ML15260A731
| ML15260A731 | |
| Person / Time | |
|---|---|
| Site: | Boiling Water Reactor Owners Group |
| Issue date: | 10/30/2015 |
| From: | James Drake Licensing Processes Branch (DPR) |
| To: | Anthony Mendiola Licensing Processes Branch (DPR) |
| Drake J | |
| References | |
| Download: ML15260A731 (6) | |
Text
October 30, 2015 MEMORANDUM TO: Anthony J. Mendiola, Chief Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation FROM:
Jason J. Drake, Project Manager
/RA/
Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JUNE 24, 2015, DROP-IN MEETING WITH THE BOILING WATER REACTOR OWNERS GROUP FINITE BREAK OPENING TIME COMMITTEE On June 24, 2015, the U.S. Nuclear Regulatory Commission (NRC) staff met with representatives of the Boiling Water Reactor Owners Group (BWROG) Finite Break Opening Time (FBOT) Committee in a public meeting at NRC headquarters in Rockville, Maryland. The enclosure provides a list of those in attendance. Presentation materials can be found in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML15212A696.
The June 24, 2015, public meeting follows the March 9, 2015, drop-in meeting with the FBOT Committee (ADAMS Accession No. ML15133A346). The BWROG requested the public meeting to inform the NRC staff of its conclusion that the application of FBOT for evaluation of Acoustic Circuit (AC) loads and Annulus Pressurization (AP) loads by Licensees for Design Basis Accident Loads can be addressed under Title 10 of the Code of Federal Regulations (10 CFR) 50.59. Staff comments and BWROG FBOT Committee responses are cited below.
Staff Comments:
- 1. The NRC staff inquired if the BWROG had conducted a survey to determine if an instantaneous break opening time assumption was included and/or required in any licensees design basis analysis.
BWROG Response: The BWROG representatives indicated that they had not performed a survey requesting this data. It was identified that within the literature search performed, no required assumptions of instantaneous separation were found.
CONTACT: Jason Drake, NRR/DPR 301-415-8378 Jason.Drake@nrc.gov
- 2. The NRC staff asked if the BWROG had identified any adverse effects of its approach on the existing BWR design basis.
BWROG Response: The BWROG representatives indicated that the evaluation was still underway, so no results were available at this time.
- 3. The NRC staff asked for justification on the use of NUREG-0609 as a BWR licensing basis document since it is specific to pressurized water reactors (PWRs).
BWROG Response: The BWROG representatives identified that no BWR-based NUREG evaluation was found that addressed break-opening times. The BWROG indicated that its position is that Section 1 and Appendix A of the NUREG are applicable to BWRs.
- 4. In light of the BWRVIP presentation made at the June 2-4, 2015, NRC/Industry Annual Technical Exchange Public Meeting, the NRC staff indicated their surprise that the BWRVIP was proceeding with revising affected BWRVIP documents under the assumption of an instantaneous break, and asked how the BWROG and BWRVIP are aligning their efforts to resolve this disparity.
BWROG Response: The BWROG representatives indicated that the BWRVIP was uncomfortable with the FBOT approach because of the potential for an extended waiting period, and because the BWRVIP wanted to commence with revising affected BWRVIP documents. The BWROG indicated that the outcome of todays meeting may influence activities, but had no further comment on future cooperation with the BWRVIP.
- 5. The NRC staff asked if any plants are currently using the FBOT provision for AP or AC loads as part of their licensing basis.
BWROG Response: The BWROG representatives expressed that at least one (1) plant had been identified that exercises the FBOT provision for AP loads. No plant details were provided.
- 6. The NRC staff asked for clarification on the basis for BWROGs determination that no Part 21 reporting was required for addressing the errors related to AC and AP loads and if that determination was contingent on the potential use of FBOT.
BWROG Response: The BWROG representatives identified that the basis for the aforementioned statement was a search of ADAMS for any licensees Part 21 reports submitted as a consequence of the issued Safety Communications that take credit for FBOT. No related Part 21 reports were found in ADAMS.
- 7. The NRC staff asked the BWROG representatives to elaborate on their interpretation of FBOT being a design basis input rather than an integral part of the design basis methodology such that the use of 10 CFR 50.59 to implement FBOT within the licensing basis is acceptable.
BWROG Response: The BWROG representatives identified that in accordance with NEI 96-07, Revision 1, Section 3.8, FBOT can be considered as an input rather than a part of the methodology.
- 8. The NRC staff asked what the basis document was for the calculation of break opening times for FBOT.
BWROG Response: The BWROG representatives identified that the break opening times are being calculated using NEDO-24548, dated January 1979. The staff subsequently located this report in ADAMS at Accession No. ML051540240.
- 9. The NRC staff asked if all BWRs in the fleet have committed to implementing FBOT and what would be gained by its implementation.
BWROG Response: The BWROG representatives identified that all BWRs in the fleet have committed to the use of FBOT on the basis of recovering their original margins.
- 10. The NRC staff asked the BWROG representatives to identify the plant grouping breakdown being utilized by the FBOT Committee.
BWROG Response: The BWROG representatives identified that sensitivity studies had been performed and that the plants were grouped specific to characteristics. No specific plant information was shared with the NRC staff.
- 11. The NRC staff asked if the FBOT Committee had identified and evaluated the potential downstream effects of this change.
BWROG Response: The BWROG representatives identified that they are currently performing an impact calculation on the dynamic and structural responses for the initial condition. The BWROG representatives identified, as an example, that for a containment response the instantaneous separation remained for the baseline calculation.
- 12. The NRC staff asked if the document search performed by the FBOT Committee for associated regulations and NRC safety evaluations (SEs) extended outside of ADAMS.
BWROG Response: The BWROG representatives identified that the primary searches were performed in General Electric Hitachi (GEH) databases and with licensees. The ADAMS searches commenced as a secondary measure.
- 13. The NRC staff asked if the FBOT Committee had plans to formally submit any documentation to the NRC staff for review.
BWROG Response: The BWROG representatives identified that they had no plans to submit any documentation to the NRC staff for formal review, but would continue to brief the NRC staff as they progress with their work, and indicated they would share information through the GEH portal.
Meeting Takeaways:
- 1. The NRC staff will evaluate the BWROG FBOT Committees regulatory basis determination and provide additional comments to the committee, if necessary.
- 2. The BWROG will provide the NRC staff with the baseline formulas and associated references that it utilized to establish the break opening time inputs.
- 3. The BWROG will provide the NRC staff a copy of the independent evaluation report for using 10 CFR 50.59 as a basis for changing the break opening time. The report was prepared by Excel.
- 4. The BWROG FBOT Committee and NRC staff will coordinate to establish a technical interface in 4Q 2015 for continued FBOT applicability discussion.
At the conclusion of the meeting, the NRC staff facilitated a summary discussion and meeting closeout.
No public comment was recorded for this meeting.
Project No. 691
Enclosure:
List of Attendees
ML15260A731; *concurred via e-mail NRC-001 OFFICE DPR/PLPB/PM DPR/PLPB/LA*
DE/EVIB/BC DPR/PGCB/BC DPR/PLPB/BC DPR/PLPB/PM NAME JDrake DHarrison JMcHale SStuchell AMendiola JDrake DATE 10/19/2015 10/20/2015 10/21/2015 10/28/2015 10/30/2015 10/30/2015
ENCLOSURE List of Attendees Drop-In Meeting between the Boiling Water Reactor Owners Group (BWROG)
Finite Break Opening Time (FBOT) Committee and U.S. Nuclear Regulatory Commission (NRC) Staff June 24, 2015 Name Organization Lesa Hill BWROG/SNC George Inch BWROG/Exelon Jerald Head BWROG/GEH Ralph Hayes BWROG/GEH Dan Pappone*
BWROG/GEH Glen Stewart*
BWROG/Excel Ethan Hoser*
BWROG/DTE Wynter McGruder*
BWROG/Excel Garold Carlisle BWROG/GEH Anthony Mendiola NRC/NRR/DPR/PLPB Sheldon Stuchell NRC/NRR/DPR/PGCB John McHale NRC/NRR/DE/EVIB Rob Tregoning NRC/RES/DE Brian Harris*
NRC/NRR/DPR/PGCB Gary Stevens NRC/NRR/DE/EVIB Alex Garmoe NRC/NRR/DPR/PGCB Jason Drake NRC/NRR/DPR/PLPB
- Participation via teleconference.