ML19056A427
| ML19056A427 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 02/21/2019 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Honcharik M | |
| Shared Package | |
| ML19056A435 | List: |
| References | |
| Download: ML19056A427 (3) | |
Text
2018 Review.
Busy year, 25th anniversary of TSTF.
5 travelers approved, most since 2011.
Areas to improve- more accurate estimates hours to be charged. NRC estimates higher than actuals for traveler reviews.
Schedules are optimistic, were usually 50% overdue. But under on hours. Idea for improvement
- perhaps have a project plan discussion during the pre-submittal meetings. Open to change and willing to make improvements to have process work better.
Providing copies of T travelers.
Wes Sparkman - NRC request to have T travelers provided for information (requested by New Reactors). T travelers are either bases only changes or consistency across industry, but not have funds for traveler reviewed. Bases only T travelers are usually rolled into NUREG upon revision. Consistency T travelers are usually implemented via LAR. Vics idea - add as a topic to quarterly agenda for our awareness and not be caught off guard when an inspector calls.
Other process issues.
When does NRC review TS Bases changes? Vic - 2 cases: Design cert and Travelers (not adoptions). Brian Mann - feels that during STS conversions. Vic - we look at the bases, but technically dont approve them. Bases may be mentioned in an RAI, but its not a question on the Bases only.
Traveler adoption issues - none.
TSTF-541 Discussed Matts mark-up, both parties want to reach agreement today - if cant then likely withdrawal. Matt provided additional pen&ink changes (comments from another reviewer).
See mark-up for agreed upon wording in the model LAR. Next steps: TSTF will make revisions to model LAR and corresponding changes to the traveler justification and send up a draft. If needed well have another call/meeting to discuss further before submittal. TSTF estimates draft to us by the end of March 2019.
TSTF-542 TSTF-505 Dave Gullot - Surprised by acceptance review questions - industry felt they should have been RAIs instead, but they worked through and responded. Taking lessons learned from these questions and applying to rest of Exelon fleet and sharing with industry to improve future submittals.
Brian Mann- at next quarterly they will update planned submittals of TSTF-505 and 50.69.
Feedback from Steve Dinsmore - rev 2 traveler table 1 (items requiring additional justification) -
difference of opinion on what is additional justification. ECCS example (3.5.2.B) - It starts getting confusing if one or more are out (when is more all). If any confusion at all on what they are applying the RICT too - they should explain. APLA Staff was expecting to see this information in a Table 1 of the LAR, but was misunderstood the format. The information should be in Enclosure 1, not a Table 1.
Michelle get Ed to let reviewers know that the LAR will not have a table 1, but that the information table 1 calls out, will likely be in the LAR Enclosure 1 and not necessarily in a tabular format.
Commitment letter TSTF-554 Pressure Boundary leakage (late March 2019 for submittal). Draft will be sent by mid-March.
TSTF-542 Russ Haskell - nothing remarkable to report. Will gain information after outages that may provide more items to consider for the supplement/improvement traveler. TSTF has reached out to licensees for feedback on improvements. Feel they have a pretty good handle on what the issues are, included outage feedback from several plants already. Vic - did 542 give benefit that industry expected? Answer is yes, positive feedback from licensees. 3rd quarter 2019 for follow-on traveler.
TSTF-566 - many plants planning to submit in 2019 and 2020. Peak in fall 2019.
TSTF-568 - Ryan Joyce reviewed presentation/handout. NRC - is what is proposed aligned with 10 CFR 50.44 (combustible gas control)? Steve Jones - agree with the concept provided the time is limited. TSTF will revise based on todays feedback. Is applicability of Mode 1 appropriate or should it be Mode 1 and Mode 2? Should completion time for Mode 2 be changed? Steve Jones pointed out that the TS Bases for 3.6.3.2 should be changed to reference criterion 4, instead of criterion 2 since 50.44 update. Staff suggested the TSTF look at a recent plant-specific RAI, which may help them understand the issue. Staff is okay with new proposed format. TSTF plans to evaluate and get back to us - it may take a while, TSTF requested to put this review on hold for now. We should hear back from them before the next meeting.
TSTF-569 - with EICB BC staff is resolving his comments. Move to end of March for DSE date.
Traveler priorities - See handout.
Management Discussion Time-
- TSTF-541 Brian Mann said VERY productive discussion today with success path.
- Target rock - safety valve traveler. Ryan Joyce - right now the traveler has setpoints in the TS. Revise that requirement to verify the SL is not exceeded (or SRVs will ensure the SLs are met). Sent out to OGs and SRV committee - have gotten good comments, but no show stoppers. We believe will be a success path to avoid future LERs. TSTF
looked through history - 73 LERs, none determined that the SLs would have been met.
Mirelas feedback - sound like they are heading where we thought they would go.
Worried about timeline, been around since 1990s. Time is factor. Plan to submit traveler by 2nd quarter 2019. This is a TS change, but parallel technical work being done.
Craigs issues - bring up by way of introduction, not expecting discussion.
RPS Test boxes (TSTF-573-T) - Vic to check with Tarico and Region and get back to TSTF.
Future traveler submissions - SGTube - April 2019 more detailed meeting with materials staff, then pre-application meeting. Caroline will be the lead.
Next meeting dates -