ML20149M019

Summary of 880128 Meeting w/C-E Owners Group (CEOG) Re Recent CEOG Activities & Ceog/Nrc Activities.List of Attendees & Viewgraphs Encl

ML20149M019
Person / Time
Issue date:	02/16/1988
From:	Anthony Mendiola Office of Nuclear Reactor Regulation
To:	Boger B Office of Nuclear Reactor Regulation
References
NUDOCS 8802250249
Download: ML20149M019 (95)

Text

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FEB 16I1988 l

_ MEMORANDUM FOR:- Bruce A. Roger, Assistant Director for Region I Reactors-Division of Reactor Projects I/II-

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FROM:

Anthony J.'Mendiola, Technical Assistant for Region I Peactors-Division of. Reactor Projects I/_II.

SUMMARY

OF MEETING HELO ON JANUARY 28, 1988 WITH COMBUSTION ENGINEERING OWNERS GROUP i

A meeting was held on January 78, 1988, between representatives of the NRC staff and members of the Combustion En0ineering Owners' Group (CEOG) to discuss recent CE0G activities.and CE0G/NRC policy issues. A list of I

attendees'and the slides pres'ented are enclosed.

The purpose of the meeting was to seek improvement in CEOG/NRC comunications, l

identify interfaces, and to sumarize. agreements between the two groups.

Dr. Joe Gasper, Chairman of the CEOG, began the presentation with an i

introduction of those CEOG representatives present. This was followed by.

CEOG subcomittee and task force briefings on current activities. The six groups which made a presentation were:

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Reliability and Availability Subcomittee 2.

Materials and Chemistry Subcomittee 3.

Configuration Management Task Force j

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Analysis Subcomittee I

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Operations Subcomittee 4

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Technical Specifications and Licensing Subcomittee 1

All of the groups highlighted their current activities and listed planned I

j future actions. The Operations Subcoimittee presented a detailed review of i

CEOG activities to date on the Charging Punp Performance Improvement Program which is concerned primarily with pump non-availability due to block j

cracking.

Since each issue will require some CEOG/NRC interface, the appropriate NRC 4

points of contact were indicated.

A list of named NRC contacts is enclosed.

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w Bruce A. Roger I B 16 IM Upon completion of the CE0G presentations, discussion was opened regarding CEOG/NRC policy issues, particularly NRC/CEOG communications and NRC review of CEOG Topical Reports.

Regarding comunications, CEOG expressed the concern that the NRC is regarding them as a licensee.

NRC understood the concern and efforts would be made in the future to clear up misunderstandings with inferral telephone calls.

Regarding the NRC review of CEOG Topical Reports, CEOG expressed the concerns that timely NRC review was not being performed on their CE0G submittals and that there was at least the appearance that other Owr.ers' Groups seemed to resolve their issues much faster.

DEST reoresentatives outlined for the CEOG members present the current resource allocations restraints for the review of these reports and the proposed new prioritization scheme for DEST work. NRC stated that if the CEOG assisted the review process up front, the NRC turn-around time on these reports could be shortened. Specific CEOG assistance would be appreciated for:

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Pre-submittal decisions by the CEOG as to which issues are of the greatest inportance.

These issues would be given the appropriate NRC attention.

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Submittal of specific application criteric.

Phat is the necessary tirie table the NRC needs to adhere to so that CE plant operation schedules are not severely impacted? Which plants would be impacted?

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CEOG topical reports must come in on the specific docket or dockets affected in order to be reviewed, q

1 NRC members further commented that if a CEOG issues impacts inore than one i

plant, then a CRGR board review would be required, adding at least one to two months to the topical review process.

After a brief discussion of proposed future CE0G/NRC issues and an open invitatior, for NRC attendance to a CEOG meeting in the future, the reeting was a

adjourned.

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i Anthony J. Mendiola, Technical Assistant for Region I Reactors j

Division of Reactor Projects I/II j

Enclosures:

As stated cc w/ enclosures:

J See next page D

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w Bruce A. Boger

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February 16, 1988 cc w/ enclosures:

Dr. Joseph K. Gasper,,Chairnen C-E Owners Group c/o Omaha Public Power District 1623 Harney-Omaha, NE 68102 Mr, Jim Pfiefer Combustion Engineering, Inc.

1000 Prospect Hill Road Windsor, CT 06095-0500 Mr. Charles Brinkman Combustion Engineering, Inc.

7910 Woodmont Avenue, Suite 1310 Bethesda, MD 20814 i

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,i ENCLOSURE NRC/CEOG INTERFACE MEETING JANUARY 28, 1988 NAME ORGANIZATION S. Lee NRC/ DEST B. Elliot NRC/ DEST P. Richardson CEOG C. Gimbrene CE0G P. Nelson CEOG J. Pfeifer CEOG/CE J. Gasper CEOG/0 PPD A. Thadani NRC/ DEST R. Phelps CEOG/SCE W. Hodges NRC/ DEST J. Williams CEOG/RGAE W. Windecker CEOG/FPL R. Bernier CEOG/APS J. Hutchinson CEOG/FPL B. Boger NRC/NRR A. Mendiola NRC/hRR F. Miraglia NRC/NRR R. Perfetti NRC/ DEST S. Hou NRC/ DEST C. Brinkran CE L. Marsh NRC/ DEST M. Hartzman NRC/0EST I

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.I ENCLOSURE LISTING OF NRC CONTACTS 7

i TECHNICAL REVIEWER DESIGNATION ISSUE DIVISION 1.

EMERGENCY PROCEDURE GUIDELINES DEST (S. SUN--SRXB) i 2.

CHARGING PUMP PERFORMANCE IMPROVEMENT DEST (M. HARTZMAN -- EMEB) l PROGRAM 3.

RESTRUCTURED TECHNICAL SPECIFICATIONS DOEA (M. WOHL -- OTSB) 4.

RPS/ESFAS TEST INTERVAL EXTENSION DEST (S. RHOW -- SELB) 5.

REFUELING SURVEILLANCE FREQUENCY EXTENSION DEST (R. PERFETTI -- SPLB) j l

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HIGHER FUEL INTERNAL GAS PRESSURE DEST (S. L. WV -- SRXB) 7.

REACT 0A COOLANT SYSTEM LEAK-BEFORE-BREAK DEST (S. LEE -- EMEB) j JUSTIFICATION 8.

MAIh STEAM LINE LEAK-BEFORE-BREAK DEST (S. LEE--EMEB)

JUSTIFICATION a

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LTOP TRANSIENT LIMIT DEST (B. ELLIOT -- EMEB) t l

10. NEW SMALL BREAK LOCA METHODS DEST (Y. H. HS!! -- SRXB) i f

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I AGENDA r

CEOG/NRC Meeting l

January 28, 1988 Philips Building Room P-ll8 I

Bethesda, Maryland 9:00 am INTRODUCTION Opening Statements Frank Miraglia (NRC)

Joe Gasper (OPPD) i CEOG Update Joe Gasper (OPPD)

Analysis Sukcqmmittee Activities Report Jerry Holman (LP&L) o SB LCCA Margin Improvement Program o

Alternate Low Temperature overpressure Protection Transient "imit o

Reactor Coolant System Leak-Before-Break Justification i

o Main Steam Line Leak-Before-Break Justification o

Justification for Higher Fuel Internal i

Gas Pressure o

Moderator Temperature Coefficient /ATWS Information Request l

i operat:,ons subcommittee Activities Report 3

Walt W:,ndecker (FP&L) o EPGs, Revision 03 o

Charging Pump Performance Improvement Program l

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i Technical Scecification~and Licensina Subcommittee Dick Bernier-(APS) l Activities Report 1

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Tech Spec Restructuring o

RPS/ESFAS Test Interval Evaluation i

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Surveillance Test Intervals Based on

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Refueling Outages I

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CECG/NRC Policy Issues

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o Communications o-Topical Report Review 1

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i NRC Input to the C-E Owners Group l

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12:00 ADJOURN

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h CE0G/NRC MEETING 1

JANUARY 28, 1988 I

BETHESDA, MARYLAND 1

MEETING OBJECTIVES 4

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IMPROVE COMMUNICATIONS d

IDENTIFY INTERFACES i

SUMMARIZE AGREEMENTS 1

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CEOG UPDATE CURRENT-0FFICERS

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CHAIRMAN J0E GASPER (OPPD) t VICE CHAIRMAN ED STERLING (APS)

STEERING COMMITTEE MIKE MEISNER (LP&L)

RALPH PHELPS (SCE) j JOHN HUTCHINSON (FP&L) i i

RRG CHAIRMAN TED ENOS (AP&L) i RRG VICE CHAIRMAN MARK MEDFORD (SCE) l 4

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i CE0G SUBCOMMITTEES / TASK FORCE SUBCOMMITTEES CHAIRMAN ANALYSIS JERRY HOLMAN (LP&L)

OPERATIONS WALT WINDECKER (FP&L)

I TECHNICAL SPECIFICATIONS DICK BERNIER (APS)

AND LICENSING RELIABILITY AND AVAILABILITY PAYSON SIERER (BG&E)

MATERit,LS & CHEMISTRY JOHN KLISIEWICZ (NU)

CONFIGURATION MANAGEMENT TASK FORCE BOB DIEDRICH (BG&E)

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I RELIABILITY AND AVAILABILITY SUBCOMMITTEE PAYSON SIERER (BG&E), CHAIRMAN t

i SUBCOMMITTEE ESTABLISHED BY CE0G IN JUNE, 1987 MISSION OF SUBCOMMITTEE IS TO PROVIDE A FORUM T0:

IDENTIFY, REVIEW, AND RESOLVE RELIABILITY, AVAILABILITY, AND PLANT PERFORMANCE ISSUES GENERIC TO CEOG PLANTS 4

THE CEOG RELIABILITY AND AVAILABILITY SUBCOMMITTEE IS:

t TAKING THE INITIATIVE TO IDENTIFY THE CONTRIBUTORS TO 4

UNAVAILABILITY AT THEIR UNITS IN ORDER TO ESTABLISH PROGRAMS TO REDUCE UNAVAILABILITY ACTIVELY FOLLOWING THE EPRI RELIABilTY ',1TERED MAINTENANCE PROGRAM j

CONSIDERING DEVELOPMENT OF A REACTOR VESSEL i

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SURVEILLANCE PROGRAM FOR DESIGN LIFE ATTAINMENT AND LIFE EXTENSION TAKING RESPONSIBILITY TO BRING OTHER LIFE EXTENSION j

ISSUES TO THE ATTENTION OF THE CEOG

MATERIALS & CHEMISTRY SUBCOM't!TTEE I

JOHN KLISIEWICZ (NU), CHAIRMAN l

1 SUBCOMMITTEE ESTABLISHED BY CEOG IN JUNE, 1987 l

4 MISSION OF SUBCOMMITTEE IS TO PROVIDE A FORM T0:

IDENTIFY, REVIEW AND RESOLVE I

MATERIALS, CHEMISTRY, AND CORROSION ISSUES GENERIC TO CE0G PLANTS i

I THE SUBCOMMITTEE IS:

4 CREATING A NON-METALLIC MATERIALS DATA BASE i

l DEVELOPING A STEAM GENERATOR CORROSION MODEL l

FOLLOWING RCP MATERIALS ISSUES EVALUATING CLOSED LOOP COOLING WATER CORROSION INHIBITORS 1

EVALUATING ALTERNATE STUD LUBRICANTS l

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i CONFIGURATION MANAGEMENT TASK FORCE

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BOB DIEDRICH (BG&E), CHAIRMAN f

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TASK FORCE ESTABLISHED IN FEBRUARY 1987 TO FOCUS ON I

ASSEMBLING AND INDEXING DOCUMENTS NECESSARY TO i

RECONSTITUTE DESIGN BASES FOR CEOG PLANTS 4

PHASE 1 i

FEASABILITY STUDY TO ASSESS THE MAGNITUDE OF THE NUMBER OF DOCUMENTS AVAILABLE, THEIR LOCATIONS, AND THE SCOPE OF EFFORT NEEDED TO ASSEMBLE AND INDEX l

PHASE 2A ASSEMBLY AND INDEXING OF DOCUMENTS RELATED TO THE l

j DESIGN BASES FOR THE SAFETY INJECTION / CONTAINMENT l

SPRAY SYSTEMS OF CEOG PLANTS l

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THIS EFFORT SCHEDULED FOR COMPLETION MARCH 1, 1988 i

PHASE 2B l

1 ASSEMBLE AND INDEX DOCUMENTS FOR THE REMAINDER l

0F THE NSSS SYSTEMS i

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j SCHEDULE TO BE DETERMINED i

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ANALYSIS SUBCOMMIiTEE l

JERRY HOLMAN (LP&L), CHAIRMAN AND CEOG CONTACT (504) 467-2791 x265 PRESENTED BY J0E WILLIAMS (BG&E)

-- OVERVIEW --

CEOG/NRC INTERACTION 1

SMALL BREAK LOCA MARGIN IMPROVEMENT PROGRAM i

ALTERNATE LOW TEMPERATURE OVERPRESSURE PROTECTION i

(LTOP) TRANSIENT LIMIT REACTOR COOLANT SYSTEM LEA'K-BEFORE-BREAK JUSTIFICATION MAIN STEAM LINE LEAK-BEFORE-BREAK JUSTIFICATION JUSTIFICATION FOR HIGHER FUEL INTERNAL GAS PRESSURE MODERATOR TEMPERATURE COEFFICIENT / ATWS INFORMATION REQUEST OTHER ACTIVITIES E0P INSTRUMENT ACCURACIES CEA INTEGRITY STUDIES ICI LIFE EXTENSION 1

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.o ANALYSIS SUBCOMMITTEE SMALL BREAK LOCA MARGIN IMPROVEMENT NEW EVALVATION MODEL DEVELOFMENT NRC CONTACT:

NORM LAUBEN IMPROVED ECCS EVALUATION MODEL TO LESSEN ISSUE OPERATIONAL RESTRICTIONS SUCCESSFUL CEOG/NRC INTERACTION NRC AGREEMENT THAT SECY 83-472 APPLIES TO SMALL BREAK LOCA MODELING POSITIVE FEEDBACK FROM NRC ON LIMIT VALUE APPROACH ADDITIONAL TEST COMPARISONS RECOMMENDED BY NRC AT JANUARY, 1987 MEETING j

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ANALYSIS SUBCOMMITTEE 1

SMALL BREAK LOCA MARGIN IMPROVEMENT NEW EVALUATION MODEL DEVELOPMENT 40" CONTACT:

NORM LAUBEN STATUS MODEL DEVELOPMENT COMPLETE DRAFT REPORTS UNDER REVIEW BY CEOG "NEW SMALL BREAK LOCA EVALVATION MODEL"

-VOLUME 1,"CALCULATIONAi.MODELS",and l

- VOLUME 2, "APPLICATION OF NEW EVALUATION MODEL" i

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TOPICAL REPORTS SCHEDULED FOR NRC SUBMITTAL l

IN april, 1988 l

ANALYSES OF THE ROSA-IV LARGE SCALE TEST f

FACILITY SBLOCA EXPERIMENTS ARE UNDERWAY i

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REQUESTED NRC ACTION REVIEW AND APPROVAL OF MODEL BY JANUARY, 1989

l TO SUPPORT UTILITY USE i

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o ANALYSIS SUBCOMMITTEE ALTERNATE LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) TRANSIENT LIMIT NRC CONTACT:

P. N, RANDALL ESTABLISH A P/T LIMIT FOR USE IN LTOP ANALYSIS ISSUE WHICH WOULD ALLOW HIGHER PRESSURES FOR LOW TEMPERATURF TFt"SIENT ASME SECTily XI JREENING CRITERIA ESTABLISHED PROVIDING N ' DENT SUCCESSFUL CEOG/NRC INTERACTIONS SEVERAL MEETINGS HELD WITH NRC YlE.';;u POSITIVE RESPONSE TO METHODOLOGY NRC INDICATED DESIRE TO SEE COST / BENEFIT ANALYSES OF ALTERNATE HARDWARE MODIFICATIONS STATUS WORK ON METHODOLOGY COMPLETE ADDITIONAL WORK SCOPE TO PROVIDE COST / BENEFITS EVALVATIONS UNDERWAY TOPICAL REPORT TO BE SUBMITTED 2ND QUARTER 1988 REQUESTED NRC ACTION REVIEW AND APPROVAL OF METHODOLOGY BY JANUARY, 1989

4 ANALYSIS SUBCOMMITTEE REACTOR COOLANT SYSTEM LEAK-BEFORE-BREAK' JUSTIFICATION NRC CONTACT:

ISSUE

' ALLOW CE0G UTILITIES TO ELIMINATE CONSIDERATION OF DYNAMIC EFFECTS OF PIPE RUPTURE FROM THE PLANT DESIGN BASIS SUCCESSFUL NRC INTERACTIONS ARIZONA PUBLIC SERVICE OBTAINED APPROVAL 0F EXEMPTION REQUEST FOR RELIEF FROM RCS PIPE BREAK DESIGN BASES FOR THE PALO VERDE UNITS ISSUANCE OF MODIFICATIONS TO GENERAL DESIGN CRITERIA 4 (GDC4) 0F 10CFR50 APPENDIX A STATUS CE0G TOPICAL RE?OJ

.cN-367, "LEAK-BEFORE-BREAK EVALUATION OF PRIMARY COOLANT LOOP PIPING IN COMBUSTION ENGINEERING DESIGNED NUCLEAR STEAM SUPPLY SYSTEMS", SUBMITTED FOR NRC REVIEW IN DECEMBER, 1987, REQUESTED NRC ACTION REVIEW AND APPROVAL 0F CEN-367 AS S00N AS POSSIBLE

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ANALYSIS SUBCOMMITTEE MAIN STEAM LINE LEAK-BEFORE-BREAK JUSTIFICATION.

NRC CONTACT:

ISSUE ALLOW CE0G UTILITIES TO ELIMINATE CONSIDERATION OF DYNAMIC EFFECTS OF STEAM LINE RUPTURE FROM THE PLANT DESIGN BASIS SUCCESSFUL NRC INTERACTION ISSUANCE OF BROAD SCOPE MODIFICATIONS TO GENERAL DESIGN CRITERIA 4 (GDC4i 0F 10CFR50 APPENDIX A STATUS TASK ONLY RECENTLY STARTED, WILL BE STRUCTURED MUCH LIKE THE RCS LEAK-BEFORE-BREAK EFFORT TOPICAL REPORT IS PLANNED FOR NRC SUBMITTAL FALL 1988 5

ANALYSIS SUBCOMMITTEE JUSTIFICATION FOR HIGHER FUEL INTERNAL GAS PRESSURE NRC CONTACT:

ISSUE FUEL R0D MAXIMUM INTERNAL GAS PRESSURE IN HIGH-BURNUP FUEL RODS (PARTICULARLY IN FUEL RODS BEING USED IN LONG RELOAD CYCLES) MAY EVENTUALLY.

EXCEED RCS PRESSURE AND POSSIBLY LIMIT REACTOR OPERATION FATES 3B CONTAINS FEATURES TO PROPERLY SIMULATE GAS RELEASE INSTEAD OF NRC IMPOSED BURNUP DEPENDENT FISSION GAS RELEASE ENHANCEMENT FACTOR IN NUREG-0418 SUCCESSFUL NRC INTERACTIONS MET WITH NRC STAFF IN SEPTEMBER, 1986: ENSURED THAT NRC CONCERNS WOULD BE ADDRESSED STATUS TOPICAL REPORT BEING PREPARED TO JUSTIFY HIGHER INTERNAL GAS PRESSURE, TO BE SUBMITTED SECOND QUARTER 1988 REQUESTED NRC ACTION REVIEW AND APPROVAL 0F TOPICAL REPORT FIRST QUARTER 1989

ANALYSIS SUBCOMMITTEE MODERATOR TEMPERATURE COEFFICIENT / ATWS INFORMATION REQUEST NRC CONTACT: ASH 0K THADANI NRC CONCERN THAT VALUES OF MODERATOR ISSUE TEMPERATURE COEFFICIENT (MTC) ARE BECOMING l.ESS NEGATIVE AND MAY IMPACT THE ATWS ANALYSES JUNE 12, 1987 LETTER TO CE0G CHAIRMAN FROM NRC REQUESTING MTC DATA SUCCESSFUL CE0G/NRC INTERACTION CEOG PRESENTATION TO NRC ON JANUARY 11, 1988 SHOWED NO TREND TOWARDS LESS NEGATIVE MTC N0 SIGNIFICANT IMPACT ON ESTIMATED PEAK PRESSURE FOR ATWS COMPARED TO 1979 VALUES STATUS CE0G PREPARING LETTER TO NRC TO DOCUMENT MEETING INFORMATION

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OPERATIONS SUBCOMMITTEE WALT WINDECKER (FP&L), CHAIRMAN AND CE0G CONTACT (305) 468-4220

-- OVERVIEW --

CE0G/NRC INTERACTION EMERGENCY PROCEDURE GUIDELINES i

CHARGING PUMP PERFORMANCE IMPROVEMENT PROGRAM 0THER ACTIVITIES SCRAM REDUCTION PROGRAM i

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OPERATIONS SUBCOMMITTEE i

EMERGENCY PROCEDURE GUIDELINES NRC CONTACT:

WAYNE H0DGES i

REVIEW 0F FINAL SUBMITTAL 0F CEN-152, REVISION 03 AND f

ISSUE RESULTING SER l

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CEN-152, REV 03 FINAL SUBMITTAL TO NRC WAS MADE OCTOBER 1, 1987 l

i LEAD REVIEWER ASSIGNED IN JANUARY, 1988 l

NEW REVIEWER IS ASSIGNED FROM RSB NO PRIOR INVOLVEMENT WITH CEN-152 I

REVIEW STATUS MEETING TENTATIVELY SET FOR FEBRUARY 10, 1988 1

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OPERATIONS SUBC0fEITTEE EMERGENCY PROCEDURE GUIDELINES NRC CONTACT:

WAYNE H0DGES l

t SUCCESSFUL NRC/CEOG INTERACTION CE0G HAS MADE TWO PRIOR SUBMITTALS OF REV. 03 NRC HAS APPROVED IMPLEMENTATION OF SUBMITTALS 1 AND 2 IN DECEMBER, 1985 AND NOVEMBER, 1986 RESPECTIVELY 1

REQUESTED NRC ACTION LIMIT SCOPE OF REVIEW TO TECHNICAL CHANGES SINCE NRC APPROVAL TO IMPLEMENT SUBMITTAL 2 0F REV. 03 i

(N0VEMBER, 1986)

MAINTAIN EXISTING REVIEWER ASSIGNMENT THROUGH COMPLETION AND ISSUE OF THE SER i

OPERATIONS SUBCOMMITTEE CHARGING PUMP PERFORMANCE IMPROVEMENT PROGRAM NRC CONTACT:

DENNIS'CRUTCHFIELD 0

CE0G/NRC INTERACTION ON BLOCK CRACKING BEGAN IN 1986 0

CE0G FUNDED TASKS IN 1987 TO EVALUATE THE BLOCK CRACKING CONCERN AND PUMP AVAILABILITY O

TASKS FINDINGS SUMMARIZED ON FOLLOWING SLIDES l

CEOG CHARGING PUMP RELIABILITY IMPROVEMENT PROGRAM i

BACKGROUND CE0G CHARGING PUMP STUDIES TASK OVERVIEW

-i PRELIMINARY FINDINGS i

ON-G0ING ACTIVITIES i

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BACKGROUND ISSUES HIGH CHARGING PUMP MAINTENANCE NUMBER OF PUMP BLOCKS HAVE CRACKED NRC CONCERNED WITH CHARGING PUMP RELIABILITY EFFORTS TO RESOLVE RELIABILITY ISSUES INDIVIDUAL UTILITY PROGRAMS TO IMPROVE RELIABILITY CE0G EFFORTS PROVIDE SHARED KNOWLEDGE BASE TO RESOLVE CHARGING PUMP RELIABILITY CHARGING PUMP MAINTENANCE WORK SHOPS CHARGING PUMP RELIABILliY IMPROVEMENT PROGRAM 4

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CHARGING PUMP-RELIABILITY IMPROVEMENT PROGRAM G0ALS IDENTIFY CONTRIBUTORS TO CHARGING PUMP UNAVAILABILITY QUANTIFY THE MAGNITUDE OF EACH CONTRIBUTOR IDENTIFY IMPROVEMENTS TO INCREASE PUMP AVAILABILITY DETERMINE SAFETY IMPACT / PLANT AVAILABILITY IMPACT OF CHARGING PUMPS PROVIDE MECHANISM TO SHARE PUMP PERFORMANCE IMPROVEMENTS t

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CHARGING PUMP RELIABILITY IMPROVEMENT PROGRAM SCOPE UPDATE 1984 DATA BASE ANALYZE TRENDS QUANTIFY PUMP UNAVAILABILITY PUMP PERFORMANCE STUDY IDENTIFY PROBLEMS IDENTIFY IMPROVEMENTS CHARGING PUMP OPERABILITY OPERABILITY / SURVEILLANCE REQUIREMENTS OVERVIEW 0F CRACK INITIATION / PROPAGATION STUDIES IDENTIFY OPERATING EXPERIENCE CVCS INTERACTIONS - PUMP CRACKING TRENDS CORRELATE CVCS CONFIGURATION /0PERATION TO PUMP BLOCK FAILURES DETERMINE ACTUAL PUMP BLOCK OPERATING TIME FOR FAILED BLOCKS

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CHARGING PUMP UNAVAILABILITY DETERMINE CONTRIBUTORS TO UNAVAILABILITY QUANTIFY OVERALL PUMP UNAVAILABILITY SIGNIFICANT IMPROVEMENT FROM 1984-1986 UNAVAILABILITY FIGURES IN INP0 NPRDS OVERSTATE PUMP UNAVAILABILITY BLOCK FAILURES ARE SMALL CONTRIBUTOR TO CHARGING PUMP UNAVAILABILITY UTILITY RESOURCES SPENT ON IMPROVING THE MAJOR CONTRIBUTORS TO PUMP UNAVAILABILITY PUMP PACKING / PLUNGER REPLACEMENT CHECK VALVE REPLACEMENT i

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PUMP UNAVAILABILITY TIME INP0 NPRDS SYSTEM PUMPS CALLED UNAVAILABLE i

PUMPS REMOVED FROM SERVICE FOR DISCRETIONARY REASONS PUMP COULD DELIVER REQUIRED FLOW TO RCS IN AN EMERGENCY THE PUMP COULD HAVE BEEN RETURNED TO SERVICE ACTVAL TIME PUMPS COULD NOT DELIVER REQUIRED FLOW WAS MUCH LESS THAN REPORTED IN NPRDS UNAVAILABILITY TIME (NPRD) INCLUDES THE TIME FROM IDENTIFYING NEED FOR PUMP MAINTENANCE UNTIL THE l

PUMP IS RETURNED TO UNRESTRICTED USE, l

REPORTED UNAVAILABILITY TIME AFFECTED BY:

ESTABLISHING CONDITIONS REQUIRED FOR REPAIR ACTUAL REPAIR TIME RETESilNG i

SCHEDULING DELAYS 1

PRIORITY AVAILABLE MANPOWER REPAIRS CAN BE AFFECTED IN MUCH SHORTER TIME FRAMES IF REQUIRED l

PACKING REPLACEMENT 8 - 16 HOURS CHECK VALVE REPLACEMENT 8 - 16 HOURS CHARGING PUMP BLOCK 13 - 20 HOURS i

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0 EARING CRACKED PutSATintt GASKETS VIBilATiott OTilER PACKIts SEALS CitECK SUCTION FAILURE BLOCKS DAMPENElt It IMICED PlutMERS VALVES STABILIZER B

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s PUMP BLOCK CRACKS SMALL CONTRIBUTOR TO UNAVAILABILITY <10%

CHARGING PUMP BLOCK CRACKS DO NOT. POSE A SAFETY CONCERN BLOCKS CRACK DUE TO CYCLIC FATIGUE SLOW FAILURE MECHANISM CAN BE IDENTIFIED BEFORE EXCESSIVE LEAKAGE OCCURS BLOCKS HAVE NOT CRACKED SIMULTANE0USLY BLOCK FAILURES HAVE NOT PREVENTED CONTINUED PLANT OPERATION I

BLOCK DESIGN IMPROVEMENTS

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DESIGN IMPROVEMENTS HAVE BEEN MADE TO INCREASE-BLOCK LIFE IMPROVED BLOCKS ARE JUST NOW BEING INSTALLED IN PLANTS l

CHARGING PUMP OPERABILITY REQUIREMENTS PURPOSE ENSURE THAT THE BORON INJECTION SYSTEM CAN SUPPLY NEGATIVE REACTIVITY CONTROL IS AVAILABLE FOR ALL MODES OF PLANT OPERATION TECHNICAL SPECIFICATION REQUIREMENT 3.1.2.4 REACTIVITY CONTROL SYSTEMS -

CHARGING PUMPS - OPERATING f

TWO PUMPS I

ALLOWS 72 HOUR ACTION STATEMENT L

I CEOG EXPERIENCE 16 LER WRITTEN 1984 THROUGH 1986 ON CHARGING PUMPS j

FOUR EVENTS REPORTED THAT LESS THAN TWO CHARGING PUMPS WERE OPERABLE ONE EVENT RESULTED IN AN ORDERLY PLANT SHUTDOWN BECAUSE-THE PLANT KNEW SPARE l

PARTS WOULD BE UNAVAILABLE FOR THE DURATION OF THE ACTION STATEMENT THREE-EVENTS THE CHARGING PUMPS WERE RESTORED TO AN OPERABLE STATUS WITHIN THE TIME FRAME OF THE ACTION STATEMENT i

NO REPORTED INSTANCES WHERE A PLANT HAS CRACKED TWO BLOCKS AT THE SAME TIME e

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I CHARGING PUMP BLOCK MODIFICATIONS i

TO POTENTIALLY REDUCE BLOCK CRACKING j

l INCREASED RADIUS AT INTERSECTION OF VALVE AND PLUNGER BORES I

SH0T PEENED INTERIOR OF THE BLOCKS AT THE INTERSECTION COMPARE FORGED BLOCKS TO CAST BLOCKS CHANGE MATERIAL TO 17-4 PH STAINLESS STEEL

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9 ON-G0ING ACTIVITIES DEVELOPMENT OF CHARGING PUMP /CVCS MODEL ASSESS THE SYSTEM CONFIGURATION AFFECTS ON PUMP INTERNAL PRESSURE INSITU TESTING 0F CHARGING PUMPS f

CONTINUED EXPERIMENTATION WITH NEW PACKING DESIGNS I

t I

SUMMARY

CE0G HAS INVESTIGATED CHARGING PUMP RELIABILITY ISSUES THESE STUDIES SHOW CHARGING PUMP UNAVAILABILITY IS DECREASING CEOG PLANTS HAVE AGGRESSIVELY PURSUED THE MAJOR CONTRIBUTORS TO UNAVAILABILITY - PUMP PACKING /

PLUNGER REPLACEMENT AND CHECK VALVE REPLACEMENT CHARGING PUMP BLOCKS SMALL CONTRIBUTION TO UNAVAILABILITY CRACK DUE TO FATIGUE - A SLOW FAILURE MECHANISM THAT DOES NOT ADVERSELY IMPACT PLANT SAFETY IMPROVED BLOCK DESIGNS HAVE BEEN FABRICATED AND SHOULD IMPROVE BLOCK LIFE CE0G CHARGING PUMP RELIABILITY IMPROVEMENT PROGRAM HAS PROVIDED A VEHICLE F0P MEMBER UTILITIES TO SHARE INFORMATION AND EXCHAhiE DESIGN AND MAINTENANCE INFORMATION THAT SHOULO IMPROVE CHARGING PUMP AVAILABILITY l

i

OPERATIONS SUBCOMMITTEE SCRAM REDUCTION PROGRAM 0

PROGRAM ELEMENTS PARALLEL INP0 CATEGORIES FOR SCRAM REDUCTION PROGRAM 0

SUBCOMMITTEE MEETS QUARTERLY TO DISCUSS PREVIOUS QUARTER SCRAMS, DISCUSSIONS INCLUDE:

GENERIC APPLICABILITY ROOT CAUSE CORRECTIVE ACTIONS TO PREVENT RECURRENCE 0

SUBCOMMITTEE CHAIRMAN MEETS WITH OTHER OWNERS GROUPS SCRAM REDUCTION CCMMITTEE CHAIRMEN TO SHARE DR0 GRAM INFORMATION 0

SCRAM DATA BASE BEING CREATED 0

ROOT CAUSE DETERMINATION GUIDELINES DEVELOPED

TECHNICAL SPECIFICATIONS AND LICENSING SUBCOMMITTEE DICK BERNIER (APS), SUBCOMMITTEE CHAIRMAN AND CE0G CONTACT (602) 371-4295 t

OVERVIEW 4

CEOG/NRC IRTERACTION i

o TECH $PEC RESTRUCTURING RPS/ESFAS TEST INTERVAL EVALVATION REFUELING OUTAGE SURVEILLANCE TEST INTERVALS j

i l

a TECHNICAL SPECIF.,ATIONS AND LICENSING SUBCOMMITTEE TECHNICAL SPECIFICATION RESTRUCTURING-NRC CONTACT:

MILLARD WOHL RESTRUCTURE TECHNICAL SPECIFIC?-TIONS BY APPLICATIONS ISSUE OF CRITERIA FOR TECH SPEC SPLITTING SUCCESSFUL CE0G/NRC INTERACTION REPORT CEN-355 (STS SPLIT RESULTS) SUBMITTED DECEMBER 11, 1987 FOR NRC REVIEW FEEDBACK EXPECTED BY FEBRUARY 20, 1988 STATUS COLLABORATING WITH WOG, BWOG, BWROG ON RSTS DEVELOPMENT COMPLETION EXPECTED BY EARLY 1989 REQUESTED NRC ACTION PROVIDE FEEDBACK ON CEN-355 BY FEBRUARY 20 i

TO SUPPORT DISCUSSIONS AT FEBRUARY 24 AND 25 CE0G MEETING n,v.-..

, _ _. _r_,y-,

.__m

,.m.,

TECHNICAL SPECIFICATIONS AND LICENSING SUBCOMMITTEE RPS/ESFAS TEST INTERVAL EVALUATION NRC CONTACT:

SCOTT NEWBERRY JUSTIFY EXTENDED SURVEILLANCE TEST INTERVALS FOR THE ISSUE REACTOR PROTECTION SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM SUCCESSFUL CE0G/NRC INTERACTION REPORT CEN-327 SUBMITTED TO NRC JUNE, 1986 EG&B TER COMPLETED JULY, 1987 MEEETING ON JANUARY 14 WITH NRC STATUS NRC REVIEW TO BEGIN FEBRUARY, 1988 COMPLETION PROMISED BY END OF MARCH, 1988 REQUESTED NRC ACTION COMPLETE REVIEW BY CURRENT SCHEDULE

,'t t

l TECHNICAL SPECIFICATIONS AND LICENSING SUBCOMMITTEE REFUELING OUTAGE SURVEILLANCE TEST INTERVALS NRC CONTACT:

MILLARD WOHL EXTEND SURVEILLANCE INTERVALS FOR TECH SPECS ISSUE IMPACTING EXTENDED FUEL CYCLES SUCCESSFUL CEOG/NRC INTERACTION MET WITH NRC ON JANUARY 14, 1988 DISCUSSED APPROACHES FOR JUSTIFICATION OF EXTENSIONS r

STATUS FURTHER CEOG WORK UNDER CONSIDERATION TWO CEOG MEMBER UTILITIES CURRENTLY WORKING ON i

EXTENSIONS.

BOTH CURRENTLY IN A 24 MONTH CYCLE.

REQUESTED NRC ACTION SUPPORT THE TWO CEOG MEMBER t

UTILITIES CURRENTLY PURSUING TEST INTERVAL EXTENSION i

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CE0G/NRC POLICY ISSUES 0

COMMUNICATIONS 0

TOPICAL REPORT REVIEW P

su

,4

.a NRC/CEOG C0thit!NICAT10NS O

CE0G POLICY CE0GSBMNTALSTONRCNOTAPPLICABLE TO INDIVIDUAL LICENSEES UNTIL REFERENCED BYLICENS$EONHISDOCKET NRCLdVESTIONs~CNCEOGSUBMITTALSHOULD BE ADDRESSED TO CE0G CHAIRMAN i

r s

t n.

REQUESTS F0'd !!50RMAT10N ON NEW ISSUES

~

SHOULD BE' ADDRESSED TO INDIVIDUAL LICE'NSEES

\\

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l-INFORMATION ITEMS CAN BE SP;T BY NRC TO CE0G CHAIRMA'N' 0

CE0G ENCOURAGES INFORMAL MEETitiGS ON CEOG SUBMITTALS O

CURRENT CONCERNS CE0G HAS RECEIVED COMMUNICATIONS THAT TEND TO TREAT GROUP AS A LICENSEE i

O DISCUSSION M

C i 4 NRC REVIEW 0F CE0G TOPICAL REPORTS 0

CE0G TOPICAL REPORTS USED TO OBTAIN NRC ACCEPTANCE OF GENERIC WORK 0

BENEFITS OF TOPICAL REPORTS ALLOWS FOR EFFICIENT USE OF CE0G AND NRC RESOURCES ENCOURAGES COMMON APPROACH AMONG OWNERS FOR RESOLVING TECHNICAL ISSUES i

O CURRENT CONCERNS LACK OF TIMELY REV!FW CUMBERSOME PROCESS VIABILITY OF THIS APPROACH IN QUESTION UTILITIES QUESTIONING USEFULNESS OF CEOG FOR OBTAINING NRC APPROVAL OF UTILITY INITIATIVES O

LISCUSSION a

x

't

DISTRIBUTION:

T

.TEB l'61988 AD RI RF-

-AJMendiola BABoger

SAVarga FMiraglia Slee-

~BElliot AThadani

~WHodges RPerfetti Shou LMarsh MHartzman

+

tJR PoR q

'o UNITED STATES

- ~,,

NUCLEAR REGULATORY COMMISSION e

i I

WASHINGTON, D. C. 20555 y*****j February 16, 1988 MEM00ANDUM FOR:

Bruce A. Boger, Assistant Director for Region I Reactors Division of Reactor Projects I/II FROM:

Anthony J. Mendiola Technical Assistant for Region I Reactors Division of Reactor Projects I/II

SUMMARY

OF MEETING HELD ON JANUARY 28, 1988 WITH COMBUSTION ENGINEERING OWNERS GROUP A meetino was held on January 28, 1988, between representatives of the NRC staff and members of the Combustion Engineering Owners' Group (CEOG) to discuss recent CEOG activities and CE0G/NRC policy issues.

A list of attendees and the slides presented are enclosed.

The curpose of the meeting was to seek improvement in CEOG/NRC communications, identify interfaces, and to sumarize agreements between the two groups.

Dr. Joe Gasper, Chairman of the CEOG, began the presentation with an introduction of those CEOG representatives present.

This was followed by CE0G subcomittee and task force brie #ings on current activities. The six orcups which made a presentation were:

1.

Reliability and Availability Suecommittee 2.

Materials and Chemistry Subcomittee 3.

Configuration Management Task Force 4.

Analysis Subcomittee 5.

Operations Subcommittee 6.

Technical Speci'ications and Licensing Subcomittee All of the groups highlichted their current activities and listed planned future actions. The Operations Subcomittee presented a detailed review of CEOG activities to date on the Charging Pump Performance Improvement Program which is concerned primarily with pump non-availability due to block cracking.

Since each issue will require some CEOG/NRC interface, the appropriate NRC Doints of contact were indicated.

A list of named NRC contacts is enclosed, f

O Bruce A. Boger

-?-

February 16, 1988 Upon completioc of the CEOG presentations, discussion was coened regarding CEOG/NPC policy i: Sues, particularly NRC/CEOG comunications and NRC reviaw of CEOG Topical Peports.

Regardino corrunications, CEOG expcessed the concern that the NRC is regarding thenh as : licensee.

HDC understond the concern and efforts would be made in the future to clear up misunderstandings with informal telephone calls.

Regarding the NRC review of CEOG Topical Reports, CEOG expressed the concerns that timely NRC review was not being performed on their CE0G submittals and that there was at least the appearance that other Owners' Groups seemed to resolve their issues ruch faster.

DEST representatives outlined for the CEOG members present the current resource allocations restraints for the review of these reports and the proposed new a

orioritization scheme for DEST work.

NRC stated that if the CEnG assisted the review process up front, the NRC turn-around time on these reports could be shortened. Specific CEOG assistance would be appreciated for:

1.

Pre-submittal decisions by the CE0G as to which issues are of the greatest importance.

These issues wr,uld be given the appropriate NRC attention.

2.

Submittal of specific application criteria. What is the necessary time table the NPC needs to adhere to so that CE plant operation schedules are not severely impacted? Which plants would be impacted?

l 3.

CEOG topical reports must come in on the specific docket or dockets affected in order to be reviewed.

I i

NRC merbers further comented that if a CEOG issues imnacts more than one l

plant, then a CRGD board review would be required, adding at least one to two

]

months to the topical review process.

After a brief discussion of proposed 'uture CE0G/NRC issues and an open invitation for tlRC attendance to a CEOG meeting in the 'uture, the meeting was adjourned.

Anthony J. Mendiola. Technical Assistant for Region i Reactors Division of Reactor Projects I/II

Enclosures:

As stated cc w/ enclosures-See next pace 1

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t Bruce A. Boger February 16, 1988 cc w/ enclosures:

Dr. Joseph K. Gasper,, Chairman C-E Owners Group

.c/o Omaha Public Power District 1623 Harney Omaha, NE 68102 Mr. Jim Pfiefer Combustion Engineering, Inc.

1000 Prospect Hill Road Windsor, CT 06095-0500 i

t Mr. Charles Brinkman Combustion Engineering, Inc.

7910 Woodmont Avenue, Suite 1310 Bethesda, MD 20814 i

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ENCLOSURE NRC/CE0G INTERFACE MEETING JANUARY 28, 1988 NAME ORGANIZATION S. Lee NRC/ DEST B. Elliot NRC/ DEST P. Richardson CEOG C. Gimbrene CE0G P. Nelson CEOG J. Pfeifer CEOG/CE J. Gasper CEOG/0 PPD A. Thadani NRC/ DEST R. Phelps CEOG/SCE W. Hodges NRC/ DEST J. Williams CEOG/RGAE W. Windecker CEOG/FPL R, Bernier CEOG/APS J. Hutchinson CEOG/FPL B. Boger NRC/NRR A. Mendiola NRL/NRR 4

F. Miraglia NRC/NRR R. Perfetti NRC/ DEST S. Hou NRC/ DEST C. Brinkran CE L. Marsh NRC/ DEST M. Hartzman NRC/ DEST 1

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t ENCLOSURE LISTING OF NRC CONTACTS t

TECHNICAL REVIEWER DESIGNATION ISSUE DIVISION 1.

EMERGENCY PROCEDURE GUIDELINES DEST (S. SUN -- SRXB) 2.

CHARGING PUMP PERFORMANCE IMPROVEMENT DEST (M. HARTZMAN -- EMEB)

PROGRAM 3.

RESTRUCTURED TECHNICAL SPECIFICATIONS 00EA (M. WOHL -- OTSB) 4.

RPS/ESFAS TEST INTERVAL EXTENSION DEST (S. RHOW -- SELB) 5.

REFUELING SURVEILLANCE FRE0VENCY EXTENSION DEST (R. PERFETTI -- SPLB) 6.

HIGHER FUEL INTERNAL GAS PRESSURE DEST (S. L. WV -- SRXB) 7.

REACTOR COOLANT SYSTEM LEAK-BEFORE-BREAK DEST (S. LEE -- EMEB)

JUSTIFICATION 8.

MAIN STEAM LINE LEAR-BEFORE-BREAK DEST (S. LEE--EMEB)

JUSTIFICATION 9.

LTOP TRANSIENT LIMIT DEST (B. ELLIOT -- EMEB)

10. NEW SMALL BREAK LOCA METHODS DEST (Y. H. HSII -- SRXB) i I

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L AGENDA l

t CEOG/NRC Meeting t

. January 28, 1988 Philips Building Room P-118 l

l Bethesda, Maryland 2

9:00 am INTRODUCTION Opening Statements Frank Miraglia (NRC) 4 Joe Gasper (OPPD1 i

f t

CEOG Update Joe Gasper (OPPD)

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Analysis Subcommittee Activities' Report'

}

Jerry Holman (LP&L) o SB LOCA Margin Improvement Program i

o Alternate Low Temperature Overpressure j

Protection Transient Limit I

o Reactor Coolant System Leak-Before-Break l

j Justification I

o Main Steam Line Leak-Before-Break Justification o

Justification for Higher Fuel Internal i

Gas Pressure i

o Moderator Temperature coefficient /ATWS j

Information Request i

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operat:.ons Subcommittee Activities Report Walt W:.ndecker ( FP&L) i I

o EPGs, Revision 01 1

1 o

Charging Pump Performance Improvement Program I

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Technical Specification and Licensino Subcomittee Activities Report Dick Bernier ( APS) i o

Tech Spec Restructuring o

RPS/ESTAS Test Interval Evaluation o

Surveillance Test Intervals Based on Refueling Outages P

CEOG/NRC Policy Issues o

Communications o

Topical Report Review d

i NRC Input to the C-E Owners Group j

a 12:00 ADJOURN f

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CE0G/NRC MEETIrlG l

JANUARY 28, 1988 i

BETHESDA, MARYLAND 4

MEETING OBJECTIVES b

1 IMPROVE COMMUNICATIONS IDENTIFY INTERFACES SUMMARIZE AGREEMENTS I

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CEOG UPDATE CURRENT OFFICERS 1

CHAIRMAN J0E GASPER (0 PPD)

.VICE CHAIRMAN ED STERLING (APS)

STEERING COMMITTEE MIKE MEISNER (LP&L)

RALPH PHELPS (SCE)

{

JOHN HUTCHINSON (FP&L)

RRG CHAIRMAN TED ENOS (AP&L)

RRG VICE CHAIRMAN MARK MEDFORD (SCE) f i

e CE0G SUBCOMMITTEES / TASK FORCE SUBCOMMITTEES CHAIRMAN ANALYSIS JERRY HOLMAN (LP&L)

OPERATIONS WALT WINDECKER (FP&L)

TECHNICAL SPECIFICATIONS DICK BERNIER (APS)

AND LICENSING RELIABILITY AND AVAILABILITY PAYSON SIERER (BG&E)

MATERIALS & CHEMISTRY JOHN KLISIEWICZ (NU)

CONFIGURATION MANAGEMENT TASK FORCE BOB DIEDRICH (BG&E)

RELIABILITY AND AVAILABILITY SUBCOMMITTEE PAYSON SIERER (BG&E), CHAIRMAN SUBCOMMITTEE ESTABLISHED BY CE0G IN JUNE, 1987 MISSION OF SUBCOMMITTEE IS TO PROVIDE A FORUM T0:

IDENTIFY, REVIEW, AND RESOLVE RELIABILITY, AVAILABILITY, AND PLANT PERFORMANCE ISSUES GENERIC TO CEOG PLANTS THE CEOG RELIABILITY AND AVAILABILITY SUBCOMMITTEE IS:

t TAKING THE INITIATIVE TO IDENTIFY THE CONTRIBUTORS TO j

UNAVAILABILITY AT THEIR UNITS IN ORDER TO ESTABLISH i

PROGRAMS TO REDUCE UNAVAILABILITY l

ACTIVELY FOLLOWING THE EPRI RELIABIITY CENTERED MAINTENANCE PROGRAM l

CONSIDERING DEVELOPMENT OF A REACTL VESSEL SURVEILLANCE PROGRAM FOR DESIGN LIFE ATTAINMENT AND LIFE EXTENSION i

TAKING RESPONSIBILITY TO BRING OTHER LIFE EXTENSION j

ISSUES TO THE ATTENTION OF THE CEOG

MATERIALS & CHEMISTRY SUBCOMMITTEE l

JOHN KLISIEWICZ (NU), CHAIRMAN SUBCOMMITTEE ESTABLISHED BY CE0G IN JUNE, 1987 MISSION OF SUBCOMMITTEE IS TO PROVIDE A FORM T0:

i IDENTIFY, REV.W AND RESOLVE MATERIALS, CHEMISTRY, AND CORROSION ISSUES GENERIC TO CE0G PLANTS l

TH'. SUBCOMMITTEE IS:

CREATING A NON-METALLIC MATERIALS DATA BASE DEVELOPING A STEAM GENERATOR CORROSION MODEL FOLLOWING RCP MATERIALS ISSUES 1

EVALUATING CLOSED LOOP COOLING WATER CORROSION

)

INHIBITORS l

EVALUATING ALTERNATE STUD LUBRICANTS

CONFIGURATION MANAGEMENT TASK FORCE BOB DIEDRICH (BG&E), CHAIRMAN TASK FORCE ESTABLISHED IN FEBRUARY 1987 TO FOCUS ON ASSEMBLING AND INDEXING DOCUMENTS NECESSARY TO RECONSTITUTE DESIGN BASES FOR CEOG PLANTS PHASE 1 FEASABILITY STUDY TO ASSESS THE MAGNITUDE OF THE NUMBER OF DOCUMENTS AVAILABLE, THEIR LOCATIONS, AND THE SCOPE OF EFFORT NEEDED TO ASSEMBLE AND INDEX l

PHASE 2A ASSEMBLY AND INDEXING OF DOCUMENTS RELATED TO THE

]

DESIGN BASES FOR THE SAFETY INJECTION / CONTAINMENT SPRAY SYSTEMS OF CE0G PLANTS 4

THIS EFFORT SCHEDULED FOR COMPLETION MARCH 1, 1988 PHASE 2B ASSEMBLE AND INDEX DOCUMENTS FOR THE REMAINDER 0F THE NSSS SYSTEMS SCHEDULE TO BE DETERMINED 2

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t ANALYSIS SUBCOMMITTEE 1:

JERRY HOLMAN (LP&L), CHAIRMAN AND CE0G CONTACT (504) 467-2791 x265 PRESENTED BY J0E WILLIAMS (BG&E) l

-- OVERVIEW --

CEOG/NRC INTERACTION SMALL BREAK LOCA MARGIN IMPROVEMENT PROGRAM ALTERNATE LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) TRANSIENT LIMIT REACTOR COOLANT SYSTEM LEAK-BEFORE-BREAK JUSTIFICATION MAIN STEAM LINE LEAK-BEFORE-BREAK JUSTIFICATION JUSTIFICATION FOR HIGHER FUEL INTERNAL GAS PRESSURE I

MODERATOR TEMPERATURE COEFFICIENT / ATWS INFORMATION REQUEST OTHER ACTIVITIES E0P INSTRUMENT ACCURACIES CEA INTEGRITY STUDIES ICI LIFE EXTENSION i

l ANALYSIS SUBCOMMITTEE SMALL BREAK LOCA MARGir IMPROVEMENT NEW EVALVATION MODEL DEVELOPMENT NRC CONTACT:

NORM LAUBEN ISSUE IMPROVED ECCS EVALUATION MODEL TO LESSEN OPERATIONAL RESTRICTIONS l

1 SUCCESSFUL CEOG/NRC INTERACTION I

NRC AGREEMENT THAT SECY 83-472 APPLIES TO i

SMALL BREAK LOCA MODELING POSITIVE FEEDBACK FROM NRC ON LIMIT J

VALUE APPROACH ADDITIONAL TEST COMPARISONS RECOMMENDED BY NRC AT JANUARY, 1987 MEETING j

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1 ANALYSIS SUBCOMMITTEE a

SMALL BREAK LOCA MARGIN IMPROVEMENT NEW EVALVATION MODEL DEVELOPMENT NRC CONTACT:

NORM LAUBEN STATUS i

MODEL DEVELOPMENT COMPLETE DRAFT REPORTS UNDER REVIEW BY CEOG "NEW SMALL BREAK LOCA EVALUATION MODEL"

- VOLUME 1, "CALCULATIONAL MODELS", and

- VOLUME 2 "APPLICATION OF NEW EVALVATION MODEL"

~

TOPICAL REPORTS SCHEDut:D FOR NRC SUBMITTAL IN APRIL, 1988 ANALYSES OF THE ROSA-IV LARGE SCALE TEST FACILITY SBLOCA EXPERIMENTS ARE UNDERWAY REQUESTED NRC ACTION REVIEW AND APPROVAL OF MODEL BY JANUARY, 1989 TO SUPPORT UTILITY USE

y ANALYSIS SUBCOMMITTEE ALTERNATE LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) TRANSIENT LIMIT' j

NRC CONTACT:

P. N. RANDALL ISSUE ESTABLISH A'P/T LIMIT FOR USE IN LTOP ANALYSIS i

WHICH WOULD ALLOW HIGHER' PRESSURES FOR LOW.

TEMPERATURE TRANSIENT ASME SECTION XI SCREENING CRITERIA ESTABLISHED i

PROVIDING PRECEDENT l

l SUCCESSFUL CEOG/NRC INTERACTIONS SEVERAL MEETINGS HELD WITH NRC YlELDED POSITIVE RESPONSE TO METHODOLOGY i

NRC INDICATED DESIRE TO SEE COST / BENEFIT ANALYSES OF ALTERNATE HARDWARE MODIFICATIONS i

STATUS WORK ON METHODOLOGY COMPLETE ADDITIONAL WORK SCOPE TO PROVIDE COST / BENEFITS EVALVATIONS UNDERWAY TOPICAL REPORT TO BE SUBMITTED 2ND QUARTER 1988 REQUESTED NRC ACTION

{

REVIEW AND APPROVAL OF METHODOLOGY BY JANUARY, 1989

I ANALYSIS SUBCOMMITTEE REACTOR COOLANT SYSTEM LEAK-BEFORE-BREAK JUSTIFICATION NRC CONTACT:

ISSUE ALLOW CE0G UTILITIES TO ELIMINATE CONSIDERATION OF DYNAMIC EFFECTS OF PIPE RUPTURE FROM THE PLANT DESIGN BASIS SUCCESSFUL NRC INTERACTIONS ARIZONA PUBLIC SERVICE OBTAINED APPROVAL 0F EXEMPTION REQUEST FOR RELIEF FROM RCS P!PE BREAK DESIGN BASES FOR THE PALO VERDE UNITS i

ISSUANCE OF MODIFICATIONS TO GENERAL DESIGN CRITERIA 4 (GDC4) 0F 10CFR50 APPENDIX A l

STATUS CEOG TOPICAL REPORT CEN-367, "LEAK-BEFORE-BREAK EVALUATION OF PRIMARY COOLANT LOOP PIPING IN COMBUSTION ENGINEERING DESIGNED NUCLEAR STEAM SUPPLY SYSTEMS", SUBMITTED FOR NRC REVIEW IN DECEMBER, 1987.

REQUESTED NRC ACTION REVIEW AND APPROVAL OF CEN-367 AS S00N AS POSSIBLE i

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i ANALYSIS SUBCOMMITTEE-1

(

MAIN STEAM LINE LEAK-BEFORE-BREAK JUSTIFICATION l

l NRC CONTACT:

ISSUE ALLOW CEOG UTILITIES TO ELIMINATE CONSIDERATION OF

)

DYNAMIC EFFECTS OF STEAM LINE RUPTURE FROM THE PLANT DESIGN BASIS l

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SUCCESSFUL NRC INTERACTION l

ISSUANCE OF BROAD SCOPE MODIFICATIONS TO GENERAL l

l DESIGN CRITERIA 4 (GDC4) 0F 10CFR50 APPENDIX A '

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STATUS

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TASK ONLY RECENTLY STARTED, WILL BE STRUCTURED i

MUCH LIKE THE RCS LEAK-BEFORE-BREAK EFFORT I

TOPICAL REPORT IS PLANNED FOR NRC SUBMITTAL I

l FALL 1988 i

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l ANALYSIS SUBCOMMITTEE JUSTIFICATION FOR HIGHER FUEL INTERNAL GAS PRESSURE l

NRC CONTACT:

ISSUE FUEL R0D MAXIMUM INTERNAL GAS PRESSURE IN HIGH-BURNUP FUEL RODS (PARTICULARLY IN FUEL RODS I

BEING USED IN LONG RELOAD CYCLES) MAY EVENTUALLY EXCEED RCS PRESSURE AND POSSIBLY LIMIT REACTOR OPERATION l

FATES 3B CONTAINS FEATURES TO PROPERLY SIMULATE GAS RELEASE INSTEAD OF NRC IMPOSED BURNUP DEPENDENT FISSION GAS RELEASE ENHANCEMENT FACTOR IN NUREG-0418 i

SUCCESSFUL NRC INTERACTIONS MET WITH NRC STAFF IN SEPTEMBER, 1986: ENSURED THAT NRC CONCERNS WOULD BE ADDRESSED I

STATUS TOPICAL REPORT BEING PREPARED TO JUSTIFY HIGHER

(

INTERNAL GAS PRESSURE, TO BE SUBMITTED SECOND QUARTER 1988 s

REQUESTED NRC ACTION REVIEW AND APPROVAL OF TOPICAL REPORT FIRST i

l QUARTER 1989

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ANALYSIS SUBCOMMITTEE MODERATOR TEMPERATURE COEFFICIENT / ATWS INFORMATION REQUEST NRC CONTACT: ASH 0K THADAN!

ISSUE NRC CONCERN THAT VALUES OF MODERATOR TEMPERATURE COEFFICIENT (MTC) ARE BECOMING

^

LESS NEGATIVE AND MAY IMPACT THE ATWS ANALYSES J

JUNE 12, 1987 LETTER TO CE0G CHAIRMAN FROM NRC REQUESTING MTC DATA i

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SUCCESSFUL CEOG/NRC JNTERACTION 1

CEOG PRESENTATION TO NRC ON JANUARY 11, 1988 q

j SHOWED NO TREllD TOWARDS LESS NEGATIVE MTC NO SIGNIFICANT IMPACT ON ESTIMATED PEAK PRESSURE FOR ATWS COMPARED TO 1979 VALUES STATUS l

CEOG PREPARING LETTER TO NRC TO DOCUMENT MEETING INFORMATION I

E t

t OPERATIONS SUBCOMMITTEE I

i WALT WINDECKER (FP&L), CHAIRMAN AND CEOG CONTACT (305) 468-4220 t

I

-- OVERVIEW --

)

i CEOG/NRC INTERACTION 1

EMERGENCY PROCEDURE GUIDELINES l

i CHARGING PUMP PERFORMANCE IMPROVEMENT PROGRAM 1

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OTHER ACTIVITIES i

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SCRAM REDUCTION PROGRAM I

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OPERATIONS SUBCOM11TTEE j

EMERGENCY PROCEDURE GUIDELINES NRC CONTACT:

WAYNE H0DGES REVIEW 0F FINAL SUBMITTAL OF CEN-152, REVISION 03 AND ISSUE RESULTING SER 9

STATUS CEN-152, REV. 03 FINAL SUBMITTAL TO NRC WAS MADE OCTOBER 1, 1987 l

1 LEAD REVIEWER ASSIGNED IN JANUARY, 1988 i

l NEW REVIEWER IS ASSIGNED FROM RSB NO f

PRIOR INVOLVEMENT WITH CEN-152 i

REVIEW STATUS MEETING TENTATIVELY SET FOR

)

FEBRUARY 10, 1988 i

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OPERATIONS SUBCOMITTEE EMERGENCY PROCEDURE GUIDELINES NRC CONTACT:

WAYNE H0DGES f

SUCCESSFUL NRC/CEOG INTERACTION 4

CE0G HAS MADE TWO PRIOR SUBMITTALS OF REV. 03 NRC HAS APPROVED IMPLEMENTATION OF SUBMITTALS r

1 AND 2 IN DECEMBER, 1985 AND NOVEMBER, 1986 RESPECTIVELY b

i REQUESTED NRC ACTION LIMIT SCOPE OF REVIEW TO TECHNICAL CHANGES SINCE NRC APPROVAL TO IMPLEMENT SUBMITTAL 2 0F REV. 03 l

(NOVEMBER, 1986)

MAINTAIN EXISTING REVIEWER ASSIGNMENT THROUGH COMPLETION AND ISSUE OF THE SER 4

OPERATIONS SUBCOMMITTEE 1

l CHARGING PUMP PERFORMANCE IMPROVEMENT PROGRAM NRC CONTACT:

DENNIS CRUTCHFIELD l

l l

0 CEOG/NRC INTERACTION ON BLOCK CRACKING l

BEGAN IN 1986 O

CEOG FUNDED TASKS IN 1987 TO EVALUATE THE BLOCK t

CRACKING CONCERN AND PUMP AVAILABILITY O

TASKS FINDINGS SUMMARIZED ON FOLLOWING SLIDES I

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A CE0G' CHARGING PUMP RELIABILITY 11MPROVEMENT PROGRAM 4

4 BACKGROUND CE0G CHARGING PUMP STUDIES i

TASK OVERVIEW PRELIMINARY FINDINGS ON-GOING ACTIVITIES-H f

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BACKGROUND

-ISSUES HIGH CHARGING PUMP MAINTENANCE NUMBER OF PUMP BLOCKS HAVE CRACKED NRC' CONCERNED WITH CHARGING PUMP RELIABILITY EFFORTS TO RESOLVE RELIABILITY ISSUES INDIVIDUAL UTILITY PROGRAMS TO IMPROVE RELIABILITY CE0G EFFORTS PROVIDE SHARED KNOWLEDGE BASE TO RESOLVE CHARGING PUMP RELIABILITY CHARGING PUMP MAINTENANCE WORK SHOPS CHARGING PUMP RELIABILITY IMPROVEMENT PROGRAM

CHARGING PUMP RELIABILITY IMPROVEMENT PROGRAM G0ALS IDENTIFY CONTRIBUTORS TO CHARGING PUMP UNAVAILABILITY QUANTIFY THE MAGNITUDE OF.EACH CONTRIBUTOR IDENTIFY IMPROVEMENTS TO INCREASE PUMP AVAILABILITY DETERMINE SAFETY IMPACT / PLANT AVAILABILITY IMPACT OF CHARGING PUMPS PROVIDE MECHANISM TO SHARE PUMP PERFORMANCE IMPROVEMENTS l

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CHARGING PUMP RELIABILITY IMPROVEMENT PROGRAM SCOPE-UPDATE 1984 DATA BASE ANALYZE TRENDS QUANTIFY PUMP UNAVAILABILITY PUMP PERFORMANCE STUDY

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IDENTIFY PROBLEMS IDENTIFY IMPROVEMENTS CHARGING PUMP OPERABILITY OPERABILITY / SURVEILLANCE REQUIREMENTS OVERVIEW 0F CRACK INITIATION / PROPAGATION STUDIES IDENTIFY OPERATING EXPERIENCE CVCS INTERACTIONS - PUMP CRACKING TRENDS CORRELATE CVCS CONFIGURATION /0PERATION TO PUMP BLOCK FAILURES DETERMINE ACTUAL PUMP BLOCK OPER.9ilNG TIME FOR FAILED BLOCKS i

CHARGING PUMP UNAVAILABILITY DETERMINE CONTRIBUTORS TO UNAVAILABILITY QUANTIFY OVERALL PUMP UNAVAILABILITY SIGNIFICANT IMPROVEMENT FROM 1984-1986 UNAVAILABILITY FIGURES IN INP0 NPRDS OVERSTATE PUMP UNAVAILABILITY l

BLOCK FAILURES ARE SMALL CONTRIBUTOR T0 CHARGING PUMP UNAVAILABILITY UTILITY RESOURCES SPENT ON IMPROVING THE MAJOR CONTRIBUTORS TO PUMP UNAVAILABILITY PUMP PACKING / PLUNGER REPLACEMENT CHECK VALVE REPLACEMENT i

PUMP UNAVAILABILITY TIME INP0 NPRDS SYSTEM PUMPS CALLED UNAVAILABLE PUMPS REMOVED FROM SERVICE FOR DISCRETIONARY REASONS PUMP COULD DELIVER REQUIRED FLOW TO RCS IN AN EMERGENCY THE PUMP COULD HAVE BEEN RETURNED TO SERVICE ACTUhLTIMEPUMPSCOULDNOTDELIVERREQUIRED FLOW WAS MUCH LESS THAN REPORTED IN NPRDS UNAVAILABILITY TIME (NPRD) INCLUDES THE TIME FROM IDENTIFYING NEED FOR PUMP MAINTENANCE UNTIL THE PUMP IS RETURNED TO UNRESTRICTED USE, REPORTED UNAVAILABILITY TIME AFFECTED BY:

ESTABLISHING CONDITIONS REQUIRED FOR REPAIR ACTUAL REPAIR TIME RETESTING SCHEDULING DELAYS PRIORITY AVAILABLE MANPOWER REPAIRS CAN BE AFFECTED IN MUCH SHORTER TIME FRAMES IF REQUIRED PACKING REPLACEMENT 8 - 16 HOURS CHECK VALVE REPLACEMENT 8 - 16 HOURS CHARGING PUMP BLOCK 13 - 20 HOURS W

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EARING CRACKED PULSATI0li GASKETS VIBilATI0tt OTilER PACKitlG SEALS CllECK SUCTION FAILURE BLOCKS DAMPENElt lillMICED PlutlGERS VALVES STAulLilER B

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i PUMP BLOCK CRACKS SMALL CONTRIBUTOR TO UNAVAILABILITY <10%

CHARGING PUMP BLOCK CRACKS DO NOT POSE A SAFETY' CONCERN BLOCKS CRACK DUE TO CYCLIC FATIGUE SLOW FAILURE MECHANISM CAN BE IDENTIFIED BEFORE EXCESSIVE LEAKAGE OCCURS BLOCKS HAVE NOT CRACKED SIMULTANE0USLY BLOCK FAILURES HAVE NOT PREVENTED CONTINUED PLANT OPERATION BLOCK DESIGN IMPROVEMENTS DESIGN IMPROVEMENTS HAVE BEEN MADE T0 INCREASE BLOCK LIFE IMPROVED BLOCKS ARE JUST NOW BEING INSTALLED IN PLANTS l

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CHARGING PUMP OPERABILITY REQUIREMENTS PURPOSE ENSURE THAT THE BORON INJECTION SYSTEM CAN SUPPLY NEGATIVE REACTIVITY CONTROL IS AVAILABLE FOR ALL MODES OF PLANT OPERATION TECHNICAL SPECIFICATION REQUIREMENT 3.1.2.4 REACTIVITY CONTROL SYSTEMS -

CHARGING PUMPS - OPERATINS TWO PUMPS ALLOWS 72 HOUR ACTION STATEMENT

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CE0G EXPERIENCE 16 LER WRITTEN 1984 THROUGH 1986 ON CHARGING PUMPS FOUR EVENTS REPORTED THAT LESS THAN TWO CHARGING PUMPS WERE OPERABLE ONE EVENT RESULTED IN AN ORDERLY PLANT SHUTDOWN BECAUSE THE PLANT KNEW SPARE PARTS WOULD BE UNAVAILABLE FOR THE DURATION OF THE ACTION STATEMENT THREE EVENTS THE CHARGING PUMPS WERE RESTORED TO AN OPERABLE STATUS WITHIN THE TIME FRAME OF THE ACTION STATEMENT NO REPORTED INSTANCES WHERE A PLANT HAS CRACKED TWO BLOCKS AT THE SAME-TIME

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CHARGING PUMP BLOCK MODIFICATIONS TO POTENTIALLY. REDUCE BLOCK CRACKING INCREASED RADIUS AT INTERSECTION OF VALVE AND PLUNGER BORES 1

l SHOT PEENED INTERIOR OF THE BLOCKS AT THE INTERSECTION COMPARE FORGED BLOCKS TO CAST BLOCKS CHANGE MATERIAL TO 17-4 PH STAINLESS STEEL l

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SUMMARY

CE0G HAS INVESTIGATED CHARGING PUMP RELIABILITY ISSUES THESE STUDIES SHOW f

CHARGING PUMP UNAVAILABILITY IS DECREASING CEOG PLANTS HAVE AGGRESSIVELY PURSUED THE MAJOR CONTRIBUTORS TO UNAVAILABILITY - PUMP PACKING /

PLUNGER REPLACEMENT AND CHECK VALVE REPLACEMENT CHARGING PUMP BLOCKS SMALL CONTRIBUTION TO UNAVAILABILITY CRACK DUE TO FATIGUE - A SLOW FAILURE MECHANISM THAT DOES NOT ADVERSELY IMPACT PLANT SAFETY I

IMPROVED BLOCK DESIGNS HAVE BEEN FABRICATED AND SHOULD IMPROVE BLOCK LIFE CEOG CHARGING PUMP RELIABILITY IMPROVEMENT PROGRAM HAS PROVIDED A VEHICLE FOR MEMBER UTILITIES TO SHARE INFORMATION AND EXCHANGE DESIGN AND MAINTENANCE INFORMATION THAT SHOULD IMPROVE CHARGING PUMP AVAILABILITY

OPERATIONS SUBCOMMITTEE SCRAM REDUCTION PROGRAM i

0 PROGRAM ELEMENTS PARALLEL INP0 CATEGORIES FOR SCRAM REDUCTION PROGRAM 0

SUBCOMMITTEE MEETS QUARTERLY TO DISCUSS PREVIOUS QUARTER SCRAMS, DISCUSSIONS INCLUDE:

GENERIC APPLICABILITY ROOT CAUSE CORRECTIVE ACTIONS TO PREVENT RECURRENCE 0

SUBCOMMITTEE CHAIRMAN MEETS WITH OTHER OWNERS GROUPS SCRAM REDUCTION COMMITTEE CHAIRMEN TO SHARE PROGRAM INFORMATION 0

SCRAM DATA BASE BEING CREATED i

0 ROOT CAUSE DETERMINATION GUIDELINES DEVELOPED

TECHNICAL SPECIFICATIONS AND LICENSING SUBCOMMITTEE

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- DICK BERNIER (APS), SUBCOMMITTEE CHAIRMAN AND CE0G CONTACT (602) 371-4295 OVERVIEW i

CEOG/NRC INTERACTION TECH SPEC RESTRUCTURING RPS/ESFAS TEST INTERVAL EVALUATION REFUELING OUTAGE SURVEILLANCE TEST INTERVALS 3

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i TECHNICAL SPECIFICATIONS AND LICENSING SUBCOMMITTEE TECHNICAL SPECIFICATION RESTRUCTURING NRC CONTACT:' MILLARD WOHL ISSUE RESTRUCTURE TECHNICAL SPECIFIC?TIONS BY APPLICATIONS OF CRITERIA FOR TECH SPEC SPLITTING SUCCESSFUL CE0G/NRC INTERACTION REPORT CEN-355 (STS SPLIT RESULTS) SUBMITTED DECEMBER 11, 1987 FOR NRC REVIEW FEEDBACK EXPECTED BY FEBRUARY 20, 1988 STATUS COLLABORATING WITH WOG, BWOG, BWROG ON RSTS DEVELOPMENT COMPLETION EXPECTED BY EARLY 1989 REQUESTED NRC ACTION PROVIDE FEEDBACK ON CEN-355 BY FEBRUARY 20 TO SUPPORT DISCUSSIONS AT FEBRUARY 24 AND 25 CE0G MEETING

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TECHNICAL SPECIFICATIONS AND LICENSING SUBCOMMITTEE RPS/ESFAS TEST INTERVAL EVALUATION NRC CONTACT:

SCOTT NEWBERRY i

ISSUE JUSTIFY EXTENDED SURVEILLANCE TEST INTERVALS FOR THE REACTOR PROTECTION SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM SUCCESSFUL CE0G/NRC INTERACTION REPORT CEN-327 SUBMITTED TO NRC JUNE, 1986 EG8B TER COMPLETED JULY, 1987 i

MEEETING ON JANUARY 14 WITH NRC STATUS NRC REVIEW TO BEGIN FEBRUARY, 1988 i

i COMPLETION PROMISED BY END OF MARCH, 1988 REQUESTED NRC ACTION COMPLETE REVIEW BY CURRENT SCHEDULE l

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TECHNICAL SPECIFICATIONS AND LICENSING SUBCOMMITTEE REFUELING OUTAGE SURVEILLANCE TEST INTERVALS NRC CONTACT:

MILLARD WOHL EXTEND SURVEILLANCE INTERVALS FOR TECH SPECS ISSUE IMPACTING EXTENDED FUEL CYCLES SUCCESSFUL CEOG/NRC INTERACTION MET WITH NRC ON JANUARY 14, 1988 DISCUSSED APPROACHES FOR JUSTIFICATION OF EXTENSIONS STATUS FURTHER CEOG WORK UNDER CONSIDERATION TWO CEOG MEMBER UTILITIES CURRENTLY WORKING ON EXTENSIONS.

BOTH CURRENTLY IN A 24 MONTH CYCLE.

REQUESTED NRC ACTION SUPFORT THE TWO CEOG MEMBER UTILITIES CURRENTLY PURSUING TEST INTERVAL EXTENSION l

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1 CE0G/NRC POLICY ISSUES 0

COMMUNICATIONS 0

TOPICAL REPORT REVIEW

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NRC/CE0G COMMUNICATIONS CE0G SUBMITTALS TO NRC NOT APPLICABLE 0

CE0G POLICY TO INDIVIDUAL LICENSEES UNTIL REFERENCED BY LICENSEE ON HIS DOCKET NRC QUESTIONS ON CE0G SUBMITTAL SHOULD BE ADDRESSED TO CE0G CHAIRMAN REQUESTS FOR INFORMATION ON NEW ISSUES SHOULD BE ADDRESSED TO INDIVIDUAL LICENSEES INFORMATION ITEMS CAN BE SENT BY NRC TO CE0G CHAIRMAN 0

CE0G ENCOURAGES INFORMAL MEETINGS ON CE0G SUBMITTALS 0

CURRENT CONCERNS CEOG HAS RECEIVED COMMUNICATIONS l

THAT TEND TO TREAT GROUP AS A LICENSEE 0

DISCUSSION I

a NRC REVIEW 0F CE0G TOPICAL REPORTS O

CEOG-TOPICAL REPORTS USED TO OBTAIN NRC ACCEPTANCE OF GENERIC WORK 0

BENEFITS OF TOPICAL REPORTS ALLOWS FOR EFFICIENT USE OF CEOG AND NRC RESOURCES ENCOURAGES COMMON APPROACH AMONG OWNERS FOR RESOLVING TECHNICAL ISSUES O

CURRENT CONCERNS LACK 0F TIMELY REVIEW CUMBERSOME PROCESS VIABILITY OF THIS APPROACH IN QUESTION UTILITIES QUESTIONING USEFULNESS OF CE0G FOR OBTAINING NRC APPROVAL OF UTILITY INITIATIVES 0

DISCUSSION