ML052730152
| ML052730152 | |
| Person / Time | |
|---|---|
| Issue date: | 10/03/2005 |
| From: | Tjader T NRC/NRR/DIPM/IROB |
| To: | Bradley B Nuclear Energy Institute |
| Tjader T., NRC/IROB, 415-1187 | |
| Shared Package | |
| ML052730142 | List: |
| References | |
| Download: ML052730152 (7) | |
Text
October 3, 2005 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708
SUBJECT:
SEPTEMBER 21, 2005:
SUMMARY
OF MEETING WITH THE NUCLEAR ENERGY INSTITUTE, ELECTRIC POWER RESEARCH INSTITUTE AND INDUSTRY REPRESENTATIVES ON RISK MANAGEMENT TECHNICAL SPECIFICATIONS GUIDELINES FOR INITIATIVE 4b
Dear Mr. Bradley:
The purpose of this letter is to transmit the summary of a meeting with the Industry representatives on Risk Management Technical Specifications Guidelines. The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on September 21, 2005.
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. Risk Management Guidelines (RMG) Requests for Additional Information (RAIs)
- 5. RMG Comments
- 6. RMTS Guidelines cc w/encl: See attached page
PACKAGE: ML052730142, LETTER, ML052730152, ENCLOSURE 4: ML052730161, ENCLOSURE 5: ML052730165, ENCLOSURE 5: ML052730170 OFFICE TSS:IROB-A:DIPM SC:TSS:IROB-A:DIPM NAME TRTjader THBoyce DATE 10/03/2005 10/03/2005
cc via e-mail:
Mr. Tony Pietrangelo Nuclear Energy Institute Mr. Biff Bradley Nuclear Energy Institute Mr. Mike Schoppman Nuclear Energy Institute Mr. Alan Hackerott, Chairman Omaha Public Power District Mr. Jim Kenny Pennsylvania Power & Light Company Mr. James Andrachek Westinghouse Electric Company Mr. Jack Stringfellow Southern Nuclear Operating Company Mr. Ray Schneider Westinghouse Mr. John Gaertner EPRI Mr. Frank Rahn EPRI Mr. Wayne Harrison STP Mr. Drew Richards STP Mr. Rick Grantom STP Mr. Gary Chung SCE-SONGS Mr. Glenn Stewart Exelon Mr. Phil Tarpinian Exelon Ms. Nancy Chapman SERCH/Bechtel Mr. Rick Hill General Electric Nuclear Energy Mr. Michael S. Kitlan, Jr.
Duke Energy Corporation Mr. Noel Clarkson Duke Energy Corporation Mr. Donald Hoffman EXCEL Services Corporation Mr. Ted Book Framatech-ANP Mr. R. J. Schomaker Framatech-ANP Mr. J. E. Rhoads Energy Northwest Ms. Deann Raleigh Scientech Mr. Ken Canavan DS&S Mr. Steven Dolly Platts Mr. Gabe Salamon PSEG Nuclear Mr. Courtney Smyth PSEG Nuclear LLC Mr. Jerry Andre Westinghouse Electric Company Mr. David Helher Exelon Mr. Eugene Kelly Exelon Mr. James Liming ABSG Mr. Stanley Levinson Framatone ANP
SUMMARY
OF THE SEPTEMBER 21, 2005 MEETING WITH NUCLEAR ENERGY INSTITUTE (NEI), ELECTRIC POWER RESEARCH INSTITUTE (EPRI) AND INDUSTRY REPRESENTATIVES ON RISK MANAGEMENT TECHNICAL SPECIFICATIONS GUIDELINES FOR INITIATIVE 4b The NRC staff met with Industry representatives on September 21, 2005, from 9:00 a.m. to 12:30 p.m. The meeting attendees are listed in Enclosure 2.
The agenda (Enclosure 3) consisted of major discussion topics/requests for additional information (RAIs) (Enclosure 4) and related comments (Enclosure 5) to the latest version of the Industrys proposed Risk Management Technical Specifications (RMTS) Guidelines (Enclosure 6) for RMTS Initiative 4b, Risk-Informed Completion Times.
Major topics of discussion and areas needing enhancement in the RMTS Guidance (RMG) document are:
The RMG should be restructured to provide requirements that can be invoked by the Administrative Controls Section of the technical specifications (TS). To the extent possible the RMG should be procedure like and utilize imperative directives such as shall. Reducing redundancy, maintaining consistency and simplifying the RMG should be a goal in restructuring. It is not deemed necessary to make the RMG document a Regulatory Guide since it will be referenced explicitly in the TS.
It should be clear that the cause of an ICDP increase above 10 -6 and an approach to the limit of 10-5 is due to emergent conditions and not a routine planned increase. Guidance is needed on the accumulation of risk, to avoid exceeding the 10 -5 limit. Guidance should be included on the periodic evaluation of the accumulation of risk, and the consideration of actions to improve the implementation of RICTs. A member of the staff proposed that a possible means controlling aggregate risk would be to add a goal to the Administrative Controls Section of the TS to keep the accumulation of risk as low as reasonably achievable.
The discussion of Common Cause Failure (CCF) needs to be enhanced by including specific actions, considerations and examples.
The discussion of TS Operability versus PRA functionality needs to be enhanced by including specific considerations and examples.
A thorough discussion is needed of the application of a RICT, with examples provided of various scenarios; how the actions associated with a RICT are entered and exited.
It must be clear that every use of a RICT requires documentation of the associated risk assessment.
The RMG should thoroughly discuss the use of qualitative and bounding assessments; e.g., how risk concerns can be qualitatively ruled out, and how quantitatively risk concerns can be bounded.
Consideration of applying a Safety Function Determination Program test, such as that provided in the Standard TS, to LCO 3.0.3 entries to determine if it is acceptable to utilize a RICT; it is not acceptable to use a RICT for an LCO 3.0.3 entry required by a bonafide loss-of-funtion. It is recognized that RICTs can be used with the actions to restore equipment to Operable status that have been created through RMTS Initiative 6.
The processes described in the STP and CE pilot plant proposals must be consistent with the RMG.
The intent is to meet again soon after a revised RMG document is developed and provided for review.
NRC/INDUSTRY MEETING ON THE RISK MANAGEMENT GUIDELINES FOR RMTS INITIATIVE 4b ATTENDANCE LIST SEPTEMBER 21, 2005 NAME AFFILIATION BIFF BRADLEY NUCLEAR ENERGY INSTITUTE JOHN GAERTNER EPRI RICK GRANTOM STP NOC WAYNE HARRISON STP NOC BILL STILLWELL STP NOC DREW RICHARDS STP NOC ALAN HACKEROTT OPPD RAY SCHNEIDER WESTINGHOUSE PSA JAMES LIMING ABSG PAT HILAND NRC/NRR/DIPM/IROB TOM BOYCE NRC/NRR/DIPM/IROB/TSS BOB TJADER NRC/NRR/DIPM/IROB/TSS DAVID ROTH NRC/NRR/DIPM/IROB/TSS SARA BERNAL NRC/NRR/DIPM/IROB/TSS MARK REINHART NRC/NRR/DSSA/SPSB ANDREW HOWE NRC/NRR/DSSA/SPSB JIM VAIL NRC/NRR/DSSA/SPSB NANCY SALGADO NRC/NRR/DSSA/SPSB DAVID SHUM NRC/NRR/DSSA/SPLB STEPHEN ALEXANDER NRC/NRR/DIPM/IPSB HUKAM GARG NRC/NRR/DE/EEIB MIKE SNODDERLY NRC/ACRS
AGENDA RISK MANAGEMENT TECHNICAL SPECIFICATIONS INITIATIVE 4b, RISK-INFORMED COMPLETION TIMES RISK MANAGEMENT GUIDANCE DOCUMENT C Risk Management Guidance (RMG) Document Comment Overview B Improving: content largely there, needs change in emphasis to support Tech Specs B Re-structure to support Tech Spec Requirements (e.g., procedure-like)
- State shall requirements, followed by implementation guidance B Larger Scope Deficiencies
- RICT Threshold of 10-5 ICDP seems high (see RAI comments 43, 13)
Implications for control of aggregate risk (e.g., ALARA concept)
- Tech Spec Operability vs PRA Functionality, (see RAI comment 19) needs to be addressed more fully in Guidance
- CCF needs to be addressed more fully in Guidance (see RAI comment 1)
- Use of Qualitative and Bounding Assessments, used to support RICTs, needs to be addressed more fully in Guidance (see RAI comment 20)
- Simplify RMG, (see RAI comment 42)
B Detailed Deficiencies (see other RAI comments); a few are mentioned below:
- Correct Flow Chart
- Every use of a RICT requires documentation
- Correct means of calculating RICT (see RAI comment 46)
- Address PRA/CRMP maintenance/updates (see RAI comment 47)
- Consistency needed: for example, RICT & TS 3.0.3 applications, uncertainty C Pilots shall be consistent with RMG C Schedule/Process C Closing Comments