ML13203A164
| ML13203A164 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 09/12/2013 |
| From: | Michelle Honcharik Licensing Processes Branch (DPR) |
| To: | Anthony Mendiola Licensing Processes Branch (DPR) |
| Honcharik M, 301-415-1774 | |
| Shared Package | |
| ML13199A403 | List: |
| References | |
| Download: ML13203A164 (8) | |
Text
September 12, 2013 MEMORANDUM TO:
Anthony J. Mendiola, 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
SUBJECT:
SUMMARY
OF JULY 18, 2013, QUARTERLY MEETING WITH THE TECHNICAL SPECIFICATIONS TASK FORCE (TSTF)
On July 18, 2013, the U.S. Nuclear Regulatory Commission (NRC) staff met with the Technical Specifications Task Force (TSTF) representatives to discuss technical issues and administrative processes related to TSTF Travelers. The meeting was held at NRC offices in Three White Flint North, 11601 Landsdown Street, North Bethseda, Maryland 20852. A list of the meeting attendees is enclosed. The meeting notice and agenda dated July 3, 2013, are available in the Agencywide Documents Access and Management System (ADAMS) at Package Accession No. ML13183A439.
Fukushima-Related Impact on NRC Staff Activities Mr. Anthony Mendiola, NRC, discussed the impacts that Fukushima-Related effort was having on the workload in the Office of Nuclear Reactor Regulations (NRR). He explained that all work in NRR has been prioritized on a scale from 1-5; with 5 being the lowest priority. Traveler reviews are a priority 4. Eighty percent of the work in NRR is priority 4 or 5. The TSTF asked when work would resume to normal. Mr. Robert Elliott, NRC, commented that work will resume to normal when all of the Fukushima-Related work and effects from sequestration have ended.
Mr. Mendiola added that his staff is attempting to line up contracts with the Department of Energy laboratories to handle Topical Report reviews. This would free up NRR staff to work on other tasks (i.e., Travelers, etc.). Mr. Mendiola also commented that specific technical areas are impacted more, for example, reactor systems, spent fuel pool, balance of plant, and instrumentation and control. Mr. Elliott added that containment is impacted too. TSTF members asked if a Traveler could be assigned a higher priority. Mr. Elliott, NRC, explained that a Traveler could be given a priority higher than 4. The TSTF should highlight/flag the Traveler to the NRC staff and provide the basis for the elevation of priority. Brian Mann, TSTF, took an action item to re-evaluate the priority (not routine) and submit a letter laying out reasons why certain Travelers should be a higher priority.
A. Mendiola Status of NRC Response to September 4, 2012, TSTF Letter, "Response to NRC Request for Supplemental Information and Withdrawal Regarding TSTF-534, Revision 0,'Clarify Application of Pressure Boundary Leakage Definition' Mr. Timothy Lupold, NRC, explained what happens when a plant has a leak that would be considered reactor coolant pressure boundary (RCPB) leakage. The NRC staff interprets the Technical Specifications (TS) as not allowing any RCPB leakage. However, the leak can be removed from the RCPB by isolating it. Once the leak is isolated, it is no longer part of the RCPB. Section 50.2 of Title 10 of the Code of Federal Regulations (10 CFR) defines the RCPB.
It states that the second of 2 valves forms the boundary. Therefore, when it is isolated any leakage through those valves is not RCPB leakage; it is now reactor coolant system (RCS) leakage.
Mr. Mann, TSTF, commented that the TSTF agreed completely. If there are 2 valves isolating the leak, then its not RCPB leakage. Its RCS leakage. Mr. Elliott, NRC, suggested that a possible strategy would be to make a RCS leakage bases change (for industry) and put it in the operability guidance (for inspectors) to document. Mr. Mann, TSTF, took an action to send the bases change to the NRC for information (not formal review). It would be a T-Traveler. Mr. Carl Schulten, NRC, and Mr. Elliott, NRC, discussed where in NRC documents would be the appropriate place to include this clarification.
The NRC staff and TSTF members all agreed this may not solve every problem, but it will clarify what the TS really means. Based on the discussion today, a formal written response to the TSTFs letter dated September 4, 2012, is no longer needed.
Active Traveler Review Status (see TSTF handout, Active Traveler Status Report, in ADAMS at Accession No. ML13199A255)
TSTF-454, Extend PCIV Completion Times (NEDC-33046)
TSTF plans to respond to requests for additional information (RAIs) by September 30, 2013.
TSTF-523, Generic Letter 2008-001, Managing Gas Accumulation The Federal Register Notice for Public Comment was signed out on July 9, 2013. It should be published before the end of the month.
TSTF-529, Clarify Use and Application Rules All Change Numbers below refer to the change numbers from NRC staff handout (ADAMS Accession No. ML13171A321). Mr. Brian Mann, TSTF, stated that the TSTF will revise the Traveler based on the NRC staff handouts and the discussion today.
a) Change #1 proposed to add two new references to the LCO 3.0.2 bases. One of the references is a very old internal NRC memo. The TSTF agreed to not include it. The other reference is the Part 9900 guidance, which does talk a lot about time of discovery, which is why the TSTF proposed to include it as a reference. Mr. Carl Schulten, NRC, explained that the NRC staff does not think it should be a reference because there is no relationship between inspector guidance and TS. The TS should stand alone. Mr. Brian Mann, TSTF, suggested removing the reference and including some of the wording in the basis to clarify. It was agreed that the reference would be removed and instead the TSTF would provide an example or discussion on completion time in Section 1.0.
A. Mendiola b) Change #3 was a minor change to Limiting Condition for Operation (LCO) 3.0.4a to avoid confusion. Mr. Carl Schulten, NRC, commented that for the NRC staff the threshold to change LCO 3.0 is very high. Mr. Brian Mann, TSTF, explained that the TSTF bundled many changes to address concerns about licensees not adopting this one particular change. It was agreed that the TSTF would revise the Traveler to change bases only and not the LCO.
c) Change #5 - Rob - dont want to use resources to fix a problem that isnt broke. Brian -
many people are using Calvert response. Rob - could reference Calvert letter in the bases.
d) Change #12 was proposed to address situations when Surveillance Requirement (SR) 3.0.3 Surveillances were never performed. The longer since a surveillance test has been performed, the higher the bar to prove operability. The NRC staff recommended the TSTF use the term objective evidence. It was agreed that surveillances that have never been performed will be lumped in with long time since performed category.
TSTF-531, Revision of Specification 3.8.1, Required Actions B.3.1 and B.3.2 Request for Additional Information (RAI) responses received. The NRC staff has not reviewed the RAI Responses yet. Earliest that the NRC staff will be ready to discuss will be September.
TSTF-536, Resolve CE Digital TS Inconsistencies Regarding CPCs and CEACs The NRC staff from the Instrumentation and Controls branch in the Division of Engineering is considering non-acceptance, because there is no technical justification. Mr. Brian Mann, TSTF, explained that the change is a TS change, not a technical change. A telephone call will be scheduled for later to discuss further, once staff has had more time to review.
TSTF-537, Increase CIV Completion Time: Update to TSTF-373 The TSTF plans to respond to RAIs by September 30, 2013.
TSTF-538, Add Actions to Preclude Entry into LCO 3.0.3 - RITSTF Initiatives 6b & 6c The NRC staff is preparing a non-acceptance letter. Issuance has been delayed due to higher priority work.
TSTF-540, Provide Completion Time in lieu of Immediate Shutdown (RITSTF Initiative 6)
The NRC staff is preparing a non-acceptance letter. Issuance has been delayed due to higher priority work.
TSTF Traveler Review Priority (see TSTF handout, Traveler Review Priority, in ADAMS at Accession No. ML13199A268)
Mr. Brian Mann, TSTF, explained why the high priority-Travelers were categorized as high.
TSTF-538 and TSTF-540 are risk-informed initiatives, TSTF-523 is in response to a Generic Letter, and TSTF-531 is a safety issue.
A. Mendiola Technical Issues Spent Fuel Pool Criticality Issue Mr. Brian Mann, TSTF, opened the discussion by clarifying that the Nuclear Energy Institute (NEI) Criticality Task Force is the primary point of contact for this issue, not the TSTF. The NEI document, NEI 12-16, is under NRC staff review. The TSTF met with the NEI Critically Task Force and reviewed NEI 12-16. As written, there would be problems attempting to fit the NEI 12-16 requirements/actions into the standard required actions format/structure of the TS.
The two industry groups discussed an administrative controls program, but any actions that licensees would end up taking would need prior approval NRC approval to do. Therefore, these actions could not be put into TS. The TSTF members support what is in NEI 12-16.
Mr. Kent Wood, NRC, summarized the issue for clarity. The TSTF feels they dont have any actions, because any actions that the licensee would take would need prior NRC staff approval and therefore cant be in TS as a required action. Mr. Kent Wood, NRC, the NRC staff was looking at it as two parallel paths and didnt want to wait 2 years to start looking at TS changes.
The monitoring program needs to be in TS and thought something similar to the program for steam generator (SG) tube monitoring might work. Mr. Brian Mann, TSTF, the TSTF members dont want to be working at cross purposes with another industry group, because industry is not proposing a TS.
Discussion of Operability and Functionality Guidance Proposed Revisions Mr. Robert Elliott, NRC, explained that the staff has finished the draft of IMC Part 9900 revision (which will be renumbered as IMC 0326). The Regions have not seen it yet. The NRC staff has not only changed the document, but theyve also provided a response to TSTF requests in letter (as if comments had been received from Federal Register Notice). The NRC staff plans to have a draft issued before the November quarterly meeting.
Status of Room Cooler Traveler Mr. Robert Elliott, NRC, Wolf Creek was recently granted notice of enforcement discretion (NOED) for inverters for an inoperable non-TS room cooler. Mr. Rob Slough, TSTF, commented that there has got to be better way than having a utility shutdown during peak demand because of an inoperable air conditioner. Mr. Matt Hamm, NRC, commented that these components/systems werent designed to be overhauled online. It was agreed that a meeting will be scheduled to discuss further; NRC staff from containment and ventilation branch should be involved in the meeting.
Status of BWR Reactor Pressure Vessel Water Inventory Control Traveler (TSTF-542)
Mr. Brian Mann, TSTF, commented that the TSTF has incorporated a lot of the NRC staff comments provided during the February meeting. Theyve also prepared a comment disposition document. The latest draft of TSTF-542 is currently out for industry review due back by end of July. Then the TSTF will provide a draft Traveler to the NRC by middle of August, at which time another pre-submittal meeting will be scheduled.
A. Mendiola Mr. Robert Elliott, NRC, informed the TSTF that the EGM will be extended to December 31, 2015.
Status of Traveler to Incorporate OMN-20 and Revise the TS Inservice Testing Program (TSTF-545)
The TSTF will submit a first draft to the NRC in early August. The Traveler will include a model relief request (RR), which is something new. RR part of the Traveler will be bracketed, because some plants may already have been granted relief. The NRC staff discussed having an internal meeting with staff from the Office of the General Counsel and management from the Division of Operator Reactor Licensing, so they can determine if and who should attend the pre-submittal meeting with the TSTF.
Future Planning Future Traveler submittals TSTF-541, "Add Exceptions to Surveillance Requirements When the Safety Function is being Performed" TSTF-542, "Reactor Pressure Vessel Water Inventory Control (RPV WIC)"
TSTF-545, "10 CFR 50.55a(f) Alternative IST Testing Request and IST Program Revision" TSTF-546, "Add Allowance to Delay Entry into RPS Actions During APRM Gain Adjustments" TSTF-547, "Clarification of Rod Position Requirements."
Next quarterly public meeting between the TSTF and NRC is scheduled for November 21, 2013.
There were no questions received from the public.
Project No. 753
Enclosure:
Attendees at the NRC and TSTF Meeting cc: See next page
Package -ML13199A403; Summary - ML13203A164; TSTF Handouts -ML13199A255 and ML13199A255; NRC Handouts: ML13171A321, ML13179A379, and ML13192A337; Notice - ML13199A255 OFFICE PLPB/PM PLPB/LA STSB/BC PLPB/BC PLPB/PM NAME MHoncharik DBaxley RElliott AMendiola MHoncharik DATE 08/1/2013 07/ 30 /2013 09/5/2013 09/11/2013 09/12/2013
Technical Specifications Task Force Mailing List cc:
Technical Specifications Task Force 11921 Rockville Pike Suite 100 Rockville, MD 20852 Attention: Brian Mann E-mail: brian.mann@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 Richard A. Loeffler Monticello Nuclear Generating Plant 2807 West County Road 75 Monticello, MN 55362-9637 E-mail: richard.loeffler@xenuclear.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
ENCLOSURE Attendees at the U.S. Nuclear Regulatory Commission (NRC) and Technical Specifications Task Force (TSTF) Meeting July 18, 2013 Name Organization Robert Elliott NRC/Office of Nuclear Reactor Regulation (NRR)/Division of Safety Systems (DSS) /
Technical Specifications Branch (STSB)
Carl Schulten NRC/NRR/DSS/STSB Matthew Hamm NRC/NRR/DSS/STSB Kadijah Hemphill NRC/NRR/DSS/STSB Gerald Waig NRC/NRR/DSS/STSB Ravinder Grover NRC/NRR/DSS/STSB Anthony Mendiola NRC/NRR/DPR/Licensing Processes Branch (PLPB)
Michelle Honcharik NRC/NRR/DPR/PLPB Timothy Lupold NRC/NRR/Division of Engineering (DE)/
Component Performance, NDE, & Test Branch (CPNB)
Keith Hoffman NRC/NRR/DE/CPNB Kent Wood NRC/NRR/Division of Safety Systems (DSS)/Reactor Systems Branch (SRXB)
Jennifer Gall NRC/NRR/DSS/SRXB John Hughey NRC/NRR/Division of Operating Reactor Licensing Eileen McKenna NRC/Office of New Reactors Regulation (NRO)
Theodore Tjader NRC/NRO Brian Mann Technical Specifications Task Force (TSTF)