ML17263A467
| ML17263A467 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/09/1993 |
| From: | Andrea Johnson Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| TAC-M86818, NUDOCS 9311170468 | |
| Download: ML17263A467 (21) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGT(N, D.g ~000]
Docket No. 50-244 LICENSEE:
Rochester Gas and Electric Corporation FACILITY:
Ginna Nuclear Power Plant
SUBJECT:
SUMMARY
OF MEETING WITH ROCHESTER GAS AND ELECTRIC CORPORATION ON OCTOBER 18, 1993
REVISED STANDARD TECHNICAL SPECIFICATIONS FOR G INNA (TAC NO. M86818)
Rochester Gas and Electric Corporation (RG&E), as a lead utility in a Cooperative Efforts Group (CEG) for two-loop Westinghouse pressurized-water
- reactor, met with the NRC on October 18, 1993, to discuss a proposed approach for conversion and adoption of new improved Revised Standard Technical Specifications (RSTSs) for the Ginna plant.
RG&E also discussed the potential for developing a generic two-loop RSTS for other CEG participants including, Wisconsin Electric Power Company (Point Beach 1
& 2), Wisconsin Public Services Corporation (Kewaunee),
and Northern States Power Company (Prairie Island 1
& 2).
RG&E presented the CEGs reasons for considering RSTS conversion as:
(1) the current plant custom Technical Specification (TS) issues are not user friendly, have limited information in the bases, and are unduly conservative, (2) numerous TS line-item improvements are now available (e.g.,
- TOPS, NUREG-
- 1431, GL 93-05, etc.),
and (3) timeliness in processing license amendments due to the NRC priority determination system for staff review efforts.
RG&E presented to the NRC 10 questions regarding their approach for conversion and adoption of the RSTS for the CEG.
The questions were addressed by the Office of Nuclear Reactor Regulation/Division of Operating Reactor Support/Technical Specifications Branch (NRR/OTSB) as follows:
1.
NRR/OTSB indicated that the RG&E/CEG proposed RSTS approach appeared reasonable, and encouraged the CEG to pursue a cooperative effort.
2.
The potential for NRR adding new requirements or changing the current TS requirements for the Ginna Station is unlikely because backfitting rules apply.
NRR/OTSB encourages licensees to adopt new requirements to ensure completeness and consistency of the TSs.
3.
Whether NRR can support RG&Es schedule, even considering the steam generator replacement in 1996, depends on all of the demands on NRR resources.
License amendments are controlled by procedures for a priority ranking system for NRR reviews.
Although the Commission policy statement on TS improvements provides that complete conversions would receive the highest priority, the particular review schedule also depends on how many conversion reviews are already underway.
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November 9, 1993 4.
guestion No.
4 did not exist.
5.
NRR/OTSB recommended that the CEG refer to the STS for Combustion Engineering (NUREG-1432) for guidance on the differences in TSs for four-loop Westinghouse plant solid state protection system design and Ginna's two-loop plant with relay protection system design.
6.
NRR/OTSB indicated that the extent to which only essential (operating and administrative) procedure changes are necessary to be accomplished at the time of TS conversion would be dependent on how well these procedures are established.
NRR/OTSB further indicated that they would rely on the views of the Regional staff regarding the practicality of an alternate procedural control system.
7.
8.
9.
NRR/OTSB indicated that it appears typical for licensees to begin training on the new technical specifications before they are approved to minimize the transition period for implementation.
Nevertheless, such plans should be coordinated with the Regional staff responsible for monitoring the training program and operator licensing.
NRR/OTSB cannot accurately estimate NRC review costs having only completed one conversion review; however, the staff recommends 1-2 PSY and
$ 50K for planning purposes (about
$ 500K).
NRR/OTSB does not recommend RG&E change their inservice testing (IST) program at the time of a RSTS submittal in order to take immediate advantage of reduced surveillance requirements.
The IST program for the Ginna Station should remain autonomous.
10.
The "NRR Priority Determination for NRR Review Efforts" ranking procedures provide the general framework for review responsibilities for NRR.
NRR/OTSB has the lead responsibility for TS conversion reviews with support from the other NRR branches as needed.
Enclosure 1 is a list of meeting attendees and Enclosure 2 is a copy of the meeting agenda and discussion material.
original signed by Allen R. Johnson, Project Manager Project Directorate I-3 Division of Reactor Projects - I/II
Enclosures:
1
~
List of Attendees 2.
Meeting agenda and discussion material cc w/enclosures:
See next page
- See revious concurrence 0FFlcE LA i I 3 PM: PDI-3
- OTSB D: PDI-3 NAME DATE ittle J
/ V/93 AJohnson:mw CGrimes I) /
/93 11/05/93 WButler i /
/93 OFFICIAL RECORD COPY FILENAME: A:iGI918.MTS
November 9, 1993 4,
5.
6.
7.
8.
9.
guestion No.
4 did not exist.
NRR/OTSB recommended that the CEG refer, to the STS for Combustion Engineering (NUREG-1432) for guidance on the differences in TSs for four-loop Westinghouse plant solid state protection system design and Ginna's two-loop plant with relay protection system design.
NRR/OTSB indicated that the extent to which only essential (operating and administrative) procedure changes are necessary to be accomplished at the time of TS conversion would be dependent on how well these procedures are established.
NRR/OTSB further indicated that they would rely on the views of the Regional staff regarding the practicality of an alternate procedural control system.
NRR/OTSB indicated that it appears typical for licensees to begin training on the new technical specifications before they are approved to minimize the transition period for implementation.
Nevertheless, such plans should be coordinated with the Regional staff responsible for monitoring the training program and operator licensing.
NRR/OTSB cannot accurately estimate NRC review costs having only completed one conversion review; however, the staff recommends 1-2 PSY and
$ 50K for planning purposes (about
$ 500K).
NRR/OTSB does not recommend RGSE change their inservice testing (IST) program at the time of a RSTS submittal in order to take immediate advantage of reduced surveillance requirements.
The IST program for the Ginna Station should remain autonomous.
10.
The "NRR Priority Determination for NRR Review Efforts" ranking procedures provide the general framework for review responsibilities for NRR ~
NRR/OTSB has the lead responsibility for TS conversion reviews with support from the other NRR branches as needed.
Enclosure 1 is a list of meeting attendees and Enclosure 2 is a copy of the meeting agenda and discussion material.
Enclosures:
1.
List of Attendees 2.
Meeting agenda and discussion material cc w/enclosures:
See next page Ally'. Johnson, Project Hanager Prospect Directo te I-3 Divisive-of-R actor Projects I/II
R.E.
Ginna Nuclear Power Plant CC:
Thomas A. Hoslak, Senior Resident Inspector R.E.
Ginna Plant U.S. Nuclear Regulatory, Commission 1503 Lake Road
- Ontario, New York 14519
,. Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Ms.
Donna Ross Division of Policy Analysis E Planning New York State Energy Office Agency Building 2 Empire State Plaza
- Albany, New York 12223 Charlie Donaldson, Esq.
Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Nicholas S.
Reynolds Winston 8 Strawn 1400 L St.
N.W.
Washington, DC 20005-3502 Hs.
Thelma Wideman
- Director, Wayne County Emergency Management Office Wayne County Emergency Operations Center 7370 Route 31
- Lyons, New York 14489 Hs.
Mary Louise Heisenzahl Administrator, Monroe County Office of Emergency Preparedness 111 West Fall
- Road, Room 11 Rochester, New York 14620 Dr. Robert C. Hecredy Vice President, Nuclear Production Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649
Enclosure 1
List of Attendees NRC AND COOPERATIVE EFFORTS GROUP IMPROVED STANDARD TECHNICAL SPECIFICATIONS R.
E.
GINNA NUCLEAR POWER PLANT OCTOBER 18, 1993 Allen R. Johnson Ronnie Lo Name USNRC NRR PDI-3 NRR OTSB Title L. B. Marsh C. I. Grimes Gary Krieser Ro er 0. Anderson Allen Hansen Richard Laufer Richard Pulec Dean Tilly K. R. Cotton W.
R. Butler C.
W.
Su s
Marsha Gamberoni Tom Lordi Randy Whetsel Calvin W.
Moon Robert C. Mecredy Hark Flaherty NRR DRPW NRR OTSB WIS Electric Northern States Power NRC NRR DRPW NRC NRR DRPW Wise. Public Service NSP Monticello NRR PDI-3 NRR PDI-3 Westin house NRR DRPW Westin house NUS
'RR/OTSB VP, Ginna Nuclear Production RG&E, Licensin
Enclosur~.
?
ROCHESTER GAS R ELECTRIC CORPORATION R.E. GINNANUCLEAR POWER PLANT POTENTIALLIMITEDCONVERSION TO REVISED STANDARD TECHNICALSPECIFICATIONS (NUREG-1431)
Meeting With NRC Technical Specification Branch One White Flint North Rockville, MD October 18, 1993
AGENDA I.
Introduction R. Mecredy Attendees
~
Purpose of Meeting II.
Conversion Approach Under Consideration G. Wrobel
~
Background
~
Proposed Approach
~
Cost Benefit Study
~
Questions for NRC III. Potential For Two-Loop Cooperative Effort -- M. Flaherty IV. Summary - R. Mecredy
ATTENDEES FROM WESTINGHOUSE TWO-LOOP UTILITIES NAME Robert Mecredy George Wrobel Mark Flaherty Roger Anderson Gary Krieser Rick Pulec TITLE VP, Ginna Nuclear Production Manager, Nuclear Safety &. Licensing Nuclear Safety &. Licensing Engineer Director, Licensing &. Mgmt Issues Manager, Regulatory &. Industry Affairs Superintendent, Licensing and Systems COMPANY RGRE RG&E NSP WEP WPS
PURPOSE OF MEETING I.
Present Proposed Approach For Conversion To Revised Standard Technical Specifications (RSTS) For Ginna Station II. Obtain NRC Feedback For Cost Benefit Study
~
Verbal
~
Written III. Discuss Potential For Two-Loop Plant Cooperative Effort
BACKGROUND I.
Reasons For Considering RSTS Conversion:
~
Custom TS "Issues":
format and structure (not user friendly) limited bases information conservative
~
Numerous Line-Item Improvements Available (e.g.,
- TOPS, NUREG-1431, GL 93-05)
Difficultyin Obtaining TS Changes II. Concerns:
Cost
~
Increased Requirements
PROPOSED APPROACH I.
Generate "Split Report" Consistent With TS Policy Statement II.
Implement Numerous Line-Item Improvements III. Convert Remaining Items To RSTS Format IV. Add Limited New Surveillance Tests and Action Statements.
In General:
No new requirements willbe added Current requirements "inconsistent" with NUREG-1431 willnot be changed
EXAMPLES OF DIFFERENCES WITH NUREG-1431 I.
No Current Ginna Specification:
~
Containment Temperature
~
RCP Seal Injection Flow
~
Main Feedwater Isolation and Regulation Valves
~
S/G Atmospheric Dump Valves
~
ECCS Requirements Below 350'F
~
Hydrogen Recombiners
~
Remote Shutdown System Ultimate Heat Sink II.
Differences With NUREG-1431:
~
Only One Pressurizer Heater Currently Required (Versus Two)
Current AOT for One D/G is 7 Days (Versus 3 Days)
Can Operate Indefinitely With One Offsite Source Unavailable Provided Both D/Gs Available (Versus 3 Day Limit)
COST BENEFIT STUDY I.
Conversion Must Be Cost Justified II.
Anticipated Costs:
~
Internal Resources For Conversion Impact on Training
~
Procedure Changes
~
NRC Review Fees III. Anticipated Benefits:
~
"Hard" Dollars Reduced Surveillance Testing
~
"Soft" Dollars Less Restrictive Requirements ("Insurance" )
More Efficient Processes (e.g., 50.59s, Operator Training and
Response
to Circumstances)
QUESTIONS FOR NRC 1.
Is proposed approach acceptable?
2.
What is the potential for the NRC adding new requirements or changing the current requirements for Ginna Station?
3.
The following is the most cost effective schedule for implementing the proposed approach.
This is due to the S/G Replacement scheduled for 1996, conversion to 18 month cycles and-optimized use of the training program.
Can the NRC support this schedule?
Item Make Final Decision To Proceed Initiate Program Provide NRC and Training With Proposed TS Obtain NRC Approval Implement New TS Date
~
12/93 1/94 1/95 1/96 6/96
QUESTIONS FOR NRC (Continued) 5.
NUREG-1431 was written for a 4-Loop Westinghouse plant with a solid-state protection system design versus a 2-Loop plant with a relay protection system design.
What impact would this have on the NRC review?
How would these type of discrepancies be resolved?
6.
Changing procedures is a significant internal cost.
RGkE would like to only change "essential" procedures (e.g.,
Operating and Administrative) at the time of conversion and change the remaining procedures during their periodic review. A cross-reference between the current and converted TS would be provided at the beginning of the converted TS document until all procedures were updated.
Does the NRC have any concerns with this approach?
What type of enforcement action would be expected for TS procedural violations in the short-term following implementation?
QUESTIONS FOR NRC (Continued)
RG&E would like to begin training Operations staff on the converted TS prior to NRC approval (mainly new licensed operator classes).
This is the most efficient use of internal resources and allows for potential problems to be resolved prior to final NRC approval.
Does the NRC has any problems with this approach?
RG&E estimates an NRC review cost of approximately $250K.
Is this a reasonable estimate?
Ifso, this is the highest individual cost for conversion and not under RG&E control.
The TS Policy Statement explains that requirements reallocated from TS "may be changed or deleted in conjunction with the filing of individual TSs".
Can RG&E change the IST Program for Ginna Station at the time of the submittal in order to take immediate advantage of reduced surveillance requirements (e.g., monthly to quarterly pump testing)?
QUESTIONS FOR NRC (Continued) 10.
What NRC branches will review our submittal?
If other than TS Branch, RG&E would like their concurrence prior to proceeding.
POTENTIAL FOR TWO-LOOP COOPERATIVE EFFORT I.
Purpose of Two-Loop Cooperative Efforts Group Formed in September of 1992 by RGkE, NSP, WEP, and WPS to share resources to reduce operating, maintenance, and capital expenditures.
II.
Potential For Cooperative Effort
~
Implement above approach for Two-Loop Plants Develop generic Two-Loop submittal Select one lead plant for detailed review
~
Each plant must cost justify the conversion.
Ginna currently has the most incentive since other plants have already implemented several of the available line-item improvements.
~
Would a combined effort change NRC responses to any of the above questions?
SUMMARY
I.
Written Response to Questions and Documentation of Meeting Minutes II.
RG&E (and Two-Loop Plants) Must Complete Cost Benefit Study Before Preceding III. RG&E Expects to Make Decision In December
DISTRIBUTION: (Enclosure 2*)
Docket=Fi-le"-
NRC
& Local PDRs*
PDI-3 Reading*
T. Hurley/F. Hiraglia J.
Partlow S.
Varga J.
Calvo W. Butler A. Johnson*
S. Little OGC E. Jordan R.
Lo L. B. Harsh C.
Grimes A. Hansen R. Laufer K. Cotton H. Gamgeroni C.
Hoon A, Chaffee H. Boyle E.
Rossi ACRS (10)
V. McCree, EDO J. Linville,RI*