ML051670054
| ML051670054 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/2005 |
| From: | Schulten C NRC/NRR/DIPM/IROB |
| To: | Schoppman M Nuclear Energy Institute |
| Schulten C. S., NRR/IROB/TSS, 415-1192 | |
| References | |
| Download: ML051670054 (7) | |
Text
June 28, 2005 Mr. Mike Schoppman Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708
Dear Mr. Schoppman:
SUBJECT:
SUMMARY
OF MEETING ON JUNE 2, 2005, WITH THE NUCLEAR ENERGY INSTITUTE (NEI) SETPOINT METHODS TASK FORCE (SMTF)
The purpose of this letter is to transmit the summary of the U.S. Nuclear Regulatory Commission (NRC) staff meeting with the Setpoint Methodology Task Force. The meeting was held at the NRC White Flint Offices in Rockville, Maryland, on June 2, 2005. At the meeting, NRC staff and task force members discussed seven Technical Specifications Task Force Concepts for resolving the generic technical specification setpoints issue, as stated in a letter from NEI SMTF of May 18, 2005.
Sincerely,
/RA/
Carl S. Schulten, 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 cc w/encl: See attached page
ML051670054 OFFICE TSS:IROB:DIPM SC:TSS:IROB:DIPM NAME CSSchulten THBoyce DATE 06/20/2005 06/28/2005 DISTRIBUTION:
ADAMS PUBLIC IROB R/F TSS Staff RidsNrrDipm RidsNrrDipmleh RidsNrrDssa RidsNrrDssaSplb RidsNrrDlpm RidsAcrsAcnwMailCenter RidsOgcRp CGratton JANakoski PJRebstock GMTartal MEMayfield HCLi
cc via e-mail:
Mr. Mike Schoppman, Nuclear Energy Institute Mr. Ron Gaston, DTE Energy Ms. Laurie Lahti,Nuclear Management Company Ms. Nancy Chapma,SERCH/Bechtel Mr. Pete LeBlond, LeBlond Associates Mr. Donald Hoffman, Technical Specifications Task Force Mr. Jeff Thomas, Duke Energy Ms. Deann Raleigh, Scientech Mr. Jim Kilpatrick,Constellation Energy Mr. Brian Mann, Technical Specifications Task Force Mr. Getachew Tesfaye, Constellation Energy
SUMMARY
OF THE JUNE 2, 2005 MEETING BETWEEN NRC AND THE NEI SETPOINT METHODS TASK FORCE ON SETPOINT AND ALLOWABLE VALUES FOR SAFETY-RELATED INSTRUMENTATION On June 2, 2005, the NRC staff met with the Task Force at the NRC Offices at White Flint in Rockville, Maryland to discuss setpoints and allowable values for safety-related instrumentation.
The purpose of the meeting was to get NRC staff feedback on seven technical specification (TS) concepts discussed in the enclosure of the NEI (A. Marion) letter dated May 18, 2005 to J. E. Lyons (NRR). The seven concepts were developed by the NEI Setpoint Methods Task Force (SMTF) as an approach to resolving staff setpoints concerns identified in the NRC (J. E. Lyons) letter dated March 31, 2005 (ML050870008) to A. Marion. This meeting was requested by NEI as a working meeting between the SMTF and the NRC staff. A copy of the agenda and the SMTF presentation handout are available in ADAMS at accession number ML051390002 and, ML051570550, respectfully. A list of attendees is attached as Enclosure 2.
The meeting provided an opportunity for NEI and the NRC staff to meet and discuss the NRC staffs concern with respect to TS operability and satisfying 10 CFR 50.36(c)(1)(ii)(A) and 10 CFR 50.36(c)(3). The staff stated that operability needs to be assessed, in part, based on the ability of the system to initiate automatic protective actions as required to protect the safety limit (SL) (i.e., satisfy its safety function) and surveillance testing needs to demonstrate that the equipment is functioning as expected.
The NEI proposed generic TS resolution sets forth seven concepts to be used to prepare a Technical Specification Task Force Traveler (TSTF) by the SMTF for submittal to the NRC. At the meeting NEI stated that the SMTF TSTF Concepts represent a consensus generic position that links the concepts for TS requirements to LSSS values defined by 10 CFR 50.36.
The SMTF coordinated this generic position to ensure that all plants are aware of the generic issue and its potential impact. The intent, as stated by the NEI, is for the SMTF generic resolution process to be applied to the TSTF developed from the seven TSTF Concepts and that the TSTF and its implementation can be applicable to all plants.
At the meeting NEI expressed a continued concern with the issuance of requests for additional information (RAIs) for licensing action requests (LARs) associated with instrument settings.
The NRC staff replied that it continues to process LARs related to instrumentation setpoints in accordance with plant-specific licensing bases. The NRC staff gave its position that compliance with the requirements of 10 CFR 50.36(c)(1)(ii)(A) applies to LARs requesting changes to LSSS associated with SLs, and that the LARs need to include TS requirements to ensure an operability determination can be made based on the results of the required testing. The NRC staff also stated that LSSS may also apply to systems other than RTS, ESFAS, RPS and ECCS based on the plant-specific licensing basis, consistent with the previous NRC staffs position in its letter to NEI dated March 31, 2005.
The NRC staff also explained why the RAIs are needed for reviewing LARs requesting changes to LSSS associated with SLs. This information is necessary for the NRC staff to conclude that the TSP provides reasonable assurance that the SL will be protected and to find that the LAR complies with NRC regulations, findings that are necessary to support issuance of the LAR.
Enclosure 1
Further, the NRC staff responded to NEI concerns about RAIs requesting that the licensee provide a brief description of the methodology used to determine its setpoints. The purpose of these requests were to solicit information from the licensee to determine whether TSPs were calculated in a manner that accounted for credible uncertainties associated with the instrument channel.
During the meeting, the NRC staff provided our feedback on the seven concepts discussed in the May 18, 2005, letter as clarified by the SMTF at the meeting. The NRC staff was in agreement with concept 1 ([limiting] trip setpoint), concept 2 (as-found trip setpoint), concept 3 (reset setpoint), concept 6 (single-column vs. multiple-column TS), and concept 7 (operability).
For concept 4, (limiting TSP vs. nominal TSP), the NRC staff agreed that the nominal TSP may be set more conservative than the limiting TSP. However, the NRC staff questioned the idea that the predefined limits for as-found and as-left values be maintained around the more conservative nominal TSP. If the idea that the setting tolerance is maintained small in comparison to the predefined limits is incorporated into concept 4 and described in the proposed TSTF TS bases, the modified concept 4 would be acceptable to the NRC staff.
For concept 5 (allowable value), there were extended discussions during the June 2, 2005, meeting regarding the acceptability of this concept. Several options were discussed during the meeting for which the NRC staff requested that the SMTF assess as viable options. As one of the options discussed, the NRC staff agreed to reconsider retaining a single column TS format that uses allowable values determined using any of the three methods described in ISA recommended practice ISA-RP67.04-1994, Part II, Methodologies for Determination of Setpoints for Nuclear Safety-Related Instrumentation.
Our meeting concluded with each party taking certain actions. NRC staff agreed it should be receptive to keeping Allowable Values in TSs. The NRC staff committed to hold additional internal discussions on this NEI concern and provide timely feedback to NEI. NEI agreed to give the NRC staff information on the industry position that the setting tolerance is small with respect to the predefined limits discussed in concept 4. NEI will present the NRC staff with approaches to resolving concept 4 differences.
PUBLIC MEETING ON INSTRUMENTATION SETPOINTS ATTENDANCE LIST JUNE 2, 2005 NAME ORGANIZATION CHRIS GRATTON NRR/DLPM DAVID BARRETT TVA CHRIS KER EXELON KEN MCELROY SOUTHERN NUCLEAR PETE KOKOLAKIS ENTERGY DEANN RALEIGH US SCIENTECH MICHAEL EIDSON SOUTHERN NUCLEAR DON WOODLAN STARS GORDON CLEFTON NEI MIKE SCHOPPMAN NEI ALEX MARION NEI PATRICK HILAND NRC/IROB/DIPM CARL SCHULTEN NRC/IROB/DIPM JOHN A. NAKOSKI NRC/IROB/DIPM PAUL REBSTOCK NRC/EEIB/DE JERRY VOSS EXCEL SERVICES DONALD HOFFMAN EXCEL SERVICES GEORGE TARTAL RES/DET PATRICK SIMPSON EXELON BOB FREDRICKSEN EXELON D.T. LANGLEY TVA LINDA CONKLIN SCE RON JARRETT TVA CORPORATE ALTHEIA WYCHE SEARCH LICENSING/BECHTEL HILBERT LI NRC/EEIB/DE JIM ANDRACHEK WESTINGHOUSE MICHAEL MAYFIELD NRC/DE Enclosure 2