ML20137Q904

Forwards Summary of TSTF Meeting in Rockville,Md on 970318 & Agenda Package Distributed During Meeting

ML20137Q904
Person / Time
Issue date:	04/08/1997
From:	Charemagne Grimes NRC (Affiliation Not Assigned)
To:	Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
NUDOCS 9704110166
Download: ML20137Q904 (15)

Text

...

April 8,-1997 Mr. James Davis '

Nuclear f gy Institute ,

1776 Eye set, N.'W.

Suite-300

' . Washington, DC 20006-2496 l

Dear Mr. Davis:

. l The purpose of.this letter is to transmit a summary of the Technical Spec"ifications Task Force'(TSTF) meeting, which took place at'the Nuclear Regulatory Commission in Rockville, Maryland, on March 18, 1997, and the Agenda package distributed during the meeting.

Sincercly, I

Original Signed by:

C. I. Grimes Christopher I. Grimes, Chief .

Technical Specifications Branch Associate Director for Projects Office of Nuclear Reactor Regulation i

Enclosures:

As stated cc: D. Hoffman, TSTF '

B. Mann, CE0G A. Maron, BWROG H. Pontious, WOG D. Wuokko, BWOG C. Szabo, BWOG B. Ford, BWROG NDISTRIBUTION:

FILE CENTER PUBLIC RZimmerman rga CGrimes

] fU ISB Staff Nec. tin He d es DOCUMENT NAME: C \DLJ\MTCSUM03.97

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,f* "%,."q UNITED STATES i

' NUCLEAR REGULATORY COMMISSION  !

5  ! WASHINGTOPl. D.C. 30 6 0001 April 8, 1997

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Mr. James Davis Nuclear Energy Institute  !

1776 Eye Street, N. W. 1 Suite 300 l Washington, DC 20006-2496 l

Dear Mr. Davis:

l The purpose of this letter is to transmit a summary of the Technical 1 Soecifications Task Force (TSTF) meeting, which took place at the Nuclear Regulatory Commission in Rockville, Maryland, on March 18, 1997, and the l Agenda package distributed during the meeting.

1 Sincerely, 1 1

A ,

Christopher I. Grimes, Chief  ;

Technical Specifications Branch '

Associate Director for Projects i Office of Nuclear Reactor Regulation

Enclosures:

As stated cc: D. Hoffman, TSTF B. Mann, CEOG

A. Maron, BWROG

, H. Pontious, WOG D. Wuokko, BWOG i C. Szabo, BWOG B. Ford, BVROG l l

I

TECHNICAL SPECIFICATIONS TASK FORCE MEETING

SUMMARY

March 18, 1997 A joint meeting between the NEI Technical Specifications Task Force (TSTF),

representatives of the Combustion Engineering owners Group (CE0G) Risk-

• Informed Technical Specifications (RI-TS) pilot program, and the NRC staff was held on March 18, 1997. The attendees were:

' James Davis, NEI .

Christopher Grimes, NRC/TSB Clint Szabo, Entergy/BWOG Deborah Johnson, NRC/TSB Harold Pontious, Comed /WOG Mary Lynn Reardon, NRC/TSB Brian Mann, BGE/CEOG Jack Foster, NRC/TSB Bryan Ford, Entergy/BWOG Nanette Gilles, NRC/TSB Donald Hoffman, EXCEL Services Cari Schulten, NRC/TSB Donald Chung, NUS LIS Mark Rubin, NRC/SPSB Ray Schneider, ABB-CE John Flack, NRC/SPSB Mike Schoppman, FP&L-Bethesda Millard Wohl, NRC/SPSB Jerry Wermeil, NRC/HICB Ian Jung, NRC/SPSB Larry Kopp, NRC/SRXB Howard Richings, NRC/SRXB Chu Liang, NRC/SRXB CEOG RI-TS Pilot Mr. Grimes opened the meeting bv describing a staff initiative to better manage licensee commitments by including a license condition for specific commitments relied on by the NRC in licensing actions. The CE0G RI-TS pilot, scheduled to be completed by March 31, 1997, relies on a programmatic commitment to manage the plant configuration when combinations of equipment are inoperable. Two viable options were described to avoid further delay in the completion of the license amendments for the pilot: (1) a license condition or (2) an administrative control that would ensure enforceability for the minimum elements of configuration control.

The CE0G pilot group had a separate meeting to decide between the two options. The result of this meeting was a proposed Administrative Control program description RI-TS Configuration Management (Attachment 1). The TSTF promised to provide comments on the proposed Administrative Control within a

week so that a consensus version of the program description would be i completed in time for the CE0G pilot completion date.

l Mr. Grimes commented that, while changes in compliance with the maintenance i rule (650.65) may result in different controls for configuration managment in

the future, the staff expects to develop an Administrative letter in the near future identifying procedures for memorializing licensee commitments in license conditions or administrative controls.

Irug))er DiscussioJ1 Representatives from the Reactor Systems Branch (SRXB) joined the discussion for three unresolved travellers as follows:

4 2

TSTF MEETING

SUMMARY

(continued) Page 2 TSTF-67: Shutdown Margin Definition. SRXB representatives described the development of the form of the present STS, and asked why the steamline break analysis is very different between CE and Westinghouse. NRC requested CE0G to supplement their explanation for topical report methodology. A separate meeting will be arranged between CE and NRC to discuss the resolution of the proposed change to NUREG-1432.

TSTF-87, R.1: The staff asked why, in Rev. 1, the TSTF old not address the comments on the proposed change to revise "RTB open" with "CRDM de-energized," and only provided editorial changes. The TSTF indicated that the editorial changes were in process before the NRC comments were received, and they had planned to address the comments in the Rev. 2 package.

TSTF-113, R.1: The staff commented that the justification for " releases i during a SGTR event are not expected below 500 degrees )

Fahrenheit T-avg." was not apparent. Rev. I did not address the comments, but only made editorial changes. The TSTF stated that Rev. 2 and Rev. 3 have been developed, but not yet submitted to NRC. SRXB described the evaluation basis that should be addressed in the revised justification.

1 Representatives from the Instrumentation and Control Branch (HICB) joined the I discussion for two unresolved travellers as follows:

TSTF-39 & -64: Both of these STS changes relate to the definition of Channel Functional Terting (CFT). In a separate action resulting from an STS conversion lesson, the NRC prepared a  ;

proposed standard definition for CFT (Attachment 2). The l staff requested that the TSTF modify their proposed STS changes or withdraw them and submit separate changes to the l

STS to incorporate consistent language for I&C testing. '

The staff suggesteo that another meeting be arranged in the near future to ensure an effective resolution of this generic problem.

Discussion Travellers The status of all travellers was discussed and a summary of those that were Modified or Rejected as of 1/30/97 is included as Attachment 3.

Conversion Lessons Two process sup4naries were issued with the Meeting Agenda, the Conversion Review Process and the ITS Implementation Checklist. Because there was

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~TSTF MEETING

SUMMARY

-(continued). Page 3 insufficient time to discuss these items, the TSTF was asked to review these summaries and be prepared to discuss at the next TSTF. meeting. In addition, Mr. Grimes suggested that the TSTF review recent license amendments and

' Notices of Enforcement Discretion at Peach Bottom and San Onofre for addition conversion process improvements.

NRC is currently sending Wordperfect files of the approved STS changes (working drafts) to the TSTF via E-mail. This practice consumes a great deal ,

of space on the NRC Local Area Network.. Therefore, NRC' requested that TSTF immediately save the files and acknowledge receipt to NRC so that the e-mail files could be removed from the LAN. The NRC also suggested that other means of communicating the STS changes'should be developed to minimize system i demands for handling the working drafts. ,

Ooerator Responsibilities and 655.4 -

During the completion of the Zion conversion amendment, the licensee identified language in the definitions in 655.4 for " actively perform duties of operator ... defined in the technical specificaations;" however, after removing the staffing requirements in 650.54(m) the STS no longer includes an explanation of active operator responsibilities. Accordingly, a provision is being added to the Zion TS to address this issue, which the staff will forward to the TSTF until this issue can be more completely resolved by rulemaking.

Data Exchanaq The NRC and TSTF are continually pursuing a means to equitably exchange data contained in the status report for up-to-the-minute reporting. A meeting will be set up in the near future with Donald Hoffman, Excel Services; Brian Mann, CE0G and Clint Szabo, BWOG (creators of the TSTF database), and Debbie Johnson and a representative from the Office of Information Resources Management, NRC, to try to resolve this issue.

Aaenda for Future Meetina j i

The next meeting of the NEI-TSTF and NRC will be held on Thursday, April 17, 1997. New agenda topics will include conversion lessons and feedback process (handouts from 3/18/97 meeting), and Standard Generalized Markup Language (SGML) issues (particularly the future of electronic formatting of the Standard Technical Specifications).

rv .

i AGENDA TSB/NEl TSTF Meeting

i March 18,1997 l Room 0-12 B 11 )

l I o Summary of January 30,1997 rnesting  !

o CEOG Risk-informed TS pilot o Status of pending travellers o Conversion lessons and feedback process o Operator responsibilities and 155.4 4

o Regulatory information Conference o Conclusion (C. Grimes)

o Agenda for future meeting

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Conversion LeSoons e Peach Bottom relay testing (OA find) e- San onofre NOEDs' e Conversion process & NEl 96 06 Guidance  !

e Transmission of " working draft travelers" i

Discussion Travelers

1. Topic l

39 l

& HICB: definition of CFT and conversion lessons 64  :

51 Fuel Handling SRP resource limited 52 Status of TSTF revision of Appendix J options 67 SRXB: need for changed definition of shutdown margin for CE plants 71 Need for and structure of 3.0.6 examples l

87 SRXB

rnodifications did not address issue

., 88 Use of " required" head bolts i j 93 Modification did not include note in SR i

103 Usefulness of " optional" versions of LCO 3.0.4 113 SRXB: Recycled or appealed PORV change does not address technicalissue j 115 IEEE status of battery testing and likelihood of near-term resolution 120 ASTM standard for fuel oil referred to EMCB - filter testing lesson l

123

& BWOG use of consistent terminology

125 134 SRXB: CE construction and editing of a "not required" note

135 HICB

substantial changes to RPS & ESFAS format ,

154 Minor Bases consistency issue i

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TSTF-39 TSTF-64 March 1997 REVISED STS DEFINITION FOR CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all required components (e.g., bistables, rnester relays and slave relays) in the channel, and other components that could affect OPERABILTlY of the channel, such as alarms, displays, and channel failure trips. Channel relay OPERABILITY shall be verified by demonstrating that at least one contact associated with the relay has changed position. All remaining required relay contacts shall be tested during the LOGIC SYSTEM FUNCTIONAL TEST. The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel stsps, so that the entire channel is tested.

i

The following other STS definitions should be reviewed for corresponding language l changes to ensure consistencyin allof the terms used for testing of

} instrumentetton and controls systems:

NUREG-1430 CHANNEL CALIBRATION l

CHANNEL FUNCTIONAL TEST

NUREG 1431 CHANNEL CAllBRATION i CHANNEL OPERATIONAL TEST

TRIP ACTUATING DEVICE OPERATIONAL TEST

NUREG-1432 CHANNEL CAllBRATION

! . CHANNNEL FUNCTIONAL TEST l

l NUREG-1433 CHANNEL FUNCTIONAL TEST CHANNEL CAllBRATION LOGIC SYSTEM FUNCTIONAL TEST NUREG-1434 CHANNEL FUNCTIONAL TEST CHANNEL CALIBRATION

LOGIC SYSTEM FUNCTIONAL TEST l

l l

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. Conversion Review Process

1. Application receipt: arrange distribution, and confirm diskettes and contractor receipt.

2. Screening review conclusion.

3. Process RFP & SOW for technical assistance contract.

4. Coordinate LA inventory & beyond scope issues identifed in application - list parallel actions.

5. Review section and contractor results to identify significant issues and information needed to complete review.

6. Verify status of related TSTF packages; recommend action to expedite review or resolve plant specific action.

7. Compare issues & additional information needed for SE.

8. Send issues to licensee.

9. Resolve issues.

10. Application update.

11. Assemble SE & relocation table.

12. Review draft SE.

13. Send draft SE to licensee.

14. Resolve comments & request certified final TS.

15. Assemble amendment.

16. Review implementation plan, license conditions and issue revised QAP.

17. Verify no recent conversion lessons or broken STS will result in the need for NOED or amendment upon implementation.

18. Issue amendment.

, ITS Implementation Checklist

1. Depending on the Amendment issuance Date, OGC should be requested to identify any legal sufficiency concerns (usually one or two for the beyond scope changes) and a meeting with OGC & TSB should be held to determine if resolution of the concern could impact the Amendment issuance Date.

2. The Licensee should ensure that the planned Amendment issuance Date allows t sufficient time before the planned Effective Date to distribute controlled copies of the new ITS, complete procedure changes and/or establish procedure change controls, and complete operator training requirements. The Effective Date should allow sufficient time before the next scheduled outage to avoid interfering with the outage schedule.

3. As part of the certification review for the Final ITS, the licensee should determine whether all of the SRs and LCOs will be up to-date upon the Effective Date. Any exceptions (for exampfe, new SRs), should be noted as License Conditions, with an appropriata gpiication from the Licensee.

4. Prior to the Effective Date of the new ITG, a briefing should be arranged for Licensee to present the implementation Plan to the Region, particularly the Resident inspector and Section Chief. While the Resident and Region may not be very familiar with the ITS at this point, it is important for them to understand what the Licensee intends and how the new ITS requirernents will be enforced. Other Region personnel (up to and including the Regional Administrator) may want to attend, but the level of participation should be a Regional decision.

1 e The Licensee should explain how SR schedules and preexisting plant I conditions will be treated at the Effective Time; the clocks can reset or l continue, provided the Licensee defines the practice in advance.

e The Li;ensee should explain how they have qualified each Shift for the new ITS, and what aids have been established to assist the operators through the transition.

l e The Lice,nsee should explain their performance objectives relative to i implementation; for example, the typical objective is to complete implementation, the procedure changes, and all the compliance verification work with no LERs.

5. Upon issuance of the ITS amendment, promptly arrange for the Licensee to verify the ITS accompanying the amendment are correct, and for copies of the ITS to be delivered to the Resident inspecter at the same time the Licensee is making their controlled copies.

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Confiauration Risk Manaaement Proaram This program provides a proceduralized risk-informed assessment to manage the risk associated with removing equipment from service to perform maintenance activities. The  !

program applies to techaical specification structures, systems, or components for which a I risk-informed extansion of the (allowed outage timal [ Completion Time] has been granted. l The program shallinclude the following elements: )

a. Provisions for the control and implementation of a PRA-based assessment methodology. The assessment shall be capable of evaluating the applicable plant configuration.

b. Provisions for performing an assessment prior to entering an LCO for pre-planned maintenance activities.

c. Provisions for assessing the need for additional actions after additional equipment outages occur while in the LCO. i l

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d. Provisions for identification and implementation of compensatory actions. j e.

cn N Provisions for consideringrcontainment concerns and external events.

f. Provisions for documenting assessments performed and result 'g actions.

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e l-L- TSTF-39 TSTF-64

, March 1997 l

REVISED STS DEFINITION FOR CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY of all required components (e.g., bistables, master relays and slave relays) in the

channel, and other components that could affect OPERABILTlY of the channel, i

such as alarms, displays, and channel failure trips. Channel relay OPERABILITY ,

shall be verified by demonstrating that at least one contact associated with the l relay has changed position. All remaining required relay contacts shall be tested i during the LOGIC SYSTEM FUNCTIONAL TEST. The CHANNEL FUNCTIONAL j TEST may be performed by means of any series of sequential, overlapping, or total channel steps, so that the entire channel is tested.

] l l

]

l The following other STS definitions should be reviewed for corresponding language i changes to ensure consistencyin all of the terms used for testing of instrumentation and controls systems: j a

f NUREG-1430 CHANNEL CAllBRATION l

CHANNEL FUNCTIONAL TEST i

NUREG-1431 CHANNEL CALIBRATION CHANNEL OPERATIONAL TEST TRIP ACTUATING DEVICE OPERATIONAL TEST l

! NUREG-1432 CHANNEL CALIBRATION CHANNNEL FUNCTIONAL TEST i I NUREG-1433 CHANNEL FUNCTIONAL TEST CHANNEL CAllBRATION LOGIC SYSTEM FUNCTIONAL TEST l

NUREG-1434 CHANNEL FUNCTIONAL TEST CHANNEL CAllBRATION LOGIC SYSTEM FUNCTIONAL TEST

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' TRAVELLER

SUMMARY

As of 3/18/97 j l

MODIFIEC MD REJECTED TRA* .LERS TSTF-79 j MODIFY: Reference the topical report on the Bases insert to SR 3.3.4.1 (digital) and add the topical report to the list of references on Bases page B 3.3-78. l l

TSTF-80 I i

REJECT: TSTF-80 is rejected because it lacks technical justification for changes i that eliminate Mode 2 requirements for Axial Power and Loss of Load RPS '

functions. In addition, the package is incomplete. It does not include markups of all affected Table and LC0 pages.

TSTF-82 I

MODIFY: The package is incomplete without confirming Bases changes. In  !

addition, the proposed change do not agree in format and substance to the 1 statement of Allowable Value requirements used in the STS surveillance i requirements. Proposed changes should be submitted that agree with format of SR j 3.3.7.2 (Analog): " Verify the Power Rate of Change--High setpoint Allowable Value ]

is 3 [2.6) dpm." i i

TSTF-85 l l

REJECT: TSTF-85 is rejected because the proposed changes are related to TSTF-80 l which were rejected because of insufficient technical justification and I incomplete TS markups. I I

TSTF-91  !

REJECT: TSTF-91 proposes to eliminate TS Allowable Value voltage and time delay limits for DG loss of power instrumentation. TS 3.3.5 meets i 10CFR50.36(c)(2)(ii)C. LCOs establish the lowest functional capability or i performance levels of equipment required for safe operation of the facility.

TSTF-91 is rejected because appropriate regulatory limits are not retained.

I DISCUSSION TRAVELLERS ISIF-39 & 64 - Definition of CFT and conversion lessons j These packages are Pending NRC review and were previously discussed in the  !

meeting summary.

TSTF Fuel Handling SRP resource limited

. _This package is pending NRC action due to limited resources.

1 e

TRAVELLER

SUMMARY

(continued) Page 2 TSTF Status of TSTF revision of Appendix J options On 10/24/96, NRC recommended that TSTF Modify package. Because some licensees have adopted the optional provisions of Appendix J, the STS changes need to i provide guidance for both Option A and Option B. (The TSTF will submit a revision package.)

TSTF Need for changed definition of Shutdown Margin for CE plants This package is pending CEOG action and was previously discussed in the meeting  ;

summary.

TSTF Need for and structure of 3.0.6 examples l A diagram that was previously removed from the Specifications is proposed to be placed in the Bases. NRC notified TSTF, as of 3/18/97, that they will modify the i package to place each example in Insert 2 immediately after its associated I explanation in Insert I for clarity.

TSTF Modifications did not address issue i

This package is pending NRC action and was previously discussed in the meeting  !

summary.

TSTF User'of " required" head bolts j The comments address the same " required" dilemma as CFT. NRC will modify the l package to retain "all" and add brackets.

TSTF Modification did not include nota in SR NRC's decision to Modify included a comment that a Reviewers Note be added to provide consistent application of the SR and ensure that the distinction in design differences is not overlooked during the application of the STS. The l TSTF's Revision 1 submittal made editorial changes, but did not address the recommendation that a Note be placed in SR. (TSTF will modify to include Insert in SR with Revision 2.)

TSTF-103 - Usefulness of " optional" versions of LCO 3.0.4 This package is pending TSTF explanation for only applying this change to WOG and CEOG, since the requirements being modified appear in all NUREGs.

TSTF-113 - Recycled or appealed PORV change does not address technical issue This package is pending TSTF action and was previously discussed in the meeting summary. (TSTF has developed Revisions 2 and 3 to this package, but has not yet submitted them to NRC.) 7 W. ._ __ _ _ __. ._ _ _ .

t Page 3 TRAVELLER

SUMMARY

(continued)

TSTF-115 - IEEE status of battery testing and likelihood of near-term resolution  !

TSTF intends to withdraw this package at the same time they resubmit only j portions that were approved by IEEE as individual travellers (approximately  ;

l five).

11Tf-12.Q - ASTM standard for fuel oil referred to EMCB - filter testing lesson  !

1 This package is pending NRC review. ASTM D-2276 standard differs deperiding upon which year is being referred to; the package has been referred to the Chemical and Mechanical Engineering Branch.

TSTF-123 - BWOG use of consistent terminology Pending TSTF action. In reviewing the justification NRC believes the TSTF did ,

not inter.d what their justification implied (i.e., creating a new definition  :

CONTROL R00 ASSEMBLIES). The TSTF will submit a revised package. .

TSTF-125 - BWOG use of consistent terminology .

Pending TSTF action. NRC requires further justification as to why there is no l

further need for the definition of EFFECTIVE FULL POWER DAYS in the BWOG TS.

(TSTF will submit revision package.)  !

I TSTF-134 - CE construction and editing of a "not required" note l Pending TSTF action. NRC determined that there seemed to be some typographical errors in the submittal package, as well as the justification in the TSTF traveller, regarding which SR is being referred to: 3.1.6 or 3.1.7. (TSTF will submit revision package.)

TSTF-135 - Substantial changes to RPS and ESFAS format Pending NRC review. The Instrumentation and Control Branch is in the p'rocess of reviewing the setpoint methodology and will probably need to join the next Owner's Group meeting.

i TSTF-154 - Bases consistency issue Pending TSTF action. lo be consistent, " Final Policy Issue" should be left in Bases, since 50.36(i)(1) was left out of Rev. I update to TS. (TSTF will submit  !

revision package.)