ML111320624

5/12/11, Summary of Meeting with NRC and the Technical Specifications Task Force

ML111320624
Person / Time
Site:	Technical Specifications Task Force
Issue date:	06/08/2011
From:	Michelle Honcharik NRC/NRR/DPR/PSPB
To:	John Jolicoeur Division of Policy and Rulemaking
References
Download: ML111320624 (10)

Text

June 8, 2011 MEMORANDUM TO: John R. Jolicoeur, Chief Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation FROM: Michelle C. Honcharik, Senior Project Manager /RA/ by SPhilpott for Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

SUMMARY

OF THE MAY 12, 2011, U.S. NUCLEAR REGULATORY COMMISSION MEETING WITH THE TECHNICAL SPECIFICATIONS TASK FORCE On May 12, 2011, the U.S. Nuclear Regulatory Commission (NRC) staff met with the Technical Specifications (TS) Task Force (TSTF) to discuss technical issues and administrative processes related to TSTF Travelers. The meeting was held at NRC offices in One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852. A list of the meeting attendees is enclosed.

The meeting notice and agenda, dated April 20, 2011, are available in the Agencywide Documents Access and Management System (ADAMS) at Package Accession No. ML111010235.

The NRC staff and TSTF representatives discussed the topics as presented on the agenda.

These topics included: issues related to completing Revision 4 of Improved Standard TS; the status of the Travelers currently under NRC review; issues related to previously approved Travelers; and other technical issues facing the industry that are generically related to TSs.

Formal presentations were not given at this meeting; rather, the meeting was conducted in an open discussion format for each item on the agenda. For selected agenda items, the NRC staff or TSTF representatives provided handouts to facilitate discussion and/or serve as an information exchange. These handouts are listed below and are publicly available in ADAMS.

• TSTF review process data (ADAMS Accession No. ML11157A045).

• TSTF-500 discussion points (ADAMS Accession No ML111320619).

I. Summary of Development of Improved Standard TS Revision 4 A. Status of Incorporation of TSTF-493, Options A and B (TSTF)

1. Mr. Brian Mann (TSTF) stated the TSTF has typed up the affected specifications, which will be ready in early June. The files incorporated TSTF-493 with a and b pages for each specification, rather than bracketing the differences between the two options.

B. Status of Review (NRC staff)

1. Mr. Gerry Waig (NRC) commented that if the TSTF prepared pages deviate from the NRC mark-up - identify those deviations. Initial NRC staff review is complete, but we are still doing verification of changes by each section leader, hoping to be

J. Jolicoeur completed by May 23, 2011. If not completed, Mr. Waig will send over what has been reviewed so far. The NUREG revision includes TSTF-500 changes because we anticipate it being approved prior to Revision 4 issuance. TSTF-508 has been withdrawn and needs to be removed; TSTF-446 has been approved and needs to be added.

2. NRC has letter from TSTF with all T travelers.

3. Once all NRC comments are incorporated and TSTF sends mark-ups, the NRC staff will review again, and then send to Office of Administration (ADM) for processing.

ADM staff will need about a month for their review, before issuance. Once issued by ADM, Revision 4 will be posted on the NRC website.

Action item: Mr. Mann to provide list of licensees that are planning on conversions this/next year.

II. Summary of Process Issues A. NRC Completion of LIC-601 (office instruction on STS Conversions) and TSTF Update of NEI 96-06.

1. Mr. Mann explained that the TSTF is working on an update to NEI 96-06, Improved Technical Specification Conversion Guidance (ADAMS Accession No. ML070810523), because it no longer reflects the current practice. The update is targeted for issuance in late summer/early fall of 2011. The update will also include changes to be consistent with NRR Office Instruction LIC-601, Improved Technical Specification Conversion Amendment Review Procedures.

2. Mr. Robert Elliott (NRC) commented that the NRC staff is still working on preparing this new office instruction and will provide TSTF with a summary of what will be in LIC-601.

3. TSTF is not a member of NEI, so NEI designation will be dropped and reissued as a TSTF document, like other guidance documents have been when updated.

B. How to Reduce Uncertainty in Traveler Review Schedules.

1. Mr. Tony Browning (TSTF) handed out a copy of the data that the TSTF members collected for recent reviews. He explained that the TSTF members looked over recent traveler reviews, comparing target milestones and actual dates. Mr. Browning commented that they were not focusing on end-to-end timeline, but instead whether the target dates are realistic. They use the target dates provided in the acceptance letter to budget for the work. If review is protracted and goes into another year that was not originally scheduled for, then it causes problems for them in budgeting.

Overall they noted that the NRC staff is not meeting the milestone dates. The TSTF members are requesting more realistic target dates to assist them in more accurately budgeting for the reviews.

2. Another issue is where to put the technical justification. Should it be included with the TSTF traveler or submitted separately as topical report first? Whats the most efficient means of getting the documents approved? Mr. John Jolicoeur (NRC) commented that submitting the technical justification as a topical report wont necessarily speed the review (or gain in higher priority).

3. Model applications (a) Mr. Mann commented that the TSTF members have started providing a model application when they submit a traveler for review. Should they include it as part of the traveler, then the NRC staff can use RAI process to make changes to the model application?

(b) Mr. Carl Schulten (NRC) commented that this is how hes handling the review for traveler TSTF-446.

J. Jolicoeur (c) Mr. Browning commented that an advantage to this approach is that it front end loads these comments, instead of these issues being raised between the notice for comment (NFC) and notice of availability (NOA).

(d) Ms. Michelle Honcharik (NRC) suggested that the notice speak to the acceptability of the model application, but the SE would be silent. It doesnt make sense for SE to speak about model application.

4. Mr. Mann brought up that substantive technical issues are being raised between NFC and NOA. Is there something that can be improved in the process, to get more certainty in our process? The TSTF wants more certainty so that once the NFC is issued, plants can safely begin working on (and budgeting) for the change.

5. Mr. Elliott commented that most of low-hanging fruit has been completed, so the items under review now are more complex in nature and more likely to have technical issues arise. He also pointed out that the recent examples all had different circumstances surrounding those reviews, which led to the delays. This indicates that its not a simple processing issue, since theres no common cause.

6. Traveler priority.

(a) Mr. Browning commented that traveler TSTF-522 was low priority for them, but it took NRC a year to complete the acceptance review. How often does the NRC revisit the priority? He suggested that we review the priority of each traveler during the quarterly meetings.

(b) Mr. Elliott suggested that we discuss priority during monthly status calls.

(c) Ms. Honcharik offered to take the action to send the TSTF a weekly e-mail with status, so there will be more frequent communication on date changes. She will also attend ITSB branch meetings more often as suggested by Mr. Elliott.

(d) Mr. Mann commented that the TSTF will begin including priority and justification in the cover letters when submitting new travelers for review in order to aid the NRC staff in setting priority and schedules.

(e) Mr. Mann requested that the NRC send electronic copy of documents when signed out.

(f)Mr. Browning handed a list of the current priority. The TSTF will provide the NRC with an updated Traveler priority at every quarterly meeting. Priorities are expected to change as Travelers are submitted and approved. The current priority is:

(1) High Priority: TSTF-500 and TSTF-505 (2) Medium Priority: TSTF-426, TSTF-432, and TSTF-522 (3) Low Priority: TSTF-490, TSTF-510, TSTF-515, and TSTF-523 (g) Mr. Browning commented that the priority is based on industry cost benefit. Mr.

Elliott commented NRC staff agrees with priorities, except TSTF-523 would be high priority.

Action items: 1) Ms. Honcharik to e-mail any schedule changes every Friday.

2) To assist the NRC in setting review priorities, the TSTF will identify if a Traveler addresses a safety issue or regulatory concern in the cover letter.

III. Summary Active Traveler Review Status A. Discussion on TSTF-500, Regarding Interaction and How Implementation Will Be Handled with Regards to TSTF-425.

1. Mr. Waig provided a history of the TSTF-500 traveler review. The NFC was issued and NRC staff was working on the comments, when a comment came in after the comment period ended (during a meeting) regarding TSTF-425. This late comment from the TSTF then raised questions about interaction of travelers TSTF-425 and

J. Jolicoeur TSTF-500. Mr. Mann commented that the TSTF recommendation is that for plants that have TSTF-425, they would reset the surveillance requirement (SR) to the frequency specified in TSTF-500, but that they then could use TSTF-425 to change the SR frequency in the future.

2. Mr. Jack Stringfellow (TSTF) explained that the 60-month frequency was moved per TSTF-425, but the other frequencies were not moved. The two conditional SRs stay in the TS.

3. Mr. Mann asked if you could feasibly make a change, it simply relocated the frequencies.

4. Mr. Matthew McConnell (NRC) commented that the NRC staff position is that if a plant already has TSTF-425, and wants TSTF-500, theyd have to relocate the frequencies back into the TS or justify why they can keep SRs in Administrative Control program of TSTF-425.

5. Mr. Mann commented to Mr. Elliott that this is not supportable position.

6. Mr. McConnell explained that the NRC staff reviewed TSTF-500 not considering TSTF-425.

7. Mr. Andrew Howe (NRC reviewer of TSTF-425), Mr. Biff Bradley (NEI) and the TSTF members discussed the surveillance frequency control program in the NEI 04-10 process and reached the conclusion that it is unlikely that a licensee could technical justify an extension to the 60-month Frequency under the NEI 04-10 process.

8. Mr. Andrew Howe (NRC) commented that the first step in process is determining commitments. If the change that a licensee wants to make conflicts with a commitment then they have to justify the change.

9. Mr. Stringfellow explained that the commitment change process is not the same as a change made via the 10 CFR 50.59 process. The commitment change process requires that licensee has to go back to the NRC staff for any changes. NEI guidance document, NEI 99-04, which was endorsed by NRC staff, details the process on how commitments are handled.

10. Mr. Mann brought up the NRC handout (ADAMS Accession No. ML111320619) and is asking for an example to help in their understanding.

11. Mr. Bradley commented that they will see what they can find out to help.

12. Mr. Mann asked about the status of the TSTF-500 review.

13. Mr. McConnell answered that in light of todays discussion the NRC has to re-review its SE position on the SR frequencies to see if it needs to be strengthened.

B. Discussion of inconsistencies between TSTF-426 and WCAP.

1. Mr. Schulten commented that the NRC staff is on track to meet July 6, 2011, RAI date.

C. TSTF-432, Target for NFC is end of August.

D. TSTF-490, Acceptance letter in concurrence.

E. TSTF-505, revision to address comments went in last week. Ms. Bucholtz stated that she has the comments already (only looked through B&W spec so far), and has noticed some inconsistency on bracketing. She will send any comments she has so far by next week (before leaving on travel.) Model SE is written and with TS branch for review.

F. TSTF-510, NFC is with OGC for review.

G. TSTF-515, on hold awaiting completion of supporting topical report review.

Mr. Browning commented that the TSTF may withdrawal instead of revising traveler.

H. TSTF-522, per acceptance letter RAIs due June 2, 2011. Mr. Hamm stated that he will not have any RAIs, but the technical staff may have some. RAI date revised to end of June.

J. Jolicoeur I. TSTF-523, NRC staff is drafting a written position, to be issued before the end of the month.

IV. Issues with Previously Approved Travelers A. Status of NRC Letter to Resolve Issues with TSTF-363, -408, and -419.

1. Ms. Honcharik commented that the letter has been through OGC review, but that we cannot issue it yet because we are awaiting OMB CRA review. Target date is end of August. Mr. Mann commented that the TSTF will prepare a traveler to be included in the revised NUREG, but are waiting on the letter to be issued first.

B. TSTF-501, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control

1. Status of NRC revision to the NOA. Ms. Bucholtz commented that shes revised the models to reflect each/a plant and Day Tank issues. Ms. Bucholtz commented that the Palisades LAR is through the technical branches, but not OGC yet. She commented that the Day Tank specification is in all 5 NUREGs, so in order to make that change the TSTF will need to submit a revision to TSTF-501. TSTF members will have to consider it and get back to NRC. Ms. Bucholtz asked if the TSTF members have considered how the recent Japan events, may impact this traveler.

The TSTF members agreed to continue with update to model, if changes are needed due to lessons learned from the Japan events, then theyll pursue those changes at that time.

V. New Travelers to be Submitted Mr. Mann briefly reviewed the content of upcoming traveler submittals. All are targeted for submission by the end of the summer.

A. TSTF-531, "Elimination of Specification 3.8.1, Required Actions B.3.1 and B.3.2" (Same as agenda item VII.D.)

1. Mr. Mann stated that the TSTF recognizes this will be an uphill battle and that they are trying to fix problems with specification interpretation. Mr. Elliott commented that fixing the specification would be fine, but eliminating it is different. He strongly recommended a pre-submittal meeting to include NRC electrical experts.

B. TSTF-XXX, "Expand Definition of Pressure Boundary Leakage" C. TSTF-529, "Clarify Use and Application Rules" address issues with use and application rules.

1. Mr. Elliott asked if this is a clarification based on NRC staff positions from prior meetings? Mr. Mann answered yes.

D. TSTF-XXX, BWR shutdown margin definition.

VI. Technical Issues A. Status of NRC Actions Related to SR 3.0.3 Application to the IST Program.

1. Mr. Elliott commented that the NRC staff will be going to LT with a proposed enforcement guidance memorandum (EGM). The EGM would have to be approved by mid-June, because its connected to a RIS.

B. Status of TSTF-493 Implementation Guidance.

1. The TSTF is preparing a proposed implementation guide using input from NRC and NEI. NRC input targeted for early June (was delayed due to higher priority items).

The TSTF plans to provide implementation guidance for both options for use by end of year. Mr. Stringfellow commented that if Kewanee doesnt come in as the pilot plant - then Vogtle will.

C. Clarify What Constitutes an Operation with the Potential to Drain the Reactor Vessel (OPDRV).

1. Mr. Elliott explained that due to the Clinton violation, the NRC has delved into this issue and its become clear that the interpretation of what constitutes an OPDRV has

J. Jolicoeur changed over time. NRC is concerned that activities that were OPDRVs are no longer considered to apply. Not clear that any activity would be considered an OPDRV under current industry approach. The industry appears to have revised the term to include only "credible" operations with the potential to drain the reactor vessel. Mr. Browning commented that at his plant the definition of an OPDRV is essentially a list of items that are not OPDRVs.

2. The NRC recommended that any plants developing an LAR to address the OPDRV definition should continue to pursue that avenue.

3. The OPDRV term is known to have been in STS revisions issued post-TMI (fall 1980), but the NRC staff is not sure if theres a connection. The NRC is trying to determine the original basis of the requirement.

4. The TSTF agreed to research the issue also.

5. BWROG will be discussing at its meeting on May 17-19, 2011, and will get back to the NRC.

Future meetings for 2011 are tentatively planned for Wednesday, August 10, and Thursday, November 10.

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: ML111320618 Meeting summary: ML111320624 Meeting notice and agenda: Package ML111010235 Meeting handouts: ML111320619 and ML11157A045 OFFICE PLPB/PM PLPB/LA PLPB/BC PLPB/PM NAME MHoncharik DBaxley JJolicoeur MHoncharik (HCruz for)

DATE 6/6/11 6/8/11 6/8/11 6/8/11 DISTRIBUTION for Summary of June 8, 2011, meeting with TSTF:

PUBLIC PLPB Reading File RidsNrrDpr RidsNrrDprPlpb RidsNrrLADBaxley Robert Elliott RidsNrrPMMHoncharik RidsNrrDirsItsb Gerald Waig Dayna Dority Matthew Hamm Kristy Bucholtz Theodore Tjader Carl Schulten Shaun Anderson Andrew Howe Melana Singletary Craig Harbuck Khadijah Hemphill Matthew McConnell Prem Sahay Robert Wolfgang EXTERNAL DISTRIBUTION:

ngchapma@bechtel.com jbergman@curtisswright.com brianm@excelservices.com tony.browning@nexteraenergy.com njstring@southernco.com andracjd@westinghouse.com reb@nei.org

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 the U.S. Nuclear Regulatory Commission (NRC) and Technical Specification Task Force (TSTF) Meeting May 12, 2011 Name Organization Michelle Honcharik NRC/Office of Nuclear Reactor Regulation (NRR)/Division of Policy and Rulemaking (DPR)

John Jolicoeur NRC/NRR/DPR Robert Elliott NRC/NRR/Division of Inspection and Regional Support (DIRS)

Carl Schulten NRC/NRR/DIRS Khadijah Hemphill NRC/NRR/DIRS Gerald Waig NRC/NRR/DIRS Matthew Hamm NRC/NRR/DIRS Kristy Bucholtz NRC/NRR/DIRS Shaun Anderson NRC/NRR/DIRS Melana Singletary NRC/NRR/DIRS Andrew Howe NRC/NRR/Division of Risk Assessment Matthew McConnell NRC/NRR/Division of Engineering (DE)

Prem Sahay NRC/NRR/DE Robert Wolfgang NRC/NRR/Division of Component Integrity Dayna Dority NRC/Office of New Reactors (NRO)

Biff Bradley Nuclear Energy Institute Jana Bergman Scientech Jim Adracheck Westinghouse Tony Browning TSTF Brian Mann TSTF Jack Stringfellow TSTF

• William Steelman TSTF

• Participated via teleconference.

ENCLOSURE