by the industry were discussed. The NRC staff is looking forward to next meeting on November 20, 2008.
Additional Remarks Mr. Coleman (ENW) discussed that the BWROG has conducted a root cause of the withdrawal of the Option 3 (LOOP/LBLOCA separation) TR. The root cause analysis identifies opportunities for both the BWROG and NRC staff to ensure better alignment on future TRs.
The NRC management requested these lessons be shared with NRC through their project manager.
Mr. Wiggins (NRC) added that the NRC staff is committed to not having longstanding issues.
Issues must be resolved in a reasonable amount of time and decisions made with the best information available at the time. Mr. Wiggins (NRC) explained that NRC is changing direction in that they will not automatically accept TRs for review. The new acceptance review process (LIC-109) must apply scrutiny up-front to ensure the NRC staff can complete the review within the timelines. Mr. Wiggins commented that accepting everything causes long-standing issues to develop.
Mr. Grobe (NRC) commented that NRR has implemented a rigorous qualification program for its technical reviewers and project managers, which should also help to prevent long-standing issues. The next step is to investigate why there are multiple rounds of RAIs, because this will improve efficiency.
Ms. Rosenberg (NRC) added that good pre-submittal meetings can also help avoid multiple rounds of RAIs and long-standing issues. She suggested that both sides share meeting summaries and actions items at the end of pre-submittal meetings to be sure we have common understanding.
Mr. Grobe (NRC) explained that NRC management is evaluating the relationship between new plants and operating plants regarding the licensing process and how to handle the review of TRs that are applicable to both. The completion of a TR review is different because of the Title 10 of the Code of Federal Regulations Part 50 process. An office instruction is in development to better handle these situations.
Closing Remarks Mr. Wiggins (NRC) stated that he appreciated todays discussion and presentations. He re-iterated the NRCs commitment to not create long-standing issues and added that the NRC staff may have to add margins to offset uncertainties, in lieu of waiting for more information.
Mr. Wiggins also stated that he wants to make sure that the NRC staff is alerted by the BWROG of any new technologies and new technical issues they are working. He explained the reason is so NRR can engage The Office of Regulatory Research and prepare for the review.
It is not the NRC staffs job to develop data to support applications using new technologies.
Rather gathering data and benchmarking are the industrys responsibility. The NRC staff does applied research to prepare the NRC staff and support applications.
Public Comments Ms. Deann Raliegh of Scientech asked about the status of the procedures for joint The Office of New Reactors and NRR TR reviews. Mr. Boger and Mr. Grobe (NRC) answered that the office instruction for technical consistency has been issued. A second office instruction which will in part detail how the two offices perform a joint review from an administrative standpoint is still being written.
Mr. Steven Dolley of Platts asked about the backlog of TRs over 2 years old in previous years.
Mr. Boger (NRC) answered that in 2006 - 33 percent were greater than 2 years old, in 2007 - 14 percent were over 2 years old, and in 2008 - only 7 percent were over 2 years old. Mr. Dolley asked if there were similar statistics for RAIs, because it was mentioned during the meeting that the NRC wants to reduce the number of RAIs. Mr. Grobe (NRC) clarified that the NRCs goal is not to reduce the number of RAIs. Our goal is to perform more efficient reviews, which if the NRC staff can ask all necessary questions in one round of RAIs, would improve efficiency and shorten review time. In answer to Mr. Dolleys question - no there is not any historical data regarding the rounds of RAIs.
Please direct any inquiries to me at 301-415-1774, or michelle.honcharik@nrc.gov.
Project No. 691
Enclosure:
List of Attendees cc w/encl: See next page
(s): ML083260102 (Package); ML083240461 (Summary);
ML082950614 (Notice); ML083260470 (Handouts)
NRC-001 OFFICE PSPB/LA PSPB/PM PSPB/BC NAME DBaxley MHoncharik SRosenberg DATE 11/25/08 11/25/08 11/26/08
ENCLOSURE List of Attendees NRC M. Honcharik S. Rosenberg M. Cunningham J. Grobe B. Boger M. Evans P. Hiland J. Wermiel T. Blount J. Wiggins F. Brown BWROG R. Anderson R. Libra D. Coleman K. McCall F. Emerson T. Schiffley Public D. Raleigh P. Campbell S. Dolley T. Dow W. McConaghy
8/6/08 BWR Owners= Group Project No. 691 Mr. Doug Coleman Chair, BWR Owners= Group Energy Northwest Columbia Generating Station Mail Drop PE20 P.O. Box 968 Richland, WA 99352-0968 DWCOLEMAN@energy-northwest.com Mr. Richard Libra Executive Vice Chair, BWR Owners= Group Exelon Generation Co, LLC 200 Exelon Way Mail Code KSA 2-N Kennett Square, PA 19348 Rick.libra@exeloncorp.com Mr. Richard Anderson BWROG, Executive Chair FPL Energy (DAEC)
Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 rich.anderson@fpl.com Mr. James F. Klapproth GE-Hitachi Nuclear Energy M/C A50 3901 Castle Hayne Road Wilmington, NC 28401 james.klapproth@ge.com Mr. Joseph E. Conen, Vice Chair Regulatory Response Group BWR Owners= Group DTE Energy-Fermi 2 200 TAC 6400 N. Dixie Highway Newport, MI 48166 conenj@dteenergy.com Dennis Madison, Hatch Vice President Southern Nuclear Operating Co.
11028 Hatch Parkway North Baxley, GA 31515-2010 drmadiso@southernco.com Frederick Emerson BWROG, Project Manager Frederick.emerson@ge.com Mr. Ken A. McCall, Program Manager GE-Hitachi Nuclear Energy M/C F12 3901 Castle Hayne Road Wilmington, NC 28401 kenneth.mccall@ge.com Oscar Limpias Entergy Nuclear Northeast 1340 Echelon Parkway.
Jackson, MS 39213-8202 olimpia@entergy.com Joe Donahue Progress Energy Inc.
410 S. Wilmington St.
PEB 6A Raleigh, NC 27601-1849 joe.w.donahue@pgnmail.com Paul J. Davison Hope Creek Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038 paul.davison@pseg.com Mr. Ted Schiffley Vice Chairman, BWROG Exelon Generation Co., LLC.
Cornerstone II at Cantera 4300 Winfield Road Warrenville, IL 60555 frederick.schiffley@exeloncorp.com Mr. Randy C. Bunt, Chair Regulatory Response Group Southern Nuclear Operating Company 40 Inverness Center Parkway/Bin B057 Birmingham, AL 35242 rcbunt@southernco.com