ML090220097
| ML090220097 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute, Boiling Water Reactor Owners Group, PROJ0669, PROJ0700, PROJ0694 |
| Issue date: | 02/04/2009 |
| From: | Tanya Mensah NRC/NRR/DPR/PSPB |
| To: | Rosenberg S NRC/NRR/DPR/PSPB |
| Mensah T | |
| Shared Package | |
| ML090230425 | List: |
| References | |
| TAC MD4832 | |
| Download: ML090220097 (15) | |
Text
February 4, 2009 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 JANUARY 8, 2009, 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 January 8, 2009, 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 January 8, 2009, public meeting notice available in the Agencywide Documents Access and Management System (ADAMS) as Accession No. ML083430151.
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. NRC Review/Audits of the -A (NRC-approved) Version of a TR.
D. Future Public Meeting Dates Opening remarks were provided by Mr. Tim McGinty, Director, Division of Policy and Rulemaking (DPR), Office of Nuclear Reactor Regulation (NRR). Mr. McGinty thanked the NRC staff and industry representatives for its continued support of the monthly TR meetings. He also emphasized the importance of these meetings as DPR moves forward to issue revised guidance on the TR process by May 2009.
CONTACT: Tanya M. Mensah, NRR/DPR 301-415-3610 Tanya.Mensah@nrc.gov
S. Rosenberg To open the meeting, Ms. Tanya Mensah, Senior Project Manager, provided an update to the 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 TR Team 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 reported that it had several internal meetings planned for the month of January 2009 to further discuss the framework for the draft prioritization scheme. As a result, the NRC TR Team was not able to share the draft scheme with industry during the January 2009 public meeting. The NRC TR Team plans to share the draft scheme with industry representatives during the February 2009 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 a Technical Champion in LIC-500 procedure by May 30, 2009.
o Current Status: On schedule. Mr. Ken Karwoski, the NRC TR Team lead for this recommendation, shared the framework for the Technical Champion during the January 2009 public meeting (ADAMS Accession No. ML090220069). The industry representatives provided some overall positive feedback on the conceptual framework; however, they had some questions regarding industry use of this process. Specifically, the industry representatives were seeking to clarify if they could raise TR issues to NRC senior management through this Technical Champion process. The NRC TR Team clarified that currently, this process is an internal initiative to help the NRC staff identify and elevate TR issues or differing internal views to senior management when it involves complex, technical or policy issues that are being reviewed by multiple NRC organizations. In addition, the industry representatives asked if the NRC TR Team could clarify some of the
S. Rosenberg attributes or factors that would help the NRC staff to determine when a senior lead should be involved to facilitate discussion on a TR. The NRC TR Team plans to discuss this internally and provide additional feedback to the industry representatives in a future public meeting.
After discussion of the near-term priorities, industry representatives provided a presentation on the following issue:
Limitations and Conditions in NRC TR SE.
The NRC TR Team provided a presentation on the following issues:
Regulatory Treatment of TR Pilot Applications (flow diagram).
NRC Review/Audits of the -A (NRC-approved) Version of a TR.
Limitations and Conditions: During the November 2008 public meeting, the 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. The industry representatives asked if the NRC TR Team could review the list of probable causes and provide feedback on them during the January 2009 monthly TR public meeting.
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 shared a partial list of TRs during the January 2009 public meeting (ADAMS Accession No. ML090220069).
The industry presentation identified a sample of TRs where limitations and conditions had no impact, moderate impact, or a significant impact in terms of reducing the value of the TR by reducing its scope of applicability and/or increasing the difficulty of implementation. The industry presentation also focused on a number of recommendations to ensure that limitations and conditions are raised/identified as early as possible in the NRC staffs review process. One of the key recommendations discussed was that the revised version of LIC-500 should include language to increase the awareness of the potentially significant impact of limitations and conditions. Specifically, the industry representatives recommended that LIC-500 include guidance to reviewers to identify and communicate limitations and conditions early-on as one of the objectives in LIC-500 and provided suggested words for NRC TR Team consideration. The NRC TR Team will consider this recommendation and provide additional feedback to NEI during the February 2009 public meeting.
Publishing of the -A (approved) version of the TR: During the meeting, the NRC TR Team provided feedback to the industry representatives regarding how audits of the approved version of the TR have been conducted in the past. Specifically, the NRC TR Team discussed how its audit of the approved version of the TR would be fee-billable if the TR review itself was fee-billable. The industry representatives maintained their position that after the NRC staff issues its TR Final SE, that the review should be complete. The industry representatives also proposed that in lieu of auditing the TR,that the NRC could request that the approved
S. Rosenberg version of the TR be submitted to the NRC under oath and affirmation to ensure that TR limitations and conditions in the TR SE will be captured in the approved version of the TR. The NRC TR Team plan to meet internally to discuss this proposal and will provide feedback during a future TR monthly public meeting.
During the November 2008 public meeting, the 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.
Pilot Plant Applications: The NRC TR Team discussed its draft flow chart (ADAMS Accession No. ML090220095) to demonstrate how this process may work. 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. Additional internal discussions with the TR Team and NRC management will be held on this topic.
Industry Feedback on LIC-500, Draft Revision 4: The industry representatives did not have any feedback on LIC-500, Draft Revision 4; however, they stated that they will have additional comments during the February 2009 public meeting. In addition, they stated that they were in agreement with the changes made as a result of the November 2008 public meeting (captured in green text within LIC-500, Draft Revision 4).
Future Public Meetings: The industry representatives proposed future meeting dates for March and April 2009. The NRC TR Team is considering these dates and will provide confirmation to the industry representatives during, or prior to, the next monthly TR public meeting.
The industry handout is available in ADAMS as Accession No. ML090220069.
The NRC handouts are available in ADAMS as Accession Nos. ML090220084 and ML090220095.
The next TR public meeting is currently planned for February 19, 2009. A meeting notice will be issued with additional detail.
Two members of the public were in attendance. One public meeting feedback form was received. One member of the public commented during the meeting that the NRR TR process was too complicated to follow and he felt that the NRO TR process was clear and easier to use.
He expressed that the NRR staff should work closely with NRO so that the two TR processes are aligned. The member of the public also discussed how potential limitations and conditions can be raised and resolved (as done in NRO) through the implementation of a weekly telephone call with the vendor or owners group. Finally, the member of the public asked that we re-examine our proposed approach for pilot plant amendments.
S. Rosenberg He explained that the process was more complicated than the flow diagram showed. The NRC TR Team thanked the member of the public for his comments before concluding the meeting.
Project Nos. 669, 689, 691, 694, and 700
Enclosure:
List of Attendees cc w/encl: See next pages
ML090230425 (Package); ML083430151 (Notice); ML090220069, ML090220084, ML090220095 (Handouts); ML090220097 (Summary) NRC-001 OFFICE PSPB/PM PSPB/LA PSPB/BC NAME TMensah DBaxley SRosenberg DATE 1/29/09 1/29/09 2/04/09 List of Meeting Attendees for January 8, 2009 Tim Abney GE Hitachi George Bacuta NRC Charles Brinkman Westinghouse Dennis Buschbaum PWROG/Luminant Jin W. Chung MNES Douglas Coleman BWROG/Energy Northwest Holly Cruz NRC Chris Gratton NRC Chad Holderbaum Westinghouse/PWROG Tim Houghton NEI Andrew Howe NRC Ken Karwoski NRC Masrur Khan Bechtel Tim McGinty NRC Tony Mendiola NRC Tanya Mensah NRC Vanice Perin NRC Stephen Philpott NRC Stacey Rosenberg NRC Mike Schoppman NEI Joe Williams NRC 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 Security 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 Vice President (Acting)
Nuclear Operations & Engineering Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 am@nei.org Mr. John Butler, Director Operations Support 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 Chairman, 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
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
NEI Handout ML090220069 Dated: February 4, 2009
Technical Champion Flowchart Diagram ML090220084 Dated: February 4, 2009
Draft Flowchart for Topical Reports Reviews ML090220095 Dated: February 4, 2009