ML20209A769
| ML20209A769 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1999 |
| From: | Marlone Davis NRC (Affiliation Not Assigned) |
| To: | Carpenter C NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-691 NUDOCS 9907060142 | |
| Download: ML20209A769 (19) | |
Text
,...
- o...
pR Ofo
{p*
UNITED STATES
~
s j
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666-0001
%*****/
June 23,1999 MEMORANDUM TO: Cynthia A. Carpenter, Chief
- Generic issues, Environmental, Financial, and Rulemaking Branch Division of Regulatory improvement Programs -
Office of Nuclear Reactor Regulation p
p FROM:
. Michael J. Davis, Project Manager j
Generic issues, Environmental, Financial, and /
Rulemaking Branch.
f Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF MAY 19,1999, MEETING BETWEEN THE NRC STAFF AND THE BOILING WATER REACTOR OWNERS GROUP (BWROG)
APPENDlX R COMMITTEE On May 19,1999, the staff met with the BWROG Appendix R Committee at the Nuclear Regulatory Commission (NRC) headquarters in Rockville, Maryland to discuss post-fire safe shutdown circuit analysis issues. The last meeting on Appendix R circuit analysis issues was held December 2-3,1998. A list of attendees of the May 19,1999, meeting and their affiliations is provided as Attachment 1. A copy of the handout provided by the BWROG for their presentations is provided as Attachment 2.
The main purpose of the May 19,1999, meeting was to discuss the use of safety relief valves (SRVs) in the automatic depressurization mode (ADS) in conjunction with low pressure coolant injection systems (LPIS) as a redundant (as opposed to alternative) means of post-fire safe shutdown, an industry position documented by the BWROG in an April 12,1999, letter to the NRC. The schedule of future activities and industry submittals was also to be discussed.
The s' taff stated that on the basis of its preliminary review, the BWROG position on the use of ADS /LPIS for post fire safe shutdown had merit. The staff noted that the BWROG position
. represents a change in a long-standing staff position. The staff also stated that it would need additional information before it could complete its review and, assuming it accepts the BWROG postion, would need to bandle its review in accordance with NRC processes for generic issues.
The staff further stated that it hopes to make near-term progress towards closure of the ADS /LPIS issue and the circuit analysis issues, and is interested in the process envisioned by the BWROG for reaching such closure. The BWROG responded that it intends to submit a circuit analysis licensing topical report (LTR) on safe shutdown circuit analysis issues (including the redundant use of ADS /LPIS for post fire safe shutdown), and that it would request a staff safety evaluation.
The BWROG stated that its research for its position on'the use of ADS /LPIS established that there is no regulatory requirement precluding the use of ADS /LPIS as the analyzed and t
. protected means for post-fire safe shutdow. The staff commented that later BWR-6s may l-(.1 V d '
jg.,
)
9907060142 990623 PDR TOPRP EPfV90E
^M^bD) t@Ci 6
C PDR
F
.:.2_
have been licensed with these systems classified as redundant rather than alternative. The BWROG stated that its review had shown that NRC regulations permitted various means and methods to achieve cold shutdown.
The BWROG included a reliability comparison of hot and cold shutdown methodologies in its April 12,1999, position paper. The BWROG result was that high and low pressure shutdown paths were at least equal from a reliability standpoint. The staff asked why a risk assessment analysis had not been conducted. The BWROG responded that their resources were limited, and that a qualitative reliability oriented analysis required fewer resources than a risk assessment, especially considering the BWR design variations. The staff suggested that the BWROG use a representative design sample as the subject of a qualitative risk analysis. The BWROG representatives stated that the organization would look into the possibility of doing a risk analysis. On a related issue, the staff suggested that the BWROG compare human error probabilities between the various high and low pressure shutdown methods. The BWROG responded that it would address human error probabilities in a qualitative manner using risk techniques.
The staff questioned whether the licensees could or would remove or abandon fire detection and fire suppression systems protecting high pressure shutdown systems if the staff accepts ADS /LPIS as a redundant shutdown path. The BWROG commented that reductions in current levels of fire protection was nct an objective of its position. Nevertheless, the staff requested that the BWROG address the levels of fire protection that would be maintained if the staff accepts the BWROG position and the consequential increases in fire risk if systems are removed. The BWROG agreed to do so.
The staff requested the BWROG address regulatory burden, if any, which would be relieved by acceptance of its ADS /LPIS position. The BWROG responded that it had not addressed regulatory burden in its submittal of April 12,1999, because it did not view its position as a request for relaxation of regulatory requirements. However, on the basis of the meeting discussions, the BWROG agreed to consider the staff's request.
During a June 21,1999, followup conference call, the BWROG Appendix R Committee and the staff reached agreement on future plans and schedules for the ADS /LPIS and circuit analysis issues. First, the BWROG committed to submit its final ADS /LPIS position (revised in light of staff feedback provided during the May 19,1999, meeting) by the end of August 1999, t
independent of progress on the circuit analysis licensing topical repcrt. This revised ADS /LPIS position would include qualitative PRA-based comparisons of high and low pressure shutdown j
methods, address any regulatory burden for which relief is cought, and identify the effect of j
possible staff approval on existing reactor plant fire detection and suppression capabilities and i
their contribution to reactor safety. Second, the BWROG agreed to target the week of August 16,1999, for a two day meeting with the staff in Rockville, Maryland to receive comments on the final draft of its circuit analysis positions, with a final circuit analysis LTR to be submitted to the. staff by September 30,1999.
Project No. 691 1
Attachments: As stated I
cc w/atts: See next page i
)
b..
hIva been licens d with thass systems cl!'ssifi:d as redundant rathtr then altsrnativo. Tha BWROG stit:d thIt its rzvisw had shown that NRC ragulations parmitt:d various mnens and l_
methods to achieve cold shutdown.
p h
-The BWROG included a reliability comparison of hot and cold shutdown methodologies in its April 12,1999, position paper. The BWROG result was that high and low pressure shutdown paths were at least equal from a reliability standpoint. The staff asked why a. risk assessment analysis had not been conducted.~ The BWROG responded that their resources were limited,
. and that a qualitative reliability oriented analysis required fewer resources than a risk assessment, especially considering the' BWR design variations. The staff suggested that the BWROG use a representative design sample as the subject of a qualitative risk analysis. The BWROG representatives stated that the organization would look into the possibility of doing a risk analysis. On a related issue, the staff suggested that the BWROG compare human error probabilities between the various high and low pressure shutdown methods. The BWROG responded that it would address human error probabilities in a qualitative manner using risk
]
techniques.
The staff questioned whether the licensees could or would remove or abandon fire detection and fire suppression systems protecting high pressure shutdown _ systems if_the staff accepts
- ADS /LPIS as a redundant shutdown path. The BWROG commented that reductions in current levels of fire protection was not an objective of its position. Nevertheless, the staff requested that the BWROG address the levels of fire protection that would be maintained if the staff accepts the BWROG position and the consequentialincreases in fire risk if systems are removed. The BWROG agreed to do so.
The staff requested the BWROG address regulatory burden, if any, which would be relieved by acceptance of its ADS /LPIS position. The BWROG responded that it had not addressed regulatory burden in its submittal of April 12,1999, because it did not view its position as a request for relaxation of regulatory requirements.- However, on the basis of the meeting discussions, the BWROG agreed to consider the staff's request.
During a June 21,1999, followup conference call, the BWROG Appendix R Committee and the staff reached agreement on future plans and schedules for the ADS /LPIS and circuit analysis issues. First, the BWROG committed to submit its final ADS /LPIS position (revised in light of staff feedback provided during the May 19,1999 meeting) by the end of August,1999, independent of progress on the circuit analysis licensing topical report. This revised ADS /LPIS position would include qualitative PRA-based comparisons of high and low pressure shutdown methods, address any regulatory burden for which relief is sought, and identify the effect of possible staff approval on existing reactor plant fire detection and suppression capabilities and their contribution to reactor safety. Second, the BWROG agreed to target the week of August 16,1999, for a two day meeting with the staff in Rockville, Maryland to receive comments on the final draft of its circuit analysis positions, with a final circuit analysis LTR to be submitted to the staff by September 30,1999.
4 Project No. 691 Attachments: As stated '
cc w/atts: See next page DISTRIBUTION: See attached page Document Name:g\\RGEB\\niidi\\519mtsum.wpd k
OFFICE RGEB/[d' h SC:SPLB/FPES BC:SPLB SC:RG SWesth JHannonh/
BZalcman j
NAME_
MDavis:sw DATE-6/p/99 6/%/99 6/h99 6/g/99 OFFICIAL RECORD COPY o
L..
p.
LIST OF ATTENDEES AT MEETING WITH BWROG APPENDIX R COMMITTEE IN ROCKVILLE, MARYLAND ON MAY 19,1999 NAME AFFILIATION L. Whitney NRC/SPLB
- P. Madden NRC/SPLB M. Davis NRC/PGEB G. Stramback GE/BWROG T. Gorman PP&L/BWROG J. Ribeiro DE&S/BWROG V. Bacanskas EOl/BWROG D. Parker Southern Co./BWROG F. Emerson NEl G. Warren SNC/BWROG S. Hardy '
CP&L/BWROG J.Lechner NPPD/BWROG J. Kenny PP&L/BWROG V. Warren PECO/NEl A. Ettlinger NYPA/BWROG R. Hill GENE R. Woods NRC/RESIDRAA/PRAB J. Hyslop NRCISPSB A. Wyche SERCH Licensing /Bechtel J.LaChance Sandia National Lab S. Lee NRC/NRR/DSSA/SPSB N.Siu NRC/RES/ DST /PRAB S. Wong NRC/NRR/SPSB J.Hannon-NRC/NRR/SPSB K. S. West NRC/SPLB M. Caruso NRC/NRR/SPSB G. Thomas NRCISRXB ATTACHMENT 1 L-
~
L 6
1 2
G tne e
m h
N c
e a
t t
t t
A I
i T
m E
mo t
E C
n9 i
M RF 9
l 9
1 x
e G
i t
d ih 9
n O
1 pWy e
R p
e a
W A nM O
G B
O
/C R
R WB N
99
/9 1
/5
1 2
re tne k
k k
s a
e c
c c
a n
a n
a d
r b
a b
a b
P n
mmm mm a
r a
r a
e r
o r
o r
t t
t g
S GS GS A
a gn i
n tn t
o e
i e
m t
i e
u s
Po&
M m
n co s
S n
D e
o P
a it e
e y
t l
I c
L Pl c
r
,u n
a u
+
d sd a
m oVtue d
m i
r ah u
u nR t
t c
I S
SS GS 99
/9 1
/
5
3 r
r u
e o
t p
a n
n e
P o
m n
n n
u o
o o
c i
i i
t o
t a
t i
m D
c so u
P o
c r
e d
f n
S n
a o
P I
d r
i t
T d
u n
+
e G
t I
a V
d f
R p
o S
Ue w
e e
l w
u i
d d
v e
i r
ve i
e v
oh v
e r
c R
PS O
99
/9 1
/
5
l1 l
e 4
no i
h t
c i
a t
s o
a o
r s
m n
P p
r o
p o
i S
A F
s t
t t
e P
n n
u e
e e
Q I
u m
m s
I u
u C
s
+
c c
R fo o
o N
V D
D n
o R
o f
f t
i o
o S
t sr p
w w
e ir e
e w
c i
i s
v v
s e
e e
n D
R R
A 99
/9 1
/
5 l
e 5
rus s
e r
n pw wo n
od l
t o
u h
h i
t t
i s
i wt s
n na o
od it n
P a
u
- e zd S
u r
e i
s u
r P
s s
a I
se s
I e
r a
h pn
+
e t
o f
Dit y
V Ve g
o c
n Pjo R
nl o
Rio i
md S
t f
o p
o i
eh r
et t
s e
c sUsym seD 99/9 1
/
5
o 6
a ev mit o
c n
r e
f p
o s
e r
i ue t
s P i
s s
i k
o e
s hi R P
twa S
ed ivn P
h e
a c
r I
a y
yt o
l e
r ef
+
p v
a i
S p
s V
A n
y, e
r R
t h
o n
et S
e r
a pl m
mgu u
oe c
CR oD 99
/9 1
/
5 l
7 y
l f
s o
C u
o n
rR i
o se v
s eN i
e i
ht r
r g
n O 's P
a o
pl o
,R o
mdo NE oo t
it I
n i
S o
Ch t
s Lt s
e e
n i
o Ga vM ra i
P
,l t
P p
a n
y R(
m t
r wa i
S F
l s
o a
o m
Ct n C
ud P
e )s Qt m
u u
wmle t
s I
t h
a e
ni t
S uu e
sy nS i
+
mvcd ml e
e ve e oo a mis s
vi roRDMs n
V F
yg s
t eA s
s a
n et e
r n
n R
s d
s nh oioAe tn t
t i s
e e
S e
a r
t t
s r
oc ypAe p
l mgpupe t
e p
m r
k p
e c
f s
u e
u n
s i
e o
a c
c RSI SARRC o
D 99
/9 1
/
5
=
8 leye T
s no n
t i
o n
ts e
e i
t t
n u
is o
Q o
C s
C n
P R
o ta i
n Nt S
r s
r c
e P
o i
u wt f
n L
F iQie e tn
/
f c
v me o
e la e
V p
nR m
ss y
S e
s t
o y
s s
R i
oi r
s e
l t
oA s
i t
i S
bl s
t s
d a
yA ai r
d l
t a
e pt Au te k
e w
gf s
e e
a i
cD YRS R
s c
n n
f AoAA 99
/9 1
/
5
0 1
)
C t
O n
T e
(
m s
tn u
e t
c n
o oC D
f o
e e
c l
n b
a a
T d
f i
o u
G we t
i s
v a
m u
r t
e r
a v
o tS O
F 9
9
/
9 1
/
5
1 1
tfa t
s r
n d
e u
h m
t n
s c
a o
e a
p h
o o
t d
c r
l S
e a
p e
e o
p v
t t
e g
r l
a pA e
n p
u p
g y
D e
mnA r
g r
t m
o a
f s
e c
L o
u n
d d
i u
wd y
n o
n t
e i
I g
u c
e nla n
t o
s i
i ne O
n vf n
D e
e o
o t
r R
mif s
t i
/
t ms a
i e
e s
n r
s e mo o D o
c tt r
i e CC P
na mTd d
ol e
e a
t d
md i
t n
n e
f a
i o
ni d
o o
t u
Cf ni ii i
l s
t e
e a
i i
G DI V
vd d
llu e
d
- RA F
99
/9 1
/
5
2 1
l s
l n
A o
l i
C d
a t
n n
a e
t O
a o
f n
a it e
S y
i T
n d
m R
t A
d u
a c
x n
i g
o d
e n
n D
n m
o e
i g
p r
d i
p u
e u
n A
i s
q c
t a
e r
n o
r o
o b
"e t
s p
D s
nmm p
n e
u o
i e
e mt i
t S
t I
i c
ua s
n o
n ct s
P a
oa s
o t
s ei n
r n
Gw d
D e-c a
e t
e i
f nir mapOo d
e P
Rd u
oo nd h
t G
yn ei c
E Whu d
e ps a GBS n
t ok p
t Bt Ao A
a 9
c 9
/9 1
/
=
5
3 1
x er i
i S
t d
eF nP s
a n
f e
al L
m o/
p Sla it V
r p
Re r is o
A v
o R
x F
O P
S r
i o
d f
e t
f nn o
n a
e a
mt pf o
a i
e r
s ei po c
m m
syAt e
t r
i x
b o
rl u
Ca ot l
f e
l f
c n
n w
i n
o om w
o gA n
o D
inic a
s ll s
s e
r a
o e ws g
e f
e Do uht o
r l
s n
Ai c
r c
ed l
iip t
n h
ud n
w a
h nn o
t oi s
wit nn d
sS s
n n
ot n
oo i
i e
i c
e i
i u
af ad e
t t
t t
a t
t nii t
S nu o
o oo n
G s
s o
oh r
CRCSP CPP9 9
/9 1
/
5
S e
4 1
P cn T
a d
V i
R u
G S
e f
z o
ila y
n w
i r
f e
a i
o v
m e
t r
m yr u
a C
S R
s s
e N
c e
n t
ro n
s f
e n
m o
e u
t u
nc i
a o
c s
l AiPD s
99
/9 1
/5
7 1
Project No. 691
. Boiling Water Reactor Owners' Group
)
cc:
W. Glenn Warren James M. Kenny j
BWR Owners' Group Chairman BWR Owners' Group Vice Chairman i
Southern Nuclear Company PP&L, Inc.
42 Inverness Parkway -
Two North Ninth Street PO Box 1295 Mail Code GENA 6-1 Birmingham, AL 35201 Allentown, PA 18101-1179 Thomas J. Rausch Drew B. Fetters RRG Chairman-PECO Energy Commonwealth Edison Company Nuclear Group Headquarters Nuclear Fuel Services MC 61 A-3 1400 Opus Place,4* Floor 965 Chesterbrook Blvd.
Downers Grove, IL 60515-5701 Wayne, PA 19087-5691 H. Lewis Sumner Carl D. Terry Southern Nuclear Company Niagara Mohawk Power Corporation 40 Inverness Parkway Nine Mile Point Station PO Box 1295 OPS Bldg /2* Floor Birmingham, AL 35201 PO Box 63 Lycoming, NY 13093 i
)
George T. Jones John Kelly PP&L, Inc.
New York Power Authority MC GENA 6-1 14* Ficor Mail Stop 14K Two North Ninth Street Centroplex Building Allentown, PA 18101 123 Mr.in Street White Plains, NY 10601 Dennis Townsend Thomas A. Green GE Nuclear Energy
. GE Nuclear Energy M/C 182 M/C 182
,175 Curtner Avenue 175 Curtner Avenue San Jose, CA 95125 San Jose, CA 95125 l
't i
f a
- .w f
f
- f,
. DISTRIBUTION: Mtg. Summary w/BWROG Dated anno 21 1999 Hard Cooy.
Project File PUBLIC "GEB r/f OGC-ACRS MDavis Email SCollins/RZimmerman i
GBoger-BShoron DMatthews CCarpenter
- JHannon i
SWest LWhitney PMadden
- RWoods i
MCaruso l
SWong -
NSiu GThomas Slee JHyslop 4
l -
JDonohew L