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BWROG Executive Oversight Committee & NRC Management Meeting July 26, 2018 Rockville, MD Copyright 2018, BWR Owners’ Group, All Rights Reserved

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Page 1: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

BWROG Executive Oversight Committee & NRC Management

Meeting

July 26, 2018Rockville, MD

Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 2: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

BWROG Introduction

Copyright 2018, BWR Owners’ Group, All Rights Reserved

1July 26, 2018

Tim Hanley (Exelon) – BWROG Executive Chairman

BWROG EOC & NRC Meeting

July 26, 2018

Rockville, MD

Page 3: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Topics

BWROG Background

BWROG Committees

Copyright 2018, BWR Owners’ Group, All Rights Reserved2July 26, 2018

Page 4: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

BWROG Background - Structure

Copyright 2018, BWR Owners’ Group, All Rights Reserved3July 26, 2018

EXECUTIVE COMMITTEE

(Executive Oversight Committee)

TECHNICAL COMMITTEES

(Generic / Non-Generic)

Chairman

(Vice Chairman)

Prime Reps

(Advisory Committee)

GEH PMO - Supports all

BWROG Utility Members

BWROG Industry Management

Responsibilities

Executive Committee:

• Responsible for overall direction

/ progress of OG activities

• Approve work scope, funding,

schedule, and final products for

Generic activities

Chairman:

• Responsible for overall

management of OG activities

and GEH Program Manager

• Sign BWROG Correspondence

to NRC, EPRI, NEI, IPO, etc.

• Address emerging BWR issues

• Oversight of GEH PMO

Prime Reps:

• Review / Approve BWROG

Correspondence to NRC

• Approve work scope, funding,

schedule, and final products for

Non-Generic Activities

Page 5: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

BWROG Background – Leadership

Copyright 2018, BWR Owners’ Group, All Rights Reserved4July 26, 2018

Tim Hanley Executive Chair

Paul Davison Executive Vice Chair

John Grubb General Chair

Greg Krueger General Vice Chair

Greg Holmes Program Manager

Page 6: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

BWROG Background – Leadership

Copyright 2018, BWR Owners’ Group, All Rights Reserved5July 26, 2018

Executive Oversight Committee

• Tim Hanley (Exelon) – Chairman

• Paul Davison (PSEG) – Vice Chairman

• Steve Douglas (TVA)

• Oscar Limpias (Entergy)

• Joe Donahue (Duke Energy)

• Glen Watford (GEH)

Page 7: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

BWROG Background - Membership

Copyright 2018, BWR Owners’ Group, All Rights Reserved6July 26, 2018

Utility (Members) Utility (Members)

DTE Energy - Fermi Exelon – Nine Mile Point

Duke Energy - Brunswick FirstEnergy -Perry

Energy Northwest - Columbia NPPD - Cooper

Entergy - Pilgrim NextEra Energy - DAEC

Entergy - River Bend / Grand Gulf PSEG - Hope Creek

Exelon - Clinton Southern Nuclear - Hatch

Exelon - Dresden / Quad Cities / LaSalle Talen Energy - Susquehanna

Exelon - FitzPatrick TVA - Browns Ferry

Exelon – Limerick / Peach Bottom Xcel Energy - Monticello

International (Members) International (Members)

CFE JAPC

Chubu KKL

Chugoku Taiwan Power Company

Hokuriku Tohoku

Iberdrola Tokyo Electric Power Holdings Inc.

Conditional (Members) Conditional (Members)

Horizon Nuclear Power J-Power

Page 8: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

2018 Generic Technical Committees

Copyright 2018, BWR Owners’ Group, All Rights Reserved7July 26, 2018

• 50.69 Working Group

• BWR Water Chemistry

• Emergency Procedures

• Fukushima Response

• IRIR

• Licensing

• RCIC Extended Ops

• Reactivity Controls Review

• Reload Analysis & Core Mgmt.

Page 9: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

2018 Non- Generic Technical Committees

Copyright 2018, BWR Owners’ Group, All Rights Reserved8July 26, 2018

System Improvement (SI) Committees | Specific Issue Committees | Plant Performance Committees

• BWR6 Rod Control & Information System

• BWR Parts Obsolescence

• Control Rod Drive (CRD)

• ECCS

• Feedwater

• BWR I&C Maintenance

• Offgas

• Operations Significant Event Review (OSER)

• Outage Management

• Radiation Protection/ALARA

• Refueling Performance

• Reactor Recirculation

• RWCU

• Target-Rock 2-Stage SRV Performance Improvement

• Turbine Generator & Aux

• Valve Technical Resolution Group

Page 10: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

9

BWROG Introduction

Copyright 2018, BWR Owners’ Group, All Rights Reserved

QUESTIONS

9July 26, 2018

Page 11: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Licensing Committee Update

Copyright 2018, BWR Owners’ Group, All Rights Reserved

1July 26, 2018

John Grubb (Xcel Energy) – BWROG Chairman

BWROG EOC & NRC Meeting

July 26, 2018

Rockville, MD

Page 12: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Topics

Joint Activities with the PWROG Licensing Committee

Industry Implementation of TSTF-542

Travelers of Interest Under NRC Review

Copyright 2018, BWR Owners’ Group, All Rights Reserved2July 26, 2018

Page 13: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Joint Activities with the PWROG Licensing Committee

The BWROG Licensing Committee is holding overlapping meetings with the PWROG Licensing Committee three times a year

• A joint meeting day held between the PWROG and BWROG separate meetings

• Expanding on the long-standing cooperation on TSTF travelers, such as:

– Impact of 50.69 adoption on Surveillance Requirements that reference the Inservice Testing Program

– ATF lead test assembly regulatory requirements

– Coordinated license amendment request submittal process

– Regulatory requirements on training and qualification of personnel

• The next joint meeting is August 15

Copyright 2018, BWR Owners’ Group, All Rights Reserved3July 26, 2018

Page 14: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Industry Implementation of TSTF-542, "Reactor

Pressure Vessel Water Inventory Control" (RPV

WIC)

• The Licensing Committee continues to support fleet

adoption of TSTF-542

• Amendments have been submitted by all applicable

plants except Browns Ferry

– All but Pilgrim and Oyster Creek are adopting

• Amendments approved for 8 plants

• NRC "tiger team" review approach has halved the review

time for later amendments

• BWROG implementation guidance revised to reflect plant

experience

– Guidance supports consistent industry implementation

July 26, 2018 4Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 15: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Active Traveler Status

Currently Nine TSTF Travelers Under NRC Review

• Eight travelers are applicable to BWRs

• Six scheduled for approval this year

July 26, 2018 5Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 16: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

TSTF-505, Provide Risk-Informed Extended

Completion Times

The BWROG, PWROG, and NEI have been working to

resolve the NRC concerns with TSTF-505.

• TSTF-505, Rev. 2, submitted on July 2, with comments

on the NRC’s draft Safety Evaluation

• Expect final SE (approving Rev. 2), clearing the way for

plant-specific amendments, in fourth quarter 2018

July 26, 2018 6Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 17: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

TSTF-563, Revise Instrument Testing Definitions

to Incorporate the Surveillance Frequency

Control Program

Revises TS definition of Channel Calibration and Channel

Functional Test such that testing frequencies for components

or devices in each step can be determined in accordance

with surveillance frequency control program

• Submitted May 10, 2017

• Draft SE scheduled for August 2018, with approval this

year

July 26, 2018 7Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 18: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

TSTF-564, Safety Limit MCPR

Replaces the cycle-specific SL MCPR with a fuel design-

based SL MCPR. Will avoid rush amendment requests

Submitted August 28, 2017

Supported by GNF and Westinghouse

Draft SE scheduled for August 2018, with approval this year

July 26, 2018 8Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 19: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

TSTF-565, Revise the LCO 3.0.2 and LCO

3.0.3 Bases

Clarifies the application of the TS by eliminating the

phrase "operational convenience" and other subjective

Bases qualifying statements from the LCO 3.0.2 and

LCO 3.0.3 Bases

• Expect NRC acceptance in 2018

• Licensees can adopt the changes using the TS

Bases Control Program

July 26, 2018 9Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 20: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

TSTF-566, Revise Actions for Inoperable

RHR Shutdown Cooling Systems

Revises the actions for an inoperable RHR-SDC

subsystem and clarifies that an inoperable but available

subsystem can be used as an alternate

• Submitted January 2018

• Draft SE scheduled for October 2018

• Expect approval in early 2019

July 26, 2018 10Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 21: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

11Copyright 2018, BWR Owners’ Group, All Rights Reserved

QUESTIONS

11July 26, 2018

Page 22: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

50.69 Working Group Committee Update

Copyright 2018, BWR Owners’ Group, All Rights Reserved

1July 26, 2018

Tim Hanley (Exelon) – BWROG EOC Executive Chairman

BWROG EOC & NRC Meeting

July 26, 2018

Rockville, MD

Page 23: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Topics

Background/Timeline

BWROG 50.69 Working Group Committee

Industry Alignment

OM Part 29

Copyright 2018, BWR Owners’ Group, All Rights Reserved2July 26, 2018

Page 24: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Background/Timeline

Copyright 2018, BWR Owners’ Group, All Rights Reserved3July 26, 2018

• South Texas Project – exemption request – approved 2001

• 10CFR50.69 Rule – issued 2004

• PWROG Pilot – Letter Report WOG-04-237 - issued 2004

– Passive categorization and other implementation issues identified

• NEI 00-04 Categorization Guideline - issued 2005

• NRC RG 1.201 - issued 2006

• Vogtle Pilot – approved 2014

– Passive categorization and other implementation issues resolved

• NEI 16-09 Risk-Informed Engineering Programs (10 CFR 50.69)

Implementation Guidance – issued 2017

• NEI 17-05 Risk Informed Engineering Programs (10 CFR 50.69): RISC-

3 Alternative Treatments – issued 2018

Page 25: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Background/Timeline (Cont.)

The rule allows licensees to use an NRC approved risk-informed process to categorize plant components as either High Safety Significant (HSS) or Low Safety Significant (LSS). Components that are categorized as LSS – even if they are Safety-Related – are removed from a number of NRC "special treatment" requirements:

Instead, these components must meet the "alternative treatment" requirements described in 10 CFR 50.69(d). The alternative treatment requirements enable increased flexibility and licensee control over design, procurement, inspection and testing, and maintenance activities. This flexibility allows resources to be focused on areas of safety significance and reduces burden on areas that are not. Copyright 2018, BWR Owners’ Group, All Rights Reserved

4July 26, 2018

Page 26: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

50.69 Working Group Committee (WGC)

In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’ Group (OG) effort with a goal of ensuring consistent implementation of 10 CFR 50.69

June 28-29, 2017: Ad Hoc meeting with BWROG, PWROG, NEI, EPRI, and supporting vendors

October 11-12, 2017: 1st Official 50.69 WGC Meeting

February 21-23, 2018: 50.69 WGC Meeting

July 9-11, 2018: 50.69 WGC Meeting

November 27-29, 2018: Next Planned 50.69 WGC Meeting

2019: 3 Meetings Planned

Copyright 2018, BWR Owners’ Group, All Rights Reserved5July 26, 2018

Page 27: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

50.69 Working Group Committee (WGC) (Cont.)

Charter - Purpose

• Provide oversight and infrastructure for the industry’s

coordinated 50.69 efforts

• Identify industry needs with regard to 50.69

• Determine the appropriate lead and scope of the work

to be performed by sub-groups (OG led)

• Ensure progress is made in a suitable timeframe with

no unnecessary overlap with other organizations

Copyright 2018, BWR Owners’ Group, All Rights Reserved6July 26, 2018

Page 28: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

50.69 Working Group Committee (WGC) (Cont.)

Focus Groups for Major Areas of Interest:

• Training and Change Management

• Categorization

• Alternative Treatments

• Procurement and Design Engineering

Copyright 2018, BWR Owners’ Group, All Rights Reserved7July 26, 2018

Page 29: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Industry Alignment – Swim Lanes

Copyright 2018, BWR Owners’ Group, All Rights Reserved8July 26, 2018

Page 30: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

OM Part 29

• OM Part 29 adds a layer of unwarranted additional requirements beyond 50.69 (the rule itself) that limit/negate a licensee's opportunity to increase overall levels of safety through more safety-benefit-focused alternate treatments of RISC-3 SSCs

• Since OM Part 29 was approved in 2008, significant industry guidance has been established in the form of NEI 00-04,16-09, 17-05, EPRI Tech Reports, and PWROG/BWROG guidelines that communicate a consistent and aligned industry position on establishing alternate treatment requirements for RISC-3 SSCs during 50.69 implementation

• Imposing additional requirements on AT through the ASME standards is a backdoor approach to adding additional regulation

Copyright 2018, BWR Owners’ Group, All Rights Reserved9July 26, 2018

Page 31: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

OM Part 29 (Cont.)

• The NRC already has a 50.69 Inspection Procedure (IP 37060) which is where inspection guidance is covered; this does not belong in a Code Case

• One of the objectives of the IP is, “To verify that the licensee properly implements alternate treatment requirements for those SSCs evaluated using the 10 CFR 50.69 categorization process and subjected to alternative treatments”

• 50.69 WGC supports removal of OM Part 29 and rejection of any proposed ASME prescribed guidance on 50.69 Alternative Treatment

Copyright 2018, BWR Owners’ Group, All Rights Reserved10July 26, 2018

Page 32: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

11

50.69 Working Group Committee Update

Copyright 2018, BWR Owners’ Group, All Rights Reserved

QUESTIONS

11July 26, 2018

Page 33: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

FLEX Equipment Data Collection for Use in Risk Informed Decision Making

Copyright 2018, BWR Owners’ Group, All Rights Reserved

BWROG EOC & NRC Meeting

July 26, 2018

Rockville, MD

Bob Rishel (Duke Energy) – BWROG IRIR Chairman

Page 34: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

2

Topics

Maintenance Rule Impact for FLEX

FLEX in Risk Informed Decision Making (FRIDM)

Plant FLEX Equipment

Industry Strategy

Data Collection

EPRI and FLEX Maintenance WG

Owners’ Group Effort

SAFER Centers Equipment

Current State of FLEX Implementation

Potential Numerical Impact of FLEX

July 26, 2018

Copyright 2018, BWR Owners’ Group, All Rights Reserved

2

Page 35: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Maintenance Rule Impact for FLEX

Draft RG 1.160 Rev 4, (DG1336) endorsing NUMARC 93-01

Rev 4f states:

Nonsafety related SSCs that are used in Emergency Operating

Procedures

The following two items apply when EOP steps are added that direct operators to

FSGs for additional defense-in-depth measures. If these are met, then the non-

safety-related equipment in the FSGs is not considered “used” in the EOPs:

• Differentiate the non-safety-related equipment in the FSGs from the equipment

providing EOP mitigation function in the Maintenance Rule scoping evaluation

or EOP change process documentation.

• Equipment already scoped into the Maintenance Rule under the “used in plant

EOPs” criteria should not be removed from the Maintenance Rule scope based

solely on the addition of non-safety-related equipment in the FSGs as a

defense-in-depth measure.

July 26, 2018 3Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 36: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Maintenance Rule Impact for FLEX

(Cont.)

Draft RG 1.160 Rev 4, (DG1336) endorsing NUMARC 93-01

Rev 4f states:

Nonsafety related SSCs that are used in Emergency Operating

Procedures

“FLEX Support Guidelines (FSGs) are not considered to be EOPs. Equipment

described only in FSGs would not be in scope of the Maintenance Rule unless

otherwise required by paragraph 50.65(b).”

Additional clarifications are made:

“that equipment described in FSGs are not “used” in EOPs for purposes of

scoping into the Maintenance Rule under 50.65(b)(2)(i) (stating that the scope of

the monitoring program includes nonsafety related SSCs that “are used in plant

emergency operating procedures (EOPs)”) as long as the other criteria are

assessed.”

July 26, 2018 4Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 37: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

FLEX in Risk Informed Decision Making (FRIDM)

FLEX in Risk-Informed Decision Making (FRIDM) Task Force established by NEI in September 2015

The Task Force objective was to develop a number of streamlined approaches for crediting FLEX in risk-informed decision making activities, including PRA models

FRIDM Task Force developed an effective framework for considering the benefits of FLEX equipment and mitigating strategies in risk-informed regulations, applications, and plant PRA models without imposing undue regulatory burden

Copyright 2018, BWR Owners’ Group, All Rights Reserved

July 26, 2018 5

Page 38: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

FLEX in Risk Informed Decision Making (FRIDM) (Cont.)

July 26, 2018

Copyright 2018, BWR Owners’ Group, All Rights Reserved

NEI 12-06 NEI 16-06 NEI 16-08

6

Page 39: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Plant FLEX Equipment

July 26, 2018

Copyright 2018, BWR Owners’ Group, All Rights Reserved7

Page 40: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Plant FLEX Equipment (Cont.)

July 26, 2018

Copyright 2018, BWR Owners’ Group, All Rights Reserved8

Page 41: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Industry Strategy

Maximize Areas of Credit

Maximize FLEXibility

FLEX and Beyond

Expand operational and regulatory credit given to mitigating strategies

Expand where portable equipment is used in plant operations

Be inclusive of all portable equipment beyond just FLEX

(e.g. B.5.b portable equipment)

The goal is to maximize the benefit of the large

investment in portable equipment at sites

July 26, 2018

Copyright 2018, BWR Owners’ Group, All Rights Reserved9

Page 42: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Industry Strategy (Cont.)

Copyright 2018, BWR Owners’ Group, All Rights Reserved

July 26, 2018

Graphic provided with permission of NEI

Potential Applications of NEI 16-06

10

Page 43: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Data Collection

To be able to credit FLEX in the applications need to

meet data requirements of RG 1.200

• Data sources that are verifiable

• Generic data

• Plant specific information

NRC staff has doubts about some of the licensee

assumptions of FLEX/Portable equipment reliability

and availability

• Need to resolve question on meeting

requirements of RG 1.200 data

July 26, 2018 11Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 44: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Data Collection (Cont.)

Equipment starts

Run hours

Failures by type (FTR, FTS)

Failure cause (what was wrong)

Type of equipment

• Diesel driven pumps (may need to separate by

capacity)

• Engine driven generators (may need to separate out

by size/design of generator

• Fans

• Air Compressors

July 26, 2018 12Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 45: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

EPRI and FLEX Maintenance WG

Maintain existing Flex Maintenance Database

• We don’t want to interfere with primary role of

database

• Leverage information in Database to improve

efficiency of Utility data gathering

• Not a referenceable source of data for OG

Reports

FLEX Maintenance Working Group

• Continue to collect data for PM purposes

• Communicate data collection lessons learnedJuly 26, 2018 13

Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 46: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Owners’ Group Effort

Download utility specific data from Flex

Maintenance Database (optional)

Collect supplemental data

Validate Data

Provide data to OGs

Retain plant specific equipment data to met RG

1.200 Capability Category II

July 26, 2018 14Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 47: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Owners’ Group Effort (Cont.)

Develop Instructions for data collection/validation

• Participate in Flex Maintenance WG calls

• Evaluate/Calculate Data

Provide NRC opportunity for review (targeted fall

2018)

Publish Reports (targeted 1st quarter 2019)

July 26, 2018 15Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 48: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Owners’ Group Effort (Cont.)

Public Report• Process description

• Calculations

• Evaluations

• Failure rates and uncertainty distributions

• Number of Failures

• Demands

• Run Hours

Lessons Learned Report• Update Frequency

• Recommendations to improve efficiency of data

collection

July 26, 2018 16Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 49: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

SAFER Centers Equipment

Large inventory of equipment

• Most of the current EPRI data is from SAFER

Centers

• SAFER Center Equipment generally not

credited in PRA

• SAFER Center data will only be credited

where it is similar to on-site equipment

– Additional cost to SAFER Center for data

collection

July 26, 2018 17Copyright 2018, BWR Owners’ Group, All Rights Reserved

Page 50: BWROG Executive Oversight Committee & NRC Management ... · 50.69 Working Group Committee (WGC) In 2017, utility members requested that BWROG and PWROG lead a joint industry Owners’

Current State of FLEX Implementation

FLEX capabilities are being included in PRAs numerically

• Both simplified approach and detailed approach

– Limited number of PRA completed with FLEX

implemented

• Most Utilities have plans to incorporate FLEX into the base

PRA models

– Includes External Events PRA models

o Fire PRA

o High Winds PRA

o Seismic PRA

Flex equipment being used to support refueling outage risk

reduction

Flex equipment being credit to reduce risk of maintenance

July 26, 2018 18Copyright 2018, BWR Owners’ Group, All Rights Reserved

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Current State of FLEX Implementation

(Cont.)Examples for use of FLEX Equipment in FRIDM

• NRC allowances to delay shut-down to allow time

for repairs– Extended Diesel Repair to 62 days and another for 30 days

– Extended Service Water Pump rebuild to 14 days

• Significance Determination Process (SDP) for

NRC violation for external hazards– External flooding

– Extended loss of off-site power

• Refueling Outage risk reduction– Spent Fuel Pool make-up

– Rx vessel water inventory control

– Water transfer to installed tanks

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Potential Numerical Impact of FLEX

CDF/LERF

BWR CDF (IE) reduction ranges: 1% to 40%

➢ Primary influence: HCVS and FLEX portable generators

BWR CDF (Fire) reduction: 40% at one pilot site

➢ Primary influence: Diverse injection free from fire damage

BWR CDF (Seismic) reduction:17% at one pilot site

➢ Primary influence: Additional diverse injection

• The calculated risks vary based on site specific plant design and existing mitigation capabilities

• Model updates are pending final considerations of HRA methods and dependent operator actions

July 26, 2018

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21

FLEX Equipment Data Collection for use in Risk Informed Decision Making

July 26, 2018

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QUESTIONS

21

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BWROG EPG/SAG Rev 4 and TSG Rev 1 Update

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1July 26, 2018

Steve Douglas (TVA) – BWROG Executive

BWROG EOC & NRC Meeting

July 26, 2018

Rockville, MD

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Topics

BWROG – Emergency Procedures Committee Guidance

Updates (Rev 4)

Proposed U.S. BWR Fleet Wide Implementation Schedules

Product Lines Addressed

All Operating Modes Addressed

Extended Loss of AC Power (ELAP)

Severe Accident Water Addition / Severe Accident Water

Management (SAWA/SAWM)

Improved Anticipated Transients Without SCRAM (ATWS)

Guidance

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3

BWROG – Emergency Procedures Committee Updated Guidance (Rev 4)

July 26, 2018

Copyright 2018, BWR Owners’ Group, All Rights Reserved

• Emergency Procedures and Severe Accident Guidelines (EPG/SAG) Rev 4 & Technical Support Guidelines (TSG) Rev 1: Formally published on June 1, 2018:

– On time delivery per agreed schedule / publication date

– U.S. fleet wide completion date: 2 refueling outages or 3 years which ever is greater from publication date (NEI 14-01)

• The Rev 4 Guidelines consist of:

– EPG/SAGs (multiple volumes for operating modes)

– EPG/SAG Appendices A to C

– TSGs

– TSG Appendix A

– TSG Calculational Aids

– Event Case Studies (Training aids)

– Optional products; Emergency Management Guideline (EMG) & the Station Blackout (SBO) flowcharts

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U.S. BWR Fleet Implementation

Schedule

EPG/SAG Rev. 4 TSG Rev 1

Proposed Implementation Schedule

• Legend: # of units (# of sites)

• Note: Two sites have different submittal dates for its units

First – Q2 2020

Last – Q2 2022

One Site Under Evaluation

Dates are approximate (Survey - July 2018)

July 26, 2018 4Copyright 2018, BWR Owners’ Group, All Rights Reserved

2020 2021 2022

Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2

3 (2) - 5 (3) 3 (2) 18 (12) - - 2 (2)

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Product Lines Addressed

• BWR Product Lines

– BWR/2-6

– ABWR

• BWR Containments

– Mark I, II, III

– ABWR

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All Operating Modes Addressed

• EPGs for Events from Modes 1 to 4

• EPGs for Events from Mode 5 (refueling)

• SAGs for Events from Modes 1 to 5

Includes new guidance for shutdown and refueling

Previous EPG/SAGs (Rev 0 to 3) & the TSGs only

addressed events beginning from Modes 1-3

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Extended Loss of AC Power

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Extended Loss of AC Power Addressed in Rev. 4

• Improved guidance is provided for conditions where core cooling is maintained by steam driven systems or by low capacity low pressure systems (FLEX)

• Guidance is provided to transfer core cooling from installed equipment to FLEX type systems

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SAWA/SAWM

Severe Accident Water Addition / Severe Accident Water Management (SAWA/SAWM) in Rev 4

• Guidance Preserves the Hardened Severe Accident Containment Vent

• New additions to TSG Rev. 1 (determination that ex-vessel core debris is stabilized)

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Improved Anticipated Transients Without SCRAM (ATWS) Guidance

New ATWS Guidance:

• A significant update for operating crews

• Improves Crew Performance and the plant’s response to ATWS events

• A pressure control parameter is provided that improves ATWS response:

– Also includes 20 years of O/E, crew insights and analysis which indicates that high pressure injection provides similar results whether injection occurs inside or outside the shroud.

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10

EPG/SAG Rev 4 and TSG Rev 1

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QUESTIONS

10July 26, 2018

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Tim Hanley (Exelon) – BWROG EOC Executive Chairman

Anchor Darling Double Disk Gate Valve (ADDDGV) Part 21 Update

Copyright 2018, BWR Owners’ Group, All Rights Reserved

BWROG EOC & NRC Meeting

July 26, 2018

Rockville, MD

July 26, 2018 1

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Topics

2

Timeline

Industry Survey

July 26, 2018

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Timeline

3

February 25, 2013: Flowserve issues 10CFR Part 21

Notification concerning wedge pin failure of an Anchor

Darling Double Disc Gate Valve.

April 2013: BWROG VTRG issues TP-13-006 to provide

a recommended industry response to the Flowserve

10CFR Part 21 Notification.

July 26, 2018

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4

Timeline (Cont.)

December 2016, TP-13-006 revised (TP16-1-112).

• Included results of 26 stem/disc connection inspections.

• 24 of 26 connections were found with loose connections but

no pin damage was observed.

• Report revised to recommend only two long-term solutions:

• Analyze the stem/wedge connection from a torque

perspective and show all anticipated loads are

acceptable (assuming no factory pre-load per the results

of the 26 inspections).

• Disassemble the valve and torque the stem/wedge

connection to a value that exceeds all anticipated

operational loads.

• The above recommended actions were to be completed

within three refueling outages (maximum of six years).July 26, 2018

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5

Timeline (Cont.)

February 11, 2017: LaSalle HPCS MOV A/D DDGV

Stem/Disc Separation Event

• 12”-900# valve manufactured in 1972 and installed in

1984 had operated without incident since plant startup.

• Identified as one of 22 susceptible MOVs using the

original BWROG guidance TP-13-006 R0).

• Wedge pin analysis could not provide evidence that the

wedge pin alone could handle the operational torque

load.

• Stem rotation checks and diagnostic thrust signature

analysis performed as interim actions.

July 26, 2018

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6

Timeline (Cont.)

May 2017: BWROG TP-16-1-112, R2, Issued• Revision to incorporate lessons learned and recommendations

resulting from the stem/disc separation event that occurred at

LaSalle station in February 2017.

• Maximum stem rotation changed to 5 degrees combined with need for better

accuracy to support trending.

• More aggressive corrective action (either wedge pin analysis or valve internal

work) recommended.

• Present diagnostic test data anomalies preceding LaSalle MOV Failure.

June 2017: BWROG TP-16-1-112, R3, Issued

• Revision to incorporate comments from Flowserve and others to

facilitate formal Flowserve Corporation endorsement of the updated

Topical Report.

• Flowserve evaluation of the LaSalle Stem/Disc separation event.July 26, 2018

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7

Timeline (Cont.)

August 2017: BWROG TP-16-1-112, R4

• Revision incorporated results of detailed failure analysis

of the LaSalle HPCS MOV stem/disc separation event.

• Provides discussion on potential scope impacts of the

failure as well as recommended actions to permanently

resolve the issue.

• Includes guidance on proper conduct of MOV stem

rotation checks as well as a new recommendation to

periodically perform rotation checks for applicable

valves.

July 26, 2018

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8

Timeline (Cont.)

NRC Draft Temporary Instruction (TI)

• NRC issued draft TI in April 2018.

• Industry had significant comments / feedback regarding

the content of TI.

– Draft TI appeared to establish expectations that

exceeded the legacy Generic Letter 89-10/96-05

programs (e.g., designing against stall torque).

• Feedback provided to NRC at public meeting held in

May 2018.

• NRC received feedback and planned to incorporate

comments, as necessary, and hold a second public

meeting to review resolution (has not occurred).

July 26, 2018

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9

Industry Survey

• During 1Q2018 VTRG meeting, committee

members agreed to provide inspection results for all

DDGV disassemblies

• Following May 2018 NRC public meeting, industry

survey was expanded to include PWRs as well

• Results were submitted July 16, 2018 to the NRC

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10

ADDDGV Part 21 Update

July 26, 2018

Copyright 2018, BWR Owners’ Group, All Rights Reserved

QUESTIONS

10

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Copyright 2018, BWR Owners’ Group, All Rights Reserved

BWROG Target Rock SRV Performance Improvement Committee

Steve Douglas (TVA) – BWROG Executive

BWROG EOC & NRC Meeting

July 26, 2018

Rockville, MD

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2

Topics

History/Scope

What is Being Done by the BWROG

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3

History/Scope

Non-Generic Committee formed in 2016

Membership: DTE/Fermi, Duke/Brunswick,

Exelon/FitzPatrick, NPPD/Cooper, PSEG/Hope Creek,

TVA/Browns Ferry

Committee Scope: address the common causes of

repetitive Target Rock 2-stage SRV as-found set-point test

failures in the fleet

• Technical Exchange Meetings: share site set point drift

performance, best practices, roadmap planning

• 2-stage valve focus

• Scope focused on setpoint drift

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4

What is Being Done by the BWROG

2017-18 Activities

• Industry-shared IBAD procedure (application of Platinum to disc surface).

• Autoclave Screening Test - used to develop sputtering application process of Platinum on test coupons and comparison to IBAD.

• Sputter Coating of (Quantity 3) pilot discs and perform valve testing. Sputtering application process of Platinum application on SRV pilot discs.

• Static Autoclave Material Screening - baseline conditions of corrosion bonding with control group and screening other materials.

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5

What is Being Done by the BWROG (Cont.)

2019 Planned Activities

Test different thickness of (sputtered) Platinum coated on pilot discs in valve lift tests.

• Sputtering opens process space for different thicknesses of Platinum Coating.

• Potential for fleet usage

– Know that current thickness of Platinum coating provided step-improvement in set point drift performance.

– Does increase in thickness provide more protection from corrosion bonding?

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6

BWROG Target Rock SRV Update

July 26, 2018

Copyright 2018, BWR Owners’ Group, All Rights Reserved

QUESTIONS

6