ML18317A170

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Summary of Meeting with Nuclear Energy Institute (NEI) Regulatory Issues Task Force (RITF)
ML18317A170
Person / Time
Issue date: 11/14/2018
From: Jeanne Johnston
Office of Nuclear Reactor Regulation
To: Marilyn Evans
Office of Nuclear Reactor Regulation
JJohnston, NRR, 415-1349
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ML18317A167 List:
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Download: ML18317A170 (6)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 14, 2018 MEMORANDUM TO: Michele G. Evans, Deputy Director for Reactor Safety Programs and Mission Support Office of Nuclear Reactor Regulation FROM: Jeanne D. Johnston, Technical Assistant /RA/

Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF OCTOBER 31, 2018, MEETING WITH NUCLEAR ENERGY INSTITUTE (NEI) REGULATORY ISSUES TASK FORCE (RITF)

On October 31, 2018, a Category 2 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of the NEI RITF at NRC Headquarters. The purpose of the meeting was to discuss several regulatory issues regarding licensing processes, oversight processes, and other issues. The meeting notice and agenda are available in the Agency-wide Documents Access and Management System (ADAMS) at Accession No. ML18299A031. A list of attendees is provided as Enclosure 1.

The NRC staff discussed with the RITF planned licensing workload management (see ), licensing action consistency and several other topics as listed in the meeting agenda. No regulatory decisions were made. Meeting notes from NEI are included as . The NRC and RITF members discussed the timeframe for the next meeting to be in February 2019.

Several members of the public were in attendance and several were on the conference bridge line. Public Meeting Feedback forms were not received.

Please direct any inquiries to me at 301-415-1349, or Jeanne.Johnston@nrc.gov.

Enclosures:

1. List of Attendees
2. Workload management handouts
3. NEI notes cc w/encl: Distribution via Listserv CONTACT: Jeanne D. Johnston, NRR (301) 415-1349

Meeting Notice: ML18299A031; Meeting Summary Pkg: ML18317A167 OFFICE NRR NAME JJohnston DATE 11/14/2018 Sign in Regulatory Issues Task Force Meeting NRC HQ - Commission Hearing Room Oct 31, 2018 9 am- 12 pm Name Organization 1 Jana Bergman Curtiss-Wright 2 Tim Riti - NEI NEI 3 Andrew Mauer NEI 4 Maggie Staiger STARS 5 Victoria Anderson NEI 6 Russ Felts NRC 7 Steve Catron NextEra 8 Paul Duke PSEG 9 Robert Krsek NRC 10 Mirela Gavrilas NRC 11 Steve Meyer STARS alliance 12 Martin Murphy Xcel Energy 13 Everett Perkins Certrec 14 Lance Sterling STP 15 Craig Erlanger NRC 16 Art Zaremba Duke 17 Terrence Reis Southern Nuclear 18 Chris Riedl TVA 19 George Gellrich Exelon 20 Greg Krueger Exelon 21 Phil Couture Entergy 22 Kenn Miller NRC 23 Michele Evans NRC 24 Eric Bowman NRC 25 Brian Benney NRC 26 Taylor Lamb NRC 27 Vic Cusumano NRC 28 Greg Casto NRC 29 Kevin Kavanagh NRC 30 Blake Purnell NRC 31 Stuart Bailey NRC 32 Mark Thaggard NRC 33 Kevin Hsueh NRC 34 Kristy Bucholtz NRC 35 Paul Duke PSEG 36 Mark Henry Salley NRR 37 Nick Melly NRC 38 Tim Reed NRC 39 Jeanne Johnston NRC 40 Stacy Rosenberg NRC 41 Kathy Brock NRC 42 Mike Franovich NRC 43 Michael Annon Member of the public Enclosure 1

REGULATORY ISSUES TASK FORCE (RITF)

Nuclear Energy Institute (NEI) Summary of 10/31/2018 Public Meeting LICENSING ACTIONS WORKLOAD UPDATE NRC provided a presentation on risk informed licensing initiatives. This included a summary of FY18 performance, current progress on TSTF-505 reviews, and projected improvements in review time. Additionally, 50.69 reviews were discussed including plant specific review factors that impact review schedule and cost. While the majority have met or will meet the 1-year timeliness target, plants without seismic PRA or a seismic margin analysis (SMA) could impact the review duration. Future workload challenges were discussed with the projected increase in submittals and options the NRC plans to use to manage workload. The key message was that any enhanced communications between the industry and the NRC regarding upcoming reviews could aid in the preparation and support of these reviews. NRC was concerned with the potential to receive a significant number of TSTF 505 submittals in the first quarter of 2019.

NRC identified that one option to deal with the bow wave of submittals may be to perform the acceptance review then place the review on hold pending resource availability.

LICENSING ACTION CONSISTENCY The industry raised a concern with handling of PRA F&Os that are addressed as license conditions. The industry suggested the NRC to consider if Safety Evaluations can be issued with open F&Os that can be closed at a later time. The industry also expressed a concern with how alternate source term (AST) licensing submittals were being considered regarding control room operator dose and how it is described in RG 1.183. The NRC responded that 10 CFR 50.67 requires a consideration for ingress/egress dose from the site boundary to the control room needs to be estimated and if that information is not included in the submittal, the NRC is asking for that information. The NRC noted the importance of being consistent in the conduct of reviews. The industry asked for a status of TMRE reviews. The NRC provided and updated that the reviews of the pilot plants are nearing completion.

EXCEPTIONS TO NON-CONSERVATIVE TECHNICAL SPECIFICATIONS The industry reinforced its concern with the two exceptions with endorsing NEI 15-03. The NRC stated that the public comments were still being discussed internally and that a public meeting will probably occur in the future once all comments are reviewed. The NRC noted that the exception to the wording on timeliness to resolve an issue did not bind the licensee to a resolution time not commensurate to safety. However, the industry warned that inspectors may use this guidance conservatively to impose a timeliness requirement differently than the licensees corrective action program.

TASK INTERFACE AGREEMENT (TIA) PROCESS ENHANCEMENTS The NRC noted that they are identifying a new TIA project manager and are open to any Enclosure 3

feedback on improvement opportunities to the process and will be looking at a public meeting specifically on this topic. The industry will provide feedback on things to be considered.

TARGET ROCK VALVES The NRC provided a summary on the number of LERs for Target Rock Two-Stage Safety/Relief Valves. While the safety significance remains low, there is an interest in what the industry is doing to resolve this issue. A member of the BWR owners group discussed the various options being considered based on the results of testing. NEI discussed the action given to the RITF from the Regulatory Issues Working Group (RIWG) to propose options to resolve non-compliance/low risk issues commensurate with the safety risk without expending large amount of personnel and financial resources. NRC made a comment relative to the issue of set point drift and its impact on a broader set of valves beyond the 2-stage target rock valves. NRC alluded to potential inspection and operability questions that may be raised relative to valve performance.

OPEN GENERIC COMMUNICATIONS The NRC discussed activities associated with generic communications. RIS 2005- 29, Rev 1, Anticipated Transients That Could Develop into More Serious Events is still being reviewed internally and is expected to be dispositioned by the end of 2018. The information notice, IN Duties and Responsibilities of Armed Responders has been withdrawn. The RIS for Pre-application Communication and Scheduling for Accident Tolerant Fuel Licensing Submittals is still being worked. Currently, it is expected to open up for public comments in the middle of 2019.

PRE-GENERIC ISSUES The industry discussed additional information being requested for effluent radiation monitors during RP inspections. While not identified as a pre-generic issue at this time, the NRC discussed how accurate effluent radiation monitor readings are dependent on energy and time and if the current calibration practices will ensure reading accuracy. The data was being requested to determine next steps. The industry wanted to ensure that the right process was being used to request this data and that there was an understanding of the industry impact to collect and provide the calibration data during inspections. The industry also expressed concerns that High Energy Arcing Fault (HEAF) testing is not representative of actual plant configurations. For example, multiple protection devices need to fail for electrical faults to hold in for as long as 8 seconds when faults typically last milliseconds. The NRC discussed the testing methods being used and how EPRI is engaged. The industry wants to ensure that they are able to provide feedback working with EPRI and the NRC to ensure that the probability and risk is being considered upfront, credit is being taken for preventative maintenance strategies, and system design and protecting relaying is considered during to ensure testing realism. A public meeting is being considered for Dec. 2018/Jan. 2019 timeframe.

EQUIPMENT QUALIFICATION STATUS The NRC discussed that they are 2 years into a 3 year inspection cycle and continuing to 2

collect information. The next public meeting will likely be held in November 2018.

OPEN PHASE CONDITION STATUS The NRC provided an update on the completion of the pilot inspections.

CONTROLLED UNCLASSIFIED INFORMATION (CUI)

The industry noted that the SECY 18-0097 was issued seeking the proposed CUI policy statement and wanted to ensure that the industry has an opportunity to provide input on the implementation process and understand the impact on the licensees. The NRC noted that a public meeting is being targeted for late in the first quarter of 2019. The industry asked to consider an earlier meeting to ensure timely input is provided.

REGULATORY GUIDE REVIEWS The industry expressed interest in providing feedback earlier in a Regulatory Guide review and update. The NRC discussed how the review process works and is looking at ways to receive input earlier.

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