ML052430026: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
 
(Created page by program invented by StriderTol)
 
(2 intermediate revisions by the same user not shown)
Line 2: Line 2:
| number = ML052430026
| number = ML052430026
| issue date = 10/18/2005
| issue date = 10/18/2005
| title = 07/27/2005 - Summary of Mtg. W/Nei to Discuss NEI 04-01, Revision D, Draft Industry Guideline for Combined License (COL) Applicants Under 10 CFR Part 52, and the Operational Program Review Performed During the Evaluation of a COL Applicatio
| title = Summary of Mtg. W/Nei to Discuss NEI 04-01, Revision D, Draft Industry Guideline for Combined License (COL) Applicants Under 10 CFR Part 52, and the Operational Program Review Performed During the Evaluation of a COL Application
| author name = Araguas C J
| author name = Araguas C
| author affiliation = NRC/NRR/DRIP/RNRP
| author affiliation = NRC/NRR/DRIP/RNRP
| addressee name =  
| addressee name =  
Line 9: Line 9:
| docket = PROJ0689
| docket = PROJ0689
| license number =  
| license number =  
| contact person = Araguas C J, NRR/DRIP/RNRP,415-3637
| contact person = Araguas C, NRR/DRIP/RNRP,415-3637
| package number = ML052150345
| package number = ML052150345
| document type = Meeting Summary
| document type = Meeting Summary
Line 16: Line 16:


=Text=
=Text=
{{#Wiki_filter:October 18, 2005ORGANIZATION:Nuclear Energy Institute (NEI)
{{#Wiki_filter:October 18, 2005 ORGANIZATION:           Nuclear Energy Institute (NEI)


==SUBJECT:==
==SUBJECT:==


==SUMMARY==
==SUMMARY==
OF JULY 27, 2005, MEETING WITH NEI TO DISCUSSNEI 04-01, REVISION D, "DRAFT INDUSTRY GUIDELINE FOR COMBINED LICENSE (COL) APPLICANTS UNDER 10 CFR PART 52,"AND THE OPERATIONAL PROGRAM REVIEW PERFORMED DURING THE EVALUATION OF A COL APPLICATIONOn July 27, 2005, the U.S. Nuclear Regulatory Commission (NRC) held a public meeting withNEI at NRC headquarters in Rockville, MD. The purpose of the meeting was to discuss NEI's,draft COL applicant guidance document and how operational programs should be addressed during the COL process. NEI and NRC discussed the electronic submission of a COLapplication, the Standard Review Plan (SRP) update, piping design acceptance criteria (DAC),probabilistic risk assessment (PRA), and the public meetings on updating SRP Section 12.5,?Radiation Protection.The meeting attendees are listed in Attachment 1 and the meetingagenda is given in Attachment 2.Several handouts were distributed during this meeting. They are listed at the end of thismemorandum with their accession numbers. All the handouts can be accessed through the Agencywide Documents Access and Management System (ADAMS) by accession number.
OF JULY 27, 2005, MEETING WITH NEI TO DISCUSS NEI 04-01, REVISION D, DRAFT INDUSTRY GUIDELINE FOR COMBINED LICENSE (COL) APPLICANTS UNDER 10 CFR PART 52, AND THE OPERATIONAL PROGRAM REVIEW PERFORMED DURING THE EVALUATION OF A COL APPLICATION On July 27, 2005, the U.S. Nuclear Regulatory Commission (NRC) held a public meeting with NEI at NRC headquarters in Rockville, MD. The purpose of the meeting was to discuss NEIs, draft COL applicant guidance document and how operational programs should be addressed during the COL process. NEI and NRC discussed the electronic submission of a COL application, the Standard Review Plan (SRP) update, piping design acceptance criteria (DAC),
ADAMS provides text and image files of NRC's public documents. If you do not have access toADAMS or if you have problems in accessing the handouts in ADAMS, call the NRC PublicDocument Room (PDR) reference staff at 1-800-397-4209 or 301-415-4737 or e-mail pdr@nrc.gov. NEI 04-01 DISCUSSIONSBelow is a summary of the topics discussed in the meeting in the order they appeared in theagenda. Several action items were identified and are summarized at the end of this summary.
probabilistic risk assessment (PRA), and the public meetings on updating SRP Section 12.5,
Section numbers refer to NEI 04-01 unless otherwise stated.Implementation of Operational ProgramsNEI said that the NEI 04-01 meetings had provided good discussions on the operationalprograms identified in the NEI letter dated May 14, 2001. As a result of the June meeting, NEIprovided the NRC with a proposal in an e-mail dated July 18, 2005 (Attachment 3). NEIproposed a list of 17 operational programs specifically required by NRC regulations. NEI saidthat the operational programs would be described in the final safety analysis report (FSAR), and would reflect past practice and current guidance (e.g., SRPs). NEI stated that these programs and their implementation would be clearly and sufficiently described in terms of scope and level of detail to allow the staff to make a reasonable assurance finding on program acceptability. Asa result, NEI stated that it no longer found it necessary to identify key elements of operational   programs in a COL application as was proposed by the NRC in the June 2005, public meeting. With this level of detailed information in the FSAR, NEI said the regulations and the oversight process (construction and inspection program) should be a significant source of establishing reasonable assurance.NEI said it now envisions five license conditions for operational programs. NEI looked at somerecent operating licenses and some standard license conditions in developing the five license conditions. The five license conditions include the implementation schedule of the 17 operational programs, as well as specific license conditions for fire protection emergency preparedness and physical security programs. NEI said the most efficient way of preparing for the inspections would be to give the staff the implementation schedules for these programs. NEI said it had made minor changes to license conditions 2 through 5 from the June 2005public meeting. These changes were incorporated to clarify the language. The staff agreed with NEI's proposed language changes to license conditions 2 and 3, and further iterated the use of Generic Letter 86-10 as guidance for fire protection. For license condition 4, the staff asked that "address" be changed to "resolve and correct."  NEI agreed to this change. The staff said that it was concerned about changes to the FSAR after issuance of the COL. NEI said that the regulations require regular updates be provided to the NRC for the designcontrol document (DCD) and the FSAR. Specifically, for operational programs described in theDCD, semiannual reports on departures from the generic DCD would be provided until fuel loadand annual updates of the plant-specific DCD would also be provided until fuel load. TheFSAR, will be updated annually between issuance of a COL and fuel load in accordance with 10CFR 50.71(e). This update includes changes to the operational programs described in the site-specific portion of the FSAR. NEI also said that for operational programs identified in the implementation schedule license condition, NRC inspectors would be informed of c hangesimplemented since the most recent plant-specific DCD/FSAR update when the inspectorsarrived on site and identified the operational program or programs to be inspected.NRC provided a list of operational programs that were included in the Westinghouse AP1000final safety evaluation report COL action item list (attachment 4). NRC said that COL actionitems are required to be addressed by the COL applicant. While NRC did not have time toevaluate this list of programs fully, some of these operational programs may need to be reviewed by the staff in a COL application. Those programs should be included in the implementation schedule license condition proposed by NEI. NRC said that the final list ofoperational programs should be determined sometime in the future, such as when the first COL application is filed to ensure that the appropriate operational programs are included in the license condition.NEI said the scope of its list is focused on programs implemented after the COL is issued andexplicitly required by regulation. NEI said it had considered a broad scope of programs but only considered those that meet the above criteria to be appropriate for a license condition. NEI said that it believes that this list of programs would be valid for any type of light water reactor design being considered. NRC acknowledged that NEI had expanded the list from thoseoriginally proposed by NEI for exclusion from inspections, tests, analyses, and acceptance criteria (ITAAC) in its letter dated May 14, 2001. NRC said it will consider the sc ope ofoperational programs further as it develops a response to the Commission staff requirements memorandum on SECY-04-0032, ?Programmatic Information Needed for Approval of a  Combined License Application Without ITAAC."NEI also commented on whether it would be necessary to incorporate a table of operationalprograms and associated milestones in the FSAR. The staff emphasized the importance of placing these tables in the FSAR. After some discussion, NEI and NRC decided that the tableswould be incorporated into the FSAR.NRC asked NEI to provide a letter describing the screening process for required operationalprograms and a proposed list of the operational programs subject to the license conditions discussed in its handout. NEI agreed to provide a letter with this information by the end of August 2005. Training Program Implementation (eg. Timeline)NEI said that it had a draft version of the timeline but was still coordinating with INPO andtherefore did not have anything to present during the meeting. NEI said it planned to continueto coordinate with INPO and would discuss this topic at a future NEI 04-01 public meeting.Standard Review Plan (SRP) Update PrioritiesThe staff gave NEI an overview of the SRP update program as well as the program. BySeptember 2005, the staff plans to have an SRP update schedule made publicly available. By October 2005, the staff expects to have technically updated approximately thirty sections of the SRP; which will be made publicly available after they complete the SRP update procedures. Ina separate activity, the staff stated their intent to make the SRP publicly available in its entiretyby October 2005. The staff also addressed the latest concerns about the future of Review Standard (RS) 002 forreviewing an early site permit (ESP) application. Specifically, the staff is waiting for lessons learned from the current three early site permit reviews, and once this information has been gathered the update will begin. It is anticipated that the technical revisions will be m ade to thecorresponding SRP sections and RS-002 will no long contain guidance but provide pointers tothe appropriate sections of the SRP. Prior to the meeting, the staff had asked NEI to provide a list of priorities regarding the SRPupdate. NEI stated that it did not have a formal list but that it would provide the staff with thislist by the end August. NEI did provide the staff with some discussion on what it currently sees as having high priorities--Chapters 13, 17, and 19, Conduct of Operations, Quality Assurance,Severe Accidents, respectively.Piping Design Acceptance Criteria (DAC)NEI was not prepared to formally discuss its approach to piping DAC. NEI said that it would beprepared to discuss its approach at a later date. Although no formal plans were outlined, NRC and NEI did exchange information in some of the issues regarding piping DAC. The staff asked whether Westinghouse would initiate the design work for piping before a COL application and whether the design work would be submitted in conjunction with a COL application. The staff said that DAC, which includes the design portion and the as-built verification, is part of ITAAC, and that it may be possible to resolve the design portions of piping DAC before the COL is  issued. NEI said it agreed with the staff's thoughts on resolving the design portions before theCOL.The staff asked about industry's intentions regarding piping DAC. NEI said that severalscenarios are being considered for how to handle this issue. One scenario discussed involved piping DAC being satisfied prior to a COL application. Another involved the applicant addressing this work at the COL stage. The staff said that industry needs to decide on how the design work will be handled. NEI said that it will work with Westinghouse and that at the nextpublic meeting NEI will have prepared a definitive approach to handling this issue.NEI also asked the staff at what point the staff wanted to get involved in piping DAC. The staffsaid it wanted to be involved during the COL application stage and after the plant is built during ITAAC. The staff said that one of its primary concerns is what happens if problems are discovered during the ITAAC stage. NEI suggested considering an engineering design verification process to look at piping at the COL stage. The staff said that engineering design verifications were used in the 1980s and might work well for verifying piping design. Both NEI
?Radiation Protection. The meeting attendees are listed in Attachment 1 and the meeting agenda is given in Attachment 2.
Several handouts were distributed during this meeting. They are listed at the end of this memorandum with their accession numbers. All the handouts can be accessed through the Agencywide Documents Access and Management System (ADAMS) by accession number.
ADAMS provides text and image files of NRCs public documents. If you do not have access to ADAMS or if you have problems in accessing the handouts in ADAMS, call the NRC Public Document Room (PDR) reference staff at 1-800-397-4209 or 301-415-4737 or e-mail pdr@nrc.gov.
NEI 04-01 DISCUSSIONS Below is a summary of the topics discussed in the meeting in the order they appeared in the agenda. Several action items were identified and are summarized at the end of this summary.
Section numbers refer to NEI 04-01 unless otherwise stated.
Implementation of Operational Programs NEI said that the NEI 04-01 meetings had provided good discussions on the operational programs identified in the NEI letter dated May 14, 2001. As a result of the June meeting, NEI provided the NRC with a proposal in an e-mail dated July 18, 2005 (Attachment 3). NEI proposed a list of 17 operational programs specifically required by NRC regulations. NEI said that the operational programs would be described in the final safety analysis report (FSAR), and would reflect past practice and current guidance (e.g., SRPs). NEI stated that these programs and their implementation would be clearly and sufficiently described in terms of scope and level of detail to allow the staff to make a reasonable assurance finding on program acceptability. As a result, NEI stated that it no longer found it necessary to identify key elements of operational


and NRC agreed to consider the topics discussed and bring this topic up in a future NEI 04-01public meeting.Electronic Submission of Combined License ApplicationsNEI provided a handout at the meeting which is Attachment 5 to this meeting summary. NEIsaid that several compatibility problems have been encountered during attempts to address therequests of multiple NRC staff within different sections. In its handout, NEI provided the staffwith what it considered the three major issues. NEI discussed the conflicting guidance on file size. ADAMS guidance limits files to 50 megabytes (MB) and suggests that numerous small files be avoided, where as the website publishers want files no larger than 5 MB. NEI said a possible solution would be for industry to provide as few files as practical and that each file be less than 50 MB in size and that only one version be submitted. NEI said that if the staffchooses to place the document on the NRC website as multiple 5 MB files, the staff shouldplace a disclaimer that the website version of the application is not the as-submitted application.The second issue that NEI identified is that ADAMS does not accept files containing objectsusing link protocols such as object linking and embedding (OLE) or dynamic data exchange (DDE). NEI said it thinks that this has created a misconception about the functionality of links in ADAMS. NEI said that links between Adobe PDF files are retained if the files are loaded directly in ADAMS and if the file names remain the same. NEI proposed that industry provide the entire application in pdf format with files named according to NRC guidance so that theycan be loaded into ADAMS retaining the links within the documents.The third issue that NEI identified is that the NRC staff has occasionally requested specific filetypes that do not meet the ADAMS formats. The staff addressed the first issue regarding the discrepancies in file size between the ADAMSversion and the website version by saying that the website version is not required but the staffthinks that it is easier to work with. The staff said it would look into NEI's suggestion of placing a disclaimer on the web for PDF files that NRC breaks into smaller "chunks" for easier Webaccess to inform readers that the website version is not the as-submitted application.The second issue, the staff addressed by saying that links within a PDF file are acceptable butlinks to separate PDF files should be deactivated (according to NRC's current electronicsubmission guidance). However, the staff also said that it would take into consideration NEI's proposal to include a "warning" (in the transmittal letter for a COL application) stating that some of the hyperlinks contained in the files may become inactive they are copied from a CD into ADAMS .On the third issue, the staff said that NRC staff should not require the submission of file formatsthat do not conform with the NRC's electronic submission guidance. The staff said that NRCmanagement is aware of and in agreement with this policy.Probabilistic Risk Assessment/Severe Accident Change ProcessNEI provided a slide package for the meeting, titled "FSAR Chapter 19 and Plant-Specific PRA"(Attachment 6 of this meeting summary). NEI said the slides contained the same information as the slides provided at the June 8-9, 2005, public meeting. NEI said it st ill supported the ideaof a phased development for FSAR Chapter 19 and the plant-specific PRA. This would include a four-phase approach with each phase representing a stage of the COL process from pre-COL to after initial fuel loading during which the FSAR Chapter 19 and the plant-specific PRA would be created and updated. NEI said that during phase 1, a summary of the status and plans for COL items and plant-specific PRA are provided in Chapter 19 of the FSAR. Chapter 19 would also include an assessment versus design PRA of plant-specific design or operational changes, or site-specific topics, which could significantly affect results and conclusions, and an assessment of impacts, and mitigation. The plant-specific PRA during this phase would be the certified design PRA which would include a description of plant-specific design or operational changes, or site-specific topics, which could significantly affect results and conclusions. It would also include an assessment of impacts, and mitigation. The staff asked NEI to clarify what kind of PRA document would be included in the submittal. NEI said the certified design PRA would be submitted and that the expectation is that any significant changes would be discussed in thesubmittal. The staff said it did not agree with this approach and that there is a large difference between a certified design and an operating plant. The staff also said it was unsure how it would determine that insights are valid. NEI responded by saying that the burden is on theapplicant to address any departures from the design certification PRA. The staff said there isn't a process to identify changes and that a multitude of small changes may have a large cumulative impact on overall plant-specific PRA. NEI said it understood the staff's concerns and that these issues would be addressed in NEI 04-01, Revision E.NEI said that during phase 2, the information provided in phase 1 for Chapter 19 would beupdated annually based on NRC requests for additional information during the COL applicationreview and the responses provided by the COL applicant. Any additional plant-specific changes and/or site-specific topics would also be addressed. The plant-specific PRA would continue to document the description of design and operational changes, and site-specific topics, whichcould significantly affect results and conclusions. Assessments of impacts and mitigation would continue to be documented throughout this phase.During phases 3 and 4, NEI said that Chapter 19 of the FSAR would continue to be updatedannually, and that phase 4 updates would be in accordance with 10 CFR 50.71(e). NEI said that during phase 3, Revision 0 of the plant-specific PRA would be completed and reviewedusing information that reasonably represents the as-built, as-to-be-operated plant. During phase 4 the plant-specific PRA would be maintained as appropriate. Regarding the phased development of PRA, the staff asked NEI how the process wouldaddress facts and observations gained in phase 3 from the industry peer review . NEI said that during phases 1-2 the focus is on whether the certified design PRA bounds the plant. In phases 3-4 the focus is realistic analysis. The phase 3 review would focus on whether the risk results accurately represent the plant. NEI said it was considering a peer review in phases 1-2.
programs in a COL application as was proposed by the NRC in the June 2005, public meeting.
The staff said a peer review in phases 1-2 would give the staff more confidence. NEI said it would evaluate whether or not to perform a peer review in phases 1-2. During the meeting, there was considerable discussion regarding when in the process a site-specific PRA (i.e., a quantified, site-specific version of the design certification PRA) would be available, and when this PRA would be submitted. There was also some discussion on whether the "margins-based" methodologies used to assess external events in the design certification should be required to be upgraded to "PRA-based" methodologies prior to COL issuance or plant startup. The PRA discussions were longer than anticipated and as a result the severe accident changeprocess discussion will be deferred until the next NEI 04-01 public meeting. Radiation ProtectionThe staff provided a brief update on the status of radiation protection. The staff said that it iswaiting for additional information from NEI on SRP Section 12.5. The staff said that a meeting to discuss the current issues regarding radiation protection had been scheduled for July 29, 2005. Clarification of NRC Written CommentsThe staff talked about where the NRC and NEI stand regarding the comment letters that theNRC has been drafting on NEI's COL guidance document. So far, the staff has given NEI fourcomment letters. The staff will send NEI one more letter. The staff and NEI decided that themost effective way of clarifying NRC's written comments would be to host a teleconference and go over each issue that NEI discovers.NEI briefly discussed its plans for the NEI 04-01 COL guidance document. NEI said it wouldlike to incorporate the staff's written comments on the document in Revision E but it will dependon whether the staff and NEI can clarify the written comments in time. NEI plans to issue Revision E as a draft document on September 30, 2005 and plans to issue the final document by the end of the year. NEI also said it is beginning work on another guidance document, NEI 06-01, "COL Implementation Guidance," and plans to issue a first draft sometime next  year.Action ItemsNEI Action Items
With this level of detailed information in the FSAR, NEI said the regulations and the oversight process (construction and inspection program) should be a significant source of establishing reasonable assurance.
*Send NRC a letter explaining NEI's criteria for selecting the required operational programsand listing the programs by the end of August 2005.*Submit a list of the industry's top priorities for the SRP update.
NEI said it now envisions five license conditions for operational programs. NEI looked at some recent operating licenses and some standard license conditions in developing the five license conditions. The five license conditions include the implementation schedule of the 17 operational programs, as well as specific license conditions for fire protection emergency preparedness and physical security programs. NEI said the most efficient way of preparing for the inspections would be to give the staff the implementation schedules for these programs.
*Establish a definitive approach to piping DAC for the next public meeting.
NEI said it had made minor changes to license conditions 2 through 5 from the June 2005 public meeting. These changes were incorporated to clarify the language. The staff agreed with NEIs proposed language changes to license conditions 2 and 3, and further iterated the use of Generic Letter 86-10 as guidance for fire protection. For license condition 4, the staff asked that address be changed to resolve and correct. NEI agreed to this change.
The staff said that it was concerned about changes to the FSAR after issuance of the COL.
NEI said that the regulations require regular updates be provided to the NRC for the design control document (DCD) and the FSAR. Specifically, for operational programs described in the DCD, semiannual reports on departures from the generic DCD would be provided until fuel load and annual updates of the plant-specific DCD would also be provided until fuel load. The FSAR, will be updated annually between issuance of a COL and fuel load in accordance with 10 CFR 50.71(e). This update includes changes to the operational programs described in the site-specific portion of the FSAR. NEI also said that for operational programs identified in the implementation schedule license condition, NRC inspectors would be informed of changes implemented since the most recent plant-specific DCD/FSAR update when the inspectors arrived on site and identified the operational program or programs to be inspected.
NRC provided a list of operational programs that were included in the Westinghouse AP1000 final safety evaluation report COL action item list (attachment 4). NRC said that COL action items are required to be addressed by the COL applicant. While NRC did not have time to evaluate this list of programs fully, some of these operational programs may need to be reviewed by the staff in a COL application. Those programs should be included in the implementation schedule license condition proposed by NEI. NRC said that the final list of operational programs should be determined sometime in the future, such as when the first COL application is filed to ensure that the appropriate operational programs are included in the license condition.
NEI said the scope of its list is focused on programs implemented after the COL is issued and explicitly required by regulation. NEI said it had considered a broad scope of programs but only considered those that meet the above criteria to be appropriate for a license condition. NEI said that it believes that this list of programs would be valid for any type of light water reactor design being considered. NRC acknowledged that NEI had expanded the list from those originally proposed by NEI for exclusion from inspections, tests, analyses, and acceptance criteria (ITAAC) in its letter dated May 14, 2001. NRC said it will consider the scope of operational programs further as it develops a response to the Commission staff requirements memorandum on SECY-04-0032, ?Programmatic Information Needed for Approval of a
 
Combined License Application Without ITAAC.
NEI also commented on whether it would be necessary to incorporate a table of operational programs and associated milestones in the FSAR. The staff emphasized the importance of placing these tables in the FSAR. After some discussion, NEI and NRC decided that the tables would be incorporated into the FSAR.
NRC asked NEI to provide a letter describing the screening process for required operational programs and a proposed list of the operational programs subject to the license conditions discussed in its handout. NEI agreed to provide a letter with this information by the end of August 2005.
Training Program Implementation (eg. Timeline)
NEI said that it had a draft version of the timeline but was still coordinating with INPO and therefore did not have anything to present during the meeting. NEI said it planned to continue to coordinate with INPO and would discuss this topic at a future NEI 04-01 public meeting.
Standard Review Plan (SRP) Update Priorities The staff gave NEI an overview of the SRP update program as well as the program. By September 2005, the staff plans to have an SRP update schedule made publicly available. By October 2005, the staff expects to have technically updated approximately thirty sections of the SRP; which will be made publicly available after they complete the SRP update procedures. In a separate activity, the staff stated their intent to make the SRP publicly available in its entirety by October 2005.
The staff also addressed the latest concerns about the future of Review Standard (RS) 002 for reviewing an early site permit (ESP) application. Specifically, the staff is waiting for lessons learned from the current three early site permit reviews, and once this information has been gathered the update will begin. It is anticipated that the technical revisions will be made to the corresponding SRP sections and RS-002 will no long contain guidance but provide pointers to the appropriate sections of the SRP.
Prior to the meeting, the staff had asked NEI to provide a list of priorities regarding the SRP update. NEI stated that it did not have a formal list but that it would provide the staff with this list by the end August. NEI did provide the staff with some discussion on what it currently sees as having high priorities--Chapters 13, 17, and 19, Conduct of Operations, Quality Assurance, Severe Accidents, respectively.
Piping Design Acceptance Criteria (DAC)
NEI was not prepared to formally discuss its approach to piping DAC. NEI said that it would be prepared to discuss its approach at a later date. Although no formal plans were outlined, NRC and NEI did exchange information in some of the issues regarding piping DAC. The staff asked whether Westinghouse would initiate the design work for piping before a COL application and whether the design work would be submitted in conjunction with a COL application. The staff said that DAC, which includes the design portion and the as-built verification, is part of ITAAC, and that it may be possible to resolve the design portions of piping DAC before the COL is
 
issued. NEI said it agreed with the staffs thoughts on resolving the design portions before the COL.
The staff asked about industrys intentions regarding piping DAC. NEI said that several scenarios are being considered for how to handle this issue. One scenario discussed involved piping DAC being satisfied prior to a COL application. Another involved the applicant addressing this work at the COL stage. The staff said that industry needs to decide on how the design work will be handled. NEI said that it will work with Westinghouse and that at the next public meeting NEI will have prepared a definitive approach to handling this issue.
NEI also asked the staff at what point the staff wanted to get involved in piping DAC. The staff said it wanted to be involved during the COL application stage and after the plant is built during ITAAC. The staff said that one of its primary concerns is what happens if problems are discovered during the ITAAC stage. NEI suggested considering an engineering design verification process to look at piping at the COL stage. The staff said that engineering design verifications were used in the 1980s and might work well for verifying piping design. Both NEI and NRC agreed to consider the topics discussed and bring this topic up in a future NEI 04-01 public meeting.
Electronic Submission of Combined License Applications NEI provided a handout at the meeting which is Attachment 5 to this meeting summary. NEI said that several compatibility problems have been encountered during attempts to address the requests of multiple NRC staff within different sections. In its handout, NEI provided the staff with what it considered the three major issues. NEI discussed the conflicting guidance on file size. ADAMS guidance limits files to 50 megabytes (MB) and suggests that numerous small files be avoided, where as the website publishers want files no larger than 5 MB. NEI said a possible solution would be for industry to provide as few files as practical and that each file be less than 50 MB in size and that only one version be submitted. NEI said that if the staff chooses to place the document on the NRC website as multiple 5 MB files, the staff should place a disclaimer that the website version of the application is not the as-submitted application.
The second issue that NEI identified is that ADAMS does not accept files containing objects using link protocols such as object linking and embedding (OLE) or dynamic data exchange (DDE). NEI said it thinks that this has created a misconception about the functionality of links in ADAMS. NEI said that links between Adobe PDF files are retained if the files are loaded directly in ADAMS and if the file names remain the same. NEI proposed that industry provide the entire application in pdf format with files named according to NRC guidance so that they can be loaded into ADAMS retaining the links within the documents.
The third issue that NEI identified is that the NRC staff has occasionally requested specific file types that do not meet the ADAMS formats.
 
The staff addressed the first issue regarding the discrepancies in file size between the ADAMS version and the website version by saying that the website version is not required but the staff thinks that it is easier to work with. The staff said it would look into NEIs suggestion of placing a disclaimer on the web for PDF files that NRC breaks into smaller chunks for easier Web access to inform readers that the website version is not the as-submitted application.
The second issue, the staff addressed by saying that links within a PDF file are acceptable but links to separate PDF files should be deactivated (according to NRCs current electronic submission guidance). However, the staff also said that it would take into consideration NEIs proposal to include a warning (in the transmittal letter for a COL application) stating that some of the hyperlinks contained in the files may become inactive they are copied from a CD into ADAMS .
On the third issue, the staff said that NRC staff should not require the submission of file formats that do not conform with the NRCs electronic submission guidance. The staff said that NRC management is aware of and in agreement with this policy.
Probabilistic Risk Assessment/Severe Accident Change Process NEI provided a slide package for the meeting, titled FSAR Chapter 19 and Plant-Specific PRA (Attachment 6 of this meeting summary). NEI said the slides contained the same information as the slides provided at the June 8-9, 2005, public meeting. NEI said it still supported the idea of a phased development for FSAR Chapter 19 and the plant-specific PRA. This would include a four-phase approach with each phase representing a stage of the COL process from pre-COL to after initial fuel loading during which the FSAR Chapter 19 and the plant-specific PRA would be created and updated.
NEI said that during phase 1, a summary of the status and plans for COL items and plant-specific PRA are provided in Chapter 19 of the FSAR. Chapter 19 would also include an assessment versus design PRA of plant-specific design or operational changes, or site-specific topics, which could significantly affect results and conclusions, and an assessment of impacts, and mitigation. The plant-specific PRA during this phase would be the certified design PRA which would include a description of plant-specific design or operational changes, or site-specific topics, which could significantly affect results and conclusions. It would also include an assessment of impacts, and mitigation. The staff asked NEI to clarify what kind of PRA document would be included in the submittal. NEI said the certified design PRA would be submitted and that the expectation is that any significant changes would be discussed in the submittal. The staff said it did not agree with this approach and that there is a large difference between a certified design and an operating plant. The staff also said it was unsure how it would determine that insights are valid. NEI responded by saying that the burden is on the applicant to address any departures from the design certification PRA. The staff said there isnt a process to identify changes and that a multitude of small changes may have a large cumulative impact on overall plant-specific PRA. NEI said it understood the staffs concerns and that these issues would be addressed in NEI 04-01, Revision E.
NEI said that during phase 2, the information provided in phase 1 for Chapter 19 would be updated annually based on NRC requests for additional information during the COL application review and the responses provided by the COL applicant. Any additional plant-specific changes and/or site-specific topics would also be addressed. The plant-specific PRA would continue to
 
document the description of design and operational changes, and site-specific topics, which could significantly affect results and conclusions. Assessments of impacts and mitigation would continue to be documented throughout this phase.
During phases 3 and 4, NEI said that Chapter 19 of the FSAR would continue to be updated annually, and that phase 4 updates would be in accordance with 10 CFR 50.71(e). NEI said that during phase 3, Revision 0 of the plant-specific PRA would be completed and reviewed using information that reasonably represents the as-built, as-to-be-operated plant. During phase 4 the plant-specific PRA would be maintained as appropriate.
Regarding the phased development of PRA, the staff asked NEI how the process would address facts and observations gained in phase 3 from the industry peer review . NEI said that during phases 1-2 the focus is on whether the certified design PRA bounds the plant. In phases 3-4 the focus is realistic analysis. The phase 3 review would focus on whether the risk results accurately represent the plant. NEI said it was considering a peer review in phases 1-2.
The staff said a peer review in phases 1-2 would give the staff more confidence. NEI said it would evaluate whether or not to perform a peer review in phases 1-2.
During the meeting, there was considerable discussion regarding when in the process a site-specific PRA (i.e., a quantified, site-specific version of the design certification PRA) would be available, and when this PRA would be submitted. There was also some discussion on whether the margins-based methodologies used to assess external events in the design certification should be required to be upgraded to PRA-based methodologies prior to COL issuance or plant startup.
The PRA discussions were longer than anticipated and as a result the severe accident change process discussion will be deferred until the next NEI 04-01 public meeting.
Radiation Protection The staff provided a brief update on the status of radiation protection. The staff said that it is waiting for additional information from NEI on SRP Section 12.5. The staff said that a meeting to discuss the current issues regarding radiation protection had been scheduled for July 29, 2005.
Clarification of NRC Written Comments The staff talked about where the NRC and NEI stand regarding the comment letters that the NRC has been drafting on NEIs COL guidance document. So far, the staff has given NEI four comment letters. The staff will send NEI one more letter. The staff and NEI decided that the most effective way of clarifying NRCs written comments would be to host a teleconference and go over each issue that NEI discovers.
NEI briefly discussed its plans for the NEI 04-01 COL guidance document. NEI said it would like to incorporate the staffs written comments on the document in Revision E but it will depend on whether the staff and NEI can clarify the written comments in time. NEI plans to issue Revision E as a draft document on September 30, 2005 and plans to issue the final document by the end of the year. NEI also said it is beginning work on another guidance document, NEI 06-01, COL Implementation Guidance, and plans to issue a first draft sometime next
 
year.
Action Items NEI Action Items
* Send NRC a letter explaining NEIs criteria for selecting the required operational programs and listing the programs by the end of August 2005.
* Submit a list of the industrys top priorities for the SRP update.
* Establish a definitive approach to piping DAC for the next public meeting.
NRC Action Items
NRC Action Items
*Office of Information Systems webpage staff to address issues regarding electronicsubmission of a COL application.*Set up a teleconference with NEI to clarify NRC's written comments on NEI 04-01./RA/Christian Araguas, Project ManagerNew Reactors Section New, Research and Test Reactors Division of Regulatory Improvement Programs Office of Nuclear Reactor RegulationAttachments:1.List of Attendees2.Agenda 3.NEI e-mail dated July 18, 2005: Industry Proposal on OperationalPrograms (ML052000149)4.NRC Handout: Selected Programs in Combined License Action Items inthe NRC AP1000 FSER (ML052100175)5.NEI Handout: Electronic Submittal Guidance - Industry Proposal(ML052100177)6.NEI Slides Handout: FSAR Chapter 19 and Plant-Specific PRA(ML052100179)Project No. 689 cc: See next pageby the end of the year. NEI also said it is beginning work on another guidance document,NEI 06-01, "COL Implementation Guidance," and plans to issue a first draft sometime next year.Action ItemsNEI Action Items*Send NRC a letter explaining NEI's criteria for selecting the required operational programsand listing the programs by the end of August 2005.*Submit a list of the industry's top priorities for the SRP update.
* Office of Information Systems webpage staff to address issues regarding electronic submission of a COL application.
*Establish a definitive approach to piping DAC for the next public meeting.
* Set up a teleconference with NEI to clarify NRCs written comments on NEI 04-01.
                                      /RA/
Christian Araguas, Project Manager New Reactors Section New, Research and Test Reactors Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Attachments: 1.       List of Attendees
: 2. Agenda
: 3. NEI e-mail dated July 18, 2005: Industry Proposal on Operational Programs (ML052000149)
: 4. NRC Handout: Selected Programs in Combined License Action Items in the NRC AP1000 FSER (ML052100175)
: 5. NEI Handout: Electronic Submittal Guidance - Industry Proposal (ML052100177)
: 6. NEI Slides Handout: FSAR Chapter 19 and Plant-Specific PRA (ML052100179)
Project No. 689 cc: See next page by the end of the year. NEI also said it is beginning work on another guidance document, NEI 06-01, COL Implementation Guidance, and plans to issue a first draft sometime next
 
year.
Action Items NEI Action Items
* Send NRC a letter explaining NEIs criteria for selecting the required operational programs and listing the programs by the end of August 2005.
* Submit a list of the industrys top priorities for the SRP update.
* Establish a definitive approach to piping DAC for the next public meeting.
NRC Action Items
NRC Action Items
*Office of Information Systems webpage staff to address issues regarding electronicsubmission of a COL application.*Set up a teleconference with NEI to clarify NRC's written comments on NEI 04-01./RA/Christian Araguas, Project ManagerNew Reactors Section New, Research and Test Reactors Division of Regulatory Improvement Programs Office of Nuclear Reactor RegulationAttachments:1.List of Attendees2.Agenda 3.NEI e-mail dated July 18, 2005: Industry Proposal on OperationalPrograms (ML052000149)4.NRC Handout: Selected Programs in Combined License Action Items inthe NRC AP1000 FSER (ML052100175)5.NEI Handout: Electronic Submittal Guidance - Industry Proposal(ML052100177)6.NEI Slides Handout: FSAR Chapter 19 and Plant-Specific PRA(ML052100179)Project No. 689 cc: See next pageADAMS ACCESSION NO. ML052150345-PackageOFFICEPM:RNRPPM:RNRPSC:RNRP NAMECAraguasJColaccinoLDudes DATE09/23/200509/26/200510/03/2005OFFICIAL RECORD COPY Distribution for July 27, 2005, Meeting Summary dated October 18, 2005Hard CopyRNRP R/FCAraguas JColaccino LDudesE-MailPUBLICJDyer (RidsNrrOd)
* Office of Information Systems webpage staff to address issues regarding electronic submission of a COL application.
RBorchardt BSheron (RidsNrrAdpt)
* Set up a teleconference with NEI to clarify NRCs written comments on NEI 04-01.
FEltawila NRR/ADPT Secretary [RidsNrrAdpt]
                                      /RA/
NEI 04-01 Reviewers RNRP Group DMatthews BBoger CCarpenter SRichards DCoe TQuay JHannon SWeerakkody JWermiel FAkstulewicz WBateman ESullivan MMitchell TChan JCalvo RJenkins TJKim, EDO MJohnson CCasto MStutzke DRoberts STingen PSekerak DJohnson RMcIntyre TFoley SAlexander TMensah (NRR Communication Coord)
Christian Araguas, Project Manager New Reactors Section New, Research and Test Reactors Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Attachments: 1.       List of Attendees
: 2. Agenda
: 3. NEI e-mail dated July 18, 2005: Industry Proposal on Operational Programs (ML052000149)
: 4. NRC Handout: Selected Programs in Combined License Action Items in the NRC AP1000 FSER (ML052100175)
: 5. NEI Handout: Electronic Submittal Guidance - Industry Proposal (ML052100177)
: 6. NEI Slides Handout: FSAR Chapter 19 and Plant-Specific PRA (ML052100179)
Project No. 689 cc: See next page ADAMS ACCESSION NO.           ML052150345-Package OFFICE PM:RNRP              PM:RNRP          SC:RNRP NAME CAraguas              JColaccino        LDudes DATE      09/23/2005      09/26/2005        10/03/2005 OFFICIAL RECORD COPY
 
Distribution for July 27, 2005, Meeting Summary dated October 18, 2005 Hard Copy RNRP R/F CAraguas JColaccino LDudes E-Mail PUBLIC                                            LCampbell JDyer (RidsNrrOd)                                 MItzkowitz, OGC RBorchardt                                       GMizuno, OGC BSheron (RidsNrrAdpt)                             TKenyon FEltawila                                         PQualls NRR/ADPT Secretary [RidsNrrAdpt]                 DNelson, OE NEI 04-01 Reviewers                               JBongarra RNRP Group                                       MChiramal DMatthews                                         PLoeser BBoger                                           HLi CCarpenter                                       GBagchi SRichards                                         MAAshley DCoe                                             STingen TQuay                                             JJennings JHannon                                           DTrimble SWeerakkody                                       YLi JWermiel                                         NKTrehan FAkstulewicz                                     DBarss WBateman                                         BMusico ESullivan                                         AKugler MMitchell                                         DThatcher TChan                                             RWeisman JCalvo RJenkins                                         External e-mail TJKim, EDO                                       bhupinder.singh@hq.doe.gov MJohnson                                         tom.miller@hq.doe.gov CCasto                                           Vanessa.Quinn@dhs.gov MStutzke                                         Kenneth.Wierman@dhs.gov DRoberts                                         James.Purvis@dhs.gov STingen PSekerak DJohnson RMcIntyre TFoley SAlexander TMensah (NRR Communication Coord)
ACRS (RidsAcrsMailCenter)
ACRS (RidsAcrsMailCenter)
OPA MEl-Zeftway JBlake RGardner CPaulk
Combination List:                              Mr. Laurence Parme cc:                                            Manager, GT-MHR Safety &
Licensing Mr. Charles Brinkman                        General Atomics Company Westinghouse Electric Co.                  P.O. Box 85608 Washington Operations                      San Diego, CA 92186-5608 12300 Twinbrook Pkwy., Suite 330 Rockville, MD 20852                        Mr. Joseph D. Hegner Lead Engineer - Licensing Mr. David Lochbaum, Nuclear Safety Engineer Dominion Generation Union of Concerned Scientists              Early Site Permitting Project 1707 H Street, NW, Suite 600                5000 Dominion Boulevard Washington, DC 20006-3919                  Glen Allen, VA 23060 Mr. Paul Gunter                            Mr. Edward L. Quinn Nuclear Information & Resource Service      MDM Services Corporations 1424 16th Street, NW, Suite 404            Utility Operations Division Washington, DC 20036                        28202 Cabot Road, Suite 205 Laguna Nigual, CA 92677 Mr. James Riccio Greenpeace                                  Ms. Lynn Connor 702 H Street, NW, Suite 300                Doc-Search Associates Washington, DC 20001                        2211 sw 1ST Ave - #1502 Portland, OR 97201 Mr. Adrian Heymer Nuclear Energy Institute                    Mr. Paul Leventhal Suite 400                                  Nuclear Control Institute 1776 I Street, NW                          1000 Connecticut Avenue, NW Washington, DC 20006-3708                  Suite 410 Washington, DC 20036 Mr. George Alan Zinke Project Manager                            Ms. Patricia Campbell Nuclear Business Development                Morgan, Lewis & Bockius, LLP Entergy Nuclear                            1111 Pennsylvania Avenue, NW M-ECH-683                                  Washington, DC 20004 1340 Echelon Parkway Jackson, MS 39213                          Mr. W. Edward Cummins AP600 and AP1000 Projects Mr. Thomas P. Miller                        Westinghouse Electric Company U.S. Department of Energy                  P.O. Box 355 NE-20, Rm. A286                            Pittsburgh, PA 15230-0355 Headquarters-Germantown 19901 Germantown Road                      Dr. Robert E. Gamble Germantown, MD 20874-1290                  Manager, ESBWR GE Nuclear Energy Ms. Marilyn Kray                            1989 Little Orchard St., M/C 365 Vice President, Special Projects            San Jose, CA 95125-1030 Exelon Generation 200 Exelon Way, KSA3-E Kennett Square, PA 19348 October 19, 2005
Dr. Jack W. Roe                          Mr. Glenn H. Archinoff Nuclear Energy Institute                  AECL Technologies 1776 I Street, NW                        481 North Frederick Avenue Washington, DC 20006-3708                Suite 405 Gaithersburg, MD. 20877 Mr. Stephen P. Frantz Morgan, Lewis, & Bockius, LLP            Dr. Regis A. Matzie 1111 Pennsylvania Avenue, NW              Senior Vice President and Washington, DC 20004                      Chief Technology Officer Westinghouse Electric Company Mr. Gary Wright, Manager                  2000 Day Hill Road Office of Nuclear Facility Safety        Windsor, CT 06095-0500 Illinois Department of Nuclear Safety 1035 Outer Park Drive                    Mr. Ed Wallace, General Manager Springfield, IL 62704                    Projects PBMR Pty LTD Mr. Brendan Hoffman                      PO Box 9396 Research Associate on Nuclear Energy      Centurion 0046 Public Citizens Critical Mass Energy      Republic of South Africa and Environmental Program 215 Pennsylvania Avenue, SE              Mr. Dobie McArthur Washington, DC 20003                      Director, Washington Operations General Atomics Mr. Tom Clements                          1899 Pennsylvania Avenue, NW 6703 Gude Avenue                          Suite 300 Takoma Park, MD 20912                    Washington, DC 20006 Mr. Lionel Batty                          Mr. Russell Bell Nuclear Business Team                    Nuclear Energy Institute Graftech                                  Suite 400 12300 Snow Road                          1776 I Street, NW Parma, Ohio 44130                        Washington, DC 20006-3708 Mr. Ian M. Grant                          Ms. Vanessa E. Quinn, Chief Canadian Nuclear Safety Commission        Radiological Emergency Preparedness 280 Slater Street, Station B              Section P.O. Box 1046                            Nuclear & Chemical Hazards Branch Ottawa, Ontario                          Federal Emergency Management K1P 5S9                                  Agency/DHS 500 C Street, SW Mr. Edward F. Sproat, III                Washington, D.C. 20472 Vice President - Intl Projects Exelon Generation                        Mr. Ron Simard 200 Exelon Way                            6170 Masters Club Drive Kennett Square, PA 19348                  Suwanee, GA 30024 October 19, 2005
Mr. Jerald S. Holm Framatome ANP, Inc.
3315 Old Forest Road P.O. Box 10935 Lynchburg, VA 24506-0935 Ms. Kathryn Sutton, Esq.
Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Ms. Anne W. Cottingham Assistant General Counsel Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006 Mr. David Repka Winston & Strawn LLP 1700 K Street, NW Washington, DC 20006-3817 Mr. Robert E. Sweeney IBEX ESI 4641 Montgomery Avenue Suite 350 Bethesda, MD. 20814 Mr. Eugene S. Grecheck Vice President, Nuclear Support Services Dominion Energy, Inc.
5000 Dominion Blvd.
Glen Allen, VA 23060 E-Mail:
jerald.holm@framatome-anp.com mwetterhahn@winston.com gcesare@enercon.com whorin@winston.com eddie.grant@exeloncorp.com rob.sweeney@ibexesi.com October 19, 2005


OPA MEl-Zeftway JBlake RGardner CPaulkLCampbellMItzkowitz, OGC GMizuno, OGC TKenyon PQualls DNelson, OE JBongarra MChiramal PLoeser HLi GBagchi MAAshley STingen JJennings DTrimble YLi NKTrehan DBarss BMusico AKugler DThatcher RWeismanExternal e-mailbhupinder.singh@hq.doe.govtom.miller@hq.doe.gov Vanessa.Quinn@dhs.gov Kenneth.Wierman@dhs.gov James.Purvis@dhs.gov October 19, 2005Combination List:
NRC Meeting with Nuclear Energy Institute To Discuss NEIs Combined License Application Guidance Document (NEI 04-01) and the Operational Program Review Performed During the Evaluation of a Combined License Application Wednesday, July 27, 2005 8:30 a.m. to 5:00 p.m.
cc:Mr. Charles BrinkmanWestinghouse Electric Co.
NRC Headquarters Conference Room O-1G16 Name                                        Organization Christian Araguas                            NRR/DRIP/RNRP Joseph Colaccino                              NRR/DRIP/RNRP Carey Fleming                                Constellation Al Passwater                                  EPRI Talmage Clements                              Progress Energy Larry Drbal Geoff Quinn                                  Bechtel Ben George                                    Southern Nuclear Jerry Phillabaum                              Enercon Joe Hegner                                    Dominion Ryuji Iwasaki                                Toshiba Al Paglia                                    SCE&G Guy Cesare                                    Enercon Eddie Grant                                  Exelon Carl Berger                                  Energetics Russ Bell                                    NEI Tolani Owusu                                  NRR/DRIP/RNRP Shiela Fabiau                                FCW Patricia L. Campbell                          Morgan Lewis Adrian Heymer                                NEI Hulbert Li                                    NRC/DE/EEIB Russ Wells                                    Parallax Matt Chiramal                                NRC/DE/EEIB Attachment 1
Washington Operations 12300 Twinbrook Pkwy., Suite 330 Rockville, MD 20852Mr. David Lochbaum, Nuclear Safety EngineerUnion of Concerned Scientists 1707 H Street, NW, Suite 600 Washington, DC 20006-3919Mr. Paul GunterNuclear Information & Resource Service


1424 16 th Street, NW, Suite 404Washington, DC 20036Mr. James RiccioGreenpeace 702 H Street, NW, Suite 300 Washington, DC 20001Mr. Adrian HeymerNuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708Mr. George Alan ZinkeProject Manager Nuclear Business Development Entergy Nuclear M-ECH-683 1340 Echelon Parkway Jackson, MS 39213Mr. Thomas P. MillerU.S. Department of Energy NE-20, Rm. A286 Headquarters-Germantown 19901 Germantown Road Germantown, MD 20874-1290Ms. Marilyn KrayVice President, Special Projects Exelon Generation 200 Exelon Way, KSA3-E Kennett Square, PA 19348Mr. Laurence ParmeManager, GT-MHR Safety &
George Zinke      Entergy/NuStart Daniel McLaughlin Westinghouse Yuichi Hatashi    Westinghouse Bob Evans        Enercon Peter Hastings    Duke Energy Alan Levin        Framatome Steven Bloom      NRR/DRIP/RNRP George Thomas     NRR/DSSA/SRXB Jerry Wilson      NRR/DRIP/RNRP Joe Mihalcik      Constellation Bruce Musico      NRC/NSIR/DPR/EPD Daniel Barss      NRC John Tsao        NRC/NRR/DE/EMCB Steve Koenick    NRC/NRR/PMAS/POEB Bob Palla        NRC/NRR/DSSA Adel El-Bassioni NRC/NRR/DSSA Donald Harrison  NRC/NRR/DSSA Keith Shaw        NRC/IS Mike Collins      NRC/IS Kenny Nguyen      NRC/IS Barry Sloane      Dominion Jim Chapman      Scientech LLC David Terao      NRC/NRR/ADPT/DLPM/LP Kamal Manoly      NRC/NRR/DE/EMEB John Fair        NRC/NRR/DE/EMEB
Licensing General Atomics Company P.O. Box 85608 San Diego, CA 92186-5608Mr. Joseph D. HegnerLead Engineer - Licensing Dominion Generation Early Site Permitting Project 5000 Dominion Boulevard Glen Allen, VA 23060 Mr. Edward L. QuinnMDM Services Corporations Utility Operations Division 28202 Cabot Road, Suite 205 Laguna Nigual, CA  92677Ms. Lynn ConnorDoc-Search Associates 2211 sw 1 ST Ave - #1502Portland, OR 97201Mr. Paul LeventhalNuclear Control Institute 1000 Connecticut Avenue, NW Suite 410 Washington, DC 20036Ms. Patricia CampbellMorgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC  20004Mr. W. Edward CumminsAP600 and AP1000 Projects Westinghouse Electric Company


P.O. Box 355 Pittsburgh, PA  15230-0355Dr. Robert E. GambleManager, ESBWR GE Nuclear Energy 1989 Little Orchard St., M/C 365 San Jose, CA 95125-1030  October 19, 2005Dr. Jack W. RoeNuclear Energy Institute 1776 I Street, NW Washington, DC  20006-3708Mr. Stephen P. FrantzMorgan, Lewis, & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC  20004Mr. Gary Wright, ManagerOffice of Nuclear Facility Safety Illinois Department of Nuclear Safety 1035 Outer Park Drive Springfield, IL 62704Mr. Brendan HoffmanResearch Associate on Nuclear Energy Public Citizens Critical Mass Energy and Environmental Program 215 Pennsylvania Avenue, SE Washington, DC  20003Mr. Tom Clements6703 Gude Avenue Takoma Park, MD  20912Mr. Lionel BattyNuclear Business Team Graftech 12300 Snow Road Parma, Ohio 44130Mr. Ian M. GrantCanadian Nuclear Safety Commission 280 Slater Street, Station B P.O. Box 1046 Ottawa, Ontario
Agenda July 27, 2005, Meeting with the Nuclear Energy Institute (NEI) to Discuss NEIs Combined License (COL) Application Guidance and the Operational Program Review Performed During the Evaluation of a Combined License Application 8:30 a.m. Introductions/Opening Remarks                                      NRC/NEI 8:40 a.m. Implementation of Operational Programs                            NRC/NEI 9:40 a.m. Training Program Implementation (eg. timeline)                    NRC/NEI 10:10 a.m. Break 10:25 a.m. SRP Update Priorities                                      NRC/NEI 11:00 a.m. Piping Design Acceptance Criteria                                  NRC/NEI 12:00 p.m. Lunch 1:00 p.m. Electronic Submission of Combined License Applications            NRC/NEI 2:00 p.m. Probabilistic Risk Assessment /Severe Accident Change Process NRC/NEI 3:00 p.m. Break 3:15 p.m. Radiation Protection                                              NRC/NEI 3:45 p.m. Clarifications of NRC Written Comments                            NEI 4:15 p.m. Future Plans for NEI 04-01                                        NEI 4:45 p.m. Adjourn NOTE: Specific topics and associated discussion times may change without notice.
Public comments will be solicited after each agenda item is completed.


K1P 5S9Mr. Edward F. Sproat, IIIVice President - Int'l Projects Exelon Generation 200 Exelon Way Kennett Square, PA 19348Mr. Glenn H. ArchinoffAECL Technologies 481 North Frederick Avenue Suite 405 Gaithersburg, MD. 20877Dr. Regis A. MatzieSenior Vice President and Chief Technology Officer Westinghouse Electric Company 2000 Day Hill RoadWindsor, CT 06095-0500Mr. Ed Wallace, General ManagerProjects PBMR Pty LTD PO Box 9396 Centurion 0046 Republic of South AfricaMr. Dobie McArthurDirector, Washington Operations General Atomics 1899 Pennsylvania Avenue, NW Suite 300 Washington, DC 20006Mr. Russell BellNuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708Ms. Vanessa E. Quinn, ChiefRadiological Emergency Preparedness Section Nuclear & Chemical Hazards Branch Federal Emergency Management Agency/DHS 500 C Street, SW Washington, D.C. 20472Mr. Ron Simard6170 Masters Club Drive Suwanee, GA 30024  October 19, 2005Mr. Jerald S. HolmFramatome ANP, Inc.
==Contact:==
3315 Old Forest Road P.O. Box 10935 Lynchburg, VA 24506-0935Ms. Kathryn Sutton, Esq.Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004Ms. Anne W. CottinghamAssistant General Counsel Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006Mr. David RepkaWinston & Strawn LLP 1700 K Street, NW Washington, DC 20006-3817Mr. Robert E. SweeneyIBEX ESI 4641 Montgomery Avenue Suite 350 Bethesda, MD. 20814Mr. Eugene S. GrecheckVice President, Nuclear Support Services Dominion Energy, Inc.
Joseph Colaccino, NRR 301-415-2753, jxc1@nrc.gov Attachment 2}}
5000 Dominion Blvd.
Glen Allen, VA  23060E-Mail:jerald.holm@framatome-anp.commwetterhahn@winston.com gcesare@enercon.com whorin@winston.com eddie.grant@exeloncorp.com rob.sweeney@ibexesi.com  NRC Meeting with Nuclear Energy Institute To Discuss NEI's Combined LicenseApplication Guidance Document (NEI 04-01) and the Operational ProgramReview Performed During the Evaluation of a Combined License ApplicationWednesday, July 27, 20058:30 a.m. to 5:00 p.m.NRC Headquarters Conference Room O-1G16NameOrganizationChristian AraguasNRR/DRIP/RNRPJoseph ColaccinoNRR/DRIP/RNRPCarey FlemingConstellation Al PasswaterEPRI Talmage ClementsProgress Energy Larry Drbal Geoff QuinnBechtel Ben GeorgeSouthern Nuclear Jerry PhillabaumEnercon Joe HegnerDominion Ryuji IwasakiToshiba Al PagliaSCE&G Guy CesareEnercon Eddie GrantExelon Carl BergerEnergetics Russ BellNEI Tolani OwusuNRR/DRIP/RNRP Shiela FabiauFCW Patricia L. CampbellMorgan Lewis Adrian Heymer NEI Hulbert LiNRC/DE/EEIB Russ WellsParallax Matt ChiramalNRC/DE/EEIB  George ZinkeEntergy/NuStartDaniel McLaughlinWestinghouse Yuichi HatashiWestinghouse Bob EvansEnercon Peter HastingsDuke Energy Alan LevinFramatome Steven BloomNRR/DRIP/RNRP George ThomasNRR/DSSA/SRXBJerry WilsonNRR/DRIP/RNRP Joe MihalcikConstellation Bruce MusicoNRC/NSIR/DPR/EPD Daniel BarssNRC John TsaoNRC/NRR/DE/EMCBSteve KoenickNRC/NRR/PMAS/POEBBob PallaNRC/NRR/DSSA Adel El-BassioniNRC/NRR/DSSA Donald HarrisonNRC/NRR/DSSAKeith ShawNRC/IS Mike CollinsNRC/IS Kenny NguyenNRC/ISBarry SloaneDominion Jim ChapmanScientech LLC David TeraoNRC/NRR/ADPT/DLPM/LP Kamal ManolyNRC/NRR/DE/EMEBJohn FairNRC/NRR/DE/EMEB AgendaJuly 27, 2005, Meeting with the Nuclear Energy Institute (NEI) to Discuss NEI'sCombined License (COL) Application Guidance and the Operational Program ReviewPerformed During the Evaluation of a Combined License Application8:30 a.m.Introductions/Opening RemarksNRC/NEI8:40 a.m.Implementation of Operational ProgramsNRC/NEI9:40 a.m.Training Program Implementation (eg. timeline)NRC/NEI 10:10 a.m. Break 10:25 a.m.SRP Update PrioritiesNRC/NEI11:00 a.m.Piping Design Acceptance CriteriaNRC/NEI 12:00 p.m.Lunch 1:00 p.m.Electronic Submission of Combined License ApplicationsNRC/NEI2:00 p.m.Probabilistic Risk Assessment /Severe Accident Change ProcessNRC/NEI3:00 p.m.Break 3:15 p.m.Radiation ProtectionNRC/NEI 3:45 p.m.Clarifications of NRC Written CommentsNEI 4:15 p.m.Future Plans for NEI 04-01 NEI 4:45 p.m.AdjournNOTE: Specific topics and associated discussion times may change without notice. Public comments will be solicited after each agenda item is completed.Contact:Joseph Colaccino, NRR 301-415-2753, jxc1@nrc.govAttachment 2}}

Latest revision as of 16:12, 8 December 2019

Summary of Mtg. W/Nei to Discuss NEI 04-01, Revision D, Draft Industry Guideline for Combined License (COL) Applicants Under 10 CFR Part 52, and the Operational Program Review Performed During the Evaluation of a COL Application
ML052430026
Person / Time
Site: Nuclear Energy Institute
Issue date: 10/18/2005
From: Christian Araguas
NRC/NRR/DRIP/RNRP
To:
Nuclear Energy Institute
Araguas C, NRR/DRIP/RNRP,415-3637
Shared Package
ML052150345 List:
References
Download: ML052430026 (14)


Text

October 18, 2005 ORGANIZATION: Nuclear Energy Institute (NEI)

SUBJECT:

SUMMARY

OF JULY 27, 2005, MEETING WITH NEI TO DISCUSS NEI 04-01, REVISION D, DRAFT INDUSTRY GUIDELINE FOR COMBINED LICENSE (COL) APPLICANTS UNDER 10 CFR PART 52, AND THE OPERATIONAL PROGRAM REVIEW PERFORMED DURING THE EVALUATION OF A COL APPLICATION On July 27, 2005, the U.S. Nuclear Regulatory Commission (NRC) held a public meeting with NEI at NRC headquarters in Rockville, MD. The purpose of the meeting was to discuss NEIs, draft COL applicant guidance document and how operational programs should be addressed during the COL process. NEI and NRC discussed the electronic submission of a COL application, the Standard Review Plan (SRP) update, piping design acceptance criteria (DAC),

probabilistic risk assessment (PRA), and the public meetings on updating SRP Section 12.5,

?Radiation Protection. The meeting attendees are listed in Attachment 1 and the meeting agenda is given in Attachment 2.

Several handouts were distributed during this meeting. They are listed at the end of this memorandum with their accession numbers. All the handouts can be accessed through the Agencywide Documents Access and Management System (ADAMS) by accession number.

ADAMS provides text and image files of NRCs public documents. If you do not have access to ADAMS or if you have problems in accessing the handouts in ADAMS, call the NRC Public Document Room (PDR) reference staff at 1-800-397-4209 or 301-415-4737 or e-mail pdr@nrc.gov.

NEI 04-01 DISCUSSIONS Below is a summary of the topics discussed in the meeting in the order they appeared in the agenda. Several action items were identified and are summarized at the end of this summary.

Section numbers refer to NEI 04-01 unless otherwise stated.

Implementation of Operational Programs NEI said that the NEI 04-01 meetings had provided good discussions on the operational programs identified in the NEI letter dated May 14, 2001. As a result of the June meeting, NEI provided the NRC with a proposal in an e-mail dated July 18, 2005 (Attachment 3). NEI proposed a list of 17 operational programs specifically required by NRC regulations. NEI said that the operational programs would be described in the final safety analysis report (FSAR), and would reflect past practice and current guidance (e.g., SRPs). NEI stated that these programs and their implementation would be clearly and sufficiently described in terms of scope and level of detail to allow the staff to make a reasonable assurance finding on program acceptability. As a result, NEI stated that it no longer found it necessary to identify key elements of operational

programs in a COL application as was proposed by the NRC in the June 2005, public meeting.

With this level of detailed information in the FSAR, NEI said the regulations and the oversight process (construction and inspection program) should be a significant source of establishing reasonable assurance.

NEI said it now envisions five license conditions for operational programs. NEI looked at some recent operating licenses and some standard license conditions in developing the five license conditions. The five license conditions include the implementation schedule of the 17 operational programs, as well as specific license conditions for fire protection emergency preparedness and physical security programs. NEI said the most efficient way of preparing for the inspections would be to give the staff the implementation schedules for these programs.

NEI said it had made minor changes to license conditions 2 through 5 from the June 2005 public meeting. These changes were incorporated to clarify the language. The staff agreed with NEIs proposed language changes to license conditions 2 and 3, and further iterated the use of Generic Letter 86-10 as guidance for fire protection. For license condition 4, the staff asked that address be changed to resolve and correct. NEI agreed to this change.

The staff said that it was concerned about changes to the FSAR after issuance of the COL.

NEI said that the regulations require regular updates be provided to the NRC for the design control document (DCD) and the FSAR. Specifically, for operational programs described in the DCD, semiannual reports on departures from the generic DCD would be provided until fuel load and annual updates of the plant-specific DCD would also be provided until fuel load. The FSAR, will be updated annually between issuance of a COL and fuel load in accordance with 10 CFR 50.71(e). This update includes changes to the operational programs described in the site-specific portion of the FSAR. NEI also said that for operational programs identified in the implementation schedule license condition, NRC inspectors would be informed of changes implemented since the most recent plant-specific DCD/FSAR update when the inspectors arrived on site and identified the operational program or programs to be inspected.

NRC provided a list of operational programs that were included in the Westinghouse AP1000 final safety evaluation report COL action item list (attachment 4). NRC said that COL action items are required to be addressed by the COL applicant. While NRC did not have time to evaluate this list of programs fully, some of these operational programs may need to be reviewed by the staff in a COL application. Those programs should be included in the implementation schedule license condition proposed by NEI. NRC said that the final list of operational programs should be determined sometime in the future, such as when the first COL application is filed to ensure that the appropriate operational programs are included in the license condition.

NEI said the scope of its list is focused on programs implemented after the COL is issued and explicitly required by regulation. NEI said it had considered a broad scope of programs but only considered those that meet the above criteria to be appropriate for a license condition. NEI said that it believes that this list of programs would be valid for any type of light water reactor design being considered. NRC acknowledged that NEI had expanded the list from those originally proposed by NEI for exclusion from inspections, tests, analyses, and acceptance criteria (ITAAC) in its letter dated May 14, 2001. NRC said it will consider the scope of operational programs further as it develops a response to the Commission staff requirements memorandum on SECY-04-0032, ?Programmatic Information Needed for Approval of a

Combined License Application Without ITAAC.

NEI also commented on whether it would be necessary to incorporate a table of operational programs and associated milestones in the FSAR. The staff emphasized the importance of placing these tables in the FSAR. After some discussion, NEI and NRC decided that the tables would be incorporated into the FSAR.

NRC asked NEI to provide a letter describing the screening process for required operational programs and a proposed list of the operational programs subject to the license conditions discussed in its handout. NEI agreed to provide a letter with this information by the end of August 2005.

Training Program Implementation (eg. Timeline)

NEI said that it had a draft version of the timeline but was still coordinating with INPO and therefore did not have anything to present during the meeting. NEI said it planned to continue to coordinate with INPO and would discuss this topic at a future NEI 04-01 public meeting.

Standard Review Plan (SRP) Update Priorities The staff gave NEI an overview of the SRP update program as well as the program. By September 2005, the staff plans to have an SRP update schedule made publicly available. By October 2005, the staff expects to have technically updated approximately thirty sections of the SRP; which will be made publicly available after they complete the SRP update procedures. In a separate activity, the staff stated their intent to make the SRP publicly available in its entirety by October 2005.

The staff also addressed the latest concerns about the future of Review Standard (RS) 002 for reviewing an early site permit (ESP) application. Specifically, the staff is waiting for lessons learned from the current three early site permit reviews, and once this information has been gathered the update will begin. It is anticipated that the technical revisions will be made to the corresponding SRP sections and RS-002 will no long contain guidance but provide pointers to the appropriate sections of the SRP.

Prior to the meeting, the staff had asked NEI to provide a list of priorities regarding the SRP update. NEI stated that it did not have a formal list but that it would provide the staff with this list by the end August. NEI did provide the staff with some discussion on what it currently sees as having high priorities--Chapters 13, 17, and 19, Conduct of Operations, Quality Assurance, Severe Accidents, respectively.

Piping Design Acceptance Criteria (DAC)

NEI was not prepared to formally discuss its approach to piping DAC. NEI said that it would be prepared to discuss its approach at a later date. Although no formal plans were outlined, NRC and NEI did exchange information in some of the issues regarding piping DAC. The staff asked whether Westinghouse would initiate the design work for piping before a COL application and whether the design work would be submitted in conjunction with a COL application. The staff said that DAC, which includes the design portion and the as-built verification, is part of ITAAC, and that it may be possible to resolve the design portions of piping DAC before the COL is

issued. NEI said it agreed with the staffs thoughts on resolving the design portions before the COL.

The staff asked about industrys intentions regarding piping DAC. NEI said that several scenarios are being considered for how to handle this issue. One scenario discussed involved piping DAC being satisfied prior to a COL application. Another involved the applicant addressing this work at the COL stage. The staff said that industry needs to decide on how the design work will be handled. NEI said that it will work with Westinghouse and that at the next public meeting NEI will have prepared a definitive approach to handling this issue.

NEI also asked the staff at what point the staff wanted to get involved in piping DAC. The staff said it wanted to be involved during the COL application stage and after the plant is built during ITAAC. The staff said that one of its primary concerns is what happens if problems are discovered during the ITAAC stage. NEI suggested considering an engineering design verification process to look at piping at the COL stage. The staff said that engineering design verifications were used in the 1980s and might work well for verifying piping design. Both NEI and NRC agreed to consider the topics discussed and bring this topic up in a future NEI 04-01 public meeting.

Electronic Submission of Combined License Applications NEI provided a handout at the meeting which is Attachment 5 to this meeting summary. NEI said that several compatibility problems have been encountered during attempts to address the requests of multiple NRC staff within different sections. In its handout, NEI provided the staff with what it considered the three major issues. NEI discussed the conflicting guidance on file size. ADAMS guidance limits files to 50 megabytes (MB) and suggests that numerous small files be avoided, where as the website publishers want files no larger than 5 MB. NEI said a possible solution would be for industry to provide as few files as practical and that each file be less than 50 MB in size and that only one version be submitted. NEI said that if the staff chooses to place the document on the NRC website as multiple 5 MB files, the staff should place a disclaimer that the website version of the application is not the as-submitted application.

The second issue that NEI identified is that ADAMS does not accept files containing objects using link protocols such as object linking and embedding (OLE) or dynamic data exchange (DDE). NEI said it thinks that this has created a misconception about the functionality of links in ADAMS. NEI said that links between Adobe PDF files are retained if the files are loaded directly in ADAMS and if the file names remain the same. NEI proposed that industry provide the entire application in pdf format with files named according to NRC guidance so that they can be loaded into ADAMS retaining the links within the documents.

The third issue that NEI identified is that the NRC staff has occasionally requested specific file types that do not meet the ADAMS formats.

The staff addressed the first issue regarding the discrepancies in file size between the ADAMS version and the website version by saying that the website version is not required but the staff thinks that it is easier to work with. The staff said it would look into NEIs suggestion of placing a disclaimer on the web for PDF files that NRC breaks into smaller chunks for easier Web access to inform readers that the website version is not the as-submitted application.

The second issue, the staff addressed by saying that links within a PDF file are acceptable but links to separate PDF files should be deactivated (according to NRCs current electronic submission guidance). However, the staff also said that it would take into consideration NEIs proposal to include a warning (in the transmittal letter for a COL application) stating that some of the hyperlinks contained in the files may become inactive they are copied from a CD into ADAMS .

On the third issue, the staff said that NRC staff should not require the submission of file formats that do not conform with the NRCs electronic submission guidance. The staff said that NRC management is aware of and in agreement with this policy.

Probabilistic Risk Assessment/Severe Accident Change Process NEI provided a slide package for the meeting, titled FSAR Chapter 19 and Plant-Specific PRA (Attachment 6 of this meeting summary). NEI said the slides contained the same information as the slides provided at the June 8-9, 2005, public meeting. NEI said it still supported the idea of a phased development for FSAR Chapter 19 and the plant-specific PRA. This would include a four-phase approach with each phase representing a stage of the COL process from pre-COL to after initial fuel loading during which the FSAR Chapter 19 and the plant-specific PRA would be created and updated.

NEI said that during phase 1, a summary of the status and plans for COL items and plant-specific PRA are provided in Chapter 19 of the FSAR. Chapter 19 would also include an assessment versus design PRA of plant-specific design or operational changes, or site-specific topics, which could significantly affect results and conclusions, and an assessment of impacts, and mitigation. The plant-specific PRA during this phase would be the certified design PRA which would include a description of plant-specific design or operational changes, or site-specific topics, which could significantly affect results and conclusions. It would also include an assessment of impacts, and mitigation. The staff asked NEI to clarify what kind of PRA document would be included in the submittal. NEI said the certified design PRA would be submitted and that the expectation is that any significant changes would be discussed in the submittal. The staff said it did not agree with this approach and that there is a large difference between a certified design and an operating plant. The staff also said it was unsure how it would determine that insights are valid. NEI responded by saying that the burden is on the applicant to address any departures from the design certification PRA. The staff said there isnt a process to identify changes and that a multitude of small changes may have a large cumulative impact on overall plant-specific PRA. NEI said it understood the staffs concerns and that these issues would be addressed in NEI 04-01, Revision E.

NEI said that during phase 2, the information provided in phase 1 for Chapter 19 would be updated annually based on NRC requests for additional information during the COL application review and the responses provided by the COL applicant. Any additional plant-specific changes and/or site-specific topics would also be addressed. The plant-specific PRA would continue to

document the description of design and operational changes, and site-specific topics, which could significantly affect results and conclusions. Assessments of impacts and mitigation would continue to be documented throughout this phase.

During phases 3 and 4, NEI said that Chapter 19 of the FSAR would continue to be updated annually, and that phase 4 updates would be in accordance with 10 CFR 50.71(e). NEI said that during phase 3, Revision 0 of the plant-specific PRA would be completed and reviewed using information that reasonably represents the as-built, as-to-be-operated plant. During phase 4 the plant-specific PRA would be maintained as appropriate.

Regarding the phased development of PRA, the staff asked NEI how the process would address facts and observations gained in phase 3 from the industry peer review . NEI said that during phases 1-2 the focus is on whether the certified design PRA bounds the plant. In phases 3-4 the focus is realistic analysis. The phase 3 review would focus on whether the risk results accurately represent the plant. NEI said it was considering a peer review in phases 1-2.

The staff said a peer review in phases 1-2 would give the staff more confidence. NEI said it would evaluate whether or not to perform a peer review in phases 1-2.

During the meeting, there was considerable discussion regarding when in the process a site-specific PRA (i.e., a quantified, site-specific version of the design certification PRA) would be available, and when this PRA would be submitted. There was also some discussion on whether the margins-based methodologies used to assess external events in the design certification should be required to be upgraded to PRA-based methodologies prior to COL issuance or plant startup.

The PRA discussions were longer than anticipated and as a result the severe accident change process discussion will be deferred until the next NEI 04-01 public meeting.

Radiation Protection The staff provided a brief update on the status of radiation protection. The staff said that it is waiting for additional information from NEI on SRP Section 12.5. The staff said that a meeting to discuss the current issues regarding radiation protection had been scheduled for July 29, 2005.

Clarification of NRC Written Comments The staff talked about where the NRC and NEI stand regarding the comment letters that the NRC has been drafting on NEIs COL guidance document. So far, the staff has given NEI four comment letters. The staff will send NEI one more letter. The staff and NEI decided that the most effective way of clarifying NRCs written comments would be to host a teleconference and go over each issue that NEI discovers.

NEI briefly discussed its plans for the NEI 04-01 COL guidance document. NEI said it would like to incorporate the staffs written comments on the document in Revision E but it will depend on whether the staff and NEI can clarify the written comments in time. NEI plans to issue Revision E as a draft document on September 30, 2005 and plans to issue the final document by the end of the year. NEI also said it is beginning work on another guidance document, NEI 06-01, COL Implementation Guidance, and plans to issue a first draft sometime next

year.

Action Items NEI Action Items

  • Send NRC a letter explaining NEIs criteria for selecting the required operational programs and listing the programs by the end of August 2005.
  • Submit a list of the industrys top priorities for the SRP update.
  • Establish a definitive approach to piping DAC for the next public meeting.

NRC Action Items

  • Office of Information Systems webpage staff to address issues regarding electronic submission of a COL application.
  • Set up a teleconference with NEI to clarify NRCs written comments on NEI 04-01.

/RA/

Christian Araguas, Project Manager New Reactors Section New, Research and Test Reactors Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Attachments: 1. List of Attendees

2. Agenda
3. NEI e-mail dated July 18, 2005: Industry Proposal on Operational Programs (ML052000149)
4. NRC Handout: Selected Programs in Combined License Action Items in the NRC AP1000 FSER (ML052100175)
5. NEI Handout: Electronic Submittal Guidance - Industry Proposal (ML052100177)
6. NEI Slides Handout: FSAR Chapter 19 and Plant-Specific PRA (ML052100179)

Project No. 689 cc: See next page by the end of the year. NEI also said it is beginning work on another guidance document, NEI 06-01, COL Implementation Guidance, and plans to issue a first draft sometime next

year.

Action Items NEI Action Items

  • Send NRC a letter explaining NEIs criteria for selecting the required operational programs and listing the programs by the end of August 2005.
  • Submit a list of the industrys top priorities for the SRP update.
  • Establish a definitive approach to piping DAC for the next public meeting.

NRC Action Items

  • Office of Information Systems webpage staff to address issues regarding electronic submission of a COL application.
  • Set up a teleconference with NEI to clarify NRCs written comments on NEI 04-01.

/RA/

Christian Araguas, Project Manager New Reactors Section New, Research and Test Reactors Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Attachments: 1. List of Attendees

2. Agenda
3. NEI e-mail dated July 18, 2005: Industry Proposal on Operational Programs (ML052000149)
4. NRC Handout: Selected Programs in Combined License Action Items in the NRC AP1000 FSER (ML052100175)
5. NEI Handout: Electronic Submittal Guidance - Industry Proposal (ML052100177)
6. NEI Slides Handout: FSAR Chapter 19 and Plant-Specific PRA (ML052100179)

Project No. 689 cc: See next page ADAMS ACCESSION NO. ML052150345-Package OFFICE PM:RNRP PM:RNRP SC:RNRP NAME CAraguas JColaccino LDudes DATE 09/23/2005 09/26/2005 10/03/2005 OFFICIAL RECORD COPY

Distribution for July 27, 2005, Meeting Summary dated October 18, 2005 Hard Copy RNRP R/F CAraguas JColaccino LDudes E-Mail PUBLIC LCampbell JDyer (RidsNrrOd) MItzkowitz, OGC RBorchardt GMizuno, OGC BSheron (RidsNrrAdpt) TKenyon FEltawila PQualls NRR/ADPT Secretary [RidsNrrAdpt] DNelson, OE NEI 04-01 Reviewers JBongarra RNRP Group MChiramal DMatthews PLoeser BBoger HLi CCarpenter GBagchi SRichards MAAshley DCoe STingen TQuay JJennings JHannon DTrimble SWeerakkody YLi JWermiel NKTrehan FAkstulewicz DBarss WBateman BMusico ESullivan AKugler MMitchell DThatcher TChan RWeisman JCalvo RJenkins External e-mail TJKim, EDO bhupinder.singh@hq.doe.gov MJohnson tom.miller@hq.doe.gov CCasto Vanessa.Quinn@dhs.gov MStutzke Kenneth.Wierman@dhs.gov DRoberts James.Purvis@dhs.gov STingen PSekerak DJohnson RMcIntyre TFoley SAlexander TMensah (NRR Communication Coord)

ACRS (RidsAcrsMailCenter)

OPA MEl-Zeftway JBlake RGardner CPaulk

Combination List: Mr. Laurence Parme cc: Manager, GT-MHR Safety &

Licensing Mr. Charles Brinkman General Atomics Company Westinghouse Electric Co. P.O. Box 85608 Washington Operations San Diego, CA 92186-5608 12300 Twinbrook Pkwy., Suite 330 Rockville, MD 20852 Mr. Joseph D. Hegner Lead Engineer - Licensing Mr. David Lochbaum, Nuclear Safety Engineer Dominion Generation Union of Concerned Scientists Early Site Permitting Project 1707 H Street, NW, Suite 600 5000 Dominion Boulevard Washington, DC 20006-3919 Glen Allen, VA 23060 Mr. Paul Gunter Mr. Edward L. Quinn Nuclear Information & Resource Service MDM Services Corporations 1424 16th Street, NW, Suite 404 Utility Operations Division Washington, DC 20036 28202 Cabot Road, Suite 205 Laguna Nigual, CA 92677 Mr. James Riccio Greenpeace Ms. Lynn Connor 702 H Street, NW, Suite 300 Doc-Search Associates Washington, DC 20001 2211 sw 1ST Ave - #1502 Portland, OR 97201 Mr. Adrian Heymer Nuclear Energy Institute Mr. Paul Leventhal Suite 400 Nuclear Control Institute 1776 I Street, NW 1000 Connecticut Avenue, NW Washington, DC 20006-3708 Suite 410 Washington, DC 20036 Mr. George Alan Zinke Project Manager Ms. Patricia Campbell Nuclear Business Development Morgan, Lewis & Bockius, LLP Entergy Nuclear 1111 Pennsylvania Avenue, NW M-ECH-683 Washington, DC 20004 1340 Echelon Parkway Jackson, MS 39213 Mr. W. Edward Cummins AP600 and AP1000 Projects Mr. Thomas P. Miller Westinghouse Electric Company U.S. Department of Energy P.O. Box 355 NE-20, Rm. A286 Pittsburgh, PA 15230-0355 Headquarters-Germantown 19901 Germantown Road Dr. Robert E. Gamble Germantown, MD 20874-1290 Manager, ESBWR GE Nuclear Energy Ms. Marilyn Kray 1989 Little Orchard St., M/C 365 Vice President, Special Projects San Jose, CA 95125-1030 Exelon Generation 200 Exelon Way, KSA3-E Kennett Square, PA 19348 October 19, 2005

Dr. Jack W. Roe Mr. Glenn H. Archinoff Nuclear Energy Institute AECL Technologies 1776 I Street, NW 481 North Frederick Avenue Washington, DC 20006-3708 Suite 405 Gaithersburg, MD. 20877 Mr. Stephen P. Frantz Morgan, Lewis, & Bockius, LLP Dr. Regis A. Matzie 1111 Pennsylvania Avenue, NW Senior Vice President and Washington, DC 20004 Chief Technology Officer Westinghouse Electric Company Mr. Gary Wright, Manager 2000 Day Hill Road Office of Nuclear Facility Safety Windsor, CT 06095-0500 Illinois Department of Nuclear Safety 1035 Outer Park Drive Mr. Ed Wallace, General Manager Springfield, IL 62704 Projects PBMR Pty LTD Mr. Brendan Hoffman PO Box 9396 Research Associate on Nuclear Energy Centurion 0046 Public Citizens Critical Mass Energy Republic of South Africa and Environmental Program 215 Pennsylvania Avenue, SE Mr. Dobie McArthur Washington, DC 20003 Director, Washington Operations General Atomics Mr. Tom Clements 1899 Pennsylvania Avenue, NW 6703 Gude Avenue Suite 300 Takoma Park, MD 20912 Washington, DC 20006 Mr. Lionel Batty Mr. Russell Bell Nuclear Business Team Nuclear Energy Institute Graftech Suite 400 12300 Snow Road 1776 I Street, NW Parma, Ohio 44130 Washington, DC 20006-3708 Mr. Ian M. Grant Ms. Vanessa E. Quinn, Chief Canadian Nuclear Safety Commission Radiological Emergency Preparedness 280 Slater Street, Station B Section P.O. Box 1046 Nuclear & Chemical Hazards Branch Ottawa, Ontario Federal Emergency Management K1P 5S9 Agency/DHS 500 C Street, SW Mr. Edward F. Sproat, III Washington, D.C. 20472 Vice President - Intl Projects Exelon Generation Mr. Ron Simard 200 Exelon Way 6170 Masters Club Drive Kennett Square, PA 19348 Suwanee, GA 30024 October 19, 2005

Mr. Jerald S. Holm Framatome ANP, Inc.

3315 Old Forest Road P.O. Box 10935 Lynchburg, VA 24506-0935 Ms. Kathryn Sutton, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Ms. Anne W. Cottingham Assistant General Counsel Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006 Mr. David Repka Winston & Strawn LLP 1700 K Street, NW Washington, DC 20006-3817 Mr. Robert E. Sweeney IBEX ESI 4641 Montgomery Avenue Suite 350 Bethesda, MD. 20814 Mr. Eugene S. Grecheck Vice President, Nuclear Support Services Dominion Energy, Inc.

5000 Dominion Blvd.

Glen Allen, VA 23060 E-Mail:

jerald.holm@framatome-anp.com mwetterhahn@winston.com gcesare@enercon.com whorin@winston.com eddie.grant@exeloncorp.com rob.sweeney@ibexesi.com October 19, 2005

NRC Meeting with Nuclear Energy Institute To Discuss NEIs Combined License Application Guidance Document (NEI 04-01) and the Operational Program Review Performed During the Evaluation of a Combined License Application Wednesday, July 27, 2005 8:30 a.m. to 5:00 p.m.

NRC Headquarters Conference Room O-1G16 Name Organization Christian Araguas NRR/DRIP/RNRP Joseph Colaccino NRR/DRIP/RNRP Carey Fleming Constellation Al Passwater EPRI Talmage Clements Progress Energy Larry Drbal Geoff Quinn Bechtel Ben George Southern Nuclear Jerry Phillabaum Enercon Joe Hegner Dominion Ryuji Iwasaki Toshiba Al Paglia SCE&G Guy Cesare Enercon Eddie Grant Exelon Carl Berger Energetics Russ Bell NEI Tolani Owusu NRR/DRIP/RNRP Shiela Fabiau FCW Patricia L. Campbell Morgan Lewis Adrian Heymer NEI Hulbert Li NRC/DE/EEIB Russ Wells Parallax Matt Chiramal NRC/DE/EEIB Attachment 1

George Zinke Entergy/NuStart Daniel McLaughlin Westinghouse Yuichi Hatashi Westinghouse Bob Evans Enercon Peter Hastings Duke Energy Alan Levin Framatome Steven Bloom NRR/DRIP/RNRP George Thomas NRR/DSSA/SRXB Jerry Wilson NRR/DRIP/RNRP Joe Mihalcik Constellation Bruce Musico NRC/NSIR/DPR/EPD Daniel Barss NRC John Tsao NRC/NRR/DE/EMCB Steve Koenick NRC/NRR/PMAS/POEB Bob Palla NRC/NRR/DSSA Adel El-Bassioni NRC/NRR/DSSA Donald Harrison NRC/NRR/DSSA Keith Shaw NRC/IS Mike Collins NRC/IS Kenny Nguyen NRC/IS Barry Sloane Dominion Jim Chapman Scientech LLC David Terao NRC/NRR/ADPT/DLPM/LP Kamal Manoly NRC/NRR/DE/EMEB John Fair NRC/NRR/DE/EMEB

Agenda July 27, 2005, Meeting with the Nuclear Energy Institute (NEI) to Discuss NEIs Combined License (COL) Application Guidance and the Operational Program Review Performed During the Evaluation of a Combined License Application 8:30 a.m. Introductions/Opening Remarks NRC/NEI 8:40 a.m. Implementation of Operational Programs NRC/NEI 9:40 a.m. Training Program Implementation (eg. timeline) NRC/NEI 10:10 a.m. Break 10:25 a.m. SRP Update Priorities NRC/NEI 11:00 a.m. Piping Design Acceptance Criteria NRC/NEI 12:00 p.m. Lunch 1:00 p.m. Electronic Submission of Combined License Applications NRC/NEI 2:00 p.m. Probabilistic Risk Assessment /Severe Accident Change Process NRC/NEI 3:00 p.m. Break 3:15 p.m. Radiation Protection NRC/NEI 3:45 p.m. Clarifications of NRC Written Comments NEI 4:15 p.m. Future Plans for NEI 04-01 NEI 4:45 p.m. Adjourn NOTE: Specific topics and associated discussion times may change without notice.

Public comments will be solicited after each agenda item is completed.

Contact:

Joseph Colaccino, NRR 301-415-2753, jxc1@nrc.gov Attachment 2