ML110140850

Summary of the January 12, 2011, Meeting with the TSTF Traveler TSTF-523

ML110140850
Person / Time
Site:	Technical Specifications Task Force
Issue date:	02/14/2011
From:	Michelle Honcharik Division of Policy and Rulemaking
To:	Melissa Ash Division of Policy and Rulemaking
References
Download: ML110140850 (6)

Text

February 14, 2011 MEMORANDUM TO: Melissa S. Ash, Acting Chief Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation FROM: Michelle C. Honcharik, Senior Project Manager /RA/

Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

SUMMARY

OF THE JANUARY 12, 2011, U.S. NUCLEAR REGULATORY COMMISSION (NRC) MEETING WITH THE TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) REGARDING TRAVELER TSTF-523 On January 12, 2011, the NRC staff met with members of the TSTF to discuss issues related to the acceptance review of Traveler TSTF-523, Revision 0, "Generic Letter [GL] 2008-01, Managing Gas Accumulation." The meeting was held at NRC offices in One White Flint North, 11555 Rockville Pike, Room O-7B4, Rockville, Maryland 20852. A list of the meeting attendees is enclosed. The meeting notice, dated December 21, 2010, and the meeting slides are available in the Agencywide Documents Access and Management System (ADAMS) at Accession Nos. ML103540116 and ML110140055.

Mr. Jack Stringfellow of the TSTF gave a presentation detailing why the industry feels that Traveler TSTF-523 is the appropriate regulatory mechanism to capture the requirements of GL 200801, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems." The three main elements of the traveler are:

• Expand the limiting condition for operation (LCO) Bases describing gas management as an important aspect of system operability,

• Add a Gas Management Program (GMP) to the Final Safety Analysis Report (FSAR) which describes the ongoing aspects of gas management, and

• Replace the existing surveillance requirements (SRs) with the GMP requirements.

The TSTF discussed the history and gave examples of other GLs that addressed operability and stated that the presence of the existing SRs should not result in GL 200801 being treated differently than the other GLs regarding operability. The TSTF also gave examples of cases where the NRC has removed SRs from the Technical Specifications (TSs). Mr. Rob Elliott of the NRC commented that the example of GL 94-01 was an instance where the existing SRs were detrimental to safety, which is not the case with the SRs on venting gas. Mr. Elliott stated that the gas management SRs are not adequate, but are not detrimental to safety.

The TSTF mentioned that TIA 2008-03 is a precedent for relocation and removing SRs from TSs. The nexus of TIA 2008-03 is back to operability. TIA 2008-03 is available in the ADAMS at Accession No. ML082560209.

M. Ash The TSTF described what the on-going requirements are for gas management and questioned why such requirements would have to be in the TS. The TSTF believes it would be contrary to the NRC Final Policy Statement for Technical Specification Improvements for Nuclear Power Plants. The final policy states, since 1969 there has been a trend towards including in technical specifications not only those requirements derived from the analyses and evaluation included in the plant's safety analysis report but also essentially all other NRC requirements governing the operation of nuclear power plants. In the Commission's view, this has diverted both NRC staff and licensee attention from the more important requirements in these documents to the extent that it has resulted in an adverse but unquantifiable impact on safety.

Gas management is tied to the operability of the LCOs. Gas management is not of controlling importance, and there is not a specific safety analysis tied to gas management.

The TSTF presented justification for why they feel that placing the GMP in the FSAR will provide durable guidance. This includes the fact that the GMP would be evaluated under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.59. Mr. Warren Lyon of the NRC commented that 10 CFR 50.59 reviews are not always black and white and can take a lot of resources.

Mr. Stringfellow of the TSTF replied that yes, hes pointing out the rigor with which these reviews are performed. Mr. Elliott of the NRC commented that it would be hard for a licensee to make a radical departure in the GMP without NRC approval.

Mr. Matthew Hamm of the NRC commented that he is still at a loss for the justification for removing the SRs on gas management from the TSs. Mr. Elliott of the NRC stated that the NRC staff will review the original submittal and the information presented during todays meeting. The NRC staff will think it over and after reaching agreement internally, will contact the TSTF regarding the acceptance of TSTF-523.

Members of the public whom participated via teleconference are listed with the meeting attendees. No public meeting feedback forms were received.

Please direct any inquiries to me at 301-415-1774 or at Michelle.Honcharik@nrc.gov.

Project No. 753

Enclosure:

List of Attendees cc w/encl: See next page

Package: ML110350388 Meeting notice ML103540116, Meeting summary ML110140850, Meeting slides ML110140055 OFFICE PLPB/PM PLPB/LA ITSB/BC PLPB/ABC PLPB/PM NAME MHoncharik DBaxley RElliott MAsh MHoncharik DATE 2/9/11 2/10/11 2/10/11 2/11/11 2/14/11 DISTRIBUTION for meeting summary dated February 14, 2011 :

PUBLIC PLPB Reading File RidsNrrAdro Resource RidsNrrDpr Resource RidsOgcMailCenter Resource RidsOpaMail Resource RidsAcrsAcnwMailCenter Resource RidsNrrPMMHoncharik RidsNrrLADBaxley RidsNrrPlpbResource RidsNrrItsbResource Melissa Ash PMNS Resource Gall, Jennifer Lyon, Warren Schulten, Carl Hamm, Matthew Ulses, Anthony Bowman, Eric EXTERNAL DISTRIBUTION:

brianm@excelservices.com kjse@pge.com Wendi.Croft@exeloncorp.com kepeter@wcnoc.com DRaleigh@CURTISSWRIGHT.com ngchapma@bechtel.com

Technical Specifications Task Force Project No. 753 cc:

Technical Specifications Task Force 11921 Rockville Pike Suite 100 Rockville, MD 20852 Attention: Donald R. Hoffman E-mail: donaldh@excelservices.com Norman J. (Jack) Stringfellow Southern Nuclear Operating Company P.O. Box 1295 Birmingham, AL 35201-1295 E-mail: string@southernco.com Roy A. (Tony) Browning Duane Arnold Energy Center 3277 DAEC Rd.

PSC/Licensing Palo, IA 52324-9785 E-mail: tony.browning@nexteraenergy.com William J. (Billy) Steelman Entergy Waterford 3 17265 River Road Hwy 18 Killona, LA 70057 E-mail: wsteelm@energy.com Wendy E. Croft Exelon Nuclear 200 Exelon Way, Suite 340 Kennett Square, PA 19348 E-mail: wendi.croft@exeloncorp.com Brian D. Mann EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 E-mail: brianm@excelservices.com

Attendees at NRC/TSTF Meeting January 12, 2011 Name Organization

• Michelle Honcharik NRC/Office of Nuclear Reactor Regulation (NRR)/Division of Policy and Rulemaking (DPR)

Melissa Ash NRC/NRR/DPR Rob Elliott NRC/NRR/Division of Inspection and Regional Support (DIRS)

Carl Schulten NRCNRR/DIRS Jennifer Gall NRC/NRR/Division of Safety Systems (DSS)

• Warren Lyon NRC/NRR/DSS Eric Bowman NRC/NRR/DPR Matthew Hamm NRC/NRR/DIRS Wendi Croft TSTF Jack Stringfellow TSTF Les England TSTF

• Henry Hegrat FirstEnergy

• Ken Peterson STARS Jim Andrachek TSTF

• Nancy G. Chapman Bechtel Power Corporation

• Deann Raleigh Scientech Ken Schrader TSTF

• Participated via teleconference.

ENCLOSURE