ML20135F589

Forwards Summary of 961114 Meeting W/Ceog in Rockville,Md to Discuss Topics of Mutual Interest

ML20135F589
Person / Time
Site:	05200002
Issue date:	12/04/1996
From:	Stewart Magruder NRC (Affiliation Not Assigned)
To:	Matthews D NRC (Affiliation Not Assigned)
References
NUDOCS 9612130136
Download: ML20135F589 (24)

Text

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l- MEMORANDUM TO: David B. Matthews, Chief i

Generic Issues and Environmental Projects Branch

, Division of Reactor Program Management

Office of Nuclear Reactor Regulation i

l f

FROM: Stewart L. Magruder, Project' Manager Generic Issues and Environmental Projects Branch 1 #'N7 b M

Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF NOVEMBER 14, 1996, MEETING WITH COMBUSTION l l ENGINEERING OWNERS GROUP EXECUTIVE COMMITTEE )

l l

l

On November 14, 1996, a public meeting was held at ABB-CE's offices in

{ Rockville, Maryland, between representatives of the U.S. Nuclear Regulatory i Commission (NRC) and the Executive Committee of the Combustion Engineering  !

! Owners Group (CE0G). Attachment 1 provides a list of attendees, j i

l The purpose of the meeting was-to discuss topics of mutual interest. I j Attachment 2 is a copy of the handouts provided to the meeting participants. i t

The meeting was opened by Mr. Charles Frizzle of Maine Yankee, the chairman of  :

the CEOG Executive Committee. After introductions, Mr. Ashok Thadani, NRC's ,

j Acting Deputy Director of the Office of Nuclear Reactor Regulation (NRR), '

l briefly discussed some current issues facing the agency.

4 Mr. Thadani noted that the staff is completing a look at some lessons-learned i

, issues related to events at Millstone. He stated that the staff 15. focusing '

on internal staff activities such as the role of the project manager and

[ inspectors. He also noted that regulatory guides and standard review plans l were under development by the staff for probabilistic safety assessment (PSA) i applications and that the industry has played a helpful role by providing feedback on implementation issues related to pilot programs on technical i specifications, inservice testing and quality assurance.

j With regard to Alloy 600 reactor vessel upper head primary water stress I

! corrosion cracking (PWSCC) issues, Mr. Thadani stated that the staff has been l frustrated by a lack of information from the industry. He stated that the { g$.9 p

. staff is preparing a generic letter to request information from the industry '

i' and that the staff would prefer a coordinated industry approach. He j emphasized that the reactor pressure vessel is the most important component in

^

the plant. In response to a question, Mr. Thadani stated that the staff would be receptive to a sampling approach and that every reactor vessel does not necessarily need to be tested. He noted that the sampling approach should be l based on agreed upon susceptibility criteria.

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c. l J-D. Matthews December 4, 1995 1

With regard to the recent 10 CFR 50.54(f) letters on design bases, Mr. Thadani

, stated that the staff may meet with the industry if NEI develops specific l

questions. He also briefly mentioned that the staff is working on a steam generator rule and a shutdown rule.

l Mr. Kevin Sweeney, chairman of the CE0G Steam Generator (SG) Task Force next made a presentation on SG issues. He noted that a SG degradation management program plan was under development by the task force. He briefly discussed the SG tube crack detection techniques in use and noted that the task force is developing criteria which would allow tubes to stay in service if cracks are detected by the more sensitive (plus point) probe but not by the less sensitive (pancake) probe. He stated that the task force is working on a i response to the proposed SG rule that includes an analysis of the risk of SG '

tube failures. He also noted that the task force has reviewed NRC Information l Notice 96-09, ' Damage in Foreign Steam Generator Internals." He stated that l the task force's initial conclusions are that there is no action required for CE0G members and that ABB-CE has been working with the French on the specifics of the issue.

Next, Mr. Brian Sheron, Acting Associate Director for Technical Review, NRR, discussed the proposed SG rule. He stated that the staff is currently working on the regulatory analysis and technical specification changes for the rule.

He stated that he believes there are two key issues related to the rule. The first issue is the consideration of severe accident conditions. He noted that the NRC is attempting to make the SG rule performance-based and risk-informed.

The performance criteria used need to be measurable and conservative and licensees will have to consider the risk of releases to the public. He noted that if licensee's can't demonstrate that the probability of a release caused by the failure of tubes due to high temperature /high pressure severe accident conditions is low, then they will need to submit additional analyses. The second issue is the fact that the NRC will no longer be approving alternate repair or plugging criteria prior to implementation. Thus, the burden for ensuring that the criteria will prevent tube failure shifts to the licensee.

Mr. Sheron stated that the staff is preparing two generic letters and an i information notice on SG issues. These may be issued in the near future. He l also emphasized that no alternate repair criteria exist for circumferential SG I tube cracks. Tubes with circumferential cracks must be plugged upon detection of the crack.

The next topic for discussion was Alloy 600 PWSCC issues. Mr. Mike Melton of ,

Arizona Public Service discussed the CE0G efforts to address the upper reactor vessel head penetration cracking problem, including the formation of a CE0G Materials Working Group. Mr. Sheron commented that he was pleased to see the industry addressing the problem but that the staff still intends to develop a generic letter. He stated that the staff would prefer that the industry commit to monitor vessel head cracks and submit a systematic approach, based on susceptibility criteria, to do so. The CE0G executives stated that they were discussing an initiative and would be contacting the staff with more

j. details in the near future.

J ,

i i

( .

s D. Matthews December 4, 1995 1

Mr. Sheron then briefly discussed the PSA regulatory guides (RGs) under l development by the staff. He stated that there will be a general RG that will l provide information on what the quality of PSA submittals need to be to  !

support amendment requests. He also stated that there will specific RGs for inservice inspection and inservice testing but not one for graded quality l l assurance.

l The final topic of discussion at the meeting was the proposed shutdown rule.

Mr. Warren Lyon of the NRC staff made a short presentation on the scope and philosophy of the rule. He stated that the current schedule calls for the staff to provide the rulemaking package to the Commission in January 1997. He noted that the rule will be performance-based and that each utility would be responsible for setting performance standards that must bound safety requirements. The proposed safety requirements are temperature, water level, pressure, and subcriticality. Mr. Lyon noted that there would be no specific equipment availability requirements in the rule but the defense-in-depth philosophy still applies. He also stated that the requirements related to fuel storage pools should not be a surprise to the industry.

Project No'. 692 Attachments: As stated cc w/atts: See next page i

December 4, 1996 D. Matthews i Mr. Sheron then briefly discussed the PSA regulatory guides (RGs) under development by the staff. He stated that there will be a general RG that will l provide information on what the quality of PSA submittals need to be to support amendment requests. He also stated that there will specific RGs for inservice inspection and inservice testing but not one for graded quality assurance. 1 i

The final topic of discussion at the meeting was the proposed shutdown rule.

Mr. Warren Lyon of the NRC staff made a short presentation on the scope and philosophy of the rule. He stated that the current schedule calls for the staff to provide the rulemaking package to the Commission in January 1997. He noted that the rule will be performance-based and that each utility would be l responsible for setting performance standards that must bound safety l requirements. The proposed safety requirements are temperature, water level, pressure, and suberiticality. Mr. Lyon noted that there would be no specific )

equipment availability requirements in the rule but the defense-in-depth 1

-philosophy still applies. He also stated thtt the requirements related to fuel storage pools should not be a surprise to the industry.

Project No. 692 Attachments: As stated '

I cc w/atts: See next page s

DISTRIBUTION:

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1 DISTRIBUTION: Mtg. Summary of. November 14,'.1996 w/ABB-CE dated 12/4/96

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NRC/CE06 EXECUTIVE COMMITTEE MEETING LIST OF ATTENDEES November 14, 1996 58ME ORGANIZATION Charles Frizzle Maine Yankee Mike Sellman Entergy-Waterford Mike Barnoski ABB-CE Gary Gates Omaha Public Power Randy Edington Entergy-ANO Randy Hutchinson Entergy-ANO JA Stall Florida Power

, ML Bunling Northeast Utilities l Charlie Cruse BGE l Ralph Frisch Consumers Power Mario Robles Northeast Utilities Paul Hijeck ABB-CE Ray Burski Entergy-Waterford Bill Goodwin ABB-CE Jim Hebert Maine Yankee Gordon Bischoff ABB-CE Jim Levine Arizona Public Service Ed Scherer ABB-CE Mike Melton Arizona Public Service Kevin Sweeney Arizona Public Service Charles Brinkman ABB-CE Phil Richardson ABB-CE Robert Evans NEI Ashok Thadani NRC Brian Sheron NRC Warren Lyon NRC Stu Magruder NRC l

i f Attachment 1

l 1

i NRC/CEOG t Executive Committee Meeting l

1 November 14,1996 Rockville, Maryland l

i l

l Attachment 2 L

l Agenda for November 14,1996 NRC/CEOG Executive Committee Meeting Thursday. November 14.1996 j 8:00 am introductions and Opening Remarks (Charles Frizzle, MY and j Ashok Thadani, NRC) 8:45 am Steam Generator Issues 1

l o Update on CEOG Activities (Kevin Sweeney, APS)

! o Update on S/G Rule and NRC Inspection Activities (Brian Sheron, NRC) 9:45 am Millstone Lessons Learned (Discussion of Licensing Basis, Design Basis and 50.54(f) letters) o Update from the NRC (David Matthews, NRC) o Report from the CEOG on Activities that Address Emerging Regulatory issues (Mario Robles, NU) 10:45 am Update on Alloy 600 PWSCC o NRC Status of Generic Letter (Brian Sheron, NRC) o Discussion of CEOG Activities to Address Alloy 600 PWSCC (Mike Melton, APS) 11:15 am Shutdown Rule Update (Brian Sheron, NRC) 11:30 am Meeting Wrap-up and Review of Action items (Stu Magruder, NRC

, and Gordon Bischoff, ABB) 11:40 pm Adjourn l

)

i i

s 1

l STEAM GENERATOR ISSUES l KEVIN SWEENEY -(APS) e SGTF formed in 1994 e SG Integrity is Number One Strategic issue for CEOG e The Mission of the Task Force:

j a To proactively and aggressively seek cost

{

effective solutions to issues which challenge  !

steam generator safety and reliability, and to reduce associated plant capital and O&M costs.

i

- Through cooperation, communication and completion of joint programs which address generic issues l

COMBUSTION ENGINEERING OWNERS GROUP 4

d t

i i STEAM GENERATOR ISSUES

_ ~_

e Degradation Management Program i

n CircumferentialCracking a Freespan AxialCracking e Alternate Repair Criteria e NRC Information Notice 96-09, internals Degradation in Foreign SGs e NDEIssues COMBU$ TION ENGINEERING OmdERS GROUP

s l

1 TUBE DEGRADATION PROGRAM PLAN 3 o The SGTF has developed a Degradation Management Program Plan

> Evolutionarydocument n Circumferential cracking section complete

- Includes recommended activities addressing:

e NDE (detection and sizing) e Mrtigation e Depositanalysis e Crack growth e Attemate RepairCriteria

> Axial degradation section - Phase 2

- Willinclude ongoing ARC development l

- Root cause assessment COM8USTION ENGINEERING OWNERS GROUP l I

TUBE AXIAL DEGRADATION ALTERNATE REPAIR CRITERIA

- ~~ _ . _ .

e Long axial cracking (> 3/4 inch)is a current issue at CE plants n includes eggerate, freespan and sludge pile regions

- Repair options limited

- Altemate repair criteria not available to CE plants a CEOG has considered this issue previously

- New information / techniques since CEOG evaluation in 1994

- Recent discovery of upper bundle cracking highlights critical nature of this effort c:vea:n: . escama: owNtR2 se.n a

l  !

l TUBE AXIAL DEGRADATION l

ALTERNATE REPAIR CRITERIA

._ _ _ = _

e Purpose n Develop axial crack evaluation methodology in three stages

1. Justify full cycle operation with " plug on detection" l

2. Plug-on-sizing ARC based on results of two EC coils

having different sensitivities

3. True plug-on-sizing ARC n Cooperate with EPRI and obtain EPRI ARC Committee concurrence a Benefit

- Outage flexibility

- Degradation management COMBUSTION ENGINEERING OWNERS GROUP 1

l TUBE AXIAL DEGRADATION ALTERNATE REPAIR CRITERIA i

e Integrate program with ongoing SGTF Tasks n SG Rule n Neural Network - Freespan Degradation n Risk based event criteria e Schedule a Plug on detection run time methods - Spring '97 a Feasibility of two coil methodology - Dec. '97 a Full ARC - Dec. '98 e This is one of the most signifiCant programs in CEOG history c:,.u v. t ...:.m . a : . . . as m

.- 'l ;

1 TUBE AXIAL DEGRADATION ALTERNATE REPAIR CRITERIA

u.. ,n. u.

,y{ .

AxialCrack ARC Methods C;a:cvea ,

Utdity Task Mgmt. Group SGTF Degradation Mgmt. InitiaEves j i i  !

L ______ .._ _ I l

__.I I Techncal Advisory Grtg ' hsguidery Advisory Gnq NDE Advisory Group Task 1: StructuralIntegrity Task 2 Leakage integrity Task 3: EOC Prgecbon Methods ,

I Task 4: Growth Rate Evaluation i

_ I I

l Task 5: Detection & Sizing l lask 6: Advanced Detection Task 7: Laboratory SpMmen { Tak 8: Pulled Tube Test Program i Capabilities ti_ & Sizing Test Program i I l Task 9- Data Base integration Task 10: Methods Integration  ;

2MBUSTION ENGINEERING OWNERS GROUP i

i i

~-

l DEGRADATION IN FOREIGN SG INTERNALS NRC INFORMATION NOTICE 96-09

-~ -

e Several EdF plants have experienced internal support system degradation a Affected SGs are similar in design to W Model 51

- Significantly different from CE SG designs j

> Concemed about possible generic issues in US, Informstion l

Notice 96-09 was issued l

- Support plate cracking

- Wastage and breakage of support plate ligaments

- Failure of bundle wrapper support welds e CEOG will document design differences between subject EdF units and CEOG plants a Showing that similar degradation is unlikely COMBUSTION ENGINEERING OWNERS GROUP l

l NDE ISSUES

.. ~.

e CEOG to address perceptions and realities regarding detectability and sizing of circumferentialcracks '

a Storyboardpresentation

- Explosive transitions versus rolled transitions

- NDE theory and experience

- Designed to support ARC position e ECT Flaw Library e Technique Qualification l e Technique Development COMBUSTCN ENGINEERING OWNERS GROUP

J

' O,

SUMMARY

e CEOG SG Task Force n Effective forum for discussion and resolution of SG

-l issues a Development of products and programs which improve safety and reliability of steam generators n Active CEOG participation on regulatory / industry issues n Communicate CEOG interests to INPO, NEl, EPRI, and other industry organizations COMBUSTION (NGINEERING OWNERS GROUP i

I l

I

-- i

,1 i

1 i

Emerging Regulatory Issues 4

Mario Robles (NU)

Chairman, Licensing Subcommittee November 14.1996 i

Combustion Engineenng owners Group

Background

e CEOG formed after TMI to address regulatory issues a regulatory issues were major driver of the CEOG for many years (e g., LOCA methods, PASS, AFW diversity, etc.)

e CEOG transitioned in late 1991 to focus on O&M cost {

reduction '

a focus on shorter outages, reduction of testing, etc e Industry is currently in a period of increased scrutiny I

e CEOG will have an important role in addressing regulatory issues a effective to address generic regulatory issues on a group l

basis j

Combustion Engineenng owners Group

i ,

4 .,

i Emerging Regulatory Issues l

,r..

j e Rules a S/G Rulemaking' n Anticipated GL on PWSCC '

> Update on GL 96-01*

a Update on GL 96-06

} > Shutdown Rulemaking* i a PRA Application Regulation

• n NRC Bulletin 96-01*

e Design / Licensing Bases

> 50.59 Evaluation Changes

)

m Results of CEOG Workshop on SFP Design Comparison

• l

> 50.54(f) letters Combustion Engineenng owners Group l

)

Generic Letter 96-01 w -w e NRC Generic Letter 96-01 addresses Yesting of Safety Related Logic Circuits a Requires comparison of as built design against surveillance test procedures to ensure all features (logic, interlocks, bypasses and inhibit circuits) are tested a CEOG is providing the above comparison for CE supplied RPS and PPS safety related logic circuits a Benefitsinclude

- development and application of a consistent method

- efficient resource allocation using OEM knowledge and a

" production line* evaluation

{

n issue being successfully addressed by CEOG '

Combustion Engineenng owners Group l

I

Shutdown Rulemaking m:__ _ .. .m~

o t.RC initiated S/D rulemaking activities in 1992 e CEOG questioned the basis and impact of the proposed requirements in 1993/1994 o NRC currently preparing revised rule and regulatory guide a proposed rule to be issued 1/31/97 m rule contains high levellanguage a recent industry events have caused SFP and internal external event considerations to be included e Proposed regulatory guide may be prescriptive, but flexibility possible via sound implementation Combusbon Engineenng owners Group Shutdown Rulemaking o OMWG reviewed 22 day outage and shutdown operations protection plan with NRC in June

= well received NRC is open to input e CEOG OMWG currently developing implementation guidance a consistent with outage rnodel, alternatives based upon rnaintenance of safety functions a expect to provide input to NEl a may be submitted to NRC for reference e CEOG desires to stay informed on rulemaking progress and work with NRC on implementation i

Cambusbon Engmeenng owners Group

1 PSA Application Regulation -

e Very strong PSA application initiative within industry e industry pilot programs being used to formulate guidance and acceptance criteria for risk based I applications

• ISI, IST, Technical Specification (CEOG industry lead),

graded Q/A

> CEOG met with ACRS and NRC 7/96 and 8/96 to help address key issues

> CEOG process seen as technically credible '

Combusbon Engmeenng owners Group PSA Application Regulation o NRC currently preparing 9 Regulatory Guides and Standard Review Plans a form future regulatory basis for PRA applications a rules can either accelerate or inhibit applications e PSA policy issues being resolved favorably a core damage frequency is an acceptable criteria a uncertainties included in applications a cross comparisons / peer review vital i

a slight risk increase acceptable under certain conditions e CEOG will continue to met with NRC r

ceP;,.s!.C E * * .s t'.1 CW 'a a c'O.C i

a

4 NRC Bulletin 96-01 o NRC issued Bulletin 96-01 on 3/8/96 documenting rod

insertion problems at 3 plants a specific response required by W a NRC held meetings with CEOG and B&WOG on 3/27

e CEOG provided a proactive response i e Results of survey and design evaluation showed a no susceptibility to problem a no restrictions on fuel management e Report issued to NRC for information in July a NRC very pleased with report excerpts from report presented at Feel and Core Performance Workshop Combustion Engineenno Owners Group SFP Design Comparison Workshop e Forces on the lodustry resulted in a proactive CEOG response to review a pilot system design basis a Millstone Watch Plant List a Time magazine article a Regulatory Information Conference o Workshop held to compare SFP designs, identify differences, and discuss future CEOG actions a attended by 18 utility and ABB participants a pilot to evaluate benefit of design comparison Comcastion Engineenng owners Group

i SFP Design Comparison Workshop e Resultsidentified a design differences among members a generic actions to lessen the burden associated with anticipated design / licensing basis reviews

- priortoissuance of 50.54(f) letters e Particip3rits underscored i

> Comparisons of system designs can proactively identify precursors and can be used to respond to future NRC questions on design bases Combuston Engineenng Owners Group l

I l

I l

i e

CEOG ACTIVITIES TO ADDRESS PWSCC OF CEDM PENETRATIONS MIKE MELTON-(APS) e CEOG has formed a Materials Working Group Recognizing the continued importance of materials

issues a Providea focused utility expertise a Working Group will address many materials issues including PWSCC of Alloy 600 Vessel Head Penetrations i l

COMBUSTION ENGINEERING OWNERS GROUP i

CEOG Activities to Address CEDM Penetration Cracking Cooling of the Vessel Upper Head e Program will:

a Evaluate current core bypass flow and estimate current upper head fluid temperatures a Evaluate increasing core bypass flow and estimating possible reductions in upper head temperature a Estimate costs of performing bypass modifications e Ultimate goalis mitigation of PWSCC Initiation and Growth cce.cs::ea EsceaEmc eu.ee caca

CEOG Activities to Address CEDM Penetration Cracking e Materials Working Group Also Considering

Development of Revised CEDM PWSCC Timing Model n incorporating

- New industry data e inspectionresults

, e Materialsresearch 1

- Updated initiation and growth algorithms

- Improvements in probabilistic treatments t

COMBUSTION ENGINEERING OWNERS GROUP f

i

e.

CE OWNERS GROUP cc: Mr. Gordon C. Bishoff CEOG Project Manager  ;

ABB Combustion Engineering  !

M.S. 9615-1932 '

1000 Prospect Hill Road Windsor, CT 06095 Mr. David Pilmer, Chairman CE Dwners Group Southern California Edison Irvine Operations Center Room 109C 23 Parker Street Irvine, California 92718 Mr. Charles B. Brinkman, Director Nuclear Systems Licensing '

ABB-Combustion Engineering, Inc.

Post Office Box 500 '

1000 Prospect Hill Road Windsor, CT 06095 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations ABB-Combustion Engineering, Inc.

12300 Twinbrook Parkway, Suite 330 Rockville, MD 20852 i

f I

i

e a.

D. Matthews December 4, 1996 Mr. Sheron then briefly discussed the PSA regulatory guides (RGs) under 1 development by the staff. He stated that there will be a general RG that will i provide information on what the quality of PSA submittals need to be to  !

support amendment requests. He also stated that there will specific RGs for )

inservice inspection and inservice testing but not one for graded quality l assurance.  !

1 The final topic of discussion at the meeting was the proposed shutdown rule.

Mr. Warren Lyon of the NRC staff made a short presentation on the scope and philosophy of the rule. He stated that the current schedule calls for the staff to provide the rulemaking package to the Commission in January 1997. He noted that the rule will be performance-based and that each utility would be responsible for setting performance standards that must bound safety requirements. The proposed safety requirements are temperature, water level, pressure, and subcriticality. Mr. Lyon noted that there would be no specific i equipment availability requirements in the rule but the defense-in-depth philosophy still applies. He also stated that the requirements related to fuel storage pools should not be a surprise to the industry.

1 Project No. 692 Attachments: As stated l cc w/atts: See next page DISTRIBUTION:

See attached page Decument Name: G:\SLM1\MSUMlll4.96 To receive a copy of this document, in icate in the box: "C" - Copy without attachment / enclosure "E" = Copy witi( Attachment / enclosure "N" - No copy 0FFICE PM:PEGB E SC:PGEBMf-l BC:PEGB

.- l NAME SMagruder:sw cun FAkstileWii DMatthews. -

DATE 12/ 9/96 12/g//96 12/s /96 0FFICIAL RECORD COPY