ML24144A010
| ML24144A010 | |
| Person / Time | |
|---|---|
| Site: | Electric Power Research Institute |
| Issue date: | 06/05/2024 |
| From: | Lois James Licensing Processes Branch |
| To: | Gerond George Licensing Processes Branch |
| References | |
| MRP-484, EPID L-2024-TOP-0002 | |
| Download: ML24144A010 (1) | |
Text
June 5, 2024 MEMORANDUM TO:
Gerond A. George, Chief Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Lois M. James, Senior Project Manager
/RA/
Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF MEETING TO DISCUSS THE PURPOSE OF MRP-484, GUIDANCE ON TIMING FOR TECHNICAL SPECIFICATIONS REVISION FOLLOWING SURVEILLANCE CAPSULE TESTING, AND ELECTRIC POWER RESEARCH INSTITUTE'S DESIRED OUTCOME OF THE U.S. NUCLEAR REGULATORY COMMISSION STAFF'S REVIEW (EPID NO. L-2024-TOP-0002)
On May 23, 2023, the U.S. Nuclear Commission (NRC) staff met with the Electric Power Research Institute (EPRI) to discuss of the purpose of EPRI Report MRP-484, Guidance on Timing for Technical Specifications Revision Following Surveillance Capsule Testing, and EPRI's desired outcome of the NRC staff's review. The meeting summary is Enclosure 1 and the list of attendees is Enclosure 2.
If you have any questions or comments, please contact me via e-mail at Lois.James@nrc.gov.
Docket No. 9902021
Enclosures:
- 1. Meeting Summary
- 2. List of Attendees CONTACT: Lois M. James, NRR/DORL/LLPB 301-415-3306
U.S. Nuclear Regulatory Commission Public Meeting Summary
Title:
Purpose of Electric Power Research Institute Report MRP-484, Guidance on Timing for Technical Specifications Revision Following Surveillance Capsule Testing, and Electric Power Research Institute's Desired Outcome of the U.S. Nuclear Regulatory Commission Staff's Review Date of Meeting:
May 23, 2024, 10:00 am - 12:00 pm Location:
Webinar Type of Meeting:
This was an Observation Meeting in which attendees had an opportunity to observe the U.S. Nuclear Regulatory Commission (NRC) performing its regulatory function or discussing regulatory issues. Attendees had an opportunity to ask questions of the NRC staff or make comments about the issues discussed following the business portion of the meeting; however, the NRC was not actively soliciting comments toward regulatory decisions at this meeting.
Purpose of the Meeting:
For the NRC staff to gain an understanding of the purpose of EPRI Report MRP-484, Guidance on Timing for Technical Specifications Revision Following Surveillance Capsule Testing, and EPRI's desired outcome of the NRC staff's review.
General Details:
The NRC staff held a public, observational meeting with EPRI to discuss the purpose of EPRI Report MRP-484 and EPRI's desired outcome of the NRC staff's review. The meeting began at 10:00 am and ended at 11:45 am. There were eight NRC staff, two EPRI staff, eleven industry members, and one member of the public or individuals who did not identify themselves. The meeting began with introductions of the NRC staff and EPRI staff.
Summary of Meeting:
The NRC staff began the briefing by stressing that the technical content or appropriateness is not the topic of todays meeting. The NRC staff is questioning whether the topical report (TR) review process in accordance with Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-500, Topical Report Process, is the correct regulatory process for review and approval of EPRI Report MRP-484.
The NRC staff stated that the MRP-484 does appear to meet the first criteria of the definition of a TR does contain generic technical or regulatory information on a topic relevant to nuclear power plant safety or licensing - compliance with Appendix G, Fracture Toughness Requirements, and Appendix H, Reactor Vessel Material Surveillance Program Requirements, of Title 10 of the Code of Federal Regulation Part 50, Domestic licensing of production and utilization facilities.
The NRC staff also stated that the second TR criteria:
adds value by improving the efficiency of other licensing processes by allowing the staff to review proposed methodologies, designs, operational requirements, or other
safety subjects on a generic basis so that they may be implemented by reference by multiple U.S. licensees The NRC staff stated it is not sure what the efficiency improvement would be if MRP-484 was approved. In addition, the NRC staff is not sure what licensing action review would be improved by approval MRP-484.
The NRC staff noted that a purpose of the MRP-484 is to address perceived undue pressure to submit a required technical specification (TS) change earlier than required.
Note: the NRC slide use the word inappropriate pressure. The use of this word was incorrect and should not be inferred as an allegation.
The EPRI staff began their presentation which summarized the report. The objective of the MRP-484 project and report is to develop conservative generic industry guidance on the timeframe within which TS changes motivated by new surveillance capsule data can be developed such that they do not adversely impact plant operating safety. EPRI is seeking NRC review and approval of the proposed guidance./
The EPRI staff stated that MRP-484 is extremely relevant for plants withdrawing capsules with high neutron fluence values and, when new surveillance test data differs substantially from Regulatory Guide (RG) 1.99, Radiation Embrittlement of Reactor Vessel Materials, Revision 2, predictions, utilities have made quick changes to TSs even if they remain bounded by a previously tested capsule neutron fluence or the neutron fluence above which the underprediction in RG 1.99 Revision 2 begins is many years away.
During the EPRI presentation, the NRC staff questioned how the regulatory process overlaid the examples provided on slides entitled Factors Influencing MRP-484 Guidance. During the discussion, an industry member acknowledged that the pressure was arising from licensees desire to avoid operating the plant with non-conservative TS limits and to satisfy resident inspector questions.
The EPRI staff stated that the primary conclusion of MRP-484 is that there will be no non-conservative pressure-temperature (P-T) limit curves as long as every plant that withdraws a capsule and needs to change their P-T limit curve does so within five years after the capsule withdrawal.
The EPRI staff concluded by stating that they are requesting NRC review and approval of MRP-484 so that licensees can use it in their response to the Appendix H reporting requirement to inform the NRC when they will update their P-T limit curves.
The NRC staff ended the meeting by thanking all participants, acknowledging that there was a good exchange of information, stating that the NRC will be considering the information provided in their acceptance determination of MRP-484.
Public Participation Themes:
No member of the public spoke on the webinar.
Action Items/Next Steps:
The NRC staff will prepare and issue a meeting summary.
Attachments:
Meeting description and agenda - ADAMS Accession No. ML24134A100 NRC slide presentation - ADAMS Accession No. ML24144A010 EPRI slide presentation - ADAMS Accession No. ML24142A534
U.S. Nuclear Regulatory Commission Public Meeting - Attendees List May 23, 2024
Title:
Purpose of Electric Power Research Institute (EPRI) Report MRP-484, Guidance on Timing for Technical Specifications Revision Following Surveillance Capsule Testing, and EPRI's Desired Outcome of the NRC Staff's Review Name U.S. Nuclear Regulatory Commission (NRC) Participants Angie Buford U.S. Nuclear Regulatory Commission (NRC)
James Delosreyes U.S. Nuclear Regulatory Commission (NRC)
Carolyn Fairbanks U.S. Nuclear Regulatory Commission (NRC)
Gerond George U.S. Nuclear Regulatory Commission (NRC)
Lois James U.S. Nuclear Regulatory Commission (NRC)
Demetrius Murray U.S. Nuclear Regulatory Commission (NRC)
David Rudland U.S. Nuclear Regulatory Commission (NRC)
On Yee U.S. Nuclear Regulatory Commission (NRC)
Electric Power Research Institute (EPRI) Participants Name Affiliation Amy Freed Electric Power Research Institute (EPRI)
Elliot Long Electric Power Research Institute (EPRI)
Industry Participants Name Affiliation John Conly Certrec Clark Shurtleff Holtec Christopher Koehler Xcel Energy Marjorie Erickson Phoenix Engineering Associates, Inc Mark Kirk Phoenix Engineering Associates, Inc Karina Assis Westinghouse Electric Company, LLC (WEC)
Joshua Coleman Westinghouse Electric Company, LLC (WEC)
Brian Hall Westinghouse Electric Company, LLC (WEC)
Brett Lynch Westinghouse Electric Company, LLC (WEC)
Benjamin Mays Westinghouse Electric Company, LLC (WEC)
Derek Simpson Westinghouse Electric Company, LLC (WEC)
Public Participants Name Affiliation Allen Hiser Member of the public
ML24144A010 (NRC and EPRI slides are listed in summary)
^via eConcurrence
- via e-mail NRR-106 OFFICE DORL/LLPB/PM DORL/LLPB/LA DNRL/NVIB/BC DORL/LLPB/PBC NAME LJames*
DHarrison ABuford GGeorge DATE 05/29/2024 06/03/2024 06/05/2024 06/05/2024 OFFICE DORL/LLPB/PM NAME LJames*
DATE 06/05/2024