ML083430107
| ML083430107 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute, Boiling Water Reactor Owners Group, PROJ0669, PROJ0700, PROJ0694 |
| Issue date: | 12/29/2008 |
| From: | Tanya Mensah NRC/NRR/DPR/PSPB |
| To: | Rosenberg S NRC/NRR/DPR/PSPB |
| Mensah T | |
| Shared Package | |
| ML083450606 | List: |
| References | |
| TAC MD4832 | |
| Download: ML083430107 (13) | |
Text
December 29, 2008 MEMORANDUM TO: Stacey L. Rosenberg, Chief Special Projects Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation FROM:
Tanya M. Mensah, Senior Project Manager /RA/
Special Project Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE NOVEMBER 20, 2008, CATEGORY 2 PUBLIC MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) AND INDUSTRY REPRESENTATIVES REGARDING THE NRCS TOPICAL REPORT (TR) PROCESS (TAC NO. MD4832)
On November 20, 2008, a Category 2 public meeting was held between the NRC staff and industry representatives at NRC headquarters to discuss issues regarding TR process improvements. A list of meeting attendees is enclosed and the meeting agenda is contained in the November 20, 2008, public meeting notice available in the Agencywide Documents Access and Management System (ADAMS) as Accession No. ML083150773.
In summary, the NRC staff and industry representatives exchanged perspectives on the following:
A. Limitations and Conditions in NRC TR Safety Evaluations (SEs).
B. Regulatory Treatment of TR Pilot Applications.
C. Publishing the -A (NRC-approved) version of a TR.
D. NRC Disposition of Comments on LIC-500, Draft Revision 4, Processing Requests for Reviews of Topical Reports. In prior public meetings, the NRC staff shared a draft version (redline/strikeout format) of LIC-500, Revision 4, with industry representatives.
Opening remarks were provided by Mr. Tom Blount, Deputy Director, Division of Policy and Rulemaking (DPR), Office of Nuclear Reactor Regulation (NRR). Mr. Blount thanked the NRC staff and industry representatives for its dedication in supporting the monthly TR meetings.
CONTACT: Tanya M. Mensah, NRR/DPR 301-415-3610 Tanya.Mensah@nrc.gov To open the meeting, Ms. Tanya Mensah, Senior Project Manager, provided an update to industry representatives on the near-term priorities that were assigned to DPR. Specifically, Ms. Mensah provided a current status for each of the following near-term priorities:
- 1: DPR should continue its current progress on TR reviews, including its current assessment of LIC-500 by May 30, 2009.
o Current Status: On schedule. The NRC TR Team and industry representatives use the monthly TR meetings to assess and discuss recommended changes to LIC-500. The NRC staff anticipates that all internal and external comments received will be tracked and resolved to support issuance of the revised LIC-500 by May 30, 2009.
- 2: DPR should develop a prioritization/valuation scheme for TRs, including consideration of internal and external views. A draft prioritization scheme developed with implementation plan and presented to the NRR Leadership Team (LT) by May 30, 2009.
o Current Status: On schedule. The NRC TR Team planned internal meetings for the month of December 2008 to discuss the framework for the draft prioritization scheme. The NRC TR Team plan to share the draft scheme with industry representatives during the next monthly TR public meeting.
- 3: DPR to reassess TR metrics for timeliness and resource expenditures, based on the new prioritization/valuation scheme. Provide results of metrics assessment to NRR LT for the first and second quarters following prioritization scheme implementation, but no later than January 30, 2010.
o Current Status: On hold. The NRC TR Team anticipates focusing on this recommendation once the draft prioritization scheme has been presented to the NRR LT in May 2009.
- 4: DPR should establish a process for the assignment of a Technical Champion for the more technically challenging TRs. Include attributes for decision to have Technical Champion in LIC-500 procedure by May 30, 2009.
o Current Status: On schedule. The NRC TR Team planned internal meetings for the month of December 2008 to discuss the framework for the Technical Champion. The NRC TR Team plan to share the framework with industry representatives during the next monthly TR public meeting.
After discussion of the near-term priorities, industry representatives provided a presentation on the following issues:
Limitations and Conditions in NRC TR SE.
Regulatory Treatment of TR Pilot Applications.
Publishing the A (NRC-approved) version of a TR.
Limitations and Conditions: During the meeting, industry representatives provided their statement of the problems that may lead to limitations and conditions being placed in the SE and identified probable causes ranging from review schedules not being extended to support the need for additional justification in the TR to technical disagreements between the TR author and NRC staff reviewers.Section I of the industry handout provides additional detail. The industry representatives asked if the NRC TR Team could review the list of probable causes and provide feedback on them during the next monthly TR public meeting.
To summarize the discussion, the NRC management commented that limitations and conditions are identified by the NRC staff when necessary to ensure an adequate safety basis in the TR SE. In addition, the NRC technical reviewers dont always know that there will be limitations or conditions until the technical review is complete. Industry representatives responded that they recognize the need for limitations and conditions in TR SEs; however, they think the TR process could be improved if the NRC TR Team could create earlier opportunities for them to address anticipated limitations and conditions. Where applicable, this would provide the TR authors with additional time to try to resolve technical issues, to preclude the need for limitations and conditions in the SE. During the discussion, the NRC TR Team asked if industry representatives could provide actual examples that illustrate where the TR author was successful in resolving potential limitations and conditions during the review, and other cases where the TR author may have been surprised by limitations and conditions in the TR SE. The industry representatives agreed to develop this partial list of TRs to discuss with the NRC TR Team in a future monthly public meeting.
In addition, to address the concern of providing earlier opportunities to industry representatives to address potential TR limitations and conditions, the NRC TR Team proposed revisions to the TR process to convey anticipated limitations and conditions in any requests for additional information (RAIs). For example, the RAI would clearly state that if additional/sufficient justification is not provided in the RAI response, that the NRC may consider adding a limitation or condition in the TR SE. This would inform industry representatives early on of the need for enhanced communication on specific technical issues that could potentially lead to a limitation or condition in the TR SE. The NRC TR Team will consider this and discuss with industry representatives during a future TR monthly meeting.
As an administrative issue, industry representatives noted that LIC-500 currently uses the terms limitations and conditions interchangeably. The NRC TR Team agreed that the correct use of these terms should be noted throughout LIC-500 as limitations and conditions and that this change would be made in LIC-500 to ensure consistency.
Publishing of the -A (approved) version of the TR: During the meeting, industry representatives provided their feedback that the NRCs formal review of the TR should end once the final SE is issued to the vendor or owners group. Additional detail is provided in Section III of the industry handout. The industry representatives agreed that it is the responsibility of the TR author to ensure that the approved version of the TR properly reflects the NRC staffs SE and that the vendor or owners group should not be billed if the NRC staff decides to review the approved version of the TR. The NRC TR Team agreed to follow up with the Office of Chief Financial Officer to determine how audits of the approved version of the TR have been conducted in the past. This feedback will be shared at a future TR monthly public meeting.
In response to the industry presentation, NRC management noted that there is variability among industry in the form that the approved version of a TR is issued. Due to the complexity of the TR and the number of proposed changes/markups to the TR, the NRC staff may sometimes request that the approved TR be submitted for NRC staff review prior to issuance of the final SE. This is to ensure that the approved TR is user-friendly for the licensee referencing it and that limitations and conditions in the NRC staffs final SE are properly reflected in the approved version of a TR.
Industry representatives clarified that the current process is for the vendor or owners group to attach the TR SE behind the title page of the approved TR, without making changes to the TR.
So a licensee reviewing the approved version, has to also read the TR SE, to determine if the TR was approved with changes or if there were limitations and conditions that would limit its use by the licensee. The industry representatives clarified that they would make changes to the approved TR, if the SE states that the TR should be revised to reflect changes as noted in the TR SE.
For a future meeting, the NRC TR Team thought that it would be a good idea to discuss how new technical information impacts previously NRC-approved TRs. The industry representatives agreed that this was an important topic and identified that is it already being pursued in a broader context through their interactions with the NRR Lessons Learned Task Force.
Pilot Plant Applications: During the meeting, industry representatives provided a flow chart (Section II of the industry handout) to the NRC TR Team which demonstrated how a TR could be reviewed in parallel with a pilot plant application. The NRC TR Team provided preliminary feedback that it would be interested in supporting pilot plant applications for TRs; however, there are some internal discussions that need to occur to better align the metrics for license amendments and TRs to support a pilot plant application.
The NRC TR Team plans to prepare a flow chart to demonstrate how this process may work and will share with industry representatives during a future public TR meeting. In addition, the NRC TR Team identified that LIC-109, Acceptance Review Procedure, may need to be revised so that a pilot-plant license amendment request (LAR) can reference an unapproved TR. Currently, the NRC staffs internal guidance does not permit a licensee to reference an unapproved TR in a LAR.
Industry Feedback on LIC-500, Draft Revision 4: With the remaining meeting time, the industry representatives guided the NRC TR Team through some of their comments on LIC-500, Draft Revision 4.Section IV of the industry meeting handout provides a listing of the comments that are still open for additional discussion during future TR monthly meetings.
The industry handout is available in ADAMS as Accession No. ML083390367.
The next TR public meetings are currently planned for January 8 and February 19, 2008. A separate meeting notice for each meeting will be issued with additional detail.
No members of the public were in attendance. No public meeting feedback forms were received.
Project Nos. 669, 689, 691, 694, and 700
Enclosure:
List of Attendees cc w/encl: See next pages
ML083450606 (Package); ML083150773 (Notice); ML083390367 (Handouts); ML083430107 (Summary) NRC-001 OFFICE PSPB/PM PSPB/LA PSPB/BC NAME TMensah DBaxley SRosenberg DATE 12/29/08 12/29/08 12/29/08 Memo to Stacey L. Rosenberg from Tanya M. Mensah dated December 29, 2008
SUBJECT:
SUMMARY
OF THE NOVEMBER 20, 2008, CATEGORY 2 PUBLIC MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) AND INDUSTRY REPRESENTATIVES REGARDING THE NRCS TOPICAL REPORT PROCESS DISTRIBUTION:
PUBLIC PSPB Reading File RidsNrrAdro RidsNrrDpr RidsNrrDprPspb RidsNrrLADBaxley RidsNrrPMTMensah RidsOpaMail RidsNrrDe MCase RJanski CGratton KKarwoski EBowman RElliott MCase TMcGinty SRosenberg WReckley JKaiser TBlount MRubin TMendiola HCruz GCranston JDonoghue TFord SPhilpott WRuland JLubinski MHoncharik VPerin CTucci RidsOgcMailCenter RidsAcrsAcnwMailCenter External Email:
mas@nei.org Frederick.emerson@ge.com Gayle.elliott@areva.com
List of Meeting Attendees for November 20, 2008 Tom Blount NRC Charles Brinkman Westinghouse Dennis Buschbaum PWROG/Luminant Douglas Coleman BWROG/Energy Northwest Gayle Elliott AREVA Tanya Ford NRC Chris Gratton NRC Chad Holderbaum Westinghouse/PWROG Ken Huffman EPRI Ken Karwoski NRC Tony Mendiola NRC Tanya Mensah NRC Tony Nakanishi NRC Stacey Rosenberg NRC Mark Rubin NRC Mike Schoppman NEI ENCLOSURE
Nuclear Energy Institute Project No. 689 Electric Power Research Institute Project No. 669 cc:
Mr. Anthony Pietrangelo, Vice President Regulatory Affairs Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 arp@nei.org Mr. Jack Roe, Director Operations Support Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 jwr@nei.org Mr. Charles B. Brinkman Washington Operations ABB-Combustion Engineering, Inc.
12300 Twinbrook Parkway, Suite 330 Rockville, MD 20852 brinkmcb@westinghouse.com Mr. James Gresham, Manager Regulatory Compliance and Plant Licensing Westinghouse Electric Company P.O. Box 355 Pittsburgh, PA 15230-0355 greshaja@westinghouse.com Ms. Barbara Lewis Assistant Editor Platts, Principal Editorial Office 1200 G St., N.W., Suite 1100 Washington, DC 20005 Barbara_lewis@platts.com Mr. Alexander Marion, Executive Director Nuclear Operations & Engineering Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 am@nei.org Mr. John Butler, Director Safety-Focused Regulation Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 jcb@nei.org Mr. James H. Riley, Director Engineering Nuclear Energy Institute 1776 I Street, NW Washington, DC 20006-3708 jhr@nei.org Mike Melton, Senior Project Manager 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 man@nei.org Mr. Chris Larsen Vice President and Chief Nuclear Officer EPRI 3412 Hillview Avenue Palo Alto, CA 94304-1338 dblarsen@epri.com Mr. David J. Modeen Director, External Affairs EPRI 1300 W. T. Harris Boulevard Charlotte, NC 28262-8550 dmodeen@epri.com Dr. Sean Bushart EPRI 3412 Hillview Avenue Palo Alto, CA 94304-1338 sbushart@epri.com Mr. Kurt Edsinger EPRI 3412 Hillview Avenue Palo Alto, CA 94304-1338 kedsinge@epri.com
Mr. Ken Canavan EPRI 1300 W.T. Harris Boulevard Charlotte, NC 28262-8550 kcanavan@epri.com Mr. Greg Selby EPRI 1300 W. T. Harris Boulevard Charlotte, NC 28262-8550 gselby@epri.com Mr. David Steininger EPRI 3412 Hillview Avenue Palo Alto, CA 94304-1338 dstenin@epri.com Mr. Neil Wilmshurst EPRI 1300 W. T. Harris Boulevard Charlotte, NC 28262-8550 nwilmshu@epri.com
BWR Owners= Group Project No. 691 Mr. Doug Coleman Vice 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 richard_l_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 Regulatory Response Group Chair BWR Owners= Group DTE Energy-Fermi 2 200 TAC 6400 N. Dixie Highway Newport, MI 48166 conenj@dteenergy.com Frederick Emerson BWROG, Project Manager Frederick.emerson@ge.com Mr. J. A. Gray, Jr.
Regulatory Response Group Vice-Chair BWR Owners= Group Entergy Nuclear Northeast 440 Hamilton Avenue Mail Stop 12C White Plains, NY 10601-5029 JGray4@entergy.com Mr. Ken A. McCall, Program Manager GE Energy M/C F12 3901 Castle Hayne Road Wilmington, NC 28401 kenneth.mccall@ge.com Mr. Tim E. Abney GE Energy M/C A-16 3901 Castle Hayne Road Wilmington, NC 28401 tim.abney@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 Dennis Madison, Hatch Vice President Southern Nuclear Operating Co.
11028 Hatch Parkway North Baxley, GA 31515-2010 drmadiso@southernco.com
PWR Owners Group Project No. 694 Westinghouse Electric Project No. 700 cc:
Mr. James A. Gresham, Manager Regulatory Compliance and Plant Licensing Westinghouse Electric Company P.O. Box 355 Pittsburgh, PA 15230-0355 greshaja@westinghouse.com Mr. Gordon Bischoff, Manager Owners Group Program Management Office Westinghouse Electric Company P.O. Box 355 Pittsburgh, PA 15230-0355 gordon.c.bischoff@us.westinghouse.com
GHNE Project No. 710 cc:
Mr. George B. Stramback GE-Hitachi Nuclear Energy Americas LLC 1989 Little Orchard Street M/C HME San Jose, CA 95125-1030 george.stramback@ge.com Mr. James F. Harrison GE-Hitachi Nuclear Energy Americas LLC Project Manager - Fuel Licensing P.O. Box 780 M/C A45 Wilmington, NC 28401 james.harrison@ge.com Ms. Patricia L. Campbell Washington Regulatory Affairs Director GE-Hitachi Nuclear Energy Americas LLC 1299 Pennsylvania Avenue, NW 9th Floor Washington, DC 20004 patricia.campbell@ge.com Mr. Andrew A. Lingenfelter Manager, GNF Fuel Engineering P.O. Box 780 M/C F12 Wilmington, NC 28401 andy.lingenfelter@gnf.com Rick Kingston GE-Hitachi Nuclear Energy Americas LLC Project Manager, Methods Licensing 3901 Castle Hayne Road PO Box 780 Wilmington, NC 28401-0780 rick.kingston@ge.com James A Ross Vice President GE - Hitachi Nuclear Energy Americas LLC Washington Regulatory Affairs 1299 Pennsylvania Ave. NW Suite 900 Washington, DC 20004 james2.ross@ge.com Mr. Robert E. Brown Senior Vice President, Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC P. O. Box 780, M/C A-30 Wilmington, NC 28401 Bob.Brown@ge.com