ML20196G147

Summary of 981119 Meeting with Executive Committee of Combustion Engineering Owners Group in Rockville,Md Re Topics of Mutual Interest.List of Attendees & Slides Used by Combustion Engineering Owners Group Encl

ML20196G147
Person / Time
Issue date:	12/03/1998
From:	Stewart Magruder NRC (Affiliation Not Assigned)
To:	Essig T NRC (Affiliation Not Assigned)
References
PROJECT-692 NUDOCS 9812070262
Download: ML20196G147 (34)

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December 3, 1998 MEMORANDUM TO: Thomas H. Essig, Acting Chief Generic issues and Environmental Projects Branch Division of Reactor Program Management Office Of Nuclear Reactor Regulation E h.AdIN,(, d FROM:

Stewart L. Magruder, Project Manager Generic Issues and Environmental Projects Branch j

Division of Reactor Program Management Office of Nuclear Reactor Regulation i

SUMMARY

OF NOVEMBER 19,.1998, MEETING WITH THE EXECUTIVE COMMITTEE OF THE COMBUSTION ENGINEERING OWNERS GROUP (CEOG)

On November 19,1998, a public meeting was helu at the U.S. Nuclear Regulatory Commission I

(NRC) offices in Rockville, Maryland, between representatives of the NRC and the Executive Committee of the CEOG. Attachment 1 provides a list of attendees. The purpose of the j

meeting was to discuss topics of mutual interest. Attachment 2 provides the slides used by the

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CEOG in their presentations during the meeting.

After introductions, Dr. Brian Sheron, Acting Assonate Director for Technical Review, Office of Nuclear Reactor Regulation (NRR) provided an overview of NRC activities. He emphasized that the NRC is looking at its regulatory processes in light of the current deregulation and competitive environment. As an example, he noted that the NRC is looking at the number and seriousness of violations and that the number of Severity Level IV violations is down by a third this year. He also noted the significant efforts underway to review the plant assessment i

process and to make the regulations more risk-informed.

Specifically, Dr. Sheron mentioned that the staff is reviewing wchnical specification amendment and topical report review process. The goalis only one round of requests for additional information (RAl) and a shorter review time. In the future, the NRC is considering not issuing RAls; just issuing a draft safety evaluation report (SER) with blanks where information is 3

9 needed,or asking the licensee to write the SER. He noted that the staff is looking for suggestions to streamline the process and suggested that the CEOG work with NEl on providing suggestions. A recent example of new ways of thinking about the process was i

discussed. In this case, ANO succeeded in reducing / eliminating hydrogen monitoring raquirements by assuming more of the burden of proving that their proposal was acceptable.

Dr. Sheron noted that the NRC has canceled more generic letters this year than they have issued and, for the time being, the staff is not planning to issue a Generic Letter on steam generator issues. With respect to other industry i-%raction, the NRC met with the Electric D ID Power Research Institute (EPRI) Materials Reliabmty Project (MRP) and the EPRI Steant Generator Management Project (SGMP) Executive Committee on November 18,1998.

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T. Essig December 3, 1998 in summary, Dr. Sheron stated that the NRC is anticipating a whole new way of working with the industry. Jim Levine indicated that utilities are very encouraged by the new openness on the part of the NRC and stated that industry executives are eager to accept any additional responsibility and accountability that comes with the NRC changes.

With respect to the Owners Groups a'nd NRC relationship, one area in which the NRC is struggling has to do with voluntary licensee commitments. The staff is looking for assurance that all CEOG members will implement a CEOO product (when it is done as a voluntary l

. commitment) and for ways to verify that is stays a commitment. The CEOG Management 1

l Committee agreed to discuss this topic at its February 1999 meeting and provide feedback to I

the staff following the meeting.

The Post Accident Sampling System (PASS) was the next topic for discussion. Ray Schneider (ABB) provided a presentation and argument for elimination of the PASS. The CEOG will submit a topical report with plant specific appendices by March 26,1999.

l The NRC staff indicated that they are requesting that NEl coordinate a meeting among the four l'

owners groups on this topic. The CEOG noted that is looking for feedback and a commitment from the NRC on the proposed 90 day review of the topical. The NRC staff noted that the proposed NEl meeting will be helpful in identifying all the issues that need to be addressed and will help in expediting the review.

Ralph Phelps, CEOG Chairman, next provided an overvlew of the CEOG organization and mission and summarized a number of the projects underway.

l With respect to topical reports, Jim Levine noted that the CEOG will identify the lead plant by December 15th,1998, and requested that the NRC identify the lead reviewers. Jim also noted that the CEOG has recently withdrawn a number of topical reports to more efficiently utilize resources both at the NRC and the utilities.

Gary Holahan, Director, Division of Systems Safety and Analysis, NRR, indicated that the NRC is trying to setup a meeting with the industry (NEI) regarding high burnup fuel for December 10, 1998. Gary indicated that there had been a weak response so far. The intent of the meeting is to talk about getting more data to support higher bumup. Jim Levine responded that the CEOG Executive Committee will work with NEl regarding this meeting.

Alan Hackerott, Chairman of the CEOG Probabilistic Safety Assessment (PSA) Subcommittee

- provk$ed an update on the CEOG PSA activities. With respect to the overall goals of risk

. informed regulation, Gary Holahan questioned the breadth of industry support for risk based applications. Jim Levine noted that the CEOG is a strong supporter of this technology, but admitted that tnere are frustrations that exist in the industry. Ralph Phelps suggested that there Is a lot of evidence of risk-informed implementation efforts at the plant level for CEOG utilities.

Also, it was noted that the CEOG action taken to upgrade PSA from a working group to a standing subcommittee is further evidence of the importance that the CEOG gives this topic.

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% r T. Essig

-3 December 3, 1998 The NRC staff stated that they believe that utilities are beginning to see that risk-informed inservice inspection is of great benefit (e.g. Vermont Yankee). Jim Levine noted that there is some sentiment within his staff for withdrawing Palo Verde as a risk-informed inservice testing pilot plant. The NRC staff agreed to explore this issue further with the Palo Verde staff to determine what their concerns are and what, if anything, the NRC can do about them.

Alan Hackerott next discussed current efforts at achieving risk-informed extended allowed outage times for several systems He noted that the CEOG would like to process more global risk-informed technical specification changes. The NRC staff continues to be supportive of this approach.

A discussion of configuration risk management programs (CRMPs) was led by Jim Levine. Jim, speaking on behalf of the CEOG, stated that some CEOG members are hesitant about committing to a CRMP oelieving that this may lead to other unknown requiremems downstream. Rich Barrett, Chief, Probabilistic Safety Assessment Branch, NRR, responded that the NRC has formed a risk-informed licensing panel. One of the topics discussed has been the CRMP. If the CRMP is an impediment to pursuing risk-informed applications, then the NRC needs td deal with this issue. The NRC did not see nor did it intend for the CRMP to be an onerous requirement. The NRC encouraged the CEOG to propose an alternate approach to the CRMP, if desired.

Alan Hackerott also discussed the CEOG PSA Certification Process. Gary Holahan noted that the NRC is observing a PSA Certification for a second time at a BWR and at some time in the future would like to observe a CE plant PSA Certification (on-site review).

Rich Barrett next provided the NRC perspective on risk-informed applications. His goal is to treat risk-informed applications as routine. He noted that the NRC now has a full time project f

manager to process risk informed licensing actions and the staff is hopeful that there will be increasing industry and NRC cooperation in the future.

After a brief review of action iterns, the group agreed to schedule another meeting in approximately six months.

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

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• <e' T. Essig December 3,1998 I

l The NRC staff stated that they believe that utilities are beginning to see that risk-informed inservice inspection is of great benefit (e.g. Vermont Yankee). Jim Levine noted that there is j

some sentiment within his staff for withdrawing Palo Verde as a risk-informed incervice testing pilot plant.- The NRC staff agreed to explore this issue further with the Palo Verde staff to determine what their concerns are and what, if anything, the NRC can do about them.

Alan Hackerott next discussed current efforts at achieving risk-informed extended allowed outage times for several systems. He noted that the CEOG would like to process more global risk-informed technical specification changes. The NRC staff continues to be supportive of this approach.

A discussion of configuration risk management programs {CRMPs) was led by Jim Levine. Jim, speaking on behalf of the CEOG, stated that some CEOG members are hesitant about I

committing to a CRMP believing that this may lead to other unknown requirements downstream. Rich Barrett, Chief, Probabilistic Safety Assessment Branch, NRR, responded that the NRC has formed a risk-informed licensing panel. One of the topics discussed has been the CRMP. If the CRMP is an impediment to pursuing risk-informed applications, then the NRC l

needs to deal with this issue. The NRC did not see nor did it intend for the CRMP to be an onerous requirement. The NRC encouraged the CEOG to propose an alternate approach to the CRMP, if desired.

Alan Hackerott also discussed the CEOG PSA Certification Process. Gary Holahan noted that the NRC is observing a PSA Certification for a second time at a SWR and at some time in the future would like to observe a CE plant PSA Certification (on-site review).

Rich Barrett next provided the NRC perspective on risk-informed applications. His goalis to treat risk-informed applications as routine. He noted that the NRC now has a full time project manager to process risk informed licensing actions and the staff is hopeful that there will be L

- increasing industry and NRC cooperation in the future.

)

i After a brief review of action items, the group agreed to schedule another meeting in approximately six months.-

L Project No. 692

- Attachments: As stated f

cc w/atts: See next page

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DISTRIBUTION: See attached page l

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CE OWNERS GROUP -

Project No. 692 r

?Mr. Gordon C. Bischoff cc:

1 l-CEOG Project Manager i ABB Combustion Engineering

M.S. 9615-1932 - '

2000 Day Hill Road Windsor, CT 06095 j

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Mr. Ralph Phelps, Chairman CE Owners Group l

l Omaha Public Power District-l P.O. Box 399 l

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Ft. Calhoun, NE 68023-0399 I

Mr. Ian C.' Rickard, Director s Nuclear Licensing I

i ABB-Combustion Engineering, Inc.

Post Office Box 500 i

2000 Day Hill Road Windsor, CT 06095 l

Mr. Charles B. Brinkman, Manager Washington Operations -

i ABB-Combustion Engineering, Inc.

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Rockville, MD 20852 l

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.6 NRC/CEOG EXECUTIVE COMMITTEE i

l-MEETING ATTENDEES November 19,1990 l

i NAME ORGANIZATION l

Jim Levine.

Arizona Public Service Gary Gates.

Omaha Public Power District

' Charlie Cruse-Baltimore Gas & Electric Marty Bowling Northeast Utilities L

Dwight Nunn Southern California Edison l..

Ray Burski Entergy Randy Hutchinson Entergy.

' Stephen Wawro Consumers Energy Ralph Phelps Omaha Public Power District Gordon Bischoff ABB-Combustion Engineering (ABB-CE)

Steve Lurie ABB-CE Ray Schneider_

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Jim Triompo ABB-CE

Roger Fagan ABB-CE lan Rickard ABB-CE Bruce Kaiser ABB-CE Leslie Collins ABB-CE Jack Bastin Westinghouse Brian Sheron NRC Gus Lainas NRC l

Gary Holahan NRC l

Rich Barrett.

NRC-Stu Magruder NRC L

' Mark Reinhart NRC:

l Adel El-Bassioni NRC l

Krzysztuf Parczewski NRC Randy Hall NRC Syed Ali NRC l

Millard Wohl NRC l

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NRC/CEOG Executive Committee Meeting November 19,1998 Rockville, MD

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CEOG-98-380 i

6 Agenda for the November 19,1998 NRC/CEOG Executive Committee Meeting Location:

NRC Offices Two White Flint Building Room T-7Al Rockville, Maryland Phone: (301) 415-0040 Thursday. November 19.1998 8:00 am Introductions (Jim levine, APS and Sam Collins, NRC) 8:15 am Openine remarks / overview of current NRR Activities (Sam Collins, NRC) 9:00 am CE Owners Group Report (Ralph Phelps, OPPD) 9:30 am Discussion of Elimination of Post Accident Sampline System (Ray Schneider, ABB with feedback from NRC) 10:00 am Licensing Issues (Brian Sheron, NRC) 10:25 am Procress Report on Risk Informed Initiatives (Allan 11ackcrott, OPPD, with feedback from NRC) 10:55 am Risk Informed Licensing Activities (Rich Barrett, NRC)

- 11:15 am Meeting Wrap-up and Review of Action Items (Stu Magruder, NRC and Gordon Bischoff, ABB) 11:30 am Adiourn i

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l CEOG Report to NRC Ralph Phelps (OPPD)

November 19,1998 CEOG Executive Commmes November 1998 I

Topics o Overview and Mission e CEOG Strategic issues e Summary of Work by CEOG Strategic issue C?sOG Executive Commmee November 1998

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l Overview i

e Membership (1998) 8 Domestic Utilities,14 Uriits

- KEPCO,2 Units (non-voting)

ABB (non-voting) e 12 Technical Committees e CEOG governed by Charter e 50+ active tasks e Current annual expenditure - approx. $5M l

CEOG Executive Committee November 1998 l

CEOG MISSION e Address safety and regulatory issues e Provide a mechanism for establishing unified positions with the NRC e Undertake efforts which will reduce O&M and capital costs and reduce outage time l

e Provide a mechanism to share costs l

i CEOG Executive Committee November 1998 4

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I 1999 CEOG Officers e Chairman - Ralph Phelps (OPPD) e Vice Chairman - Ray Burski (WSES) i e Steering Committee i

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- Dave Pilmer (SCE)

- Dick Bernier (APS)

CEOG Executive Commmee November 1998 CEOG Organization (1999)

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Recent Organization Changes e Disbanded the Reactor Vessel Working Group and moved remaining activities under the Materials Working Group e Upgraded the PSAWG to a standing subcommittee o Formed ECCS Performance Task Force o Renamed the CEOG as the CEOG Management Committee o Created Charter for the Regulatory Response Function (handled by the Steering Committee)

CEOG Executwo Committee November 1998 CEOG Topical Reports

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e 14 Topical Report Submitted to NRC for Information or Review

- 5 reports - risk informed TS changes

- 3 reports - CEDM and RV issues 3 reports - SG issues I

- 1 report - RTCB surveillance extension (WSES lead plant) l 1 report - TS change for EOC MTC (WSES lead i

plant) 1 report - Exteiid 1 Pin Burnup Limit to 65 mwd /KgU CEOG Executwo Committee November 1998 I

CEOG Topical Reports e 6 Topical Reports planned for submittal in 1999 PASS Elimination RTT Elimination in Pressure Transmitters Common O Platform Qualification Credit for Moisture Carryover in MSLB Analyses Risk Informed Technical Specification Changes for Containment isolation Valves Risk Informed Technical Specification Changes for DC Power Supplies CEOG Executive Committee November 1998

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Work Done under CEOG Strategic Issues CEOG Executive Committee November 1998 1

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1999 CEOG Strategic Issues l

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1. Steam Generator Integrity l

2. Design / Licensing Basis

3. Materials issues 1

4. Plant Performance improvement

5. Shorter Refueling Outages

6. O&M and Capital Cost Reduction

7. Equipment Obsolescence CEoG Executive Committee November 1998 Steam Generator integrity e Development of EPRI in-Situ Pressure Testing (ISPT) Guidelines

- significant CEoG involvement Guidelines address leak rate testing e Axial Crack Alternate Repair Criteria

- Support condition monitoring and operational assessments using current technical specifications e Internals Degradation Assessment

- Expect RAls in 12/98 l

e Steam Generator Design Bases l

supports degradation assessment per NEl 97-06 program CEoG Executive Committee November 1998 i

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4 Design / Licensing Basis e Compliance with SER limitations for analytical methods e Configuration Risk Management Program (CRMP) guidelines for members / industry (MR relationship) e Joint Owner's Group Programs for MOV, AOV e Development of risk informed TS (AOT extensions) e Development of PSA certification process e Developed qualitative safety assessment for ECCS sump strainer performance e SSFl/ utility resource sharing CEoG Executwo Committee November 1998 Materials Issues EL Wrw en-e improved Characterization of RV Weld Chemistry (Best estimate Cu and Ni values)

. database issued to NRC; responded to RAls e Direct Measurement of Fracture Toughness

- being transferred to EPRI Materials Reliability Project e Reactor vessel baffle bolts, internals defect susceptibility

- support to EPRI Materials Reliability Project e Reactor vessel head penetration defect susceptibility timing and inspection addressing GL 97-01 RAls with NEl, EPRI CEOG Executwe Committee November 1998 l

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Plant Performance Improvements e Plant Performance Improvement Program for continuous monitoring and improvement of fleet l

performance

- Identify reasons for Unplanned Capability Loss Factor (UCLF)

Identified largest contributors to unreliability and failures

- RCP issues (95,842 MW lost over a 3 year period)

- Feedwater System (36,359 MW lost over a 3 year period)

Developing recommendations to eliminate / mitigate the RCP and feedwater system issues

- maintenance, monitoring, procedures, refurbishment CEoG Executive Committee November 1998 Shorter Refueling Outages e CEOG Outage Readiness Review Program

- Ft. Calhoun (11/97), Palisades (1/98), Palo Verde (8/98),

Waterford (11/98), SONGS (11/98) e Developed 22 day benchmark outage model e Review of containment purge requirements e Support changes to industry documents and the Maintenance Rule for S/D operations e Credit for N/C heat removalin Mode 6 CEOG Executive Committee November 1998

l O&M Cost Reduction e Risk based ISI e Elimination / Reduction of Post Accident Sampling System o Extension of Reactor Vessel ISI beyond 10 years j

o Development of AMG training scenario templatos e Extend 1 pin burnup to 65 mwd /KgU CEoG Executive Committee November 1998 I&C Equipment Obsolescence o CEOG/EPRI Reactor Protection System / Plant Protection System obsolescence management project

- maintain RPS/PPS forlife of plant

- CEOG utilities continue to support EPRI program l

e Common Q platform eliminates obsolescence through i

upgrades to analog and digital-based I&C safety systems

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CEOG/EPRI program l

e Year 2000 Readiness

- inventory and assessments of NSSS I&C systems - completed

- remediation-ongoing CEoG Executive Committee November 1998 l

1998 CEOG Topical Rsprrt Status Topical Topical Report Submittal CEOG CEOG NRC NRC NUREG-390 Comments Title Date and Report Status Review Contact Review TaskID Number Reference Perception Priority Status CE NPSD Joint Applications 7/10/95 Under Review High Nanette Under M92981 Represents a collaborative effort between the CEOG Repods for SIT, LPSI Gilles Review and Individual licensees. CEOG and licensees have

-994 and EDG AOT requested a coordinated review of the reports and 301/415-Review

-995 Extensions faciW Heense ameMmmts.

1180 Completion

-996 Date TBD SIT, LPSI and EDG AOT change license amendments issued to lead plant (SCE) 9/98.

CE NPSD-1041 Joint Application for 3/11/98 Under Review High Nanette Under MA1555 Represents a collaborative effort between the CEOG HPS! System Gilles Review and Individual licensees. CEOG and licensees have CEOG Technical Specification requested a Mnated reWew o% repods aM.

117 301/415-Review Modifications facility license amendments.

1180 Completion Date

1. 1. 99 NRC issued RAI on risk based work; awaiting CEOG response.

NRC will issue RAI on systems issues, date TBD CE NPSD-1045 Joint Applications 4/6/98 Under Review High Nanette Under MA1956 Represents a collaborative effort between the CEOG Report for Gilles Review and Individual licensees. CEOG and licensees have CEOG Modifications to the CS requested a coodnated resew of the repods and 155 301/415-Review and LPSI Technical facility license amendments.

1180 Completion Specifications Date Sept

'99 NRC issued RAI on risk based work; awaiting CEOG response.

NRC will issue RAI on systems issues, date TBD CENPD-388-P Extension of the 1 Pin 2/16/98 Under Review High Shih-Liang Under MA1058 Bumup Limited to 65 Wu Review CEOG mwd /kgU for ABB 069 301/415-Review PWR Fuel with OPTIN 3284 Completion Cladding Date 3/99 CE NPSD-951 Reactor Trip Circuit 7/17/96, letter Ongoing Medium Jerry Under M96366 The report was submitted by Entergy Operations. Inc.

Rev. 01 Breakers Survei!Iance W3F1 Review Wermeil Review as a lead plant submitted for the CEOG.

Frequency Extension 0004 301/415-Review 2821 Completion Date 3/99 GWIRK/MSWFILES/CEOG/TOPCL'98. DOC 12 November,1998 1:48 PM ly c Mcoususrion enaineenina ownens anour

1998 CEOG Tepical Repart Status Topical Topical Report Submittal CEOG CEOG-NRC NRC NUREG-390 Comments Title Date and Report Status Review Contact Review TaskID Number Reference Perception Priority Status CE NPSD-311 Analysis of Moderator 12/9/94, letter Ongoing Low Margret Under M91296 The report was submitted by Entergy Operations, Inc.

Temperature W3F1 Review Chatterton review; as a lead plant submitted for the CEOG.

Coefficients in Support 0131 and date TBD 301/415-NRC issued RAI (7 questions) on February 26,1998; of a Change in the Letter CEOG-2889 NRC awaiting response from WSES.

Technical Specification 94-714 End-of-Cycle Negative 12/20/94 Final response to the RAI was issued by the MTC Limit CEOG/WSES 9/98.

CE NPSD-1039 Best Estimate Copper June,1997 Ongoing High Matt Under M99305 CEOG RVWG Task recently initiated to address Rev. 2 and Nickel Values in review. RAl's Mitchell Review RAl's. Received NRC letter in March to RVWG CE Fabricated Reactor recently issued chairman with comment on CE NPSD-1039. NRC 301/415-Review Vessel Welds to licensees suggested that CEOG may be needed to help 33M Completion address RAl's.

Date TBD CE NPSD-1085 CEOG Response to July,1997 Ongoing High Jim Under MA0203 CEOG MWG will address preparation of a NRC GL 97-01, review. NRC Medoff Review supplement to CE NPSD-1085 to reflect use of Degradation of CEDM has asked if EPRl/ del timing model. Original report referred to Review Nozzle and Other supplement will ABB CE timing model.

Completion Vessel Closure Head be issued to 301/415-Date TBD Penetrations address use of 2715 EPRl/ DEI timing model.

RAI s may be issued if no supplement is submitted CE NPSD-1092, Evaluation of April,1998 Report N/A Ted N/A N/A Each OG prepared a template response to GL 97-06 Rev.1 Degraded Secondary submitted to Sullivan for licensees to use in their submittals. NEl has Intemals Operability NRC from NEl collected OG reports referred to in templates and has 301/415-Assessment for information submitted to NRC for information. No formal review 2795 has been requested.

CE NPSD-1103 Evaluation of April,1998 Report N/A Ted N/A N/A Each OG prepared a template response to GL 97-06 Degraded Secondary submitted to Sullivan for licensees to use in their submittals. NEl has Intemals Susceptibility NRC from NEl coHected OG reports refeM to in templates W h 301/415-Assessment for information submitted to NRC for information. No formal review 2795 has been requested.

G 1W R K/M SW FILES /C EOG/TO PCL*98. DOC 12 November,1998 1:48 PM Cf

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1998 CEOG Tepical Rep @rt Status Topical Topical Report Submittal CEOG CEOG NRC NRC NUREG-390 Comments Title Date and Report Status Review Contact Review TaskID RMemnce Number Perception Priority Status CE NPSD-1104-P Evaluation of April,1998 Report N/A Ted N/A N/A Each OG prepared a template response to GL 97-06 Degraded Secondary submitted to Sullivan for licensees to use in their submittals. NEl has Intemals Bounding NRC from NEl dectM M mports mferrM to h tempates aM W 301/415-Analysis for information submitted to NRC for information. No formal review 2795 has been requested.

CE-NPSD-1115 Response to Request April 10,1998 Ongoing High Bob Review N/A Mike Melton (CEOG MWG Chairman) discussed with for Information on Review Hermann Complete Bob Herman on May 7,1998. No follow-up action CEOG CEDM Housings in 193 301/415-s W mqeted.

CEOG Plants 2768 G:/WRK/MSWFILES/CEOG/TOPCL'98. DOC 12 November,1998 1:48 PM C

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Tepical R porto ta be Submitted in 1999 Expected Completion Submittal of NRC NRC Lead Report Topic Date Review Reviewer Comments 1

Elimination of PASS Requirements 3/99 6/99 2

Elimination of Response Time Testing 5/99 9/99 in Pressure Transmitters Appendices to report to be submitted in 12/98.

3 Common Q Platform Qualification 11/98 6/99 Meeting with NRC staff held in June 1998 to 4

Credit for Moisture Carryover in MSLB 10/99 3/00 discuss preliminary results.

Analyses 5

Risk Informed Technical Specification 5/99 12/99 i

Changes for Containment isolation valves 6

Risk Informed Technical Specification 6/99 12/99 Changes for DC Power Supplies TRREV99. DOC 1I/12/98 Cf

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i CEOG PASS ELIMINATION PROJECT Ray Schneider, ABB CEOG Executive Committee INRC Meeting November 19,1998 CEOG PASS Elimination Agenda:

o Purpose of PASS elimination for CEOG plants

> objectives

> strategy

> reasons o CEOG project scope and schedule o Discussion CEOG Executive Committee / NRC Meeting November 19,1998

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CEOG PASS Elimination

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Objective:

o Eliminate unnecessary features of the post accident sampling system (PASS) in all CEOG plants by 11/30/99

> remove PASS requirements from CEOG plant technical specifications e discontinue operation and maintenance activities on selected PASS components CEOG Executive Committee 1 NRC Meeting November 19,1998 CEOG PASS Elimination Strategy:

o Demonstrate that PASS is not relied on for responding to and recovery from an accident at CEOG plants e Establish technical basis for relaxation of post accident sampling requirements, sufficient to eliminate PASS for core damage assessment at CEOG plants CEOG Executive Committee i NRC Meeting November 19,1998 g

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CEOG PASS Elimination Process:

e Revise CEOG core damage assessment (CDA) by 2/26/99

> establish a CDA based on use of existing control room instruments o similar to proposed W CDA methodology e Demonstrate that alternate sampling and assessment capabilities at CEOG plants are sufficient for post accident surveillance e Submit CEOG joint application topical report by 3/26/99, justifying elimination of PASS for NRC safety evaluation e Receive NRC SER by 6/30/99 CEoG Executive Committee i NRC Meeting November 19,1998 I

Reasons for CEOG PASS Elimination Why is CEOG Revisiting PASS Relief?

e From IPE assessments and a decade of SAMG development and implementation, PASS information is not needed for accident management in CEOG plants e PASS measurements are not used for decision making

. Altemate methods to boron sample requirements in EOPs can assure reactivity control in the short term

. Site Emergency Plans can establish EALs on area and site radiation levels, core exit temperatures without using PASS

. SAMGs utilize containment radiation levels and hydrogen concentration measurements to initiate Candidate High Level Actions (CHLAs) Independent of PASS CEoO Executive CommitteeINRC Meeting November 19,1998

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Reasons for CEOG PASS Elimination e Use of PASS is not risk beneficial:

> ALARAimpact I

> High pressure RCS sample lines pose inter-system LOCA (ISLOCA)-potential l

. PASS operation diverts resources away from accident management i

i CEOG Executive Committee / NRC tiesting November 19,1998 i

Reasons for CEOG PASS Elimination e System operation and maintenance costs are high and rapidly growing:

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> surveillance, maintenance costs are ~$100K/yr/ plant i

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> obsolescence issues escalate repair, replacement costs

> resolution of Y2K issues

> training on complex and obscure procedures

> diverts resources from other activities

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i CE00 Enocutive Committee / NRC Meeting November 19,1998 l'

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Summary in light of existing plant accident management and core damage assessment most PASS requirements are now assessed to be:

o duplicative, since equivalent information is available from control room instruments i

e non risk beneficial e costly i

CEOG Executive Committee i NRC Meeting November 19,1998 P

CEOG PASS Elimination Project Summary: areas of PASS relaxation e PASS requirements proposed to be modified to reflect their role in accident management and post accident decision making process e PASS to be removed from technical specifications o' Retained features to be limited to RCS liquid boron sample (delayed)

> hydrogen sample previously approved via on-line (containment) monitor l

CEOG Executive Committee i NRC Meeting November 19,1998 l

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i Actions PASS submittal / review schedule:

e CEOG joint application topical report on PASS elimination l

feetures to be submitted to NRC by March 26,1999 l

. technical bases for elimination of requirements

> all CEOG plants will participate in the joint submittal e 90 day NRC review requested in co"urdination with other j

submittals l

a CEOG will support meetings / discussions as requested to support NRC review i

e CEOG plant licensing amendments to follow SER L

e Approval to be sought for all CEOG utilities CEOG Executive Committee / NftC tisoting November 19,1998 i

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Risk Informed Regulation Alan Hackerott (OPPD) l CEOG Execudve Commmes/NRC Meeung November 19,1998 Topics o Overview i

e Risk Informed Technical Specifications Progress e PSA Certification Process I

l CEOG Executr.s Commmee/NRC Meetng Novemoer 19 1998 l

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r Risk informed Regulation e Goal i

e Focus Resources on Activities important to Safety by using Risk insights in the decision-making process e Benefits Enhanced plant safety Reduced cost of operations Added flexibility in allocating resources CEoG Execupve Committee /NRC Moebng November 19,1998 i

Risk Informed Technical Specifications e Development of robust RG and SRP for risk informed changes to Technical Specifications

. CEOG Pilot - most successfui of the pilots approved and accepted e

l e CEOG increased allowed outage times (AOT) for several plant systems and components:

. safety injection Tanks (1 to 24 hr AOT)

. Low Pressure Safety injection System (1/3 to 7 day AOT) l

. Emergency Diesel Generators (3/7 to 10/14 day AOT) o Above are modifications to improve plant safety and reduce operational costs e CEOG also evaluated the AOT for the Auxiliary Feedwater i

System I

. existing AOT is appropriate, no increase recommended CEoG ExecuDve Commmee/NRc Meecng November 19.1998

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Risk Informed Technical Specifications e San Onofre Nuclear Generating Station was the first to receive AOT extensions e NRC has granted SIT AOT extensions to all participants revised license amendment not required a

Configuration Risk Managerr. ant Program (CRMP) not required e Submitted Joint Applications Report for risk informed technical specification changes

. Containment Spray and HPSI (7 day AoT)

CEOG Executwo Commmee/NRC Meetmg November 19,1998 Risk Informed Technical Specifications e Future risk informed technical specification l

changes (submit June 1999)

. Containment Isolation Valves (up to a 7 day AOT)

. DC Power Supplies (8-12 hour AOT) o Support the new initiative for efficiently progressing to a more global risk informed technical specification environment

. CRMP/ Maintenance Rule sufficient to support implementation

. No changes needed to 10CFR50.36 CEOG ExecuDve Commmee/NRC Meetmg November 19,1998 1

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4 PSA Certification Process e Effective risk informed regulation requires a process to assess PSAs and their applications e The process will provide:

e an understanding of the key PSA strengths and limitations e an evaluation of the configuration risk i

management program o an evaluation of the PSA maintenance program CEOG Execuuve Commmee/NRC Meehng November 19,1998 PSA Certification Process e Intensive peer review of PSA and PSA Maintenance processes

. on-site peer review l

. team of utility and ABB PSA experts e Evolved from BWROG Certification Process j

e Consistent with Industry Program i

i e Integrates CEGG experience

. PSA Cross Comparisons

. issue resolution process

. PsA standards i

e All member utilities will be reviewed by December of 2001 (one per quarter starting 1999)

CEOG Execuevo Commmee/NRC Meegng November 19.1998 i

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PSA Certification Process e CEOG has led the industry in understanding member plant PSAs and developing standards for PSA modeling and application - critical fer PSA certification process e Application Specific plant cross comparisons accompany PSAWG regulatory submittals i

. PSASC Comparisons of PSA Inputs and Results have been used to explain / understand impact of PSA Modeling assumptions and plant differences

. PSASC issue Resolution Process has been developed to identify, explore and resolve PSA modeling issues

. PSA Standards have provided CEOG consensus guidance on PSA modeling, input, methods, and application processes f

CEoG Execuuve CommitteeeNRC Meeung November 19,1998 PSA Certification Process l

e CEOG PSA Standards have been developed for:

> Initiating Event Frequencies:

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- LOCA. MSLB, SGTR

- LOCA standard used c hasis for EPRI Indust;y Standard

. Success Criteria:

- LOCA Injection Paths

> Scenario Models

- ATWS, RCP Seal LOCA, Station Blackout, common cause failures

> Application Processes

- risk ranking process 1

- expert panel process

- CRMP guidance CEoG Executive Committee /NRC Meetmg November 19,1998 4

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Observations o CEOG Experience on Tech Spec Reg Guide

. Most successful of the pilots

. Good communication with Staff i

- e Future Concerns l

. Regulatory uncertainty

. Duration / resources

. Shifting expectations l

. Added layers of regulation 1

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CEoG Execuhve Commmee/NRC Moseng November 19,1998 I

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Conclusion e CEOG has been proactive in the development, and implementation of a Risk Informed Regulation e The CEOG is encouraged with the present NRC

. emphasis on risk and believes risk informed regulation will benefit the public both in terms of safety and economy e CEOG activities with establishing standards and performing peer review certifications will prornote a 4

risk beneficial / cost effective mechanism for regulatory change

.I CEoG Execubve Commmee/NRC Moabng November 19.1998

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