ML23038A001
| ML23038A001 | |
| Person / Time | |
|---|---|
| Issue date: | 02/24/2023 |
| From: | Ngola Otto Licensing Processes Branch |
| To: | Cindy Rosales-Cooper Licensing Processes Branch |
| Shared Package | |
| ML22341A010 | List: |
| References | |
| Download: ML23038A001 (1) | |
Text
February 24, 2023
MEMORANDUM TO: Cindy Rosales-Cooper, Acting 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 12, 2022, PUBLIC MEETING WITH THE BOILING WATER REACTOR OWNERS GROUP EXECUTIVE OVERSIGHT COMMITTEE AND THE NUCLEAR REGULATORY COMMISSION
On December 12, 2022, 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. This meeting was initially scheduled as hybrid but was later changed to a virtual format with participation held 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 Managem ent System (ADAMS) at Accession No. ML22304A018, and presentation slides can be viewed in ADAMS at Package Accession No. ML22341A010. A list of attendees is enclosed.
The BWROG representatives presented the following topics :
BWROG Introduction, BWROG Mission, Organization Structure, Leadership, EOC Membership, Priorities, and Committees Steve Douglas, the BWROG EOC Chairman
Emergency Procedures Committee (EPC) Update Brent Humm, EPC Vice Chairman
Risk Topics Robert Rishel, Integrated Risk Informed Regulation (IRIR) Committee Chair
CONTACT: N. Otto, NRR/DORL 301-415-6695 C. Rosales-Cooper
Technical Specifications Task Force (TSTF)-576, Revise Safety/Relief Valve [(SRV)]
Requirements Update Ryan Joyce, BWROG EOC Member
Regulatory Guide (RG) 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors Tamara Malaney, RG 1.183 Committee Vice Chairman
BWROG Introduction
In the introduction, the BWROG EOC representatives provided an overview of the BWROG, including its mission, organizational structure, leadership, committees (Special Topic, System Improvement, Plant Performance, Core), and priorities. The BWROG EOC priorities include:
equipment reliability associated with f eedwater system consequential event analysis and the recirculation system troubleshooting guide.
risk initiatives associated with 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 offgas system stream jet air ejector training and the stator cooling water guide international support and participation.
EPC Update
For the EPC update, the BWROG representative focused on EPC purpose, Emergency Procedure and Severe Accident Guidelines (EPG/SAGs) Rev. 4 implementation status, workshop with the NRC, and committee activiti es. The committee purpose includes advising the BWROG on issues related to emergency and severe accident response strategies and the maintenance and revision of EPG/SAGs and related documents. The EPC products highlighted include EPGs/SAGs, Technical Support Guidelines, FLEX Support Guidelines, and SAMG Computer Based Training. The BWROG representative explained that currently, all US sites have completed their implementation of EPG/SAG Rev. 4 that was published in 2018. The original schedule for implementation was within 2 refueling outages or 3 years, whichever is longer.
Risk Topics
For the risk topic, the BWROG representative discussed BWR IRIR focus areas including the endorsement of various standards by NRC, including potential endorsement of American Nuclear Society/American Society of Mechanical Engineers (ANS/ASME) 2022 Probabilistic Risk Assessment (PRA) Standard for Low Power Shutdown (LPSD) in RG 1.200, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, Rev. 4, LPSD fire PRA methods development and industry participation, concern of transparency with seismic research currently in process, and common cause failure of digital instrumentation and control systems.
For IEEE 1819, IEEE Standard for Risk-Informed Categorization and Treatment of Electrical and Electronic Equipment at Nuclear Power Generating Stations and Other Nuclear Facilities, the BWROG highlighted issues that it has with the IEEE 1819 standard associated with a conflict that it sees with NRC endorsed guidance for 10 CFR 50.69 in NEI 00-04, 10 CFR 50.69 C. Rosales-Cooper
Structures, Systems and Components (SSC) Categorization Guideline.
For LPSD standard, and specifically the potential endorsement of ANS/ASME 2022 PRA standard for LPSD in RG 1.200, Rev 4, the BWROG representative discussed issues the BWROG has with the standard such as certain supporting requirements being unrealistic, and that there was no identified application. The BWROG also communicated that it is not sure what the driver is for development of a LPSD fire PRA for the existing fleet, and that outage fire risk would seem to require at least a rudimentary LPSD PRA.
For the treatment of common cause failure (CCF) in digital instrumentation and control systems, the BWROG representative indicated that the BWROG agrees that RM-SECY-93-087, Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light-Water Reactor Designs, needed to be updated to address modern digi tal systems, and that its position is that CCFs of 1.0 are not reasonable and could mask other risks.
For the TSTF-576, Revise Safety/Relief Valve Requirements, the BWROG representative discussion focused on the need to work with the NRC staff on a final position for TSTF-576 and highlighted recent interactions.
RG 1.183 Committee
For RG 1.183, the BWROG representatives indicated that they had developed a one pager on this issue and that BWRs were more affected than pressurized water reactors on this guidance.
The BWROG expressed concern that the NRC sta ff would issue the revision by end of 2022, without feedback on its comments. The BWROG representatives also mentioned that they thought the current schedule was aggressive and would not allow the BWORG time to react.
For the concerns expressed by the BWROG, the NRC staff indicated that they would respond to the 160+ comments by industry and then go back to the Advisory Committee on Reactor Safeguards (ACRS) subcommittee. Then the NRC staff plans to develop Revision 2, ACRS full committee meeting, and then publish the final guide by spring 2023.
The NRC staff presented the following topics :
Proprietary Information Tom Wengert, Division of Operating Reactor Licensing, NRR
Update on Inspection Plans and Schedule for EPG/SAG Revision 4 Aron Lewin, Division of Reactor Oversight (DRO), NRR
Licensing and TSTF-576, Revise Safety/Relief Valve Requirements, Update Michelle Honcharik and Victor Cusumano, DSS, NRR
Engineering Program Inspections Changes Douglas Bollock, DRO, NRR
Subsequent License Renewal Lauren Gibson, Division of New and Renewed Licenses, NRR, Ted Smith, Office of C. Rosales-Cooper
Nuclear Material Safety and Safeguards, Division of Rulemaking, Environmental, and Financial Support
Digital Instrumentation and Controls (DI&C)
Mike Waters, Division of Engineering and External Hazards, NRR
Proprietary Information
For the proprietary discussion, the NRC staff provided information, on applicable regulations, review process, examples of recent issues with proprietary withholding requests, and a summary that captured the important aspects of the proprietary review process.
Update on Inspection Plans and Schedule for EPG/SAG Revision 4
For the update on inspection plans and schedule for EPG/SAG Revision 4, the NRC staff indicated that the Inspection Procedure 71111.18, Plant Modifications, inspections required for SAMGs are planned for completion by end of 2022.
Licensing and TSTF-576
For the update on licensing and TSTF-576, Revise Safety/Relief Valve Requirements, the NRC staff discussed the need for internal NRC alignment and evaluations for each valve. In addition, the NRC staff discussed the need for discussion with the industry on key gaps and that there will be an opportunity for discussion in the January/February 2023 timeframe.
Engineering Program Inspections Changes
For the Engineering Program Inspection Changes update, the NRC staff provided information and updates on the engineering inspection guidelines, Comprehensive Engineering Team Inspection, Focused Engineering Inspections, Commercial Grade Dedication Inspections, and Age-Related Degradation Inspections that the NRC staff is currently using for plant inspections.
For the subsequent license renewal (SLR) discu ssion, the NRC staff provided an update on the SLR application status, SLR review process, planned environmental reviews and timelines, and outlook by the end of 2024. For the outlook, the NRC staff highlighted that 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.
Digital Instrumentation and Controls
For the DI&C presentation, the NRC staff focused on the NRC vision, accomplishments, and ongoing initiatives. For accomplishments, the NRC staff discussed establishing clear expectations for performing upgrades of lower-level safety significant systems and components under 10 CFR 50.59, Changes, Tests and Experiments, with the issuance DI&C Interim Staff Guidance 06, Revision 2. The NRC staff also discussed the development of NRC Branch Technical Position 7-19 Defense-in-Depth and Diversity to Address DI&C CCF and Non-Light-Water Reactor I&C Design Review Guide, and RG 1.250: Dedication of Commercial-Grade Digital I&C Items in Nuclear Plants. For ongoing initiatives, the NRC staff highlighted DI&C safety system licensing, Risk-Informing DI&C CCF policy, and continuing work on RGs C. Rosales-Cooper
endorsing updated standards.
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 December 12, 2022
NAME ORGANIZATION Denver Atwood SNC, Boiling Water Reactor Owners Group (BWROG) Chair Steve Douglas Tennessee Valley Authority (TVA), BWROG Executive Oversight Committee (EOC) Chairman Pete Gardner Xcel Energy, BWROG CNO Sponsor Sean Miers GE-Hitachi Nuclear Energy (GEH), BWROG EOC member Brent Humm Talen Energy, BWROG Emergency Procedures Committee Vice-Chair Ho Nieh Southern Nuclear Company (SNC), BWROG EOC Member Robert Rishel Duke Energy (Duke), BWROG Integrated Risk Informed Regulation Committee Chairman Ryan Joyce SNC, BWROG EOC Member Kenneth Knaide Public Service Electric and Gas, BWROG EOC At Large Member Lucas Martins GEH, BWROG Director Bill Williamson TVA, Emergency Procedures Committee Chair Robert Hartwick GEH, BWROG Operations PM Shawn Gibby Duke, BWROG EOC Vice Chairman
Mike King Nuclear Regulatory Commission (NRC)
Bo Pham NRC Gregory Suber NRC Jamie Heisserer NRC Michele Sampson NRC Brian Smith NRC Mike Franovich NRC Chris Miller NRC Meena Khanna NRC Laurel Bauer NRC Eric Benner NRC Jonathan Evans NRC Latonia Enos-Sylla NRC Barbara Hayes NRC John Lane NRC Douglas Bollock NRC Lauren Gibson NRC Shilp Vasavada NRC Sheila Ray NRC Victor Cusumano NRC Kevin Hsueh NRC Clifford Munson NRC Stephanie Garza NRC Nicholas Hansing NRC Jigar Patel NRC Vic Cusumano NRC Ngola Otto NRC Enclosure NAME ORGANIZATION Mehdi Reisi Fard NRC Robert Rivera-Roche NRC Jeffery Smith NRC Ian Tseng NRC Michael Waters NRC Thomas Wengert NRC Antonios Zoulis NRC
Suzanne Loyd Constellation Nuclear Jana Bergman Curtiss-Wright Alan Campbell Nuclear Energy Institute
Package: ML22341A010 Mtg. Summary: ML23038A001 NRC Presentation: ML22341A012 BWROG Presentation: ML23055A294 OFFICE DORL/LLPB/PM DORL/LLPB/LA DORL/LLPB/BC DORL/PLPB/PM NAME NOtto DHarrison CRosales-Cooper NOtto DATE 02/13/2023 02/22/2023 02/22/2023 02/24/2023