ML051800640
| ML051800640 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/2005 |
| From: | Craig Harbuck NRC/NRR/DIPM/IROB |
| To: | Marion A Nuclear Energy Institute |
| Harbuck C, NRC/NRR/DIPM/301-415-3140 | |
| Shared Package | |
| ML051800633 | List: |
| References | |
| TAC MC0519 | |
| Download: ML051800640 (17) | |
Text
June 23, 2005 Mr. Alex Marion Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708
Dear Mr. Marion:
SUBJECT:
SUMMARY
OF MEETING HELD MAY 26, 2005, BETWEEN NRC STAFF AND INDUSTRY ON TSTF-448, CONTROL ROOM HABITABILITY, REVISION 1 (TAC NO. MC0519)
The purpose of this letter is to transmit the summary of the public meeting between the Nuclear Regulatory Commission (NRC) staff, the Nuclear Energy Institutes control room habitability task force (CRH TF) and the owners group technical specifications task force (TSTF) to discuss improvements to control room habitability-related requirements in standard technical specifications (STS). The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on May 26, 2005. At the meeting NRC staff and industry representatives made progress towards agreement on most issues stemming from the NRC staffs letter dated January 24, 2005, in which it proposed model TS for CRH. Based on the progress made during the meeting, it was agreed that the TSTF will prepare Revision 2 to TSTF-448 for submission to the NRC by July 2005.
Sincerely,
/RA/
C. Craig Harbuck, Senior Reactor Engineer Technical Specifications Section Reactor Operations Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation
Enclosures:
- 1. Meeting Summary
- 2. Agenda
- 3. Summary of End Point of Discussions on the 12 Issues Identified by the Industry
- 4. List of meeting attendees
- 5. Slides of presentation by NRC staff
PACKAGE: ML051800633, LETTER ML051800640, ENCLOSURE 5: ML051800658, ENCLOSURE ML051800672 DOCUMENT NAME: E:\\Filenet\\ML051800640.wpd OFFICE IROB-A:IROB:DIPM SC:SPSB-C:SPSB:DSSA SC:IROB-A:IROB:DIPM NAME CCHarbuck RLDennig THBoyce DATE 06/23/2005 06/29/2005 06/23/2005
DISTRIBUTION:
TSS R/F PLHiland WDReckley THBoyce HWalker JELyons CCHarbuck MKWebb JJHayes RLDennig MDTschiltz WMBlumberg
Technical Specifications Task Force tstf@excelservices.com 11921 Rockville Pike Suite 100 Rockville, MD 20852 Michael Crowthers (BWROG) mhcrowthers@pplweb.com PPL Susquehanna Mail Code GENPL4 Two North Ninth Street Allentown, PA 18101-1179 Wes Sparkman (WOG) wasparkm@southernco.com Southern Nuclear Operating Company P. O. Box 1295 / Bin B048 Birmingham, AL 35201 Paul Infanger (BWOG)
Paul.Infanger@pgnmail.com Crystal River Nuclear Plant Mail Code NA1B 15760 W. Power Line Street Crystal River, FL 34428 Brian Woods (WOG/CE) woodsbl@songs.sce.com mailstop: AWS-D3d San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674 Donald R. Hoffman (TSTF) donaldh@excelservices.com EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Brian Mann (TSTF) brianm@excelservices.com EXCEL Services Corporation 12624 Amershire Court Glen Allen, VA 23059 Tony Pietrangelo, Director arp@nei.org Risk and Performance Based Regulation Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708 MEETING
SUMMARY
On Thursday May 26, 2005, NRC management and staff from ADPT, DSSA, IROB and SPSB met with the Industry Owners Group Technical Specifications Task Force (TSTF) and the Nuclear Energy Institute (NEI) Control Room Habitability Task Force (CRHTF) in a public meeting to discuss improvements to standard TS (STS) control room habitability requirements, which industry had proposed in TSTF-448, Revision 1. The meeting centered on issues stemming from the NRC staffs latest thinking on CRH STS requirements as presented in the letter from the NRC to members of the TSTF dated January 24, 2005. The meeting began with a presentation by the NRC staff explaining the reasons behind the changes to CRH STS requirements it had proposed in the letter. The TSTF then presented its comments in the form of 12 issues concerning the staffs proposal. The slides from both presentations are attached to this meeting summary. Progress towards agreement was made on all but one of the issues, which was whether to put CRE unfiltered inleakage limit values in TS. For this and the other major issues, the details of implementation in the STS remain to be worked out. These details were (1) the appropriate way for TS to limit the duration of plant operation with a control room envelope (CRE) boundary that is considered inoperable because unfiltered inleakage is greater than assumed in the CRE occupant accident radiological dose analysis, while relying on mitigating actions to meet GDC-19 habitability requirements, (2) the role of CRE differential pressure measurements in assessing CRE unfiltered inleakage, (3) whether TS should include numerical values for limits on CRE unfiltered inleakage, and (4) the appropriate level of detail in the proposed TS administrative controls program for testing and maintaining the CRE boundary. Based on the progress made during the meeting, the NRC staff and the industry agreed that the TSTF will prepare Revision 2 to TSTF-448 for submission to the NRC by July 2005.
The meeting concluded with the preparation of an informal written summary of the status of each of the 12 issues that the industry had identified (Summary of end point of discussions on the 12 issues identified by the Industry). The following presents a brief description of each issue followed by the status as stated in the summary. For all issues, additional information is provided to further clarify the status. The NRC staff verified the accuracy of the additional information with the TSTF on June 17, 2005.
1.
Issue The NRC proposed a 30-day Completion Time to restore an inoperable CRE boundary to operable status.
Status Summary 30 days shutdown requirement not acceptable to industry. Industry recognizes need for a backstop on the length of time that compensatory measures can be used when control room inleakage is greater than the analysis assumption but GDC-19 is met. If GDC-19 cannot not be met, CREFS is inoperable and a shutdown is appropriate.
Industry will propose options.
Clarification There was agreement that in the event the measured CRE unfiltered inleakage exceeds the inleakage assumed in the CRE occupant radiological dose analysis, the CRE boundary may not be able to perform its required function of supporting the operability of the control room emergency filtration system (CREFS).
2 If CRE inleakage exceeds the facilitys assumed inleakage, restoring the CRE boundary and CREFS to operable status requires a licensee to either reduce inleakage to below its limit or change the limit. If the licensee elects to revise the inleakage limit and the limit value is stated in the TS, then the licensee must request a license amendment to adopt an inleakage limit that is greater than or equal to the measured inleakage. The NRC staff would approve the amendment based on the acceptability of the licensees CRE occupant radiological dose analysis for demonstrating the facility can meet GDC-19 assuming the proposed inleakage limit. The licensee may alternatively propose adopting an alternative accident source term (AST) per 10 CFR 50.67 to restore the CRE boundary and CREFS to operable status. In either case, the CRE boundary and the CREFS would be considered inoperable until the NRC approves the amendment.
If the CRE inleakage limit value is not stated in the SR, the licensee may revise its CRE occupant dose analyses under 10 CFR 50.59 in order to demonstrate the CRE boundary and CREFS are operable with the measured inleakage.
From the industrys perspective, limiting plant operation with CRE inleakage above its assumed value is an issue of allowing sufficient time to (a) re-analyze the consequences of a radiological, hazardous chemical or fire challenge to establish a new inleakage limit that accounts for the measured inleakage, and if necessary obtain a license amendment, (b) repair or modify the CRE boundary to reduce inleakage to a level at or below the assumed value, or (c) complete a combination of these actions. In any case, to consider the CRE boundary and CREFS operable, the licensee must demonstrate that the facility can meet GDC-19 without reliance on CRE occupants taking mitigating actions, such as use of self-contained breathing apparatus or ingestion of potassium iodide. The industry contends that repairing or modifying the CRE boundary or the CREFS to restore the capability to meet GDC-19 without relying on mitigating actions will usually require significantly more than 30 days to accomplish. In addition, industry questions why a shutdown would be required when implementation of mitigating actions will enable meeting GDC-19 until the CRE excessive inleakage condition is resolved.
From the NRC staffs perspective, limiting plant operation with CRE inleakage above its assumed value is an issue of minimizing the duration of facility operation while relying on mitigating actions that may hinder control room operator performance during accident conditions. Subsequent to the inleakage testing and corrective actions licensees were requested to complete by Generic Letter 2003-01, the NRC staff expects that restoring inleakage to within limits (e.g., by repairing the CRE boundary) in most cases will require less than 30 days to complete. Requiring more than 30 days would be an indication that the facilitys CRE boundary administrative controls program is ineffective.
The NRC staffs proposal to require a shutdown stems from a safety concern about burdening plant operators with mitigating actions during accident conditions. The longer the facility operates under mitigating actions, the greater the chance of this happening.
To establish a time limit on operation, the NRC staff prefer specifying a finite Completion Time in the TS Actions. The industry agree to establish a time limit, and will propose options for doing so in Revision 2 of TSTF-448. Note that these options will depend on whether the inleakage limit values are stated in TS or in a licensee-controlled document.
3 2.
Issue The NRC proposed clarifying the CRE differential pressure (P or dP) surveillance requirement (SR) with details in the CRE boundary TS administrative controls program.
Status Summary Agree dP test is not a TS Surveillance. Put dP testing in TS 5.0 program as part of assessment program. NRC is looking for changes since the tracer gas test. Industry understands NRC position and will propose TS wording.
Clarification The CRE P test proposed in the NRC staffs January 24, 2005, letter, although stated as a SR, was effectively not a SR because it contained no acceptance criteria for CRE P and CRE emergency ventilation system flow that relate directly to the operability of the CRE boundary. Rather, the proposed CRE boundary TS administrative controls program (the program) would require comparing the P and flow measurements with corresponding measurements taken during the most recent performance of the CRE inleakage SR. The program would require evaluating any differences to determine whether the condition of the CRE boundary may have changed, and in turn whether CRE inleakage may have increased above the existing limit. Industry agreed on the usefulness of periodic (18-month frequency on a staggered test basis) CRE P measurements to detect possible degradation of the CRE boundary during the 6 year to 7.5 year interval between tracer gas tests. However, industry wants P measurement to be a programmatic requirement only and its adoption to be optional. The NRC staff agreed with making P measurement a program requirement, and deleting the P SR from the CRE emergency ventilation system specification. However, the NRC staff wants P measurement to be mandatory, even for facilities that do not pressurize the CRE, because of its understanding that tracer gas testing always involves P measurement mapping of the CRE boundary.
The NRC staffs proposed administrative controls program described certain aspects of a method of P measurement acceptable to the staff. The industry pointed out that the NRC staffs description of the proposed locations of P measurements could be read as requiring many more P measurements than currently taken at most facilities. The NRC staff stated that the P measurements at each facility should be sufficient in number and location to account for all outside areas adjacent to the CRE boundary; and that each licensees application for adopting TSTF-448 should include a justification for the scope of P measurements its program will require. Industry will propose a programmatic CRE P measurement requirement in Revision 2 of TSTF-448.
3.
Issue The NRC proposed specifying in the administrative controls program explicit numerical limits on CRE unfiltered inleakage and the ASME or ASTM standards for measuring air duct flow.
Status Summary Industry does not agree with putting specific inleakage numbers in the TS. No specific solution proposed that both parties accepted. One option presented was to put a methodology in the TS instead of the specific values. The number should be the current analysis assumption.
4 Clarification It was agreed that the SR acceptance criterion for CRE inleakage should be the value assumed in the CRE occupant accident dose analysis. The NRC staff and the TSTF disagree on whether the number should be in TS or in a licensee-controlled document.
With the CRE inleakage limit value in TS, a licensees options for restoring the CRE boundary to operable status would be limited to either repairing the CRE boundary to reduce inleakage to within limit, or obtaining a license amendment to increase the inleakage limit. Industry contends neither of these options can be completed quickly. As discussed under Issue 1, if TS limit facility operation under mitigating actions to a finite Completion Time, such as 30 days, then industry believes a TS-required shutdown would be likely.
With the CRE inleakage limit value in a licensee-controlled document, a licensee would have additional options for restoring the CRE boundary to operable status. If a licensee plans to restore CRE inleakage to within the existing analysis assumption, then it can establish operability with an analysis that assumes revised values for some analysis inputs. An example might be the use of alternative accident source term (AST) methods for radiological analysis. Or a licensee could revise the assumed CRE inleakage in accordance with 10 CFR 50.59 to establish a new CRE inleakage assumption that bounds the measured inleakage. Even if TS limit facility operation under mitigating actions to a finite Completion Time, these options would make a TS-required shutdown unlikely.
4.
Issue The NRC proposed using inleakage limit values assumed in design basis accident CRE occupant dose analyses as acceptance criteria for the inleakage SR (tracer gas test), and including those values in the TS administrative controls program. Industry interpreted this as not allowing licensees to use alternative accident source term (AST) methods to support a conclusion of operable but degraded in the event CRE measured inleakage exceeds the value assumed in the CRE dose analyses for the facility.
Status Summary The summary provided for Issue 3 also applies to Issue 4.
Clarification The clarification provided for Issue 3 also applies to Issue 4.
5.
Issue The NRC proposed including other filtered ventilation system boundaries in TSTF-448.
Status Summary Agree to not include other ventilation systems in TSTSF-448, but NRC would like a commitment to address those other systems in the future.
Clarification The industry considers that including the other ventilation system specifications in the scope of TSTF-448 would unnecessarily delay completion of TSTF-448, and therefore wants to exclude them. The NRC staff wants to include these specifications to maintain consistency among the STS Section 3.7 filtered ventilation specifications, and because of the potential impact on control room habitability were one
5 of the associated boundaries inoperable. To hasten completion of TSTF-448, the NRC staff and the TSTF agreed that the TSTF will consider any NRC staff proposed changes to the other filtered ventilation specifications outside TSTF-448.
6.
Issue The NRC staff proposed treating the CRE boundary separately from CR emergency filtration system (CREFS) trains in the TS limiting condition for operation (LCO) and associated Actions Conditions.
Status Summary Industry will revise Bases to make clear that the CREFS includes all aspects of the system, including the boundary, instead of the LCO stating that the CREFS includes the boundary.
Clarification Industry disagrees with the NRC staffs proposal to revise the title of the CREFS specification to CREFS and CR Boundary because it wants to maintain the existing convention of most facilities TS that treat the CRE boundary is a necessary support system for the CREFS trains. The NRC staff believes this convention leads to ambiguities in current TS and STS regarding which Actions Condition applies when inleakage exceeds the CRE occupant accident dose analysis assumed value. Industry prefers maintaining the current convention of treating the CRE boundary as a support system for the CREFS. However, to settle the concern about ambiguous action requirements, industry will propose clarifications in the CREFS STS Bases in Revision 2 of TSTF-448.
7.
Issue The NRC staff proposed referencing the administrative controls program in the LCO Note on intermittent opening of the CRE boundary under administrative control.
Status Summary TS specifies controls for opening boundary - Industry will propose clarification.
Clarification The current STS Specification for CRE emergency ventilation / filtration system contains an LCO note which states, The control room boundary may be opened intermittently under administrative control.
The associated STS Bases state, The LCO is modified by a Note allowing the control room boundary to be opened intermittently under administrative controls. For entry and exit through doors, the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls consist of stationing a dedicated individual at the opening who is in continuous communication with the control room. This individual will have a method to rapidly close the opening when a need for control room isolation is indicated.
6 The NRC staffs January 24, 2005, proposal modified the note to state, The control room envelope may be opened intermittently under administrative control in accordance with the Ventilation Boundary Test Program (VBTP).
The proposed VBTP states, The VBTP shall maintain and control the configuration, design basis, and licensing basis of the boundaries of the control room, [ECCS pump rooms, the fuel building, and penetration rooms]. It shall also control the preventive and corrective maintenance of these boundaries. The VBTP shall require an approved procedure in writing to govern intermittent opening of a specified ventilation boundary under administrative controls.
These controls shall be pre-planned and adequate to ensure quick restoration of the boundary to a condition equivalent to its design condition in the event a need for an OPERABLE boundary arises.
The NRC staff proposed referencing the program in the note and placing requirements for implementing the note in the program because the program governs all aspects of maintaining the CRE boundary. Although it is not necessary for the program to explicitly require an approved procedure in writing, the description conveys the NRC staffs expectation that the administrative controls for opening the CRE boundary be governed by procedure like any other activity affecting quality. In addition, with regard to closing the boundary, the NRC staff believes the phrase restoration of the boundary to a condition equivalent to its design condition, better conveys the intent of the corresponding language in the STS Bases.
Industry prefers the existing presentation with the implementation of the note being described in the Bases, but in Revision 2 of TSTF-448 will propose clarifying the STS Bases for the note to more fully explain what is meant by closing the boundary.
8.
Issue The NRC staff included a list of mitigating actions in the proposed administrative controls program. Industry was concerned that the list was exclusive.
Status Summary List of mitigating actions in TS - Industry will propose clarification.
Clarification The NRC staff explained that the following sentence containing the list was not meant to be exclusive:
Mitigating actions that may be credited include the staging of Potassium Iodide (KI) and Self-Contained Breathing Apparatuses (SCBAs) for use by control room occupants, [and] temporary realignment of ventilation systems [, and ].
Note that Regulatory Guide 1.196, Section 2.7.3, Degraded and Nonconforming Conditions describes the NRC staffs endorsement of NEI 99-03, Rev. 0, Section 8.4 regarding use KI and SCBAs (called compensatory measures), and recommends using
7 Regulatory Guide 1.194, and 1.195 or 1.183 instead of Appendices C and D of NEI 99-03, which are not endorsed..
Industry will propose a clarification to this sentence, in Revision 2 of TSTF-448, so that it cannot be read as being an exclusive list.
9.
Issue The NRC staff proposed using the term occupant in place of operator for referring to radiation exposure limits of GDC-19 related to permitting personnel access and occupancy of the control room under accident conditions.
Status Summary Industry accepts NRC change.
Clarification Industry will use occupant instead of operator as appropriate in Revision 2 of TSTF-448..
10.
Issue The NRC staff proposed using the term control room instead of CRE to mean the space which must meet the habitability requirements of GDC-19.
Status Summary CR versus CRE terminology - Need to use consistent terminology. Be careful with use of term "boundary." Industry will review use of terminology in TSTF-448.
Clarification The dictionary definition of the word envelope is analogous to the term boundary as used in the STS filtered ventilation system specifications. However, both industry and NRC guidance on control room habitability define control room envelope (CRE) as the space enclosed by the boundary, which may include areas in addition to the space called the control room. But the same guidance also uses CRE when it means the boundary, which is inconsistent. The NRC staff proposed that when referring to the boundary, that the STS exclusively use the phrase CRE boundary. Industry will ensure consistent terminology is used in Revision 2 of TSTF-448.
11.
Issue The NRC staff included guidance from Section 1.5 of Regulatory Guide 1.197 in Paragraph 5.5.18.b.2.(c)(3) of the proposed administrative controls program regarding a condition warranting testing of the CRE boundary for inleakage. This paragraph states
- 2. The VBTP required testing shall be performed:
c)
For the affected specified ventilation boundary, following any:
(3)
Event (radiological, hazardous chemical, or fire) that challenges the boundary, if the resulting conditions lead to a change in an SSCs [structure, system, or components]
operating mode, alignment, or response that could result in a new limiting condition.
Status Summary Post event testing - Industry will propose clarification.
8 Clarification The paragraph is based on the following guidance on test periodicity in Section 1.5 of Regulatory Guide 1.197 (emphasis added):
CRE testing should be performed when changes are made to the structures, systems, components, and procedures that could impact CRE integrity. The structures, systems, and components could be within the envelope itself or could serve or be within areas adjacent to the envelope.
Additional testing may be warranted if the conditions associated with a particular challenge result in a change in operating mode, alignment, or response that could result in a new limiting condition. Testing should be commensurate with the type and degree of modification or repair that has been made. For some changes, a new baseline test may be required.
Industry believes proposed paragraph 2(c)(3) is confusing and will clarify post-event testing requirements for the CRE boundary in Revision 2 of TSTF-448.
12.
Issue The NRC staff included requirements in the proposed administrative controls program that are specified elsewhere in TSs or regulations.
Status Summary Duplicative requirements - Industry will propose clarification.
Clarification The NRC staff does not propose that TSTF-448 contain redundant requirements, but did intentionally include such requirements in its proposed TS administrative controls program to make clear to industry its expectations for maintaining and testing the CRE boundary. The NRC staff agreed that information redundant to existing general requirements and guidance is not appropriate for inclusion in a STS Section 5.5 administrative controls program specification. However, the NRC staff proposed that Revision 2 of TSTF-448 require licensees adopting TSTF-448 to include this information in the Bases for the inleakage test surveillance requirement, as appropriate, and commit to NRC staff endorsed industry guidance and NRC regulatory guidance on control room habitability. Such documents should contain information and guidance that is consistent with the information contained in the NRC staffs draft TS administrative controls program. The NRC staff also expects that the CRE boundary proposed TS administrative controls program will continue to require CRE unfiltered inleakage testing to be in accordance with RG 1.197. Industry proposed to clarify the duplicative requirements as they relate to testing of the CRE boundary in Revision 2 to TSTF-448.
PUBLIC MEETING BETWEEN NRC STAFF AND INDUSTRY OWNERS GROUP TECHNICAL SPECIFICATIONS TASK FORCE (TSTF AND THE NUCLEAR ENERGY INSTITUTE (NEI) CONTROL ROOM HABITABILITY TASK FORCE REGARDING TSTF-448, CONTROL ROOM HABITABILITY One White Flint North, Room O-12B4, 11555 Rockville Pike, Rockville, Maryland May 26, 2005 AGENDA 9:00 Introduction and opening remarks 9:15 Presentation by NRC staff on the improvements to control room habitability (CRH) technical specifications (TSs) proposed in the January 24, 2005, letter from the NRC to TSTF members
- CRH TS issues recognized by NRC staff
- Rationale for proposed resolutions of CRH TS issues 10:00 Presentation by TSTF of industry comments on the January 24, 2005, letter and discussion regarding:
1.
A 30-day Completion Time to restore CR envelope (CRE) boundary operability.
2.
Clarifying the CRE boundary differential pressure (dP) surveillance requirement (SR) with details in the administrative control program.
3.
Specifying in the administrative controls program explicit numerical limits on CRE unfiltered inleakage and ASTM standards for measuring air duct flow.
4.
Using inleakage limit values assumed in design basis accident CRE dose analyses as acceptance criteria for the inleakage SR (tracer gas test).
5.
Including other filtered ventilation system boundaries in TSTF-448.
6.
Treating the CRE boundary separately from CR emergency ventilation trains in the TS limiting condition for operation (LCO) and associated Actions Conditions.
7.
Referencing the administrative controls program in the LCO Note on intermittent opening of the CRE boundary under administrative control.
8.
Clarifying that mitigating actions listed in the administrative controls program are not thew only ones permissible.
9.
Using occupant instead of operator.
- 10. Using the term control room instead of CRE to mean the space that must meet the habitability requirements of GDC-19.
- 11. Paragraph 5.5.18.b.2©)(3) of the proposed administrative controls program.
- 12. Repeating requirements in the administrative controls program that are specified elsewhere in TSs or regulations.
11:45 Identify issues requiring further discussion.
12:00 Break for lunch.
1:00 Continuation of discussion (in Room O-4B6).
10 4:00 Adjourn.
TSTF-448 TSTF - NEI CRHTF - NRC Meeting May 26, 2005 Summary of end point of discussions on the 12 issues identified by the Industry.
1.
30 day shutdown requirement - 30 days shutdown requirement not acceptable to industry.
Industry recognizes need for a backstop on the length of time that compensatory measures can be used when control room inleakage is greater than the analysis assumption but GDC-19 is met. If GDC-19 cannot not be met, CREFS is inoperable and a shutdown is appropriate. Industry will propose options.
2.
P surveillance expansion - Agree P test is not a TS Surveillance. Put P testing in TS 5.0 program as part of assessment program. NRC is looking for changes since the tracer gas test. Industry understands NRC position and will propose TS wording.
3 &4. CR in-leakage limits in TS & Use of AST in evaluating in-leakage - Industry does not agree with putting specific inleakage numbers in the TS. No specific solution proposed that both parties accepted. One option presented was to put a methodology in the TS instead of the specific values. The number should be the current analysis assumption.
5.
Inclusion of other ventilation TS in TSTF-448 - Agree to not include other ventilation systems in TSTSF-448, but NRC would like a commitment to address those other systems in the future.
6.
LCO to include CR boundary - Industry will revise Bases to make clear that the CREFS includes all aspects of the system, including the boundary, instead of the LCO stating that the CREFS includes the boundary.
7.
TS specifies controls for opening boundary - Industry will propose clarification.
8.
List of mitigating actions in TS - Industry will propose clarification.
9.
CR "occupants" vs. "operators" - Industry accepts NRC change.
10.
CR versus CRE terminology - Need to use consistent terminology. Be careful with use of term "boundary." Industry will review use of terminology in TSTF-448.
11.
Post event testing - Industry will propose clarification.
12.
Duplicative requirements - Industry will propose clarification.
PUBLIC MEETING BETWEEN NRC STAFF AND INDUSTRY ON TSTF-448 May 26, 2005 Persons in Attendance Name Organization E-Mail Brian Sheron NRC/NRR/ADPT bws@nrc.gov Jim Lyons NRC/NRR/DSSA jel@nrc.gov Michael Johnson NRC/OE mrj1@nrc.gov Tom Boyce NRC/NRR/DIPM/IROB/IROB-A thb@nrc.gov Craig Harbuck NRC/NRR/DIPM/IROB/IROB-A cch@nrc.gov Andrzej Drozd NRC/NRR/ADPT/DSSA/SPSB/SPSB-C axd@nrc.gov John Hayes NRC/NRR/ADPT/DSSA/SPSB/SPSB-C jjh@nrc.gov Harold Walker NRC/NRR/ADPT/DSSA/SPSB/SPSB-C hxw@nrc.gov Mark Blumberg NRC/NRR/ADPT/DSSA/SPSB/SPSB-C wmb1@nrc.gov Mark Reinhart NRC/NRR/ADPT/DSSA/SPSB/SPSB-B fmr@nrc.gov Alex Marion NEI am@nei.org Jim Riley NEI jhr@nei.org Brian Mann TSTF, EXCEL Services Corporation brianm@excelservices.com Thomas Shaub Dominion tom_shaub@dom.com Jerry Kloecker Dominion jerry_kloecker@dom.com Stephen P. Schultz Duke Energy spschultz@duke.energy.com Robert Campbell Tennessee Valley Authority rrcampbell@tva.gov Laurie Lahti Nuclear Management Company (NMC) laurie.lahti@nmcco.com John Duffy PSEG Nuclear john.duffy@pseg.com Dennis Adams FENOC Corporation dqadams@firstenergycorp.com Ken Taplett STPNOC kjtaplett@stpegs.com Jimmy Cash Southern Nuclear jpcash@southernco.com David Distel Exelon david.distel@exeloncorp.com Nancy Chapman SERCH, Bechtel ngchapma@bechtel.com
13
PUBLIC MEETING BETWEEN NRC STAFF AND INDUSTRY ON TSTF-448 May 26, 2005 NRC Staff Presentation Slides
PUBLIC MEETING BETWEEN NRC STAFF AND INDUSTRY ON TSTF-448 May 26, 2005 NEI CRH TF / TSTF Presentation Slides