ML20196E326

Summary of 981118 Meeting with Nei,Epri & Industry Re Management & Regulation of SG Degradation.List of Attendees, Agenda & Slides Presented at Meeting Encl

ML20196E326
Person / Time
Issue date:	12/01/1998
From:	Tim Reed NRC (Affiliation Not Assigned)
To:	Sullivan E NRC (Affiliation Not Assigned)
References
TASK-*****, TASK-RE NUDOCS 9812030121
Download: ML20196E326 (13)

Text

.. -.

Letoq g

UNITED STATES 4

s j

NUCLEAR REGULATORY COMMISSION

• g WASHINGTON, D.C. 20066 4 001 4

December 1, 1998 MEMORANDUM TO: Edmund Sullivan, Acting Chief Materials and Chemical Engineering Branch Division of Engineering Office of Nuclear Reactor Regulation THRU:

($nmett Murphy, Acting Section Chief Section B Materials and Chemical Engineering Branch Division of Engineering Office of Nuclear Reactor Regulation I

FROM:

Timothy A. Reed, Senior Project Manag Materials and Chemical Engineering Br c Division of Engineering Office of Nuclear Reactor Regulation l

SUMMARY

OF THE NOVEMBER 18,1998 SENIOR MANAGEMENT MEETING WITH NUCLEAR INSTITUTE AND INDUSTRY TO DISCUSS STEAM GENERATOR ISSUES On November 18,1998, the NRC staff met with representatives of Nuclear Energy Institute (NEI), Electric Power Research institute (EPRI), and industry to discuss issues regarding the management and regulation of steam generator (SG) degradation. Meeting attendees are identified in Attachment 1. The agenda and slides presented during the meeting are provided as.

Mike Tuckman (Duke Power Company) discussed (see slides) the industry's proposed regulatory framework for implementing the NEl initiative entitled NEl 97-06 " Steam Generator Program Guidelines". The proposal involves changes to the SG technical specifications (TSs) which remove the SG TS surveillance requirements to the updated final safety analysis report

/

(UFSAR) and other licensee controlled documents. The staff provided a status of its regulatory

/

efforts addressing SG tube integrity indicating that a Commission paper proposing to put the proposed generic letter (GL) effort on hold and issue DG-1074 for public comment is currently

[J/2/.3 with the Commission for negative consent. The staff expects a Commission decision by November 19,1998, t

1 i

CONTACT: T. Reed, EMCB/De 415-1462 9812030121 981201 PDR REVGP ERGNUMRC g /P[F/

i PDR i /lf /Wff (w (()

/ r

(? o - a E

2 The staff and industry committed to the following actions as a result of the meeting discussion:

l

1. Industry will finsiize its position on the technical issues that stem from a comparison of the industry NEl 97-06 approach versus DG-1074 and submit the position to the staff in mid-December 1998. A draft of the industry's position on the technical issues was provided to the

. staff at the November 12,1998 technical meeting.

l-

2. Industry will develop a proposal for revising the SG TS with accompanying changes to the UFSAR and other licensee controlled documents to facilitate implementation of NEl 97-06. As part of this proposal, industry will identify those areas where prior staff review and approval are required and where risk insights need to be considered to support the licensing submittals (ex.

alternate repair criteria).

j

3. Industry will provide a list of milestones and schedule supporting the development of guidance on implementation of a regulatory framework for NEl 97-06 via TS changes and UFSAR changes. The staff will need to interact with NEl to provide schedule estimates for tasks that involve staff review.

4. The staff will consider, given the risk work performed to date and the insights that have been gained, whether it is more efficient to issue a staff white paper discussing the issue of SG tube l

degradation related risk or whether it is better to continue with efforts to develop draft regulatory guide DG-1073. The staff will provide industry with an estimate of the schedule for issuance of the either the white paper or DG-1073, dependent on which approach the staff pursues.

5. The staff will develop a Commission paper which indicates that as a result of interactions to date with industry on NEl 97-06, sufficient progress has been made to warrant a continued effort l

to resolve staff concerns with NEl 97-06. The Commission paper will recommend that the proposed SG tube integrity GL be kept on hold pending further progress with industry.

l

6. The staff will ensure that the federal register notice (FRN) that issues DG-1074 for public j

comment indicates that it is not the staff's intent to cause industry to spend significant resources commenting on the DG-1074 since the staff is already familiar with industry views via the recent num' er of technical meetings. Instead, the FRN will indicate that the staff's chief purpose in l

o i

issuing DG-1074 for public comment is to solicit comments from the public who, to date, have l

not had an opportunity to comment. The staff will consider the public comments both in the i

finalization of the SG regulatory guidance and in its interactions with industry concerning NEl 97-06.

7. The staff will develop internal guidance for regionalinspectors and headquarters personnel that indicates that draft regulatory guide DG-1074 is not an official staff position. Instead, DG-1074 is a draft position that describes one acceptable means of monitoring and maintaining SG tube integrity. The intemal guidance will therefore indicate that DG-1074 should not be utilized to inspect licensee's activities associated with the implementation of NEl 97-06.

L l

5 7

4'

};

3

~

Industry and staff senior management tentatively agreed to meet again at the end of January 1999, industry senior management also indicated that the industry is still going forth with its l

plans to implement NEl 97-06 at the first refueling outage in 1999.

Attachment:

As stated DISTRIBUTION:

[PUBLIC/PDR -

Co' lins /Miraglia 12-G-18 EMCB RF OGC BSheron L..

GLainas GHolahan j

l SNewberry REmch DMatthews SMagruder JStrosnider i

I l

Document Name: G:\\ REED \\NOV1898. MIN L

To receive a copy of this document, indicate in the box C= Copy w/o attachment / enclosure E= Copy with attachment / enclosure N = No copy n /2:4%u OFFICE DE:EMCBA0 h

DE:FM:(AlSC NAME Treed h

DATE-11h98 1h (/98 OFFICIAL RECORD COPY l-4 i.

)

l l

l l

e n

l L

030071

3 Industry and staff senior management tentatively agreed to meet again at the end of January 1999. Industry senior management also indicated that the industry is still going forth with its plans to implement NEl 97-06 at the first refueling outage in 1999.

Attachment:

As stated

l*

NEl/EPRil!NDUSTRY STEAM GENERATOR ISSUES SENIOR MANAGEMENT MEETING NOVEMBER 18,1998 1

LIST OF ATTENDEES NAME ORG/ POSITION

1. Tim Reed NRC/NRR/DE/EMCB

2. C!ive Callaway NEl

3. Jack WoMard Southern Nuclear l

4. Mike Tuckman Duke Power

5. Dave Modeen NEl

6. Gary Holahan NRC/NRR/DSSA

7. Sam Collins NRC/NRR

8. Brian Sheron NRC/NRR/ADT

9. Emmett Murphy NRC/NRR/DE/EMCB

10. Steve Long NRC/NRR/DSSA/SPSB

11. Chuck Welty EPRI

12. Rick Mullins Southern Nuclear

13. Ted Sullivan NRC/NRR/DE/EMCB

14. Rich Barrett NRC/NRR/DSSA/SPSB

15. A. El-Bassioni NRC/NRR/DSSA/SPSB

16. Warren Bilanin EPRI

17. Tom Bergman NRC/NRR/DRPM/PGEB

18. Michael Short Southem California Edison

19. David Stellfox McGraw-Hill

20. Charles Peterson Morgan, Lewis, & Bockius

21. Don Streinz ABB-CE

22. John Biomgren Comed

23. David Steininger EPRI

24. Theresa Sutter Bechtel

25. Mike Schoppman FP&L - Washington Rep.

26. Richard Pearson ilSP

27. Eileen McKenna NRC/NRR/DRPM PGEB

28. Mike Neal NUSIS

29. Jack Strosnider NRC/NRR/DE

30. Jim Riley NEl 1

l l

~.

Agenda

~

i NRC /NEI Senior Management Meeting November 18,1998 4

10:00 a.m.

Introductions / Purposes NRC/ Industry 10:15 a.m.

Proposed RegulatoryFramework Industry 11:15 a.m.

Discussion of plans regarding Tube Integrity NRC Generic Letter, DG-1074 and DG-1073 l

11:30 a.m.

Schedule for futureinteractions NRC/ Industry 12:00 p.m.

MeetingA$ourned 1

i i

e i

ATTACHMENT 2

i l

l l

A Proposed Regulatory Framework for Steam Generators NRC Senior Management NEI Steam Generator Working Group November 18,1998 Rockville, MD

't*'

Framework Objectives a Industry's

. Safe and reliable operation of steam generators

. An industry standard applied consistently at all PWR sites

. Performance-based concepts

. Flexibility to adapt program elements to new information/ techniques sg I

1

Framework Objectives a NRC's (an industry perspective)

. Assure regulations are met

. Establish a consistent industry approach consistent with NRC licensing, inspection, t

assessment and enforcement policies

. Maintain appropriate level ofNRC involvement for actions encroaching on current licensing basis s

i Framework Structure &

Implementation a Regulations

= Licensing Amendment l

. Tech Specs /FSAR revisions to define i

licensing basis

= Licensee Commitments

. NEI 97-06, EPRI Guidelines

= Plant Procedures l

2 l

i

i e

Technical Specifications i

= Overhaul consistent with 50.36 (1995)

= Primary-Secondary Operational Leakage reduced to 150 gpd per S/G

= Appropriate surveillances contained in licensce-controlled documents a Change package development will follow the already established iSTS protocol (travellers)

FSAR

= Include Performance Criteria from Section 2, of NEI 97-06 (design bases and limits on SSC operation required by the license)

= Clarifles the design bases a Changes made through 50.59 with on-site review board oversight a Content consistent with NEI 98-03

4 NEl 97-06, Steam Generator Program Guidelines i

m Establishes consistent, industry-wide expectation for each S/G program element

= Each PWRlicensee committed to implement via the formalindustry position d

a To the degree appropriate, key aspects will be reflected in licensee-specific documents iti J

4 EPlJ Guidelines t

= Dynamic and flexible industry guidance responsive to technical & programmatic i

developments a Formal change protocol (SGMP) e Mandatory use ofdirective documents via NEI 97-06

= Provided to NRC forinformation

'd' 3

Plant Procedures m Contents: Reflect NEI 97-06 & EPRI l

Guidelines

= NEI 97-06 Section 3," Licensees shall document the program through plant procedures."

a Changes made through f50.59 with on-site review board oversight l

e Opportunity for NRC review for program &

procedure compliance t3 Framework For NRC Oversight l

e Prior Approval

. Licensing package

. ARCS a

50.59 Evaluation

. Repair methods S

4 Hard Spots a Lack of agreement on what level of detail constitutes the licensing basis:

. Structuralintegrity (use ofprobabilistic method?)

. Accident-induced leakage (a specific leakage rate or radiological dose)

. Uncertainty values to apply to both a Specific instances warranting prior NRC review and/or approval glitI Hard Spots a Decisions regarding application ofrisk insights (very uncertain at this point).

. Strong need for a documented, peer-reviewed analysis of severe accident risk

. Determine if there a demonstrated need to do anything on a plant-specific basis?

. If so, when? How (use a quantitative'or qualitative approach)? What are generic criteria and methods by which tojudge plant-specific application?

g 1

l 6

4 Hard Spots e Operability calls and reporting

. Consistent with changes to NUREG 1022 and Q 50. 72/73

= Clear statement of objective ifissuing DG-1074 for comment Y'

~

The Next Steps e Industry: Develop comprehensive license charge package, excluding risk element a NRC staff

. Assure the industry proposal meshes well with the proposed NRC Performance Assessment Process Improvement

. Issue risk assessment methods and application criteria for comment a Establish schedules

't* '

7

_ _..