ML20212H778
| ML20212H778 | |
| Person / Time | |
|---|---|
| Issue date: | 06/19/1999 |
| From: | Tim Reed NRC (Affiliation Not Assigned) |
| To: | Bateman W NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9906280140 | |
| Download: ML20212H778 (14) | |
Text
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j NUCLEAR REGULATORY COMMISSION Ie WASHINGTON, D.C. 20066-0001
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I June 19, 1999 MEMORANDUM TO:- William H. Bateman, Chief
' Materials and Chemical Engineering Branch Division of Engineering THRU:
Edmund J. Sullivan, Chief f
. NDE & Metallurgy Section
= Materials and Chemical Engineering Branch Division of EA' gineering
' FROM:
Timothy A. Reed, Senior Project Manager NDE & Metallurgy Section Materials and Chemical Engineering Branc Division of Engineering
SUBJECT:
SUMMARY
OF THE MAY 18,1999, SENIOR MANAGEMENT MEETING WITH NEl/EPRl/ INDUSTRY TO DISCUSS ISSUES INVOLVING lMPLEMENTATION OF NEl 97-06
- On May 18,1999, the NRC staff met with representatives of Nuclear Energy institute (NEI),
Electric Power Research Institute (EPRI), and industry to discuss issues regarding the implementation of the industry initiative entitled NEl 97-06 " Steam Generator Program Guidelines." Meeting attendees are identified in Attachment 1. The agenda and slices presented during the meeting are provided as Attachment 2.
Mike Tuckman (Duke Power Company) led the discussion of the status of ine key technical and regulatory framework issues (see slides in Attachment 2) which the staff and industry are working to resolve in support of a generic industry proposal to revise the steam generator (SG) regulatory framework. The NRC staff and industry representatives agreed, that in general, there has been substantial progress in resolving technical and regulatory framework issues.
The majority of technicalissues are now considered resolved, and there is conceptual agreement on the remaining open issues. Two issues where there has been substantial technical disagreement, the probab!!istic structural criteria issue (both the use of the criteria without prior NRC review and the criteria values) and the induced accident leakage issue
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(regarding proposed increases that satisfy licensing basis criteria but may increase risk), are no
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longer being pursued by industry as part of the genaric change package. For both issues, the staff would review and approve proposed changes for these criteria, and as such, the industry concluded it was not necessary tc resolve these issues to support the staff's review of the
. generic change package, c
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2 With regard to the open technical and regulatory framework issues, the following key points were made during the meeting:
- 1. In response to the staff's comments (at the May 6 technical meeting) on the most recent industry SG technical specification (TS) proposal, industry management indicated that they would rework the SG TS and supporting technical requirements manual (TRM) proposal. The objective is to make the revised SG TS/TRM proposal more consistent with the maintenance rule philosophy. Industry intends to simplify the " action statement" portion of the TRM and to revise the language to be more consistent with a TRM (i.e.,
remove language that is more typical of a TS since the TRM is part of the UFSAR).
- 2. Industry management requested the staff reconsider the need for the 12 month report that the staff had incorporated into its earlier suggested SG TS drafts (the staff envisioned that this report would contain the results of the licensee's SG inspection).
The industry commented that an approach more consistent with the maintenance rule would be to require licensees to submit a report to the staff only in the event that the licensee falls to meet the performance criteria. For the normal situation where the performance criteria are satisfied, the licensee would retain the information on site for staff inspection. The staff agreed to consider the industry comments.
- 3. Industry management commented that the staff has not identified the acceptance criteria for what level of risk would be acceptable in conjunction with new SG proposals.
Brian Sheron discussed the current status of the staff's efforts to develop policy in this area, and specifically discussed the staff's difficulties with the ongoing review of the Callaway electro-siseve submittal and its relevance to the SG generic effort. He indicated that the staff's risk decision regarding the Callaway electro-sleeving submittal should not be construed by industry as setting a precedent for future SG submittals since the staff's deliberations are entirely specific to the Callaway submittal. A central policy issue which remains unresolved at this time, concerns what limitations, if any (up to and including rejection of the proposal), the staff can impose on a licensee's nonrisk-informed submittal that stem from the staff's independent consideration of risk. Dr.
Sheron indicated that the staff has concluded that it is acceptable to ask licensee's
- questions concerning the risk impact of proposals and suggested that licensees should consider the risk implications of SG proposals to be able to respond to such questions.
If the NRC staff determines that risk impact satisfies the RG 1.174 criteria, then the submittal would be found acceptable. However, if the risk impacts falls into the gray region of the RG 1.1'T4 acceptance criteria, then additional staff management attention will be focused on the submittal. At present, there is no clear criteria as to what level of risk would be considered acceptable.
- 4. Ir'dustry management commented that the staff and industry SG TS proposals t
oeveloped to date need to be clarified to indicate that new SG plug repairs do not I
require prior NRC review and approval, since plug repairs are currently performed in accordance with ASME Code requirements and industry plans to continue this practice
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under the revised regulatory framework. The staff agreed with the comment.
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- 5. Regarding the issue of grandfathering previously approved repair criteria and repair methods (i.e., making previously approved approaches available to licensees without the need for a TS amendment or need for gaining prior NRC review and approval), t'.1e l
Industry offered to look at past staff approvals and document the basis and constraints
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i that the staff utilized to approve the proposals. The staff commented that on a plant-specific basis, grandfathering-approved approaches is a relatively simple task of removing the approved approaches from the current SG TS and placing them in the TRM. Regarding the issue of making previously approved repair criteria and repair methods available to other licensees on a generic basis, the staff indicated that in addition to identifying the constraints for adopting these previously approved approaches, there are at least two issues that need to be addressed. The staff needs to determine whether the public must be offered an opportunity to comment on these grandfathered approaches, and the staff must gain CRGR approval for these grandfathered approaches since the staff would be granting a generic approval to licensees who satisfy the constraints and adopt the grandfathered approaches in the future. The staff commented that the effort to grandfather previously approved SG approaches could potentially be resource intensive and suggested that industry identify and prioritize the previous approved repair criteria and repair methods where it would like the staff to focus its efforts. The staff also commented that it intends to work through a specific case (such as laser welded sleeves) to flush out any additional problems that need resolution to facilitate the grandfathering approach.
Industry management commented that for industry senior management to be successful in persuading PWR licensees to adopt a generic SG TS/TRM approach, the staff needs to be reasonable in its demands regarding the SG TS/TRM proposal and maintain an approach that is consistent with policies in other regulatory areas. If the new SG TS approach appears to industry to be simply more requirements added to the current SG inspection requirements, then industry management believes there is little chance for gaining industry support for the SG TS initiative.
The next senior management meeting was tentatively scheduled for mid-August, following the industry's scheduled submittal of the SG TS generic change package.
Attachments: As stated i
i NEl/EPRl/ INDUSTRY STEAM GENERATOR ISSUES SENIOR MANAGEMENT MEETING MAY 18,1999 1
LIST OF ATTENDEES NAME ORG/ POSITION 1.
Tim Reed NRC/NRR/DE/EMCB 2.
Jim Riley NEl 3.
Jack Woodard Southern Nuclear 4.
Mike Tuckman Duke Power 5.
Rich Barrett NRC/NRR/DSSA/SPSB 6.
David Steininger EPRI 7.
L,ill Bateman NRC/NRR/DE/EMCB 8.
Brian Sheron NRC/NRR/ADT 9.
Emmett Murphy NRC/NRP/DE/EMCB
- 10. Rick Mullins Southern Nuclear
- 11. Charles Brinkman ABB CENP
- 12. Donald Streinz ABB
- 13. Ted Sullivan NRC/NRR/DE/EMCB
- 14. Mike Schoppman FPL Washington Rep
- 15. Dick Wessman NRC/NRR/DE
- 16. Eileen McKenna NRC/NRR/ DRIP
- 17. David Stellfox McGraw-Hill
- 18. Nancy Chapman SERCH/Bechtel
- 19. Mike Mayfield NRC/RES
- 20. Jack Strosnider NRC/NRR/DE E
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- 5. Regarding the issue of grandfathering previously approved repair criteria and repair methods (i.e., making previously approved approaches available to licensees without the need for a TS amendment or need for gaining prior NRC review and approval), the industry offered to look at past staff approvals and document the basis and constraints that the staff utilized to approve the proposals. The staff commented that on a plant-specific basis, grandfathering-approved approaches is a relatively simple task of removing the approved approaches from the current SG TS and placing them in the TRM. Regarding the issue of making previously approved repair criteria and repair methods available to other licensees on a generic basis, the staff indicated that in addition to identifying the constraints for adopting these previously approved approaches, there are at least two issues that need to be addressed. The staff needs to determine whether the public must be offered an opportunity to comment on these grandfathered approaches, and the staff must gain CRGR approval for these grandfathered approaches since the staff _would be granting a generic approval to licensees who satisfy the constraints and adopt the grandfathered approaches in the future. The staff commented that the effort to grandfather previously approved SG approaches could potentia! y be resource intensive and suggested that industry identify and prioritize the previous approved repair criteria and repair methods where it would like the staff to focus its efforts. The staff also commented that it intends to work through a specific case (such as laser welded sleeves) to flush out any additional problems that need resolution to facilitate the grandfathering approach.
industry management commented that for industry senior management to be successful in persuading PWR licensees to adopt a generic SG TS/TRM approach, the staff needs to be reasonable in its demands regarding the SG TS/TRM proposal and inaintain an approach that is consistent with policies in other regulatory areas. ' If the new SG TS approach appears to industry to be simply more requirements added to the current SG inspection requirements, then industry management believes there is little chance for gaining industry support for the SG TS initiative.
The next senior management meeting was tentatively scheduled for mid-August, following the
- industry's scheduled submittal of the SG TS generic change package.
Attachments: As stated DISTRIBUTION: PUBLIC PDR.
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