ML23349A202
| ML23349A202 | |
| Person / Time | |
|---|---|
| Issue date: | 01/08/2024 |
| From: | Ngola Otto Licensing Processes Branch |
| To: | Gerond George Division of Operating Reactor Licensing |
| Shared Package | |
| ML23349A203 | List: |
| References | |
| Download: ML23349A202 (1) | |
Text
January 8, 2024
MEMORANDUM TO: Gerond A. George, 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 OCTOBER 26, 2023, PUBLIC MEETING WITH THE BOILING WATER REACTOR OWNERS GROUP EXECUTIVE OVERSIGHT COMMITTEE AND THE NUCLEAR REGULATORY COMMISSION
On October 26, 2023, the U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Reactor Regulation (NRR), management met with representatives of the Boiling Water Reactor (BWR) Owners Group (BWROG) Executive Oversight Committee (EOC) in a virtual public meeting. 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. ML23268A433, and presentation slides can be viewed in ADAMS at Package Accession No. ML23349A203. A list of attendees is enclosed.
The BWROG representatives presented the following topics:
BWROG introduction, meeting objectives, and overview
- Ho Nieh, Southern Nuclear Company (SNC), Vice President for Regulatory Affairs
Technical Specifications Task Force (TSTF)-576, Revise Safety/Relief Valve (SRV)
Requirements, Update
- Phil Lashley, Energy Harbor, BWROG Licensing Committee Chair
Licensing and TSTF-585, Revise LCO 3.0.3
- Phil Lashley, Energy Harbor, BWROG Licensing Committee Chair
Risk (Code Case N-752, PRA Configuration Control Inspections, Software Common Cause)
- Bob Rishel, Duke Energy, BWROG Integrated Risk Informed Regulation Committee Chair
CONTACT: N. Otto, NRR/DORL 301-415-6695 G. George
- Denver Atwood, SNC, BWROG Chairman
BWROG Introduction
In the introduction, the BWROG representative provided an overview of the BWROG, including its mission, organizational structure, leadership, committees (Special topic, System improvement, Plant performance, Core), membership, and priorities. The BWROG EOC priorities include:
Plant/equipment reliability associated with obsolescence, project management optimization, surveillance test intervals, and best practices.
Risk initiatives associated with risk informed completion times, outage safety assessment, peer reviews, optimizing probab ilistic risk assessment (PRA) models, Title 10 of the Code of Federal Regulations (10 CFR) 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components, implementation.
Knowledge transfer in the areas of handbooks, workshops/training, workforce proficiency, and troubleshooting guides.
International support and participation.
TSTF-576 Update
For the TSTF-576, Revise Safety/Relief Valve Requirements, the BWROG representative discussed that the valve issue will have the intended impact and that there was success on this issue within the last year because of interactions with the NRC and the industry.
Licensing and TSTF-585
For TSTF-585, the BWROG representative discussed that the TSTF provides an alternative 24-hour completion time to initiate shutdown on entering limiting conditions for operation (LCO) 3.0.3. Regarding the NRC suggested revisions, the BWROG plan to send back to the NRC by the end of 2023.
The BWROG also provided an update on other major TSTF activities which include, TSTF-592, Rev. 0, Revise Automatic Depressurization System (ADS) Instrumentation Requirements, TSTF-597, Rev. 0, Eliminate LCO 3.0.3 Mode 2 Requirement, and TSTF-596, Rev. 0, Expand the Applicability of the Surveillance Frequency Control Program (SFCP).
Regarding strategic initiatives, the BWROG representative discussed plans for 10 CFR 50.36 Rulemaking, treatment of TS as data rather than as a document, and work with Nuclear Energy Institute (NEI) on the license amendment review process. The BWROG representative also indicated that a project was started to revise the Informed Completion Time (RICT) program to extend the 30-day backstop to 90 days. The NRC representative also clarified that feedback regarding strategic initiatives will be through the TSTF.
G. George
Risk (Software Common Cause, PRA Configur ation Control Inspections, Code Case N-752)
For the treatment of common cause failure (CCF) in digital instrumentation and control systems, the BWROG representative indicated that the industry is outpacing the updates of NRC policy and guidance and were pursuing guidance regarding digital CCF modeling. The NRC staff were able to clarify their questions about regulatory gaps the industry sees, associated with current regulatory infrastructure, risk informing CCF, and 10 CFR 50.59, Changes, Tests, and Experiments, options. The industrys concern wa s related to change in NRC staff personnel in the digital CCF review area and not an issue regarding the regulatory infrastructure and current guidance.
For PRA configuration control inspections, the BWROG representative discussed a Self-Assessment Checklist as part of the PRA Configuration Control process, and that the PRA Inspection procedure/guidance be made available to licensees. The BWROG representative indicated that they would like feedback on the inspection approach. The NRC representatives indicated that there was ve ry high NRC regional engagement. The NRC regions have the lead and NRC headquarters staff will assist. The NRC staff representative also discussed PRA oversight including smart sample guidance, and cross regional inspection panels for consistency.
For the Code Case N-752, the BWROG representatives indicated that they see an issue with alignment regarding previous submittals and wanted to see the NRC maintain alignment in reviews. The NRC representative indicated that plant specific reviews are in-house, and the NRC have held recent public meetings on this issue.
For power uprates, the BWROG representative indicated that there is potential for power uprates in BWRs and that likely candidates will come from the Idaho National Laboratory report 23-74681, Assessing the Impact of the Inflation Reduction Act on Nuclear Plant Power Uprate and Hydrogen Cogeneration. Additionally, utilities who have not submitted subsequent license renewal (SLR) could be candidates in the 2025 - 2026 window. There were also discussions about preparing the licensing process for future submittals. The NRC representatives also mentioned that lessons learned from past integr ated review team reviews could be used as an example for power uprate submittals.
The NRC staff presented the following topics:
NRC introduction, opening, and closing remarks.
- Mike King - Deputy Office Director for Reactor Programs
Small Modular Reactor
- Michelle Hayes, Division of New and Renewed Licenses (DNRL), Office of Nuclear Reactor Regulation (NRR)
Human Factors Engineering
- Jesse Seymour, Division of Reactor Oversight (DRO), NRR
- Lauren Gibson, DNRL, NRR
- John Moses, Division of Rulemaking, Environmental, and Financial Support, Office of Nuclear Material Safety and Safeguards G. George
Data-driven Licensing
- Doug Broaddus, Division of Operating Reactor Licensing, NRR
NRC Introduction
Mike King, Deputy Office Director for Reactor Programs, NRC, provided opening and closing remarks, and thanked the BWROG EOC for the opportunity to discuss topics of mutual interest as they pertain to the BWR fleet, including licensing, risk related topics, power uprates, small modular reactors, human factors engineering, and SLR. In addition, provided responses to the BWROG questions on NRC licensing and oversight.
Small Modular Reactor
For the small modular reactor presentation, the NRC staff provided an update on NRCs cooperation with the Canadian Nuclear Safety Commission (CNSC). The focus was on the 2022 charter that established cooperation on GE Hitachis BWRX-300 small modular reactor and the discussion included areas of collaboration, challenges, and next steps. Collaborations under the 2019 memorandum of cooperation on advanced reactor and small modular reactor technologies were also shared.
Human Factors Engineering
For the human factors engineering update, the NRC representative discussed how human factor engineering (HFE) supports operator performance, some benefits of digital upgrades, variations in plant-specific HFE-related regulatory basis, and commitments and need for early engagement regarding digital upgrades.
For the SLR, the NRC staff discussed possible ways to make SLR more efficient, initial license renewals under review, provided an update on the SLR application status, planned environmental reviews and timelines, and outlook by the end of 2024. For the outlook, the NRC staff highlighted that 9 applications are expected by end 2024, resources are expected to be a potential challenge, and that the industry should continue to send Notices of Intent so that the NRC staff can plan for future submittals.
Data-driven Licensing
For the data-driven licensing discussion, the NRC staff focused on the managing licensing workload, licensing actions, performance drivers, resource estimating, tracking performance, and using data to drive improvements. The NRC staff also addressed questing from the BWROG representatives, on how past practices, historical data, help best practices, and whether different parts of the NRC organization were more efficient. The NRC staff explained that to be more efficient, we must make the routine work easier and more efficient.
No comments or questions were received by members of the public.
Enclosure:
Attendees List U.S. Nuclear Regulatory Commission and Boiling Water Reactor Owners Group Executive Oversight Committee Public Meeting Attendee List October 26, 2023
NAME ORGANIZATION Denver Atwood SNC, Boiling Water Reactor Owners Group (BWROG) Chair Pete Gardner Xcel Energy, BWROG CNO Sponsor Sean Miers GE-Hitachi Nuclear Energy (GEH), BWROG EOC member Ho Nieh Southern Nuclear Company (SNC), BWROG EOC Member Robert Rishel Duke Energy (Duke), BWROG Integrated Risk Informed Regulation Committee Chairman Kenneth Knaide Public Service Electric and Gas (PSEG), BWROG EOC At Large Member Lucas Martins GEH, BWROG Director Robert Hartwick GEH, BWROG Operations PM Phil Lashley Energy Harbor, BWROG Licensing Committee Chair Mitch Dior PSEG Nuclear, BWROG Vice Chair
Mike King Nuclear Regulatory Commission (NRC)
Eric Benner NRC Bo Pham NRC Jamie Heisserer NRC Vic Cusumano NRC Joseph Donoghue NRC Mike Franovich NRC John Moses NRC Doug Broaddus NRC Jeff Smith NRC James Delosreyes NRC Lauren Gibson NRC Michelle Hayes NRC Clinton Hobbs NRC Daniel King NRC Scott Krepel NRC Michael Marshall NRC Shivani Mehta NRC Ed Miller NRC Jesse Seymour NRC Ian Tseng NRC John Lane NRC Wendell Morton NRC William Orders NRC Jason Paige NRC Bob Pascarelli NRC Lundy Pressley NRC Reinaldo Rodriguez NRC Gokul Vasudevamurthy NRC Shilp Vasavada NRC Brian Wittick NRC Steve Wyman NRC Enclosure Antonios Zoulis NRC
Mary Miller Services - 6 Alan Campbell Nuclear Energy Institute Rob Burg Chico Pellizzari Steven Alferink Steven Dolley David Gennardo Dean Raleigh Jonathan Zeitz
Package: ML23349A203 Mtg. Summary: ML23349A202 NRC Presentation: ML23353A046 BWROG Presentation: ML23296A249 OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DORL/LLPB/BC NRR/DORL/PLPB/PM
NAME NOtto DHarrison GGeorge NOtto
DATE 12/15/2023 12/26/2023 12/26/2023 1/8/2024