ML18284A132

Summary of Joint Nrc/Technical Specifications Task Force Owner'S Group Meeting, Held April 22, 1998, in Rockville, MD

ML18284A132
Person / Time
Issue date:	05/19/1998
From:	Beckner W Office of Nuclear Reactor Regulation
To:	Jennifer Davis Nuclear Energy Institute
References
NUDOCS 9805290314
Download: ML18284A132 (12)

Text

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ID f May 19, 1998 Mr. Jame, Davia Nuclear Energy Institute 1776 Eye Street, N. W.

Suite 300 Washington, DC 20006-2496 De11r Mr. Davia:

Enclosed 11 a aumma,y of the joint NRC/Technlcal Specifications Task Force (TSTF) Owner's Group meeting, v.tilch toc,k place at the Nuclear Regulatory Comml11lon In Rockville, Maryland, on April 22, 1998. Should the TSTF have any comments or queatJons, please do not hesitate to contact me on 301-415-1181 or by e-mail at wdb@nrc.gov.

Sincerely, Orlginal Signed By William D. Beckner, Chief Technical Sp1clflcatlon1 Branch Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See attached Attendees Usl PISIBIBUTIQN:

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UNITED 8TATEI NUCLEAR REGULATORY COMMISSION WAIHINGTON, D,C, ~

May 19, 1998 Mr. James Davi, Nuclear Energy ln1tltute 1778 Eye Street, N. W.

Suite 300 W11hlngton, DC 20006-2496

Dear Mr. Davis:

Endosed 11 a 1ummary of the Joint NRCITIChnJcal Speclftcation1 Tuk Force (TSTF) Ownef s Group mHtlng, which took place at the Nuclear Regulatory Comml11lon In Rockville, Maryland, on April 22, 1998. Should the TSTF have any commentl or questions, pleaae do not h11lt1te to contact me on 301-415-1161 or by e-mail at wdb@nrc.gov.

Sincerely, William D. Beckner, Chief Technical Speclflcatlon1 Branch Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See attached Attendees List

TECHNICAL SPECIFICATIONS TASK FORCE MEETING

SUMMARY

April 22, 1088 A meetln" between the Nuclear Energy Institute (NEI) Technical Specifications Task Force (TSTF),

and NRC staff was held on April 22, 1998. The attendeH 1111 Is Attachment 1..

The meeting was called to order and Introductions were made.

December 24, 1eez Meeting summary There were two objections to thi meeting summary of the December 2 and 3, 1997 Joint NRC!TSTF Owner's Group meeting as described below.

• lt11m 1 The TSTF disagre*d with the bullet describing discussion of TSTF-5~. The TSTF commented that because the Technical Specifications already contain Option A and the level of effort to Include both Options A and B Is too great, the revision they submit to NRC will only contain Option B.

• ltam 2 The TSTF wished to discuss the processes described In the last paragraph of the meeting summary, involving a new procedure to facilitate more productive meetings In the future, at

~ the conclusion of this meeting. The results of this discussion ~re contained at the end of this meeting summary under Generic Process.

NEI-Reauested Topics for Discussion .

The following involves discussion of travelers contained In NEl's March 20, 1898 letter to William D.

Bi,ckner, NRC (Attachment 2).

1. Changes to Battery Technical Specifications (TSTFs-198 through -203).

The NRC determined that because of conflicting views between NRC's Electrical Englnetring Branch, the IEEE Working Group, and the TSTF, a meeting Is warranted between these three entitles. Therefore, NRC's disposition Is to modify the traveler so that all parties involved are In agreer.1ent. The TSTF agreed to meet with represer .. atlves of NRC's Electrical Engineering Branch and the IEEE Working Group to produce a package that Is mutually acceptable, and submit a revision to NRC.

2. Changes submitted to support ITS conversions at Duane Amold and Brunswick (TSTFs-206 through 208).

TSTFs-207 and -208 were approved prior to the meeting. Because of higher priorities, the NRC had not had an opportunity to review TSTF-206 prior to the meeting.

3. TSTF-135 (RPS and ESFAS Instrumentation). NEI letter dated March 10, 1998 provldas changes to address NRC questions.

NRC stated that the proposed changes appeared to be based on preference or style rather than safety or clarity; the review effort to support the proposed changes could be significant: and

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lleen1ee support for the proposed change1 l1 not apparent. Therefore, TSTF-135 1 was rejeded.

However, the staff f11l1 that II could work with a propoul that addr111ed 4 Items of TSTF-135 If submitted Hparately. ThlH Item, ralate to the following TSTF-135 Ju1tlflcatlon numbers: (1) The port of Juatlftcatlon number.3 that addre1ae1 LCO 3.0.3; (2) Ju1tlflcatJon number 4, regarding the CDPabllity of rod withdrawal; (3) Ju1tlflcatlon number 5, regarding Source Range Monitors; and (4)

Justification number 7, regarding lntennedl1te Range Monitors. The staff finds a number of licensees wanting to u11 one or more of th111 propo11d ch1ng11.

4. Changes to travelers reaulting from prevlou1 meetings with the 1taff. Revl1lon1 forwarded February 20, 1998 (TSTF-024, Rev. 1, -027, Rev. 3, -038, Rev. 3, -103, Rev. 1, -105, Rev.

1, -113, Rev. 4, -116, Rev. 2, *125, Rev. 1, -134, Rev. 1, -151, Rev. 1, *154, Rev. 2, -163, Rev. 1, -176, Rev. 2, and-190, Rev. 1).

TSTFS-024, Rev. 1, -027, Rev. 3, *134, Rev. 1, and *178, Rev. 2 were ipproved; TSTF-163, Rev.

1 was modified to Include an addltlonal phrase In lnaert 7; and TSTFS-038, Rev. 3, which needs a more specfflc resolution, and-105, Rev. 1, which lhould be submitted on a pl1nt-1peclfic basis, w~re rejected prior to Utt meeting. During the meeting TST-=a-103, Rev. 1 wa1 recommended for rejeclJon by the NRC reviewer because It 11 perceived to be c:onfuslng and lncon1l1tent, and TSTF-154, Rev. 2 was recommendttd for approval by the NRC reviewer. Subsequent to' the meeting, TSTF-154, Rev. 2 was approved and TSTF-103, Rev. 1 w11 rejected. Because of higher priorities, too NRC had not had the opportunity to revlewTSTFs-113, Rev. 4, -116, Rev. 2, -125, Rev. 1, -151, Rev. 1, and *190, Rev. 1 prior to the meeting.

lha TSTF was given prior notification of the modific.atlon to TSTF-163, Rev. 1, and was able to make a revision and submit TSTF-163, Rev. 2, to NRC at the meeting. TSTF-163, Rev. 2, was recommended for approval by the NRC reviewer. Subsequent to the meeting TSTF-163, Rev. 2 w1111pproved.

5. Revisions to previously approved travelers (TSTFs-021, Rev. 1, -096, Rev. 1, -098, Rev. 2, and *161, Rev. 1).

TSTF-098, Rev. 2, was approved. Because of higher priorities, the NRC had not had the opportunity to review TSTFs-021, Rev. 1, -096, Rev. 1. and -161, Rev. 1 pnor to the meeting. The TSTF was requested to exercise discipline to estabii.:ih a very high threshold to proposing modifications to previously approved TSTFs.

6. Brief the Technical Spec1ficatlon1 Branch on recanUy submitted travelers (TSTFs-204, -212,

-213,-218, *217, *220, *221, *230, -232, -235, -238, -239, -243, *and *245).

TSTFs-216, -220, -221, and -230 were approved. Becauae NRC had not had the opportunity to review TSTFa-204, *212, *213, *217, *232, *235, *238, -239, -243, and *245 prior to the meeting, no briefing by NEI was necessary.

Qtbor Traveler Plsposltlon NRC has made disposition to other travelers not Included In NEl's March 20, 1998 letter as follows:

1 1n NEl'1 March 20, 1988 letter to NRC (Attachment 2), NEI referred to TSTF-135, Rev. 1.

Th1re wH no formal revision submitted to NRC. Hence, the NRC reference to TSTF-135 without the revision number.

TSTFs-23, Rev. 3, -156, Rev. 1, -158, Rev. 1, -162, -210, -214, -222, and 225 were approved.

TSTF-209 was dl1posltloned II modify to make the Bases In the BWOG STS consistent with the WOG and CEOG STS or the WOG and CEOG STS Baa11 consistent with the proposed BWOG Base, change. Either change would be acceptable by the staff.

TSTF-224 wa1 rejected. Based on recent Information on risk analyses, combinations of lnoperabllltlea can have 1ubtle Interactions for which a Configuration Risk Management Program provld11 lignlflcant Information. NRC recommended thal the TSTF lnterf11ce with the CE Owner's Group to Integrate Information leamed from their effort, on Improving ECCS system Completion Times.

TSTF-236 was rejected. The proposed change does not addreu an enor In technical speclflcations; It rather seeks operational flexibility regarding the ECCS system and reactor coolant pump semis.

Such a change appears to require more significant technical justification and extensive staff review.

TSTF-257 was rejected. In most technical specifications cases, a loss of function would defaula to LCO 3.0.3; In some cases, a specific action dlrectl the operator to go to LCO 3.0.3. In this proposed change, the shutdown track of the ACTIONS table would be a relaxation from LCO 3.0.3, because LCO 3.0.3 Includes a specific time to be In MODE 4 while the ACTIONS tabla doH not.

Other Discussion Topics NRC asked for a status of TSTF-111, Rev. 1. In July 1997, the NRC recommended the propoHd changes be modified. This TSTF was then discussed during the October 1 and 2, 1997 Owneir's Group meeting and again at the December 2 and 3, 1997 OWner's Group meeting. The NRC had ln~lcated that the propoaed change did not "fix" any Mbrol;en* technical specification and was not 1piaclflc. During thl1 meeting (April 1998), the TSTF 1tat1d that the,y believed the NRC was to provide* some lnfonnatlon to the TSTF. The TSTF agreed that they would contact the Instrumentation Branch to try to resolve the TSTF.

Tht TSTF asked to discuss a list of travelers that had been mentioned orally during the October 1 and 2, 1997 Owner's Group meeting. The meeting summary, dated October 21, 1997, shows that the TSTF Identified fourteen travelers for which they would like the NRC to assign priority rqvlew:

TSTFs-002, Rev. 2,-027, Rev. 2, -036, -037, -111, Rev.1, -135, -198, -199, -200, -201, -202, -203,

-204, and the then future TSTF-205. TSTF-205 w11 received by NRC In late November 1997.

Th11 NRC responded that during the December 2 and 3, 1997 Owner's Group meeting, there was agFNment between the NRC and the TSTF that each future meeting would be based on priorities documented In correspondence from NEI at least one month prior to the next meeting. For this meeting (April 1988), the NEI letter to the NRC dated March 20, 1998, ll1te:t TSTFs to be discussed at the meeting; It did not list the TSTFs referenced from the October meeting. Holt\'.aver, the NRC did provide the status of the referenced TSTFs prior to or during the April meeting, as follows:

Prior to the April meeting, In a letter to NEI, dated November 4, 1997, the NRC provided I modify disposition for TSTF-037, Rev. 1. The NRC letter to NEI, dated December 24, 1997, summarizing the December 2 and 3, 1997 Owner's Group meeting showed that NRC made disposition to TSTF-205 (modify) and 11 awaiting a revision from the TSTF. The TSTF commented that they would provide the ravlslon by the end of May 1998. During the April meeting, the NRC Informed the TSTF that TSTF*002, Rev. 2 had been referred to a technical branch, and TSTF-204 was pending TSB

mvlew. Thu1, as shown In this paragraph and above, the fourteen travelers the TSTF mentioned In the October 1987 meeting were dlacusaed prior to or during thl1 meeting.

Genodc proce11 Ther9 wu some dl1cu11ion regarding how lmporiant the generic review process h1 to the proe011 of plant conversion to the lrnproved St1ndard Technical Specification,. The conclusion was that It ta Important, but the conversion review maintain* higher priority 1tatu1 and requires more re1oul'Clls.

In an effo;t to make the generic review process more efficient, the NRC and TSTF agreed to the following:

• The TSTF will provide, In some priority order, a list of travelera, Including the subject and any comments, within one month from April 22, 1998.

• The TSTF will ensure there Is a need for the proposed changes submitted to NRC and that the proposed changes contain adequate justification.

• The NRC will, In general, contact the TSTF before rejecting proposed changes In order to ensure mutual understanding.

The TSTF asked NRC to provide feedback on travelers, such II the name of the reviewer assigned to travelers and when the travelers are referred to technical bl'lnch~s. NRC Is considering this request.

NRC acknowledges the need for a cursory review of proposed changes by the staff and feedbmck to TSTF within about one month.

The next meeting of the NRC/TSTF OWner's Group 1110 be scheduled at a future date, once NRC receives the TSTF'1 ll1t of travelers for priority review. NRC will coordinate with NEI to detennine a mutually convenient date.

Attachment 1 ATTENDEES LIST NRCITSTF OWNER'S GROUP MEETING April 22, 1998 NAME ORGANIZATION ADDRESS PHONE# E-MAIL ID James Davia Nuclear Energy 1778 Eye Street, NW 202-739-8105 jwd@nel.ort~

Institute (NED W11hlnaton, DC 20006 John Volkoff CEOG 1850 Cllvert Cllff1 Parkway 410-495-3649 john. volkoffl)2!BGE.

Lusbv MO 20657-4702 com Donald Hoffman EXCEL/TSTF 11921 Rockville Pike 301-984-4400 donalolh@

Suite 100 excelsvcs.

Rockvllle MO 20852 com Bryan Ford BWROG Entergy Services, Inc. 601-368-5792 bford@

1340 Echelon Parkway, ontergy.com M-ECH-860 J1ck1on MS 39213-8298 Noel Clarkaon BWOG Mall Code: ON03RC 884-885-3077 ntclarki@duko-Hlghwaya 130 & 183 (29678) energy.com P.O. Box 1439 Seneca, SC 29679-1439 Dennis E. .Buachbaum 254J.897-5851 dbuschb1@

tuelectrlc. com Dan Williamson W:EXCEL 271 Glenlyon Or. 904-272-5300 dwdan@

Ch1rt11 Boyce EXCEUOELTA Oranae Park FL 32073 609-866-5624 man.com kannaore@

WOECo min.com Glen Ohlemacher Detroit Edison 6400 N. Dixie Hwy 313-586-4275 ohlemucher@

Newport, Ml 48186 detroittldlson.com Ed Forrest NUSIS 301-258-2456 eforrest@

sclentech.com William Beckner NRCITSB/AOPR NRC 301-415-1161 wdb@nrc.gov Mark Relnh~rt NRRITSB/ADPR NRC 301-415-1181 fmr@nrc.gov Debbie John1on NRRITSB/ADPR NRC 301-415-3060 dlj@nrc.gov '

Carl Schulttn NRRITSB/AOPR NRC 301-415-1192 c111@nrc.gov Bob Tjader NRRITSB/ADPR NRC *301-415-1187 trt@nrc.gov TIida LJu NRCITSB/ADPR NRC 301-415-1315 tyl1@nrc.gov

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Attachment 1 ATTENDEES LIST NRC/TSTF OWNER'S GROUP MEETING April 22, 1898 NAME ORGANIZATION ADDRESS PHONE# E-MAIL ID NanetteGIIIH NRR/TSB/ADPR NRC 301-415-1180 nvg@nrc.go,,

M1ggalean Weston NRR/TSB/ADPR NRC 301-415-3151 mww@nrc.gov N. B. (Tommy) Le NRR/TSB/ADPR NRC 301-415-1458 nbl@nrc.gov I I

Robert J. Giardina NRR/TSB/ADPR NRC 301-415-3152 none Craig Harbuck NRR/TSB/AOPR NRC 301-415-3140 cch@nrc.gov

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. IIUClfAI ENEUY INSTITUTE March 20, 1998 Mr. Mark Reinhart Technical Specifications Branch Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Code 0-13 H15 Washington, DC 20555 PROJECT NUMBER: 889

Dear Mr. Reinhart:

At our next meeting the Technical Specification Task Force is ready to discuss technical issues related to the following travelers.

1. Changes to Battery Technical Specifications Traveler Title Additional Information TSTF-199 Delete Maintenance Surveillance Ready to respond to staff' technical issues TSTF-201 Omit battery "Conditional Evaluations" Ready to respond to staff technical issues 'I TSTF-203 Add Bases for 3.8.6 Actions Note Ready to respond to staff TSTF-198 Unlimited use of battery charsinr technical issues Added information per NEI TSTF-200 current in lieu of sDecific navity Unlimited use of battery modified letter dated March 10, 1998 Added inf'ormation per NEI oerformance dischar1re teat

• letter dated March 10 1998 TSTF-202 Revise battery Surveillance weekly Added information per Frequencies NEI letter dated March ll.O, 1998  !

17Po I ITlll1. NW IUITI *oo WAIHINOTON, DC 2000t*a,01 PHONI 202 PH 1000 JAi 202.PIS .* 019 www.nel.org

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Mr. Mark Reinhart March 20, 1998 Pa1e2

2. Cban1es submitted to support ITS conversions at Duane Arnold and Brun1wicl!t Traveler Title Status TSTF-206 Applicability's of Suppre11ion Pool Submitted February 18, Averare Temoerature 1998 TSTF-207 Completion Time for Restoration of Submitted February 18, MISV Leaka1re Rate 1998 TSTF-208 Extension of time to reach Mode 2 in Submitted February 18, LC03.0.3 1998 (We understand this item is aooroved)

3. TSTF-135, Rev. 1, 3.3 *( RPS and ESFAS Instrumentation)

NEI letter dated March 10, 1998 provides changes to addreSB NRC questions.

4. Changes to travelers resulting from previous meetings with the stafl'. Revisions forwarded February 20, 1998.

Traveler Title Add~ '.ional Information TSTF-24, Rev. 1 Delete the details on updating the This revision addressee an tarret tlux difference. NRC reiection of Rev. 0 TSTF-27, Rev. 3 Revise SR frequency for Minimum Thia revision addressee an Temperature for Criticality NRC rejection of Rev. li.

TSTF-36, Rev. a Addition of LCO 3.0.3 NIA to Revised to mddreas NRC shutdown electrical power comments. The expanded specifications clarification was accepted by E. Tomlinson during the Brunswick ITS review.

TSTF-103, Rev. 1 Add bracketed information to LCO Added information on 3.0.4 inappropriately deleted by applicability of change Rev. 0 Chanre BWR-26 reauested by the NRC.

TSTF-105, Rev. :! Remove the details of performing Responds to NRC rejection an* RCS tlow measurement of Rev. 0 TSTF-113, Rev. 4 Eliminate Shutdown to MODE 4 for Addresses NRC questions b1ooerable PORVa f'!L Rev. 3 TSTF-116, Rev. 2 RCS Inventory Balance SR: Steady Supplies NRC 1uggested State Clarification chann on Rev. 1 TSTF*125, Rev. 1

• Delete EFPD Definition Addresses NRC comments onBev.1 TSTF-134, Rev. 1 Add Note Crediting CEA Drop Time Addreaaea NRC commeiats SR for CEA Trip from 60% and conecta editorial Withdrawn SR errors.

Mr. Mark Reinhart March 20, 1998 Pages Traveler Title Additional Information TSTF-151, Rev. 1 PORV Operability Clarification Incorporates NRC requested changes on Rev.O TSTF~154, Rev. 2 Revise Criteria Discussions of Incorporates NRC Special Teat Exceptions requested clumps on Rev. 1 TSTF-163, Rev. 1 Minimum vs. Steady State Voltage Addresses NRC comments and Frequency on Rev. 0. Will discuss comments in Deborah Johnson email of March 18, 98.

TSTF-176, Rev. 2 Revise SR 3.1.4.1 to delete SR Note In incorporating NRC requested editorial changes,discovered solution to problem consistent with other PWR NUREGs.

TSTF-190, Rev. 1 Remove reference to inadvertently Revised to mddreBS NRC bYDassinr a redundant channel comments.

5. Revisions to previously approved travelers. Modifications should be easy to review.

Traveler Title Additional Information TSTF-21, Rev. 1 Make RHR

• Low Water Level Rev. 0 was approved by Surveillances consistent between NRC. This revision PWRNUREGs addresses the same technical problem, but corrects it in a way that makes the PWR NUREOs consistent.

TSTF-96, Rev. 1 Delete the initial performance of the Rev. 0 was approved by the boron concentration measurement NRC. Thia nvilion include11 with no source ran1e detectors NUREG-1430 in the chanre.

TSTF-98, Rev. 2 Relocate the Fq(z) penalty factor to Rev. 1 was approved by the theCOLR NRC. Thia change adchl a Reviewer's Note to the Bases to clarify

-* imolementation details.

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• Mr. Mark Reinhart March 20, 1998 Pe1e4 Traveler Title Additional Information TSTF-161, Rev. 1 SI Beference Applicability Bev. 0 approved by NRC.

Editorial correction of column title.

6. The Technical Specification Task Force ii also prepared to brief the Tecbufoal Specification Branch on the following recently aubmitted travelers that propose corrections to technical apecificationa (letter dated March S, 1998): TSTF-204; TSTF-212, TSTF-218, TSTF-216, TSTF-217, TSTF-220, TSTF-221, TSTF-280, TSTF-232, TSTF-235, TSTF-238, TSTF-239, TSTF-243, and TSTF-245.

If you have any questions, please contact me at (202) 739-8105.

JVG/rs c: Deborah L. Johnson