ML042580008

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Summary of Meeting with the Risk-Informed Technical Specification Task Force
ML042580008
Person / Time
Issue date: 09/15/2004
From: Tjader T
NRC/NRR/DIPM/IROB
To: Bradley B
Nuclear Energy Institute
Tjader T., NRC/IROB, 415-1187
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Download: ML042580008 (13)


Text

September 15, 2004 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708

SUBJECT:

SUMMARY

OF MEETING ON SEPTEMBER 9, 2004, WITH THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE

Dear Mr. Bradley:

The purpose of this letter is to transmit the summary of a meeting with the Risk-Informed Technical Specification Task Force. The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on September 9, 2004. Significant progress is being made on the Risk Management Technical Specifications Initiatives. By the end of the year, generic changes are expected to be made available via the consolidate line item improvement program on: Initiatives 1, on preferred end states for CE plants (followed shortly thereafter by similar changes for BWR plants); and, Initiative 7, on snubber inoperability for all plants (followed shortly thereafter by changes on hazard barrier inoperability).

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. RAI/PRA Issues Categories
6. TSTF-372 RAI Responses cc w/encl: See attached page

Package: ML042580006, Letter: ML042580008, : ML042580010, Enclosure 5: ML042580029, Enclosure 6: ML042580011 DOCUMENT NAME: C:\MyFiles\Checkout\RITSTF-MTGsum-9-9-04.wpd OFFICE TSS:IROB:DIPM SC:TSS:IROB:DIPM NAME TRTjader THBoyce DATE 09/15/2004 09/15/2004 DISTRIBUTION:

ADAMS PUBLIC IROB R/F TSS Staff BBoger/MJCase (RidsNrrDipmDpr)

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FMCostello (RidsNrrDipmIrob)

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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 SEPTEMBER 9, 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 September 9, 2004, from 9:00 a.m. to 12:10 p.m. The meeting attendees are listed in .

The agenda (Enclosure 3) consisted of discussions of five of the active RITSTF initiatives, and Initiative 4a generic completion time extension submittals. 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: The safety evaluations for the Combustion Engineering Owners Group (CEOG) and Boiling Water Reactor Owners Group (BWROG) topical reports have been issued, and the industry has proposed technical specifications changes which are under staff review. NEI provided draft implementation guidance for the CE STS change, TSTF-422, for staff review, on May 27, 2004. Staff provided comments on the draft implementation guidance in July 2004, and issues are currently being resolved. The RITSTF submitted the B&W Topical Report (BAW-2441, Rev 2) on January 19, 2004. The staff provided RAIs on the B&W Topical Report on June 29, 2004, and subsequently the BWOG informed the staff that RAI responses would not be provided before March 2005. Therefore, the B&W Topical Report review is on hold. Next Action: NEI will provide TSTF-422 RAI responses in September 2004. TSTF-422 is expected to be available through the Consolidated Line Item Improvement Process (CLIIP) in December 2004. The staff will provide feedback on the content of the implementation guidance needed for the BWR STS change, TSTF-423.

Initiative 4b, Risk Informed CTs/AOTs: The staff provided RAIs to the Risk Management Guidance Document, the CE pilot proposal, TSTF-424, and the South Texas Project draft pilot proposal in July 2004. The industry has established an Initiative 4b subgroup, which has classified the RAI/PRA issues into 20 categories, listed in Enclosure 5. STP submitted their official pilot plant license amendment proposal on August 2, 2004, and FCS submitted their pilot plant license amendment proposal on May 14, 2004. Hope Creek, a BWR plant, expects to submit at the end of 2005. Prairie Island, an STS plant, has volunteered to be a pilot plant.

Next Action: The industry will respond to the RAIs on the RMTS Risk Management Guidance, CE TSTF-424, and the STP pilot proposals, with a meeting to discuss issues scheduled for December 15, 2004. NEI will be providing a point paper on the nexus between I4b and Initiative 6, on LCO 3.0.3 entry times. The staff plans visits to the regional staff to conduct educational briefs, and then subsequent visits to pilot plants.

Initiative 4a, CT/AOT Extensions: Generic RG 1.177 CT/AOT extension submittals were discussed, in light of recent staff rejections. The staff noted that the generic topical reports supporting multiple CT/AOT extensions were lacking in that Tier 2 configuration constraints were lacking, and that multiple CT/AOT extensions need to consider the potential risk of multiple system inoperabilities either through extensive Tier 2 configuration constraints or in an Initiative 4b manner, and that aggregate risk must be taken into account. Next Action: Further discussions on future submittals are needed, with consideration given to routing generic Initiative 4a CT/AOT extension submittals through the RITSTF for a comprehensive and integrated review.

Enclosure 1

Initiative 5, Relocation of non-safety SRs (5a) and relocation of all SR frequency requirements (5b) out of TS: Exelon submitted Limericks proposed pilot plant license amendment request on June 25, 2004. The industry is developing an Initiative 5b methodology. The associated proposed technical specifications changes, TSTF-425, were submitted on 31 August, 2004.

Next Action: The industry will submit an Initiative 5b methodology document in September 2004. The staff will then commence an integrated review of Limericks proposed pilot plant license amendment, TSTF-425, and the Initiative 5b methodology.

Initiative 6, Modification of LCO 3.0.3 Actions and Completion Times: The staff approved and issued the SER on the CE Topical Report on July 9, 2004. Industry submitted a proposed CE TSTF-426 on August 30, 2004. Next Action: NEI will provide draft implementation guidance in November 2004.

Initiative 7, Non-TS support system impact on TS operability determinations: The RITSTF submitted TSTF-372, Revision 4, on April 27, 2004, and the staff responded with comments on May 18, 2004. TSTF-372R4 included 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 is acceptable. The staff has requested additional information on non-seismic snubbers (Enclosure 6). The staff has started writing the SE for TSTF-372, Revision 4, in May 2004, and is reviewing and resolving issues related to RITSTF responses to staff comments as they are provided. The staff has found that the industry response to staff comments on TSTF-427 are generally acceptable, though lacking in detail. Next Action: The staff is scheduled to issue the safety evaluation for TSTF-372 in September 2004, subsequent to the resolution of the final issue. The RITSTF will provide TSTF-427 draft implementation guidance in September 2004.

The staff conducted a public workshop on Generic Letter 91-18, Operability, on August 25, 2004.

The next NRC TSS/NEI RITSTF meeting is tentatively scheduled for the last week in January 2005, at the NRC Headquarters.

NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE ATTENDANCE LIST SEPTEMBER 9, 2004 NAME AFFILIATION BIFF BRADLEY NUCLEAR ENERGY INSTITUTE DON HOFFMAN RITSTF/EXCEL SERVICES JIM LIMING ABSC/EPRI JIM ANDRACHEK WESTINGHOUSE/WOG ALAN HACKEROTT OPPD GARY CHUNG SONGS WAYNE HARRISON STP NOC DREW RICHARDS STP NOC MARK RIEMER FENOC RAY SCHNEIDER WESTINGHOUSE PSA GABE SALAMON NMC YU SHEN NMC MIKE KITLAN DUKE ENERGY RICK HILL GE WEI HE PSEG NUCLEAR DEANN RALEIGH SCIENTECH NANCY CHAPMAN SERCH/BECHTEL FRANK COSTELLO NRC/NRR/DIPM/IROB BOB TJADER NRC/NRR/DIPM/IROB/TSS CARL SCHULTEN NRC/NRR/DIPM/IROB/TSS KERRI KAVANAGH NRC/NRR/DIPM/IROB/TSS MARK REINHART NRC/NRR/DSSA/SPSB MARK CARUSO NRC/NRR/DSSA/SPSB NICK SALTOS NRC/NRR/DSSA/SPSB MICHELE LAUR NRC/NRR/DSSA/SPSB Enclosure 2

AGENDA TSS/NEI RITSTF MEETING SEPTEMBER 9, 2004 9:00 A.M. - 12:30 P.M.

0-9 B4 1 Status of Initiatives 1 Initiative 4b, Risk-Informed Completion Times RMTS Risk Management Guidance Document CE Pilot, TSTF-424 FCS Pilot STP Pilot Hope Creek Pilot Prairie Island Pilot 1 Initiative 4a, Generic RG 1.177 Completion Time Extensions 1 Public Questions and Discussion 1 Initiative 1, End States CEOG TSTF-422 Status BWROG TSTF-423 Status B&W Topical 1 Initiative 5b, SR Frequency Evaluation Methodology/SR Frequency TS Program Limerick Pilot Status SR Frequency TS Program/Methodology 1 Initiative 8, Remove/Relocate non-safety & non-risk significant systems from TS 1 Public Questions and Discussion 1 Initiative 6, LCO 3.0.3 Actions and Completion Times CEOG TSTF-426 Status 1 Initiative 7, Non-TS Support System Inoperability Impact on TS System & TSTF-372 TSTF-372, Rev 4, SER Status TSTF-427 Status 1 Public Questions and Discussion 1 Schedule Next Meeting 1 Closing Comments Enclosure 3