ML040540668

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Summary of Meeting with Risk-Informed Technical Specification Task Force (RITSTF)
ML040540668
Person / Time
Issue date: 02/23/2004
From: Tjader T
NRC/NRR/DIPM/IROB
To: Bradley B
Nuclear Energy Institute
Tjader T., NRC/IROB, 415-1187
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Download: ML040540668 (8)


Text

February 23, 2004 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708

SUBJECT:

FEBRUARY 11, 2004:

SUMMARY

OF MEETING WITH RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)

Dear Mr. Bradley:

The purpose of this letter is to transmit the summary of a meeting with the RITSTF. The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on February 11, 2004. In principle, the final industry submittals for Risk Management Technical Specifications (RMTS) Initiatives 1, on preferred end states for CE and BWR plants, and Initiative 7, on snubber and hazard barrier inoperabilities, have been agreed to and success in these areas is expected in the coming months. Progress is also being made on the other initiatives.

Sincerely,

/RA/

T. R. Tjader, Senior Reactor Engineer Technical Specifications Section Reactor Operations Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation

Enclosures:

1. Meeting Summary
2. Attendance List
3. Agenda
4. RITSTF Initiative Status
5. RMTS Initiative 4b Acceptance Criteria cc w/encl: See attached page

Package ML040540662, ML040540668, : ML040540678, Enclosure 5: ML040540685 DOCUMENT NAME: G:\TSS\TJADER\RITSTF-MTGsum-11-13-03.wpd OFFICE TSS:IROB-A:DIPM SC:TSS:IROB-A:DIPM NAME TRTjader THBoyce DATE 02/23/2004 02/23/2004 DISTRIBUTION:

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Mr. Biff Bradley cc via e-mail:

Mr. Tony Pietrangelo Mr. Rick Hill Nuclear Energy Institute General Electric Nuclear Energy Mr. Biff Bradley Mr. Michael S. Kitlan, Jr.

Nuclear Energy Institute Duke Energy Corporation Mr. Mike Schoppman Mr. Noel Clarkson Nuclear Energy Institute Duke Energy Corporation Mr. Alan Hackerott, Chairman Mr. Donald Hoffman Omaha Public Power District EXCEL Services Corporation Mr. Jim Kenny Mr. Ted Book Pennsylvania Power & Light Company Framatech-ANP Mr. James Andrachek Mr. R. J. Schomaker Westinghouse Electric Company Framatech-ANP Mr. Jack Stringfellow Mr. J. E. Rhoads Southern Nuclear Operating Company Energy Northwest Mr. Donald McCamy Ms. Deann Raleigh Browns Ferry Nuclear Plant Scientech Mr. Ray Schneider Mr. Ken Canavan Westinghouse Electric Company DS&S Mr. Frank Rahn Mr. Sam Chien EPRI SCE Mr. Wayne Harrison Mr. Gary Chung STP SCE-SONGS Mr. Drew Richards Mr. Courtney Smyth STP PSEG Nuclear LLC Mr. Gabe Salamon Mr. Jerry Andre PSEG Nuclear Westinghouse Electric Company Mr. Gene Kelly Mr. David Helher Exelon Exelon Mr. Glenn Stewart Mr. James Liming Exelon ABSG Mr. Phil Tarpinian Mr. Stanley Levinson Exelon Framatone ANP Ms. Nancy Chapman SERCH/Bechtel

SUMMARY

OF THE FEBRUARY 11, 2004, NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE The NRC staff met with the NEI Risk-Informed Technical Specification Task Force (RITSTF) on February 11, 2004, from 9:00 a.m. to 11:15 a.m. The meeting attendees are listed in .

The agenda (Enclosure 3) consisted of discussions of the six active RITSTF initiatives. The RITSTF provided a summary of the status of the initiatives (Enclosure 4). Following is a brief description of the status of the initiatives.

Initiative 1, TS Actions End States Modifications: NEI responded to staff comments on CE TSTF-422 by letter on November 10, 2003. Review comments to BWR TSTF-423 were provided on November 13, 2003. CE and BWR issues were discussed at a meeting on January 30, 2004, and most issued were resolved. NEI to provide draft implementation guidance, for staff review, by March 15, 2004. Final issues are to be resolved subsequent to receipt of draft implementation guidance. The RITSTF stated that the B&W Topical Report was submitted during the week of January 23, 2004; the BWOG will provide an electronic version of the Topical Report to the staff. The Westinghouse Topical Report will be submitted by June 30, 2004.

Initiative 4b, Risk Informed CTs/AOTs: The staff and industry met to discuss the Risk Management Guidance Document on December 16, 2003. The staff and industry met to discuss the STP pilot proposal, including the staffs initial comments, on January 21, 2004. The staff and industry met to discuss the CE pilot proposal, including the staffs acceptance review comments on TSTF-424, on January 29, 2004. Significant points from those meetings were summarized and briefly discussed. The staff will provide written feedback resulting from the recent meetings by the end of March 2004. The industry will then update the RMTS Risk Management Guidance Document, CE TSTF-424, and the STP pilot proposals. If necessary, meetings to discuss and resolve final issues will held prior to approval of the pilot plant proposals. It was noted that an objective of the Risk Management Guidance Document is to provide enough detail about the I4b process to allow the NRC to endorse it, possibly as a Regulatory Guide, such that it is suitable to be referenced it in the Administrative Controls Section of the TS. This will provide suitable generic guidance on the I4b process for all follow-on plants adopting I4b. The staff provided RMTS Initiative 4b Pilot Plant Acceptance Criteria (Enclosure 5) for consideration; the general principles (Reliable, Repeatable, Oversight/Enforcement, and Exportable) for acceptance criteria were agreed upon. Also, it was agreed that I4b should be performance based. NEI will be providing a point paper on the nexus between I4b and Initiative 6, on LCO 3.0.3 entry times, in March 2004; a topic that was discussed at the STP pilot meeting on January 21, 2004.

Enclosure 1

Initiative 5, Relocation of non-safety SRs (5a) and relocation of all SR frequency requirements (5b) out of TS: It was noted that the I4b acceptance criteria, noted above, is equally applicable to this initiative. The RITSTF will now submit the Limerick pilot license amendment request, a Methodology Document, and the associated proposed technical specifications changes, TSTF-425, in late March or early April 2004. NEI no longer plans to submit a white paper on Initiative 5b addressing staff concerns that this proposal may conflict with requirements of 10 CFR 50.36. Industry believes that, between existing precedents for defining SR frequency requirements external to the TS and the documents to be submitted, a white paper would be superfluous.

Initiative 6, Modification of LCO 3.0.3 Actions and Completion Times: The RITSTF submitted a revised CE Topical Report on October 3, 2003. The staff will prepare a draft SE by April 30, 2004, on the revised CE Topical Report. The RITSTF plans to submit a proposed TSTF-426 after issuance of the final SER.

Initiative 7, Non-TS support system impact on TS operability determinations: The staff provided comments regarding TSTF-427, on barriers, to the RITSTF on June 26, 2003, and the RITSTF responded to the comments on November 7, 2003. The RITSTF submitted TSTF-372, Revision 3, on snubber inoperability, in November 2003. The staff provided feedback to TSTF-372, Revision 3, and TSTF-427, on barriers, at the meeting. It was agreed that the industry will provide, in Revision 4 to TSTF-372, a bounding risk assessment for snubbers affecting two trains, showing that the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> delay time proposed in TSTF-372, Revision 3, is acceptable. The staff has found that the industry response to staff comments on TSTF-427 is generally acceptable, though lacking in detail. It was agreed that the industry will provide draft implementation guidance providing the necessary detail, that in its final form can be committed to by licensees, for implementation of TSTF-427. NEI will submit TSTF-372, Revision 4, and the TSTF-427 draft implementation guidance in March 2004.

Initiative 8a, Remove/Relocate non-safety and non-risk significant systems from TS that do not meet 4 criteria of 10 CFR 50.36: NEI noted that the priority of Initiative 8b, on rule making, may need to be increased if an appropriate methodology cannot be found for Initiative 5b, or if other problems arise.

The staff will be presenting an RMTS overview, with emphasis on I4b, to an ACRS subcommittee on March 25, 2004, and to the full ACRS Committee on April 15, 2004.

Industry/NEI participation was invited, and NEI accepted.

The next NRC TSS/NEI RITSTF meeting is scheduled for April 29, 2004, at the NRC Headquarters.

NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE ATTENDANCE LIST FEBRUARY 11, 2004 NAME AFFILIATION TONY PIETRANGELO NUCLEAR ENERGY INSTITUTE BIFF BRADLEY NUCLEAR ENERGY INSTITUTE DON HOFFMAN TSTF/EXCEL SERVICES FRANK RAHN EPRI JIM ANDRACHEK WESTINGHOUSE/WOG JACK STRINGFELLOW SOUTHERN NUCLEAR OPERATING COMPANY DREW RICHARDS STP NOC GARY CHUNG SCE DON McCAMY TVA/BWROG STANLEY LEVINSON FRAMATOME-ANP RAY SCHNEIDER WESTINGHOUSE PSA DEANN RALEIGH SCIENTECH NANCY CHAPMAN SERCH/BECHTEL BILL BECKNER NRC/NRR/DIPM/IROB TOM BOYCE NRC/NRR/DIPM/IROB/TSS BOB TJADER NRC/NRR/DIPM/IROB/TSS KERRI KAVANAGH NRC/NRR/DIPM/IROB/TSS CARL SCHULTEN NRC/NRR/DIPM/IROB/TSS PETER HEARN NRC/NRR/DIPM/IROB/TSS MARK REINHART NRC/NRR/DSSA/SPSB NICK SALTOS NRC/NRR/DSSA/SPSB MILLARD WOHL NRC/NRR/DSSA/SPSB MARK CARUSO NRC/NRR/DSSA/SPSB DAVID SHUM NRC/NRR/DSSA/SPLB SUMMER SUN NRC/NRR/DSSA/SRXB WAYNE SCOTT NRC/NRR/DIPM/IEHB Enclosure 2

AGENDA TSS/NEI RITSTF Meeting FEBRUARY 11, 2004 9:00 A.M. - 12:30 P.M.

0-13 B4 Status of Initiatives N Initiative 4b, Risk-Informed Completion Times RMTS Risk Management Guidance Document CE Pilot, TSTF-424 STP Pilot N Public Questions and Discussion N Initiative 1, End States CEOG TSTF-422 Review Status BWROG TSTF-423 Review Status N Initiative 5b, SR Frequency Evaluation Methodology/SR Frequency TS Program Limerick Pilot SR Frequency TS Program/Methodology N Initiative 8, Remove/Relocate non-safety & non-risk significant systems from TS N Public Questions and Discussion N Initiative 6, LCO 3.0.3 Actions and Completion Times CEOG Final SER Status N Initiative 7, Non-TS Support System Inoperability Impact on TS System & TSTF-372 TSTF-372, Rev 4, Status TSTF-427 Status N Public Questions and Discussion N Schedule Next Meeting N Closing Comments Enclosure 3