ML22144A066

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Summary of December 1, 2021, Public Meeting with the Boiling Water Reactor Owner'S Group Executive Oversight Committee and the Nuclear Regulatory Commission
ML22144A066
Person / Time
Issue date: 05/27/2022
From: Ngola Otto
Licensing Processes Branch
To: Richard Chang
Licensing Processes Branch
Otto N, NRR/DORL/LLPB
Shared Package
ML22136A124 List:
References
Download: ML22144A066 (6)


Text

May 27, 2022 MEMORANDUM TO: Richard Chang, Chief Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Ngola A. Otto, Project Manager /RA/

Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF DECEMBER 1, 2021, PUBLIC MEETING WITH THE BOILING WATER REACTOR OWNERS GROUP EXECUTIVE OVERSIGHT COMMITTEE AND THE NUCLEAR REGULATORY COMMISSION On December 1, 2021, management of the U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Reactor Regulation (NRR) met with representatives of the Boiling Water Reactor (BWR) Owners Group (BWROG) Executive Oversight Committee (EOC) in a hybrid public meeting. In-person participation was held at NRC headquarters and online with Teams. The purpose of the meeting was for the NRC and BWROG managers to discuss current BWR issues of interest. At the meeting, both the NRC staff and the BWROG representatives made presentations. The meeting notice is available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML21312A555. A list of attendees is enclosed. The presentation slides used at the meeting can be viewed at ADAMS Package Accession No. ML22136A124.

The BWROG representatives presented the following topics:

BWROG Introduction, Tim Hanley, the BWROG executive committee chairman BWROG Overview and Mission, Structure, Leadership, Membership BWROG Committees Emergency Procedures Committee and Emergency Procedures Guidelines (EPG)/Severe Accident Guidelines (SAG) Revision 4 Workshop Update, Steve Douglas, BWROG Executive Vice Chairman Risk Informed Consensus Standards (Institute of Electrical and Electronics Engineers, etc.)

Licensing Committee Update, Robert Rishel, Integrated Risk Informed Regulation Committee Chair Flex Operator Actions and Integrated Human Event Analysis System adoption

R. Chang BWROG Licensing and Technical Specifications Task Force (TSTF) Update, Ryan Joyce, BWROG Licensing Committee Chair TSTF-576, Revise Safety/Relief Valve [SRV] Requirements TSTF-582, Reactor Pressure Vessel (RPV) Water Inventory Control (WIC)

Enhancements The BWROG representatives provided the 1) introduction and EOC overview, membership, and committees (Special topic, System improvement, Plant performance, Core committee), 2) an overview of the BWROG emergency procedures committee purpose and products including EPGs/SAGs, technical support guidelines, and diverse and flexible coping strategies support guidelines. An update on the EPG/SAG Revision 4 implementation and December 2020 workshop with the NRC and industry representative was provided.

For Risk Informed Consensus Standards, the BWROG representative discussed standards for risk applications of interest to the BWROG, including Regulatory Guide (RG) 1.200, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, and Title 10 of the Code of Federal Regulations (10 CFR) 50.69, Risk-informed categorization and treatment of structures, systems and components [(SSCs)] for nuclear power reactors. The BWROG representative discussed their issue with the 1) low power shutdown portion of RG 1.200, Rev. 4, which is endorsed by the NRC; and 2) a concern of conflict, or over-prescriptive requirements when compared to 10 CFR 50.69 alternate treatments for SSCs. The BWROG representatives also mentioned having an industry discussion before issuing RG 1.200, Rev. 4.

The NRC staff asked about Human Reliability Analysis numbers. The NRC staff also discussed a recommended workshop, which would include public interaction before endorsement of RG 1.247, Acceptability of PRA Results for Advanced non-LWRs Risk-Informed Activities.

For the TSTF, a background and update on the TSTF-582 enhancements, adoption by the industry, and feedback from licensees was provided. The issues, review timeline, and current status was discussed for TSTF-576, including recent interactions.

It was noted that there was good interaction with the NRC and the TSTF task force. With respect to TSTF-576, it was noted that there is still work to figure out implementation. The NRC staff mentioned about convergence on the issue since both the NRC and the industry had invested significant time in the review. The BWROG representatives mentioned that there is a need to provide a TSTF that the industry will adopt. Also highlighted during the discussion is the fact that there was some level of commitment from the NRC staff and the industry in a meeting on November 23, 2021.

The NRC staff presented the following topics:

NRC Transformation Update Accepting Risk in Decision Making, Ian Tseng, Acting Branch Chief, Division of Engineering and External Hazards (DEX), Nuclear Reactor Regulation (NRR)

Systematic Approach to Risk-informed Licensing, Anders Gilbertson, Division of Risk Analysis, Office of Research Licensee billing process update, Jawanza Gibbs-Nicholson, Fee Billing Team Lead, Office of the Chief Financial Officer

R. Chang Update on Inspection Plans and Schedule for EPG/SAG Revision 4 Implementation, Jeffrey Bream, Division of Reactor Oversight (DRO), NRR Update on Power Operated Valve (POV) Inspections, Tom Scarbrough, Michael Farnan, DEX, NRR and Douglas Bollock, DRO, NRR 10 CFR 50.55a(b)(3)(xi) Rulemaking and American Society of Mechanical Engineers (ASME) Code Case, Tom Scarbrough and Michael Farnan, DEX, NRR and Douglas Bollock, DRO, NRR Digital Instrumentation and Controls (I&C), Jeanne Johnston, Branch Chief, DEX, NRR Accident Tolerant Fuel (ATF), Joe Donoghue, Director, Division of Safety Systems, NRR The NRC staff provided an update on the culture of accepting risk in decision making and systematic approaches to risk-informed licensing, focusing on NRR Office Instruction LIC-206 Revision 1, Integrated Risk-Informed Decision-Making for Licensing Reviews (ML19263A645),

including its implementation. In addition, the NRC staff discussed other systematic uses of risk in licensing, such as RG 1.200 and 10 CFR 50.69; this discussion focused on the consensus probabilistic risk assessment (PRA) standards, regulatory guides for the consensus standards, and implementation of RG 1.200. For the licensee billing process update, the NRC staff discussed the licensee billing process focusing on the Nuclear Energy Innovation and Modernization Act (NEIMA) standard for accurate invoicing, including invoice and billing data structure redesign, standardization of the fee billing validation process, and electronic (e)-billing.

For the update on inspection plans and schedule for EPG/SAG Revision 4 implementation, the NRC staff discussed the reactor oversight process for the oversight of severe accident management guidelines (SAMGs), including NRC staff revised inspection procedure (IP) 71111.18, Plant Modifications, to inspect SAMG commitments, inspection samples completed and next steps.

The NRC staff provided an update on the POV inspection program, including the POV inspection program, status, results, lessons learned, and POV Region panels. In summary, the NRC staff highlighted the success of the implementation of IP 71111.21N.02, Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements, for POV inspections, the importance of lessons learned, and the NRC staffs planned completion of the POV inspections in 2022.

The NRC staff provided a background, applicable guideline, status, and next steps for 10 CFR 50.55a(b)(3)(xi) and the ASME Code Case. For the next steps, the NRC staff planned to review licensee requests to implement the ASME Code for Operations and Maintenance of Nuclear Power Plants Case OMN-28, complete the safety evaluation on Electric Power Research Institute Technical Report 3002019621, and complete the review of public comments on the 10 CFR 50.55a proposed rule.

The NRC staff digital I&C presentation focused on NRCs modernization strategy, accomplishments, guidance, completed review activities, and ongoing work. The NRC staff discussed a plan to have a future workshop to get industry feedback on IP-52003, Digital Instrumentation and Control Modification Inspection (ADAMS Accession No. ML21113A169),

alternate review process (ARP).

R. Chang This is used to verify that the licensee has performed enhanced vendor oversight activities, as defined by the Vendor Oversight Plan for designs licensed by the NRC staff using the digital I&C Interim Staff Guidance-06 Revision 2. The NRC staff also discussed updated guidance, Branch Technical Position 7-19, Guidance for evaluation of defense in depth and diversity to address common-cause failure (CCF) due to latent design defects in digital safety systems (ADAMS Accession No. ML20339A647), Revision 8, used CCF in digital systems.

For ongoing work, the NRC staff also discussed that NEI 17-06, Guidance on Using IEC 61508 Safety Integrity Level (SIL) Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications, was developed to support key aspects of the commercial grade dedication process for dedicating digital I&C equipment for use in safety applications. The NRC staff highlighted early engagement as a key for digital I&C reviews.

For ATF, no slides were used for this topic, however, the NRC staff asked the BWROG representatives about industry plans regarding ATF. BWROG agreed to provide a response to the NRC at a later date.

No comments or questions were received by members of the public.

Enclosure:

Attendees List

U.S. Nuclear Regulatory Commission Public Meeting Attendance Boiling Water Reactor Owners Group Executive Oversight Committee December 1, 2021 NAME ORGANIZATION Denver Atwood SNC, Boiling Water Reactor Owners Group (BWROG) Chair Steve Douglas TVA, BWROG EOC Executive Vice Chair Pete Gardner Xcel Energy, BWROG CNO Sponsor Tim Hanley Constellation, BWROG Executive Chair Robert Rishel BWROG/Duke Energy Gregory Holmes BWROG/GE Hitachi Ryan Joyce BWROG/SNC Kenneth Knaide PSEG, BWROG EOC At Large Member James Burke GEH, BWROG EOC At Large Member Lucas Martins BWROG/GE Hitachi Bill Williamson BWROG/TVA Robert Brightup BWROG/Constellation Gary DeMoss BWROG/PSEG Shawn Gibby Duke, BWROG EOC At Large Member Mike King Nuclear Regulatory Commission (NRC)

Caroline Carusone NRC Joseph Donoghue NRC Kristy Bucholtz NRC Jeffrey Bream NRC Douglas Bollock NRC Mihaela Biro NRC Luis Colon Fuentes NRC Victor Cusumano NRC Evan Davidson NRC Michael Farnan NRC Jawanza Gibbs-Nicholson NRC Anders Gilbertson NRC Raymond Hoffman NRC Zachary Hollcraft NRC Jeanne Johnston NRC Michelle Kichline NRC Kenneth Kolaczyk NRC John Lane NRC Michael Marshall NRC Dennis Morey NRC Jordan Natreon NRC Ngola Otto NRC Robert Pascarelli NRC Jessie Quichocho NRC Robert Rivera-Roche NRC Tom Scarbrough NRC Ian Tseng NRC Michael Waters NRC Robert Wolfgang NRC Antonios Zoulis NRC Enclosure

Package: ML22136A124 Mtg. Summary: ML22144A066 NRC Presentation: ML22136A126 BWROG Presentation: ML22136A125 OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DORL/LLPB/BC NRR/DORL/PLPB/PM NAME NOtto DHarrison RChang NOtto DATE 5/24/2022 5/26/2022 5/26/2022 5/27/2022