ML16342D431

Summary of 960823 Meeting W/Tu Electric,Ue,Wcnoc & PG&E in Rockville,Md Re Joint TS Conversion Process & Schedule.List of Attendees & Draft Application Guidance Encl

ML16342D431
Person / Time
Site:	Wolf Creek, Diablo Canyon, Callaway, Comanche Peak
Issue date:	09/16/1996
From:	Polich T NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9609190285
Download: ML16342D431 (32)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 16, 1996 LICENSEES:

FACILITIES:

SUBJECT:

Texas Utilities Electri c Company Union Electric Company Wolf Creek Nuclear Operation Corporation Pacific Gas

& Electric Company Comanche Peak Units 1 and 2, Callaway, Wolf Creek, and Diablo Canyon Units 1 and 2

SUMMARY

OF MEETING WITH TEXAS UTILITIES ELECTRIC COMPANY (TU ELECTRIC),

UNION ELECTRIC COMPANY (UE),

WOLF CREEK NUCLEAR OPERATION CORPORATION (WCNOC),

AND PACIFIC GAS

& ELECTRIC COMPANY (PG&E)

ON THE JOINT TECHNICAL SPECIFICATION CONVERSION PROCESS AND SCHEDULE On August 23,

1996, members of the NRC staff met with representatives of Texas Utilities Electric Company (TU Electric), Union Electric Company (UE), Wolf Creek Nuclear Operation Corporation (WCNOC),

and Pacific Gas

& Electric Company (PG&E) at NRC Headquarters in Rockville, Maryland to discuss the joint technical specification conversion process and schedule.

The topics discussed were electronic file format for the conversion, relocated requirements and relocated detail, location of moved and relocated information, handling of the industry's Technical Specification Task Force (TSTF) travelers, out-of-scope

changes, format of descriptions, justifications and comparison tables.

The utilities described the conversion schedule and progress.

The first of the six packages has been completed through review by most of the safety committees and all the packages have been marked-up, reviewed and discussed.

The utilities still expect to submit, in parallel, the conversion License Amendment Requests (LARs) in January of 1997.

A brief discussion was held on implementation schedules.

The utilities noted

that, due to the varying operating schedules of the six units involved, implementation schedules will vary and will be difficult to specify at the time of the submittals are made.

The NRC stated that implementation schedules can be described in a fairly general manner at the time of the submittal although the proposed implementation can influence the priority assigned for NRC review.

A firm implementation schedule will be required at the time of NRC approval.

The NRC also stated that the implementation schedules should not extend more than a year beyond the approval date.

The next meeting between the NRC and the utilities was discussed and November was selected as the target month.

The utilities will take the lead to initiate setting a firm date for the meeting.

At that meeting NRR management from the Technical Specification Branch and the Project Directorates for PD 4-1 and 4-2 will be available to resolve any remaining or emergent issues prior to submittal of the conversion packages.

9609190285 9609i6 PDR ADOCK 05000275 P.,

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4 The utilities reiterated their desire to use WordPerfect

6. 1 as the standard for the development of their submittals.

They stated that their submittals will be converted into WordPerfect

5. 1 for submittal unless the NRC notifies them otherwise.

The pilot project to convert the Standard Technical Specifications (STSs) to Standard Generalized Markup Language (SGML) format has not progressed sufficiently for SGML to be considered a viable option.

The utilities noted that there have been occasions in which it was difficult to determine if a change is a "relocation" or a "move" change (i.e.,

an "R" or an "LG").

The Nuclear Energy Institute (NEI) guidance addresses the difference briefly.

The basic criteria being used by the utilities is that if a "requirement" (and this usually means part of the limiting condition for operation (LCO) is being moved, the change is considered a relocation and "R"

is used.

If the change moves descriptive information or supporting details, "LG" is used.

In many cases the difference is not clear.

The NRC criteria for an "R" is a complete relocation of an entire LCO or an entire instrumentation function in the instrumentation section.

When material is being relocated or moved, the utilities are noting that the material is going to a licensee controlled document,

program, procedure, etc.

In some cases, the specific document or program is identified (e.g.,

the FSAR or the Bases for the TS).

In many cases the specific document is not identified because that determination is best made during implementation.

The precise location of some moved information and some relocated requirements will not be known precisely until the implementation activities are well along.

The NRC stated that utilities did not need to identify the specific document where all the material will be relocated when the submittal is made.

However, in those cases where the submittal uses a general location (e.g.,

a licensee controlled document),

a specific location must be identified during the NRC's review.

The utilities asked if including that information in the comparison tables was acceptable and the NRC said that it was.

The utilities informed the NRC that, in general, travelers are being evaluated as they get approved for submittal to the NRC.

The utilities will cutoff adopting additional travelers after the October meeting of the Westinghouse Owners Group mini-group.

Travelers issued at a later date will not be considered unless there is a safety impact or a significant operational impact.

The utilities updated the NRC on the use of traveler TSTF-10 (the utilities did not incorporate,TSTF-10 involving shutdown margin and rod position in NODE 2).

The NEI recently issued new generic guidelines on how to perform and submit TS conversion requests.

At the meeting, the NRC handed out guidance that it is developing to describe its expectations (Attachment 1).

The utilities discussed the degree to which their conversion processes and products are consistent with the new generic guidelines and the degree to which they differ.

The utilities will not have a separate Criteria Application Report in their submittals.

The same information has been integrated into the base package.

There will be no matrix of the LCOs versus the 10 CFR 50.36 criteria.

The NRC state there should not be a problem with this approach based on the degree to which each of the utilities have already completed the "split" activity.

The utilities use the same abbreviations and acronyms although the letters used to identify the change types are slightly different.

The NRC stated that this should not impact the review as long as the methodology was explained in the document.

The utilities confirmed that the appropriate methodology was included in the document.

The utilities intend to meet with the NRC reviewer(s) shortly after the submittals are made to review the organization

, and methodology of the packages.

The utilities stated that the conversion packages will identify the material deleted from the TS Bases via strikeout.

Redline will be used to show the material which will be added to the bases.

Identification numbers will not be assigned and justifications will not be submitted for these changes.

A discussion was held on the potential impact and value of the numbers/justifications.

It was noted that the area that might be of most concern to the NRC is the deletion of major portions of the generic safety analysis discussions.

The utilities noted that there are cases where the Westinghouse generic descriptions were replaced with plant specific descriptions and some cases where very specific descriptions (which exist elsewhere) were replaced with more general descriptions.

The NRC stated in general, this was acceptable and should not significantly impact the review.

There may be times when the NRC reviewer would request an explanation for a bases change and the utilities responded that such requests would not be a

problem.

The definition for out-of-scope (OOS) changes was discussed.

In general, it was agreed that if the conversions adopt the Improved Standard Technical Specification (ISTS),

Rev. I, plus approved travelers, that they are not out of scope.

Line item improvements in the ISTS, which include new allowed outage times (AOTs),. surveillance frequencies, etc.

and which must be addressed if they are not in the current TS, are not out of scope.

Bracketed numbers which are plant specific (e.g., result from a plant specific calculation) must use the current TS value or justify the change as an 00S change.

For other numbers, bracketed or not, the plant may use the ISTS value if properly justified and the change is not out of scope.

The utilities stated at the March 27, 1996, meeting that they would propose to the NRC an arrangement in the submittals that would aid in the identification of OOS items.

The utilities intend to attach a table to the submittal cover letter which lists the OOS changes in the conversion request.

The utilities noted that they intend to use brackets in some descriptions, No Significant Hazards Consideration (NSHC) evaluations or justifications when brackets provide a clear, convenient means of denoting plant specific differences.

It was felt by the utilities that this was the clearest way to identify the differences.

The NRC had no objections with the approach.

In other related matters, the NRC found the continued use of electronic version of LAR submittals along with the hard copy to be useful.

The utilities stated they would like to continue to take advantage of the parallel multi-utility submittal

process, not only for the conversion, but for other licensing actions.

The process benefits the NRC as well as the licensees by consolidating resources.

The utilities previously informed the NRC that they intend to follow the format of NUREG-1431, REV. 1, for the Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) instrumentation tables.

This approach was reaffirmed and it was also noted that at least three of the plants intend to use the single column format (allowable value is retained and setpoint value is moved) as allowed by the reviewers note in the NUREG.

PG&E may retain the two column format because their setpoint study may not allow the use of the single column format.

In conclusion, the staff characterized the meeting as informative and constructive.

As stated above additional interactions between the staff and the four utilities will be held on a periodic basis as the process evolves.

The next meeting is targeted for November 1996.

n ~>w~~

Timothy J. Polich, Project Nanager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.

50-275, 50-323, 50-445, 50-446, 50-482, and 50-483 Attachments:

1.

Draft Application Guidance 2.

Heeting Attendees cc w/atts:

See next page

Union Electric Company Callaway Plant, Unit 1

CC:

Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, Maryland 20855 Gerald Charnoff, Esq.

Thomas A. Baxter, Esq.

Shaw, Pittman, Potts E Trowbridge 2300 N. Street, N.W.

Washington, D.C.

20037 Mr. H. D.

Bono Supervising

Engineer, Site Licensing Union Electric Company Post Office Box 620 Fulton, Missouri 65251 U.S. Nuclear Regulatory Commission Resident Inspector Office 8201 NRC Road

Steedman, Hissouri 65077-1302 Hr.

G. L. Randolph, Vice President Nuclear Operations Union Electric Company P.O.

Box 620 Fulton, Missouri 65251 Manager - Electric Department Hissouri Public Service Commission 301 W. High Post Office Box 360 Jefferson City, Missouri 65102 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower 8 Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Hr. Ronald A. Kucera, Deputy Director Department of Natural Resources P.O.

Box 176 Jefferson City, Missouri 65102 Hr. Neil S.

Cams President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O.

Box 411 Burlington, Kansas 66839 Hr. Dan I. Bolef, President Kay Drey, Representative Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, Missouri 65130 Hr.

Lee Fritz Presiding Commissioner Callaway County Court House 10 East Fifth Street Fulton, Missouri 65151 Hr. Alan C. Passwater, Manager Licensing and Fuels Union Electric Company Post Office Box 149 St. Louis, Missouri 63166 Hr. J.

V. Laux, Manager guality Assurance Union Electric Company Post Office Box 620 Fulton, Missouri 65251 Hr. Donald F. Schnell Senior Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, Missouri 63166

TU Electric Company CC:

Senior Resident Inspector U.S. Nuclear Regulatory Commission P. 0.

Box 1029

Granbury, TX 76048 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mrs. Juanita Ellis, President Citizens Association for Sound Energy 1426 South Polk

Dallas, TX 75224 Hr. Roger DE Walker TU Electric Regulatory Affairs Manager P. 0.

Box 1002 Glen Rose, TX 76043 Texas Utilities Electri c Company c/o Bethesda Licensing 3 Metro Center, Suite 610

Bethesda, MD 20814 George L. Edgar, Esq.

Horgan, Lewis 5 Bockius 1800 M Street, N.W.

Washington, DC 20036-5869 Comanche Peak,'nits 1 and 2

Honorable Dale McPherson County Judge P. 0.

Box 851 Glen Rose, TX 76043 Office of the Governor ATTN:

Susan Rieff, Director Environmental Policy P. 0.

Box 12428

Austin, TX 78711 Arthur"C. Tate, Director Division of Compliance 8 Inspection Bureau of Radiation Control Texas Department of Health 1100 West 49th Street

Austin, TX 78756-3189 Hr.

C.

Lance Terry TU Electric Group Vice President Nuclear Attn:

Regulatory Affairs Department P. 0.

Box 1002 Glen Rose, TX 76043

0-

Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant CC:

NRC Resident Inspector Diablo Canyon Nuclear Power Plant c/o U.S. Nuclear Regulatory Commission P. 0.

Box 369 Avila Beach, California 93424 Dr. Richard

Ferguson, Energy Chair Sierra Club California 1100 11th Street, Suite 311 Sacramento, California 95814 Hs.

Nancy Culver San Luis Obispo Hothers for Peace P. 0.

Box 164 Pismo Beach, California 93448 Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, California 93408 Hr. Truman Burns Hr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, California 94102 Hr. Steve Hsu Radiologic Health Branch State Department of Health Services Post Office Box 942732 Sacramento, California 94232 Diablo Canyon Independent Safety Committee ATTN:

Robert R. Wellington, Esq.

Legal Counsel 857 Cass Street, Suite 0

Honterey, California 93940 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower

& Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Christopher J. Warner, Esq.

Pacific Gas

& Electric Company Post Office Box 7442 San Francisco, California 94120 Hr. Robert P.

Powers Vice President and Plant Hanager Diablo Canyon Nuclear Power Plant P. 0.

Box 56 Avila Beach, California 93424 Hr. Gregory H. Rueger Nuclear Power Generation,,

B14A--

Pacific Gas and Electric Company 77 Beale Street, Rom 1451 P.O.

Box 770000 San Francisco, CA 94106

Wolf Creek Nuclear Operating Corporation Wolf Creek Generating Station CC:

Jay Silberg, Esq.

Shaw, Pittman, Potts 8 Trowbridge 2300 N Street, NW Washington, D.C.

20037 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. 0.

Box 311 Burlington, Kansas 66839 Chief Engineer Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Road

Topeka, Kansas 66604-4027 Office of the Governor State of Kansas

Topeka, Kansas 66612 Attorney General Judicial Center 301 S.W.

10th 2nd Floor

Topeka, Kansas 66612 County Clerk Coffey County Courthouse Burlington, Kansas 66839 Public Health Physicist Bureau of Air E Radiation Division of Environment Kansas Department of Health and Environment Forbes Field Building 283

Topeka, Kansas 66620 Vice President Plant Operations Wolf Creek Nuclear Operating Corporation P. 0.

Box 411 Burlington, Kansas 66839 Supervisor Licensing Wolf Creek Nuclear Operating Corporation P.O.

Box 411 Burlington, Kansas 66839 U.S. Nuclear Regulatory Commission Resident Inspectors Office 8201 NRC Road

Steedman, Missouri 65077-1032 Supervisor Regulatory Compliance Wolf Creek Nuclear Operating Corporation P.O.

Box 411 Burlington, Kansas 66839 Hr. Neil S.

Cams President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O.

Box 411 Burlington, Kansas 66839

0

he utilities noted that they intend to use brackets in some descriptions, No Significant Hazards Consideration (NSHC) evaluations or justifications when brackets provide a clear, convenient means of denoting plant specific differences.

It was felt by the utilities that this was the clearest way to identify the differences.

The NRC had no objections with the approach.

In other related matters, the NRC found the continued use of electronic version of LAR submittals along with the hard copy to be useful.

The utilities stated they would like to continue to take advantage of the parallel multi-utility submittal

process, not only for the conversion, but for

'other licensing actions.

The process benefits the NRC as well as the licensees by consolidating resources.

The utilities previously informed the NRC that they intend to follow the format of NUREG-1431, REV. 1, for the Reactor Trip System (RTS) and Engineered Safety Features Actuation System'(ESFAS) instrumentation tables.

This approach was reaffirmed and it was also noted that at least three of the plants intend to use the single column format (allowable value is retained and setpoint value is moved) as, allowed by the reviewers note in the NUREG.

PGRE may retain the two column format because their setpoint study may not allow the use of the single column format.

In conclusion, the staff characterized the meeting as informative and constructive.

As stated above additional interactions between the staff and the four utilities will be held on a periodic basis as the process evolves.

The next meeting is targeted for November 1996.

TimoBy f. 30/lc(,9roJect Hanager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-275, 50-323, 50-445, 50-446, 50-482, and 50-483 Attachments:

1.

Draft Application Guidance 2.

Heeting Attendees cc w/atts:

See next page 0ISTRI BUTION: ~Becket Ij~e PUBLIC PD4-1 r/f OGC ACRS eteDA pP Document Name:

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