ML13169A365

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Meeting Handout - SF-SSF Definition Presentation
ML13169A365
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Site: Technical Specifications Task Force
Issue date: 10/18/2012
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Technical Specifications Task Force
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Division of Policy and Rulemaking
Honcharik M
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ML12303A038 List:
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Technical Specifications Task Force TSTF A Joint Owners Group Activity Proposed Changes to the Part 9900 Inspection Manual Chapter, "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety" NRC / TSTF Public Workshop October 18, 2012 1

Technical Specifications Task Force TSTF A Joint Owners Group Activity Overview

  • Proposed Changes to the Definitions of Specified Function and Specified Safety Function

- History of the Operability Determination Process (ODP) Guidance

- Problems with the Current Definition of "Specified Function / Specified Safety Function"

- Discussion of Proposed Definitions

  • Proposed Changes to Appendices C.1 and C.2 to Clarify the Relationship Between General Design Criteria (GDC) and Technical Specifications Operability
  • Examples 2

Technical Specifications Task Force TSTF A Joint Owners Group Activity Proposed Changes to the Definitions of Specified Function and Specified Safety Function 3

Technical Specifications Task Force TSTF A Joint Owners Group Activity History of the ODP Guidance

  • On November 7, 1991, the NRC issued Generic Letter 91-18, "Information to Licensees Regarding two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability."

- The GL announced two new NRC Inspection Manual Part 9900 chapters:

  • Resolution of Degraded and Nonconforming Conditions, and
  • Operable/Operability: Ensuring the Functional Capability of a System or Component
  • On October 8, 1997, the NRC issued Revision 1 to GL 91-18.

- The section "Resolution of Degraded and Nonconforming Conditions" was revised. The guidance on operability was not affected.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity History of the ODP Guidance

  • On August 14, 2003, the NRC held a public workshop to discuss development of proposed revisions to the Part 9900 guidance announced in GL 91-18.
  • On August 3, 2004, the NRC published for comment in the Federal Register (69FR46599) a draft Regulatory Issue Summary (RIS) titled "Draft Revision to NRC Inspection Manual Chapter 9900, "Technical Guidance, Operability Determinations and Resolution of Nonconformances of Structures, Systems, and Components" (Regulatory Issue Summary 2004-XX)."

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Technical Specifications Task Force TSTF A Joint Owners Group Activity History of the ODP Guidance

  • The revisions to the Part 9900 Manual Chapter were to:

- Reflect relevant changes in the NRC regulatory process and regulations contained in 10 CFR 50.59, Changes, Tests, and Experiments, and 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and

- Clarify the guidance for selected issues based on operating experience, and

- Consolidate and streamline the guidance in two previously separate Part 9900 sections

  • The NRC held a public workshop on the draft RIS on August 25, 2004.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity History of the ODP Guidance

  • The NRC received extensive comments, both at the August 25 workshop and in writing.
  • The NRC and industry agreed to a series of workshops to resolve the comments.

- NEI formed the ODP Task Force to represent the industry at the workshops.

- The NRC formed a team with Technical Specification Branch, Project Management, and Regional participation 7

Technical Specifications Task Force TSTF A Joint Owners Group Activity History of the ODP Guidance

  • The NRC and the ODP Task Force met on:

- February 27, 2005 (Summary at ADAMS ML050740002)

- April 19, 2005 (Summary at ADAMS ML051260445)

- April 25, 2005 (Summary at ADAMS ML051300077)

- May 10-12, 2005 (Summary at ADAMS ML051520373)

  • At the May meeting, the NRC and ODP Task Force finalized a draft that was attached to the meeting summary.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity History of the ODP Guidance

  • Following the May meeting, the NRC staff pursued internal approval of the guidance.

- This resulted in many changes to the draft guidance which were not shared with the ODP Task Force.

  • The final guidance was announced in RIS 2005-20 on September 26, 2005.
  • NEI held an ODP workshop on November 9, 2005 with NRC participation.

- The ODP Task Force pointed out the error in the definition of "specified function/specified safety function."

  • The NRC conducted internal training for NRR and the Regions in November and December 2005.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity History of the ODP Guidance

  • On April 16, 2008, the NRC issued Revision 1 to RIS 2005-20, which announced changes to the Part 9900 guidance, Appendices C.11 and C.12, to address through-wall leakage.
  • On July 5, 2011, the TSTF submitted a letter to the NRC requesting that the NRC revise the Part 9900 guidance definitions of " specified function" and "specified safety function" to be consistent with the definition of Operability and the usage of the terms in the guidance.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Problems with the Current Definition of SF/SSF

  • What are the problems with the existing definition of specified functions / specified safety functions?

The Part 9900 definition was taken from GL 91-18, but is missing the first sentence which states, "The definition of operability refers to capability to perform the 'specified functions'."

(continued) 11

Technical Specifications Task Force TSTF A Joint Owners Group Activity Problems with the Current Definition of SF/SSF Evolution of the Change to the Definition of Operability GL 91-18, Pre-ISTS (< 1993) RIS 2005-20, ISTS ( 1993)

A system, subsystem, train, component, A system, subsystem, train, component, or device shall be OPERABLE or have or device shall be OPERABLE or have OPERABILITY when it is capable of OPERABILITY when it is capable of performing its specified functions, and performing its specified safety function(s) when all necessary attendant and when all necessary attendant instrumentation, controls, electrical instrumentation, controls, normal or power, cooling or seal water, lubrication emergency electrical power, cooling and or other auxiliary equipment that are seal water, lubrication, and other required for the system, subsystem, train, auxiliary equipment that are required for component, or device to perform its the system, subsystem, train, function(s) are also capable of component, or device to perform its performing their related support specified safety function(s) are also function(s) . capable of performing their related support function(s).

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Old Generic Letter 91-18 From GL 91-18, Definition 3.1, Operable/Operability:

A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified functions, and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication, or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function(s) are also capable of performing their related support function(s).

This definition was supported by: Same terms From GL 91-18, Definition 3.3 Specified Function(s):

The definition of operability refers to capability to perform the specified functions. The specified function(s) of the system, subsystem, train, component or device (hereafter referred to as system) is that specified safety function(s) in the current licensing basis for the facility.

The adjective safety was used to describe a subset of CLB functions.

Technical Specifications Task Force TSTF A Joint Owners Group Activity RIS 2005-20 From Definition 3.8, Operable/Operability:

A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety functions, and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function(s) are also capable of performing their related support function(s).

Terms are This definition is intended to be supported by: different Definition 3.10, Specified Function/Specified Safety Function:

The specified function(s) of the system, subsystem, train, component or device (hereafter referred to as system) is that specified safety function(s) in the CLB for the facility. In addition to providing the specified safety function, a system is expected to perform as designed, tested and maintained. When system capability is degraded to a point where it cannot perform with reasonable expectation or reliability, the system should be judged inoperable, even if at this instantaneous point in time the system could provide the specified safety function.

The term of interest is not defined in the RIS.

Technical Specifications Task Force TSTF A Joint Owners Group Activity Problems with the Current Definition of SF/SSF Section 2.2 Scope of SSCs for Functionality Assessments SSCs warrant functionality assessments within the processes used to address degraded and nonconforming conditions because they perform specified functions described in the Updated Final Safety Analysis Report (UFSAR), technical requirements manual, emergency plan, fire protection plan, regulatory commitments, or other elements of the current licensing basis (CLB).

Section 3.5 Functional/Functionality "An SSC is functional or has functionality when it is capable of performing its specified function, as set forth in the CLB.

Functionality does not apply to specified safety functions, but does apply to the ability of non-TS SSCs to perform other specified functions that have a necessary support function."

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Problems with the Current Definition of SF/SSF

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Discussion of Proposed Definitions 3.6 Functions This section differentiates the terms specified function (SF), specified safety function (SSF),

and necessary and required support function.

3.6.1 Specified Function A SF is a function performed by a SSC in the CLB. SFs are the functions the SSC was designed to accomplish, as described in the UFSAR and other CLB documents.

3.6.2 Specified Safety Function SSFs are a subset of the set of SFs. A SSF is a function performed by a SSC described in TS. For each licensee, the plant-specific SSF scope derives from information relied on by the licensee and the NRC when the TS were prepared, submitted, reviewed, and approved. For some plants, additional events beyond the scope of design-basis events (such as station blackout and ATWS) may have been considered when the plant-specific SSF scope was established. For plants with improved standard technical specifications, these events are normally discussed in the TS Bases.

If their treatment is unclear, the primary sources for deciding whether a specified function is a specified safety function are the application and supplements submitted by the licensee and the requests for additional information (RAIs) and safety evaluations prepared by the NRC.

Note that not all functions of TS SSCs are considered SSFs, and the functions of non-TS SSCs are never considered SSFs.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Discussion of Proposed Definitions

  • Key concepts:

- The proposed specified safety function definition is consistent with the ISTS definition of operability.

- Specified functions are all the functions as described in the licensing basis.

- Specified safety functions are a subset of the specified functions.

  • A TS SSC can (and frequently will) have both specified functions and specified safety functions.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Discussion of Proposed Definitions

  • Key concepts:

- The proposed definitions provide a consistent, straightforward method (i.e., the TS Bases or licensing basis) for determining operability when a TS system is degraded or nonconforming.

- The plant-specific specified safety function scope is specifically stated in information relied on by the licensee and the NRC when the TS were prepared, submitted, reviewed and approved (i.e., applications, supplements, RAIs, and SEs). This is usually documented in the Bases.

- The specified safety function scope principally addresses design-basis events but some plants TS include events beyond DBAs as documented when the TS were developed.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Discussion of Proposed Definitions

  • The proposed definitions are consistent with the NRC presentation at the November 9 workshop 20

Technical Specifications Task Force TSTF A Joint Owners Group Activity Discussion of Proposed Definitions

  • The proposed definitions are consistent with the NRC training slides and examples.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Discussion of Proposed Definitions

  • The proposed definitions are consistent with the Attachment 2 of the Part 9900 Guidance and the NRC training slides 22

Technical Specifications Task Force TSTF A Joint Owners Group Activity Discussion of Proposed Definitions

  • What is the basis of the prevent or mitigate a DBA statement in the proposed definition?
  • The NRC May 2005 meeting summary stated:

- "Definition (Section 3.6.2, Specified Safety Function) - This definition was clarified to include a broader use of terminology to ensure the appropriate scope of SSCs, as required by the plant current license basis, are considered for operability determinations. A clarification was made to include events beyond the scope of design basis, such as station blackout and ATWS, if they were included when the plant-specific specified safety function scope was established. In addition, the guidance identifies typical documents that contain definitions of SSC specified safety function(s): Bases of the TS; plant UFSAR; and documents from license amendments such as safety analyses, requests for additional information and safety evaluations." 23

Technical Specifications Task Force TSTF A Joint Owners Group Activity Summary

  • The terms specified function and specified safety function are distinct concepts
  • There must be a method to distinguish between a specified safety function and a specified function
  • The existing Section 3.10 fails to provide these distinctions and needs to be revised
  • The May 2005 draft definitions were carefully crafted to provide these distinctions
  • The May 2005 draft definitions provide the appropriate definitions and tie TS Operability to the plants licensing basis 24

Technical Specifications Task Force TSTF A Joint Owners Group Activity Summary

  • Recognizing that the inspection manual is NRC guidance, it does add value to the industry as a benchmark process for assessing Operability.
  • The incorrect Section 3.10 definition detracts from the value of the document for the industry and NRC.
  • The May 2005 definitions provide a solid regulatory basis for determining operability when a SSC is degraded or nonconforming 25

Technical Specifications Task Force TSTF A Joint Owners Group Activity Example 26

Technical Specifications Task Force TSTF A Joint Owners Group Activity Example from the NRC 2005 Training Related to SF/SSF 27

Technical Specifications Task Force TSTF A Joint Owners Group Activity Example from the NRC 2005 Training Related to SF/SSF 28

Technical Specifications Task Force TSTF A Joint Owners Group Activity Examples from the NRC 2005 Training Related to SF/SSF

  • The industry agrees with the conclusion in this example.

- For all licensees of which we are aware, Station Blackout (SBO) mitigation is a "specified function," not a "specified safety function" because SBO mitigation was not a function considered when the TS were proposed and approved.

  • Note this is consistent with NRC TIA 2009-002 and 2011-014, "Revised Response to Task Interface Agreement - Requirements for Testing Station Batteries for Station Black-out Conditions at the San Onofre Nuclear Generating Station," April 26, 2012.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Proposed Changes to Appendices C.1 and C.2 to Clarify the Relationship Between General Design Criteria (GDC) and Technical Specifications Operability 30

Technical Specifications Task Force TSTF A Joint Owners Group Activity General Design Criteria and OPERABILITY

- Part 9900, Operability Determination, dated April 16, 2008

- Appendix C, Section C.1, Relationship Between the General Design Criteria and the Technical Specifications

- Appendix C, Section C.2, Single Failures

  • A DRAFT Regulatory Issue Summary (RIS), issued for comment July 31, 2012 supported the positions in Part 9900, and addressed the same concerns.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity General Design Criteria and OPERABILITY

  • In summary, Part 9900 indicates that failures to comply with the GDC should be considered a nonconformance requiring evaluation under existing operability determination processes.
  • Industry agrees with this position.

GDC or other principal design criteria established in a plants licensing basis constitute commitments to design requirements.

Failure to meet such a commitment is a nonconforming condition.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity General Design Criteria and OPERABILITY

- Appendix A was issued in 1971 to establish minimum requirements for the principal design criteria1 included in construction permit applications (PSAR).

- In considering the issuance of an operating license, the NRC require(s) assurance that these criteria have been satisfiedand that any changes in such criteria are justified.1

  • Discussion of conformance to GDC is set forth in FSAR, similar to other design basis requirements.
  • With a few specific exceptions, general design criteria are not operating restrictions.

1 32 FR 10203, July 11 1967 and 36 FR 03256, February 20 1971

Technical Specifications Task Force TSTF A Joint Owners Group Activity General Design Criteria and OPERABILITY Industry Comments* on Part 9900, Operability Determination Guidance - Section C.1

  • Second paragraph: Remove statement regarding derivation of Technical Specifications. Statements consistent with 10CFR50.36 are provided in paragraph three.
  • Fourth paragraph: Clarify that GDC are met by design only, and that TS compliance provides limits on operation when the safety provisions of the GDC are compromised.
  • Last paragraph: Provide clarification that failure to conform to a GDC does not necessarily render an SSC inoperable. Failure to meet a GDC is a nonconforming condition.
  • Proposed changes to Part 9900 are provided in a separate handout.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity General Design Criteria and OPERABILITY

- Add GDC 21 to the list of GDC with stated single failure requirements.

- Replace the example statement regarding redundancy with a general description, to avoid inappropriate emphasis regarding electrical redundancy.

- Provide additional language to clarify the role of the plant specific licensing basis.

- Clarify statement regarding failure to meet single failure requirement, consistent with Section C.1.

- Add paragraph to clarify the relationship between design requirements and Technical Specifications.

Technical Specifications Task Force TSTF A Joint Owners Group Activity General Design Criteria and OPERABILITY

  • Conclusions

- Part 9900 broadly addresses Operability Determinations, with specific considerations for GDC applicability.

- Part 9900 guidance establishes the difference between design considerations (such as GDC) and operational limits (TS).

- Industry positions are consistent with the general concepts provided as inspector guidance in Part 9900, however, clarification of the language would be beneficial.

- Part 9900 is the most appropriate and only necessary location for such guidance. The draft RIS is unnecessary.

Technical Specifications Task Force TSTF A Joint Owners Group Activity Next Steps

  • Recommendations

- Revise Part 9900 to address concerns identified by the industry.

- Communicate these considerations in a revision to RIS 2005-20.

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