ML060300235

Summary of Meeting with the Risk-Informed Technical Specification Task Force

ML060300235
Person / Time
Issue date:	01/26/2006
From:	Tjader T NRC/NRR/ADRO/DIRS/ITSB
To:	Bradley B Nuclear Energy Institute
Tjader T, 415-1187
References
Download: ML060300235 (11)

Text

January 26, 2006 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708

SUMMARY

OF MEETING ON JANUARY 19, 2006, 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 January 19, 2006. Since the last meeting in August 2005, the Risk Management Technical Specifications (RMTS) Initiative 1 TSTF-423 (Modified End States for Boiling Water Reactor Plants) has been noticed in the Federal Register requesting public comment, in preparation for approval via the Consolidate Line Item Improvement Process.

Sincerely,

/RA/

T. R. Tjader, Senior Reactor Engineer Technical Specifications Branch Division of Inspection & Regional (DIRS/ADRO)

Office of Nuclear Reactor Regulation

Enclosures:

1. Meeting Summary

2. Attendance List

3. Agenda

4. RITSTF Initiative Status cc w/encl: See attached page

ML060300235 DOCUMENT NAME: E:\Filenet\ML060300235.wpd OFFICE ITSB:DIRS:ADRO SC:ITSB:DIRS:ADRO NAME TRTjader THBoyce DATE 1/26/06 1/26/06 Letter to Biff Bradley from T. Tjader dated January 26, 2006

SUMMARY

OF MEETING ON JANUARY 19, 2006, WITH THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE DISTRIBUTION:

ADAMS PUBLIC TSS R/F TSS Staff BABoger (RidsNrrAdro)

BWSheron (RidsNrrAdes)

GMHolahan) (RidsNrrAdra)

JELyons/MDTschiltz (RidsNrrAdraDra)

MJCase/PLHiland (RidsNrrAdroDirs)

THBoyce (RidsNrrAdroDirsItsb)

MPRubin (RidsNrrAdraDraAplb)

OGC (RidsOgcRp)

ACRS/ACNW (RidsAcrsAcnwMailCenter)

AJHowe (AJH1)

NSaltos (NTS)

WDReckley (WDR)

FMReinhart (FMR)

DGHarrison (DGH)

CKDoutt (CKD)]

DFThatcher (DFT)

SDAlexander (SDA)

PFPrescott (PFP)

MDrouin (MXD)

MCThadani (MCT)

GWMorris (GWM2)

YGHsii (YGH)

DHShum (DHS)

GWParry (GWP)

HCGarg (HCG)

MAStutzkie (MAS7)

DHJaffe (DHJ)

JAVail (JAV)

ABWang (ABW)

BMPham (BMP)

JGKramer (JGK)

NLSalgado (NLS)

LAMrowca (LXM4)

GSShukla (GSS)

SPWall (SPW)

MLWohl (MLW1)

METonacci (MET)

BKVaidya (BKV)

JGLamb (JGL1)

Letter to Mr. Biff Bradley from T.J. Tjader dated: January 26, 2006

SUMMARY

OF MEETING ON JANUARY 19, 2006, WITH THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE cc via e-mail:

Mr. Tony Pietrangelo Nuclear Energy Institute Mr. Gabe Salamon arp@nei.org PSEG Nuclear gabor.salamon@nmcco.com Mr. Biff Bradley Nuclear Energy Institute Mr. Glenn Stewart reb@nei.org Exelon glenn.stewart@exeloncorp.com Mr. Mike Schoppman Nuclear Energy Institute Ms. Nancy Chapman mas@nei.org SERCH/Bechtel ngchampa@bechtel.com Mr. Alan Hackerott, Chairman Omaha Public Power District Mr. Fred Emerson hhackerott@oppd.com General Electric Nuclear Energy frederick.emerson@ge.com Mr. Ray Schneider Westinghouse Electric Company Mr. Michael S. Kitlan, Jr.

raymond.e.schneider@us.westinghouse.co Duke Energy Corporation m mskitlan@duke-energy.com Mr. Jim Kenny Mr. Stanley Levinson Pennsylvania Power & Light Company Framatone ANP jimkenny@pploweb.com stanley.levinson@framatone-anp.com Mr. James Andrachek Mr, Scott Head Westinghouse Electric Company STP Andracjd@westinghouse.com smhead@stpegs.com Mr. Jack Stringfellow Mr. Rick Grantom Southern Nuclear Operating Company STP njstring@southernco.com smhead@stpegs.com Mr. John Gaertner Mr. Wayne Harrison EPRI STP jgaertner@erpi.com awharrison@stpegs.com Mr. Frank Rahn Mr. Donald Hoffman EPRI EXCEL Services Corporation frahn@epri.com donaldh@excelservices.com

Mr. J. E. Rhoads Mr. Steven Dolley Energy Northwest Platts jerhods@energynorthwest.com stevendolley@platts.com Ms. Deann Raleigh Mr. Gary Chung Scientech SCE-SONGS draleigh@scientech.com gary.chung@songs.sce.com Mr. Stephen Hess EPRI shess@epri.com Mr. Jerry Andre Westinghouse Electric Company Adykes@absconsulting.com Mr. Eugene Kelly Exelon eugene.kelly@exeloncorp.com Mr. Andrew Dykes ABSC Adykes@absconsulting.com Mr. Courtney Smyth PSEG Nuclear LLC courtneysmyth@pseg.com

SUMMARY

OF THE JANUARY 19, 2006, 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 January 19, 2006, from 9:00 a.m. to 12:25 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, in the order in which they were discussed.

Initiative 1, TS Actions End States Modifications: The CE TSTF-422 notice of availability for licensee adoption was published in the Federal Register (70 FR 38729, July 5, 2005), as part of the Consolidated Line Item Improvement Process (CLIIP). The BWR TSTF-423 SE was published in the Federal Register, requesting public comment, as part of CLIIP (70 FR 74037, December 14, 2005). Comments were received on January 13, 2006. The staff is preparing the B&W Topical Report SE. The WOG submitted its Topical Report on September 9, 2005.

Next Action: The BWR TSTF-423 Notice of Availability will be published after comments have been dispositioned, by the end of March 2006. The B&W Topical Report will be approved soon thereafter.

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 submitted an Initiative 5b methodology document in February 2005. The staff provided RAIs on Limericks proposed pilot plant license amendment and the Initiative 5b methodology. The staff and industry met to discuss the RAIs. A revised methodology document was submitted on December 20, 2005. Next Action: The licensee will provide RAI responses in January 2006. The staff will then conduct a final review of the RAI responses, the methodology document, and TSTF-425. A staff site visit will then be conducted to confirm Limerick PRA acceptability for the Initiative 5 application.

Initiative 4b, Risk Informed CTs/AOTs: The NRC staff met with South Texas Project (STP) representatives on December 14 & 15, 2005, to discuss their pilot proposal for RMTS Initiative 4b. STP RAI issues have been resolved. San Onofre (SONGS 1 & 2) is considering being a full plant Standard technical Specification pilot plant. Next Action: Industry will submit a revised Risk Management Guidance document early in February 2006. The industry and staff will meet again about three weeks after receipt of the RMG document submittal to resolve final issues. The staff will conduct site visits to the pilot plants to confirm PRA, CRMP Tool, and process acceptability for the Initiative 4b application. The industry will provide an updated CE TSTF-424. The staff will be developing a TI for inspection guidance.

Initiative 4a, CT/AOT Extensions: As written TSTF- 468, Declare Systems Inoperable or Distribution Panel in Lieu of Technical Specification (TS) 3.8.9," is an Initiative 4a CT extension submittal. As such, it lacks adequate justification and the staff would like to see it routed through the RITSTF. The industry noted that it was in reality a deterministic based change. As Enclosure 1

a deterministic TSTF it needs to be reworked; the justification revised and the TS restructured.

The staff intends to reject TSTF-468 as it currently exists.

Generic RG 1.177 CT/AOT extension submittals were also discussed. The staff noted that generic topical reports supporting multiple CT/AOT extensions frequently lacking Tier 2 configuration constraints and compensatory actions. In addition, multiple CT/AOT extension requests need to consider: the potential risk of multiple system inoperabilities either through extensive Tier 2 configuration constraints or in an Initiative 4b manner; aggregate risk must be taken into account; and, external events must be addressed. The North Anna fluid systems completion time extension license amendment request has been found lacking in these areas.

The WCAP-15791 on PCIV CT extensions lacks a Tier 3 LERF methodology/calculation, which will have to be provided on a plant specific basis. 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.

+Initiative 6, Modification of LCO 3.0.3 Actions and Completion Times: RAI issues have been resolved for CE TSTF-426 and its associated implementation guidance. Next Action: The staff will publish the TSTF-426 SE, model license amendment, and request for public comment in the Federal Register by the end of March 2005, as part of the process to make TSTF-426 available via CLIIP.

Initiative 7, Non-TS support system impact on TS operability determinations: The staff has found the industry response to staff comments on TSTF-427 on Hazards Barrier Inoperability and its associated implementation guidance acceptable. Next Action: Industry will update TSTF-427. The staff will prepare the SE, model license amendment, and request for public comment for publication in the Federal Register Notice (FRN) by the end of March 2006, as part of the process to make TSTF-427 available via CLIIP.

Initiative 2, Missed Surveillance Requirements (SR), SR 3.0.3: The staff brought to industries attention a mis-application of SR 3.0.3, in that a licensee applied SR 3.0.3 to missed post maintenance testing (PMT). To apply SR 3.0.3 a licensee must not have any reason to believe that the associated equipment may be inoperable; there is no reason to doubt the SR, if conducted, would pass. In general, the performance of maintenance does not provide the requisite level of confidence that the SR would pass if performed. Industry agreed, and volunteered to revise their implementation guidance to make it clear that SR 3.0.3 is not to be utilized on missed PMT.

The next NRC staff/NEI RITSTF meeting is scheduled for May 25, 2006, at the NRC Headquarters.

NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE ATTENDANCE LIST JANUARY 19, 2006 NAME AFFILIATION BIFF BRADLEY NUCLEAR ENERGY INSTITUTE GARY CHUNG SONGS/RITSTF JACK STRINGFELLOW SNC SCOTT HEAD STP NOC WAYNE HARRISON STP NOC RICK GRANTOM STP NOC ALAN HACKEROTT OPPD DON HOFFMAN RITSTF/EXCEL SERVICES RAY SCHNEIDER WEC MIKE KITLAN DUKE ENERGY STEPHEN HESS EPRI JIM ANDRACHEK WESTINGHOUSE/WOG STANLEY LEVINSON AREVA DEANN RALEIGH SCIENTECH NANCY CHAPMAN SERCH/BECHTEL PAT HILAND NRC/NRR/ADRO/DIRS TOM BOYCE NRC/NRR/ADRO/DIRS/ITSB BOB TJADER NRC/NRR/ADRO/DIRS/ITSB ROBERT CLARK NRC/NRR/ADRO/DIRS/ITSB MARK TONACCI NRC/NRR/ADRO/DIRS/IPAB LYNN MROWCA NRC/NRR/ADRA/DRA/APLB ANDREW HOWE NRC/NRR/ADRA/DRA/APLB STEVE ALEXANDER NRC/NRR/ADRA/DRA/APOB JAMES VAIL NRC/NRR/ADRA/DRA/APOB MARTY STUTZKE NRC/NRR/ADRA/DRA/APLA CLIFF DOUTT NRC/NRR/ADRA/DRA/APLA DAVID SHUM NRC/NRR/ADES/DSS/SBPB Enclosure 2

AGENDA TSS/NEI RITSTF MEETING JANUARY 19, 2006 9:00 A.M. - 12:30 P.M.

0-13 B4 N Status of Initiatives N Initiative 1, End States BWROG TSTF-423 Status B&W Topical W Topical N Initiative 5b, SR Frequency Evaluation Methodology/SR Frequency TS Program Limerick Pilot Status SR Frequency TS Program/Methodology N Public Questions and Discussion N Initiative 4b, Risk-Informed Completion Times RMTS Risk Management Guidance Document STP Pilot FCS Pilot, CE Pilot, TSTF-424 N Initiative 4a, Generic RG 1.177 Completion Time Extensions TSTF-468 4a Submittal deficiencies, including CIV LERF Tier 3 Considerations N Initiative 6, LCO 3.0.3 Actions and Completion Times CEOG TSTF-426 Status N Public Questions and Discussion N Initiative 7, Non-TS Support System Inoperability Impact on TS System & TSTF-372 TSTF-427 Status N Initiative 8, Remove/Relocate non-safety & non-risk significant systems from TS N Initiative 2, Missed Surveillances Application: Post Maintenance Testing vs Surveillance Requirements N Public Questions and Discussion N Schedule Next Meeting N Closing Comments Enclosure 3