ML12303A040

Summary of October 17, 2012, Meeting with the BWROG Members of the TSTF Pre-Submittal of Reactor Pressure Vessel (RPV) Water Inventory Traveler

ML12303A040
Person / Time
Site:	Technical Specifications Task Force
Issue date:	12/04/2012
From:	Michelle Honcharik Licensing Processes Branch (DPR)
To:	Stuchell S Licensing Processes Branch (DPR)
Honcharik M
Shared Package
ML12303A037	List: ML12303A040
References
Download: ML12303A040 (5)

Text

December 4, 2012 MEMORANDUM TO: Sheldon D. Stuchell, Acting Chief Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation FROM: Michelle C. Honcharik, Sr. Project Manager /RA/

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

SUMMARY

OF OCTOBER 17, 2012, MEETING WITH THE BOILING WATER REACTOR OWNERS GROUP (BWROG) MEMBERS OF THE TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) RE: PRE-SUBMITTAL OF REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY TRAVELER Mr. Tony Browning (TSTF) reviewed the background of the current technical specification (TS) requirements related to operations with the potential to drain the reactor vessel (OPDRVs). He discussed how there is no formal definition of an OPDRV in the TS, that the safety basis is unclear, and that there is a one size fits all approach. Enforcement Guidance Memorandum (EGM) 11-003, which expires on December 31, 2013, contains the U.S. Nuclear Regulatory Commissions (NRCs) plain language definition of OPDRV and provides enforcement discretion for compliance with TSs that establish requirements for OPDRVs. The EGM set the NRCs expectation for industry to have a final resolution on a graded approach to OPDRVs. The TSTF Traveler will be that final resolution.

Mr. Browning detailed the key decisions that the TSTF made in developing the TS changes.

The TSTF decided to replace the term OPDRV with the more accurate conceptual term, RPV water level inventory control. The TSTF proposed to pull all the requirements related to OPDRV (which are currently scattered through the TS) and put them into a TS entitled RPV Water Level Inventory Control. The TSTF proposes to place the new TS into the existing limiting condition for operation (LCO) 3.5.2, ECCS [emergency core cooling system] Shutdown, which replaces the current LCO 3.5.2 with the new TS requirement.

Mr. Browning went on to explain the key assumptions the TSTF members used when developing the new RPV water level inventory control TS: an OPDRV is not an accident and should be treated similar to an abnormal operational occurrence in TS; the goal of the proposed TS is to protect the safety limit; the new TS does not account for any additional single failure/loss-of-offsite power/natural hazard occurrences; common mode failures are considered; the new TS will meet Criterion 4 of 50.36(c)(2)(ii) to Title 10 of the Code of Federal Regulations be based upon operating experience; and the new TS will follow the shutdown risk management guidelines of NUMARC 91-06.

S. Stuchell Mr. Browning explained that when developing the new TS requirements, the TSTF members re-evaluated EGM 11-003 requirements. The proposed approach the TSTF used centers around the EGM 11-003 drain down time (i.e., hours) in lieu of leakage rates (i.e., gallons per minute) or penetration size (i.e., inches). The reference point used for this approach is the top of active fuel in lieu of the RPV flange. Mr. Browning then discussed the draft of the new TS, which would be numbered 3.5.2, replacing the ECCS Shutdown specification and entitled RPV Water Level Inventory Control. The drain down time would be calculated by using either the worst case drain path or by adding up multiple drain paths for common cause leaks.

Mr. Robert Elliott (NRC) commented that additional NRC technical staff will need to be involved.

Other NRC comments included the NRC staffs concern with the amount and level of detail to be included in the TS Bases. The NRC staff also questioned how they would be able to inspect or enforce these new TS requirements, with so much of the detail in the TS Bases. One recommendation was to have definitions of protected and unprotected in the Definitions section instead of the TS Bases.

The next steps agreed upon during the meeting are: The TSTF will prepare a draft of the Traveler, including proposed TS and TS Bases changes soon. A follow-up pre-submittal meeting will be scheduled sometime in late January 2013. All appropriate NRC technical branches will be invited to the next meeting as well as the Office of the Chief Financial Officer.

The TSTF plans to submit the Traveler for review in February 2013.

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

ML12303A040; Package ML12303A037; Notice ML12270A261 NRR-106 OFFICE PLPB/PM PLPB/LA PLPB/BC (A) PLPB/PM NAME MHoncharik DBaxley SStuchell MHoncharik DATE 11/27/2012 11/20/2012 11/29/2012 12/4/2012 LIST OF ATTENDEES AT MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) AND THE BOILING WATER REACTOR OWNERS GROUP (BWROG)

MEMBERS OF THE TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) REGARDING THE PRE-SUBMITTAL OF REACTOR PRESSURE VESSEL WATER INVENTORY TRAVELER October 17, 2012 Name Organization Michelle Honcharik NRC/Office of Nuclear Reactor Regulation (NRR)/Division of Policy and Rulemaking (DPR)/Licensing Processes Branch Robert Elliott NRC/NRR/Division of Safety Systems (DSS)/Technical Specifications Branch (STSB)

Kristy Bucholtz NRC/NRR/DSS/STSB Carl Schulten NRC/NRR/DSS/STSB Warren Lyon NRC/NRR/DSS/Reactor Systems Branch (SRXB)

Harold Walker NRC/NRR/DSS/Containment Ventilation Branch (SCVB)

Shaun Anderson NRC/NRR/DSS/STSB Theodore (Bob) Tjader NRC/Office of New Reactors (NRO)/Division of Safety Systems and Risk Assessment (DSRA),

Balance of Plant and Technical Specifications Branch (BPTS)

Richard Plasse NRC/DSS/Balance of Plant Branch (SBPB)

Tony Browning BWROG/TSTF Brian Mann TSTF Mitchell Matthews BWROG Rick Loeffler BWROG/TSTF Richard Russin BWROG Bradley Ferrell First Energy ENCLOSURE

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 Robert A. Slough Comanche Peak Nuclear Power Plant P. O. Box 1002, Mail Code A08 Glen Rose, Texas 76043 E-mail: robert.slough@luminant.com Roy A. (Tony) Browning Duane Arnold Energy Center 3277 DAEC Rd.

PSC/Licensing Palo, IA 52324-9785 E-mail: Tony.Browning@nexteraenergy.com Wendy E. Croft Exelon Nuclear 200 Exelon Way, Suite 340 Kennett Square, PA 19348 E-mail: Wendi.Croft@exeloncorp.com Otto W. Gustafson Entergy Nuclear Operations, Inc.

Palisades Nuclear Power Plant 27780 Blue Star Memorial Highway Covert, MI 49043 E-mail: ogustaf@entergy.com Brian D. Mann EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 E-mail: brianm@excelservices.com