ML20135C674

Summary of 961120 Meeting W/Nuclear Energy Institute, Electric Power Research Institute & Industry to Discuss Management Issues Re Development of Draft SG Rule & Reg Guide.List of Attendees & Agenda Encl

ML20135C674
Person / Time
Issue date:	12/03/1996
From:	Tim Reed NRC (Affiliation Not Assigned)
To:	Wichman K NRC (Affiliation Not Assigned)
References
NUDOCS 9612090034
Download: ML20135C674 (6)

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i Decenber 3,1996 MEMORANDUM T0:

Keith Wichman, Acting Chief Materials and Chemical Engineering Branch Division of Engineering Office of Nuclear Reactor Regulation 1

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THRU:

Edmund Sullivan, Chief Inservice Inspection Section l) G # )4 Materials and Chemical Engineering Branch Division of Engineering Office of Nuclear Reactor Regulation FROM:

Timothy A. Reed, Senior Project Manage Inservice Inspection Section Materials and Chemical Engineering Branc Division of Engineering Office of Nuclear Reactor Regulation l

SUMMARY

OF THE NOVEMBER 20, 1996 MANAGEMENT MEETING WITH l'

NUCLEAR INSTITUTE AND INDUSTRY TO DISCUSS DEVELOPMENT OF A DRAFT STEAM GENERATOR RULE On November 20, 1996, the NRC staff met with representatives of Nuclear Energy l

Institute discuss man (NEI), Electric Power Research Institute (EPRI), and industry to i

agement issues regarding the development of a draft steam generator (SG) rule and regulatory guide (RG). Meeting attendees are identified in i

The agenda for the meeting is provided as Attachment 2.

During the November 20, 1996 management meeting the following important issues l

were discussed:

1. Industry (i.e., representatives from the SG Management Program herein referred to as " industry") clarified an issue discussed at ACRS stating that it was not the industry's original intent that a performance-based rule be i

developed.

Instead, it was the NRC who thought that a rule (for various l

reasons) was the most appropriate regulatory vehicle to address the problems associated with the regulatory framework gcverning tube integrity.

Industry was initially interested in pursuing stearo generator degradation specific management via technical specification amendments.

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2. Industry believes that the draft rule and draft RG presented to ACRS k l contain areas having too much prescription.

It continues to be the industry view that much of the detail in the rule and RG can be located within industry documents.

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Contact:

T. Reed, NRR/EMCB I[)fhnucD p 415-1462 9612090034 961203 PDR REVGP ERGNUNRC / PDR l l

=. l l } is , Keith Wichman t

3. Industry believes that the draft rule and RG are more restrictive than current requirements governing tube integrity.

This was contrasted with what the industry views as the apparent staff position that the rule contains relaxations. The industry believes that risk was incorporated into the rule framework to address what the staff has concluded are relaxations.

4. The staff stated that under " risk-informed" regulation all postulated l

events are considered for gaining risk insights. With the SG rule, this risk-l informed aspect takes on particular importance since the tubes function as I both the RCPB and containment and therefore failure of the tubes has a direct connection to risk (i.e., failure of the tubes represents a bypass of containment). Hence, this resulted in the significant effort that the staff has undertaken to better understand the risk implications of degraded tubes for the proposed rule.

5. The staff reiterated its concern regarding the application of performance-based regulation to SG tube integrity given the potentially high cost of SG tube maintenance in conjunction with the current utility de-regulation climate l

and the associated increased pressure on utilities to reduce costs. The staff needs to have sufficient confidence that repair criteria implemented by licensees via the SG rule will have a sound engineering basis and continue to maintain tube integrity. In this regard, the staff developed a detailed draft RG as the staff's standard for what is required to develop and implement l l repair criteria under the rule framework. 1 l

6. The staff indicated that the 50.109 backfit approach for the proposed rule l

is currently a combination of a " compliance" exception backfit for the non-l risk requirements and an " enhanced safety" backfit for the risk requirements. l The staff indicated that this work is ongoing and that it was not clear, at this point whether risk requirements could be justified from the " enhanced safety" (i.e. cost benefit approach) standpoint. 1

7. The industry asked whether there would be opportunity for additional interaction on technical issues involving both the severe accident risk analysis and the draft regulatory analysis prior to issuance of the proposed i

rule for public comment. The staff indicated that given the tight schedule, there didn't appear to be an opportunity for such interaction.

8. Industry requested that the staff give consideration to lengthening the public comment period to 90-120 days to enable industry to adequately review the draft rule package and coordinate their response. The staff indicated that it would consider this request.

9. Industry indicated that the staff may need to be flexible with regard to the time period for implementation of the rule given the limited industry 1

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i ~ l Keit_h Wichman, resources available for developing SG programs. The staff suggested that industry should provide public comments regarding the appropriate implementation period.

10. Industry indicated that the staff should, whenever possible and as early as possible, make publicly available, as much information as is practical, associated with the draft rule package to enable the industry to have the maximum amount of time to address the information.

11. The industry indicated that they would try to be more responsive in the future regarding the staff's desire to hear about new developments in the NDE area.

Industry agreed to meet on these issues. The meetings would be generic in nature, coordinated through industry's SGMP group, and focused on information exchange. Additionally, the industry will provide timely notification regarding developments involving the "de-certification" of NDE techniques.

12. The staff noted and briefly discussed two generic letters regarding steam generators (addressing the sizing of SG degradation and degradation SG internals) that will soon be going out for public comment.

l The next periodic meeting to discuss the SG rule status was not established. It was noted that it would be preferable to hold the next meeting after the l staff has met with ACRS and CRGR to discuss the draft rule package. l Attachments: 1. List of Attendees - November 20, 1996 Management Meeting 2. Agenda - November 20, 1996 Management Meeting l l DlSTRIBUTION: PUBLIC/PDR Miraglia/Thadani 12-G-18 EMCB RF OGC BSheron Glainas GHolahan RJones TCollins l EMurphy JDonoghue Slong MMayfield, RES DMatthews SMagruder CAder, RES CTinkler, RES l CMiller ACRS (10 JStrosnider JHayes l Document Name: G:\\ REED \\NOV96MTG. MIN To receive a copy of this document, indicate in the box C= Copy w/o attachment / enclosure E= Copy with attachment / enclosure N = Wo copy OFFICE DE:EMCB M E DE:EMCB E NAME Treed:ad[ TSu11ivan M DATE Il/N/96 G-/ 2./96 0FFICIAL RECORD COPY 4 l l

l l I* l \\ \\ NEI/EPRI/ INDUSTRY STEAM GENERATOR ISSUES AND SG RULEMAKING SENIOR MANAGEMENT MEETING NOVEMBER 20, 1996 l LIST OF ATTENDEES H8ME ORG/ POSITION

1. Tim Reed NRC/DE/EMCB

2. R. Clive Callaway NEI

3. Jack Woodard SNC/GPC

4. Mike Tuckman Duke Power l

5. Joe Donoghue NRC/NRR/DSSA/SRXB l

6. Dave Modeen NEI l

7. Brian Sheron NRC/ADT l

8. Lynn Conner DSA, Inc

9. Jack Strosnider NRC/DE

10. Sherry Bernhoft WPSC

11. Emmett Murphy NRC/DE

12. Charles Tinkler NRC/RES

13. Steve Long NRC/DSSA/SPSB

14. Joe Muscara RES/DET/EMMEB

15. Chuck Welty EPRI l

16. Dan Mayes Duke Power

17. Tim Collins NRC/NRR/DSSA/SRXB

18. Bill Ide APS/Palo Verde l

19. Gus Lainas NRC/NRR/DE

20. Theresa Sutter Bechtel l

21. Robert Jones NRC/NRR/DSSA

22. Richard Pearson NSP l

23. Greg Kammerdeiner Dusquesne Light

24. Noel Dudley ACRS

25. Rick Mullins SNC l

I l l ATTACHMENT 1

I l ..l. SG RULE MANAGEMENT MEETING NEl/EPRl/ INDUSTRY l NOVEMBER 20,1996 AGENDA OBSERVATIONS FROM NOV 1996 ACRS PiEETINGS -- NRC/ INDUSTRY - RISK-INFORMED REGULATION - SEVERE ACCIDENT POLICY ISSUE AND CURRENT APPROACH - PERFORMANCE-BASED APPROACH POLICY ISSUE - LEVEL OF PRESCRIPTION / DOCUMENT DETAIL - OTHER OBSERVATIONS l STATUS OF EFFORT TO ISSUE DRAFT SG RULE NRC ALTERNATE REPAIR CRITERIA SUBMITTALS -- NRC/ INDUSTRY = l - QUALITY OF SUBMITTALS/ BASIS FOR RG l - IMPACT OF RG ON SUBMITTALS (INDUSTRY CASE Si sIES) CIRCUMFERENTIAL CRACK SIZING /NDE APPROACH -- NRC/ INDUSTRY - PROBLEMS WITH STAFF /NEI INTERACTIONS - DE-CERTIFYING ECT METHODS l - LEAVING CIRC CRACKS IN SERVICE ATTACHMENT 2 2

~ Kdith Wichman resources available for developing SG programs. The staff suggested that industry should provide public comments regarding the appropriate implementation period.

10. Industry indicated that the staff should, whenever possible and as early as possible, make publicly available, as much information as is practical, associated with the draft rule package to enable the industry to have the maximum amount of time to address the information.

l

11. The industry indicated that they would try to be more responsive in the l

future regarding the staff's desire to hear about new developments in the NDE area. Industry agreed to meet on these issues. The meetings would be generic in nature, coordinated through industry's SGMP group, and focused on information exchange. Additionally, the industry will provide timely notification regarding developments involving the "de-certification" of NDE techniques.

12. The staff noted and briefly discussed two generic letters regarding steam generators (addressing the sizing of SG degradation and degradation SG internals) that will soon be going out for public comment.

1 f The next periodic meeting to discuss the SG rule status was not established. l It was noted that it would be preferable to hold the next meeting after the j staff has met with ACRS and CRGR to discuss the draft rule package. Attachments: 1. List of Attendees - November 20, 1996 Management Meeting 2. Agenda - November 20, 1996 Management Meeting l DISTRIBUTION: l PUBLIC/PDR Miraglia/Thadani 12-G-18 EMCB RF OGC BSheron l Glainas GHolahan l RJones TCollins EMurphy JDonoghue l Slong MMayfield, RES l DMatthews SMagruder CAder, RES CTinkler, RES CMiller ACRS (10 JStrosnider JHayes Document Name: G:\\ REED \\NOV96MTG. MIN To receive a copy of this doctment, indicate in the box C= Copy w/o attachment / enclosure E= Copy with I attachment / enclosure N s No copy 0FFICE DE:EMCB M E DE:EMCB E NAME Treed:ad[ TSullivan b DATE 11/N/96 G-/ 2/96 0FFICIAL RECORD COPY .}}