I.E BWR Owners' GroupOWNERS' GROUP
Rich Anderson (NextEra Energy)
BWROG Executive Chair.
BWROG I NRC ManagementPublic MeetingMay 15, 2009
BWROG
Agenda
Introductions
BWROG Submittals
ECCS Gas Intrusion
ECCS Suction Strainers
GI 193 ECCS Suction Concern
MOV Magnesium Rotors
TSTF update2/
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BWROG
Mission
Provide a forum, in the spirit of partnership withGeneral Electric - Hitachi, that allows its memberutilities to:" maintain and improve plant safety," achieve higher plant reliability," minimize and share costs,* facilitate regulatory interaction,* and effectively apply limited technical resources for
mutual resolution of issues applicable to two ormore members.
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BWROG
Leadership
Executive Oversight Committee* Rich Anderson, NextEra Energy (Chair BWROG Exec Committee)* Oscar Limpias, Entergy (Vice Chair BWROG Exec Committee)* Rick Libra, Exelon* Paul Davison, PSEG Nuclear* Joe Donahue, Progress Energy" Dennis Madison, Southern Company
BWROG General Committee* Chair: Doug Coleman, Energy Northwest" Vice Chair: Ted Schiffley, Exelon (becomes Chair January 2010)" Program Manager: Ken McCall, GEH
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Schedule ReviewBWROG Submittals
Doug Coleman (Energy Northwest)
BWROG Chairman
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Current BWROG Submittals
*Recent CompletionsODYSY (Stability)
* Revision A submitted April2009
* Final SE received Feb 2009
PTC-GEH" Revised TR submitted Jan
2009" Draft SE received March
2009" Final SE received May 2009" Revision A planned for June
2009.
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Current BWROG Submittals
Delayed Schedule
RITS 4a/6b* NRC requested BWROG
withhold re-submittal untilMay 2009 (following draftSE for PWROG submittal)
* Prepared to resubmit
Reg Guide 1.97" RAI responses submitted
Oct 08" Final SE originally expected
May 09" Delay in reviews
Containment AccidentPressure Credit" RAIs responses submitted
March 2009* Draft SE expected May
2009* NRR request for
Commission guidancebecause of ACRS concernswill delay final SE
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BWROGECCS Gas Intrusion
Doug Coleman (Energy Northwest)
BWROG Chairman
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ECCS Gas Intrusion
Background
BWROG committee formed to address:* Generic Letter 2008-01, "Managing Gas
Intrusion in Emergency Core Cooling,Decay Heat Removal and ContainmentSpray Systems"
" SER 2-05 Revision 1 "Gas Intrusion inSafety Systems"7
These slides include updates, since theNovember 2008 EOC-NRC Meeting
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ECCS Gas Intrusion
Industry Response
In response to the GL, the industry has:- Formed a Gas Accumulation Management team- Engaged the BWROG, PWROG, NEI, EPRI, and INPO- Developed Operability acceptance criteria- Conducted testing on gas transport
Plants have:- Performed detailed walkdowns of systems- Determined critical locations and established acceptance criteria- Implemented numerous improvements in plant:
- Monitoring of gas- Processes (Operations, Work Management, Outage Planning)- Procedures- Training- Corrective Action Programs
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EGCS Gas Intrusion
Gas Accumulation Team (GAT)
Management Team:* Doug Coleman
- BWROG Chairman
" Denny Buschbaum- PWROG Chairman
* Mike Melton- Nuclear Energy Institute
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ECCS Gas Intrusion
Technical Support TeamT1
Utility Leadership* Chris Brennan, BWROG Gas Intrusion Committee Chair, Exelon,*Andersen Lin, PWROG lead, PG&E
Utility Technical Support NSSS Vendor Leadership
Laird Bruster, FPL Energy * Greg Holmes, GE-Hitachi
Mo Dingier, WCNOC Bill Turkowski, Westinghouse
Brian Dunn, FPL Energy Industry Technical Support
Les England, Entergy 0 Nick Camilli, EPRI
Don Gregoire, Energy Northwest 0 Carl Faller, INPO
Wes McGoun, Progress Energy 0 Ken Huffman, EPRI
Brian McKercher, Dominion
Elizabeth Newberg, Xcel Energy
Mark Radspinner, APS 12/BWROG /
Completion of Products for 9-monthResponsesBWROG-TP-08-014 BWROG ECCS Pumps Suction VoidFraction Study
- Issued on 8/12/2008
BWROG-TP-08-017 Potential Effects of Gas Accumulation onECCS Analysis as Part of GL 2008-01 Resolution
- Issued on 9/9/2008
BWROG-TP-08-020 Effect of Voiding in ECCS Drywell Piping- BWROG EOC approved Project Change Request for this
work- Issued 9/17/08
All transmitted to NRC by the BWROG on April 30, 200913/
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Completion of Products for 9-monthResponses (continued)BWROG-TP-08-021 (Fauske 08-70) Gas Voids PressurePulsations Program
- Re-issued on 9/3/2008 due to errors found in thecalculations section
BWROG-TP-08-022 (WCAP 16692-NP) Survey of PeriodicVenting and Industry Practices
- Issued 8/31/2008
All transmitted to NRC by the PWROG
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ECCS Gas Intrusion
Industry Response
The industry's ongoing efforts include:- Developing an industry guideline document on
preventing and mitigating entrained gas- Addresses other systems beyond the GL (INPO SER
2-05 Rev 1)- Developing industry training modules (generic,
operations, maintenance)Determining appropriate Technical Specificationschanges
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ECCS Gas Intrusion
Current Status
NRC Meeting March 19, 2009:- NRC is asking for industry comment on their
draft assessment criteria for GL 2008-01 reviews- NRC will issue the final assessment criteria to
NEI for industry distribution and information- Utilities will have the opportunity to supplement
their responses to GL 2008-01- NRC will follow-up and issue a GL response
assessment to each licensee for review (bySeptember 2009) and issue any RAIs withinapproximately 45 days
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BWR ECCS Suction Strainers
Brian Davenport (Exelon)Committee Vice Chairman
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ECCS Suction Strainers
Project Plan Major Topics
Downstream Effects
• Fuel- Debris Filter Clogging-Debris Deposition on Fuel
" Components- Clogging- Long-term effect of Abrasion
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ECCS Suction Strainers
Project Plan - Major Topics (cont'd)F -7
Potential Changes to Debris Source Term
* Latent Debris
* Debris Transport and Erosion
e Coatings* Confirmation of Cal-Sil & Micro-Porous
QuantitiesInsulation
- Spherical Zone of Influence (ZOI ) Assumptionl Chemical Effects
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ECCS Suction Strainers
Project Plan - Major Topics (cont'd)
Potential Effects on Head Loss Correlations
" Near Field Effect/Scaling
" Conservatism of NUREG/CR-6224 forCal-Sil & Micro-porous Insulations
e Thin Bed Effects
* Non-homogeneous debris beds
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Relationship of Strainer Issues& Resolution Logic
Assess Questions on the Nature and Quantity of Debris 1. Downstream Effects of Debris
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ECCS Suction Strainers
Committee Actions
Plan chemical effects and fuel blockage testing
* Phased approach
- Chemical dissolution testing (starting 2009)- Test GNF fuel first (starting 2010)- Determine whether testing of W and AREVA fuel
needed (2010)
- If necessary, use GNF fuel results to optimizetesting of other fuel (2011)
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ECCS Suction Strainers
Current Committee Actions
Complete URG-PWROG gap analysis reports andplan actions needed to address gaps
Downstream Effects: Perform adaptation of WCAP-16406 for use by all BWRs
Source Term: Continue containment walkdowns
Complete Operability Roadmap
Keep NRC informed of plans and actions23/
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ECCS Suction Strainers
Major Tasks Completed to Date
PWR Survey on Downstream Effects oncomponents
Coatings: Report on assessment of BWROG,Industry,.and PWROG Activities since URG
Containment Walkdown Guidance DocumentWalkdown ProcedureJustification for resolution schedule letter to
NRC
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ECCS Suction Strainers
Major Tasks In Progress
Utility containment walkdownsGE-Hitachi Fuel Blockage Thermal-Hydraulic
AnalysisOperability CommuniqueOperability Guidance documentAdaptation of PWROG WCAP regarding downstream
effects on equipmentURG-PWROG Gap Analysis
- Break locations- All other gaps
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ECCS Suction Strainers
Surveys Underway
PWR Su rvey on ZOI/Air Jet
BWR Su rveysLicensing Basis source termsInventory of Reactive Containment Materials
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ECCS Suction Strainers
International Coordination
Participated in recent WANO workshop inFinland on strainer issues
Consulting with European BWRs on testingthey have performed
'Reviewing international testing results suppliedby NRC
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ECCS Suction Strainers
BWROG Schedule
BWROG is in the process of refining the schedule
Schedule dependent on:- URG-PWROG gap analysis- GEH thermal-hydraulic analysis- Fuel testing planning with. GE-Hitachi- Chemical dissolution testing- Utility containment walkdowns
June committee meeting will refine the schedule
BWROG will meet with NRC staff to explain anddiscuss the schedule
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GI 193 ECCS Suction ConcernsMOV Magnesium Rotor Failures
Rick Libra (Exelon)
BWROG EOC
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GI 193 ECCS Suction Concerns
UpdateNRC Letter to BWROG - GI-1 93, "ECCS Suction Concerns",Information Request Submitted to the BWROG, September 4.2008
GEH Draft Report - July 10, 2009
Proposed meeting - committee with NRC week of July 28,2009 to review report
Final Report - August 28, 2009
Open Request by NRC R&D for BWROG geometry(downcomer to suction strainer) information to support Purduetest facility runs in June 2009.
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MOV Magnesium Rotor Guideline
,Update
BWROG produced technical guideline: Inspection of MotorOperated Valve .Limitorque AC Motors with Magnesium Rotors
* Discussion of degradation and failure mechanisms formagnesium rotors
* How to inspect an in-service motor via borescope anddisassembled inspection
* Develop a standard acceptance criteria for inspection ofmagnesium rotors for both in-service and new motors
" Develop MOV programmatic implementation
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MOV Magnesium Rotor Guideline
UpdateBWROG has offered to share this with PWROG, PWROG iscurrently evaluating.
BWROG is providing an "information only" copy to NRC asrequested at last EOC/NRC meeting November 2008.
BWROG considers portions of the document as proprietary.
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TSTF Traveler Updates
Doug Coleman (Energy Northwest)
BWROG Chairman
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Technical Specifications
TSTF Traveler 493
TSTF-493, "Clarify Application of Setpoint Methodologyfor LSSS Functions" has been contentious with NRCStaff since it was originally submitted in January 2006
" Three revisions have been submitted to address evolvingissues and changes in staff position
" Revision 3 was submitted January, 2008" NRC Staff provided latest position in November .4, 2008
letter
A public meeting was held between NRC management,TSTF, and the PWROG and BWROG Chairmen onJanuary 8, 2009 to reach agreement on actionsneeded to close the issue
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Technical Specifications
TSTF Traveler 493
The TSTF agreed to submit Revision 4 to provide:*Clarification of scope to include select Reactor Protection System andEmergency Core Cooling System and the additional BWR instrumentfunctions in TSTF-493, Revision 3 (excluding manual actuation circuits,mechanical devices, interlocks, permissive, and automatic actuationlogic circuits)
*A general statement in each TS Bases for functions not includedabove that states that calibrations are performed consistent with theplant's setpoint methodology
*An option to add a Setpoint Control Program to the "AdministrativeControls" of TS, and eliminate allowable values from the TS tables
*Implementation strategies for TSTF-493 that minimize the submittal ofinformation related to setpoint methodology and calculations
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BWROG /
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Technical Specifications
TSTF Traveler 493
The TSTF agreed to meet with the Staff whenTSTF-493 R4 is in final draft to resolve anymisunderstandings or discrepancies before it isformally submitted
The agreements in the January 8 meeting reflect acompromise that should lead to resolution of the issuewith the least impact
The TSTF documented the proposed solution in a letterdated February 23, 2009. NRC accepted the solutionin letter dated March 9, 2009.
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BWROG /
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Technical Specifications
TSTF Traveler 514
In the last few years, Resident Inspectors havequestioned the Operability of containment gaseousradiation leakage monitoring system.
Reduced RCS specific activity due to improved fuelperformance have rendered many plant's gaseousdetector unable to detect 1 gpm within 1 hour.
Last Fall, NRC DORL management became aware ofthe issue and engaged the TSTF to develop ageneric solution.
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Technical Specifications
TSTF Traveler 514
TSTF provided information that led the NRC to issueRIS 2009-02 and an Enforcement GuidanceMemorandum (EGM) in January to allow licensees totake no action until Travelers addressing the issueare approved.
Revision 1 of RIS 2009-02 issued May 8, 2009RIS stated that Operability is currently based on the ability todetect 1 gpm within 1 hour but that adopting the Traveler willallow Operability to be based on the original designassumptions.
EGM allows licensees 4 months to submit an LAR afterTraveler approval and then is extended until LAR approval.
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Technical Specifications
TSTF Traveler 514
Two Travelers were submitted in February.
TSTF-513 is applicable to PWRs
TSTF-514 is applicable to BWRs.Provides shorter CT when gaseous monitor is the onlyOperable monitor (7 days vs. 30 days)
Provides 72 hours instead of LCO 3.0.3 entry when noleakage monitors are Operable
Clarifies the Operability requirements for all monitors
TSTF requested a fee waiver for the NRC review of TSTF-513and TSTF-514.
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