ML20138J837

Transmits Summary of 970417 TS Task Force Meeting in Rockville,Md

ML20138J837
Person / Time
Issue date:	05/06/1997
From:	Charemagne Grimes NRC (Affiliation Not Assigned)
To:	Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
NUDOCS 9705090054
Download: ML20138J837 (17)

Text

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May 6, 1997 Mr. James Davis Nuclear Energy Institute 1776 Eye Street, N. W.

Suite 300 Washington, DC 20006-2496 j l

Dear Mr. Davis:

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1 The purpose of this letter is to transmit a summary of the Technical Specifications Task Force (TSTF) meeting, which took place at the Nuclear Regulatory Commission in Rockville, Maryland, on April 17, 1997.

l Sincerely, j Original signed Dy:

Christopher I. Grimes, Chief Technical Specifications Branch i

Office of Nuclear Reactor Regulation

Enclosure:

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• • • • • ,$ May 6, 1997 Mr. James Davis Nuclear Energy Institute 4

1776 Eye Street, N. W.

Suite 300 Washington, DC 20006-2496

Dear Mr. Davis:

The purpose of this letter is to transmit a summary of the Technical Specifications Task Force (TSTF) meeting, which took place at the Nuclear Regulatory Commission in Rockville, Maryland, on April 17, 1997.

Sincerely, k

Christopher I. Grimes, Chief Technical Specifications Branch Office of Nuclear Reactor Regulatic'n

Enclosure:

As stated

cc

B. Mann, CE0G B. Ford, BWROG L~. Bush, CE0G D. Wuokko, BWOG C. Szabo, BWOG D. Hoffman, TSTF 1

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3 TECHNICAL SPECIFICATIONS TASK FORCE MEETING

SUMMARY

April 18, 1997 j

A meeting between the NEI Technical Specifications Task Force (TSTF), and NRC

, staff was held on April 17, 1997. The attendees were:

l James Davis, NEI Christopher Grimes, NRC/TSB l Clint Szabo, Entergy/BWOG Deborah Johnson, NRC/TSB j

Lee Bush, Comed /WOG Mary Lynn Reardon, NRC/TSB i

! Brian Mann, BGE/CEOG Tom Dunning, NRC/TSB  !

Bryan Ford, Entergy/BWROG Angela Chu, NRC/TSB Donald Hcffman, EXCEL Services Robert Tjader, NRC/TSB Edward Wenzinger, NUS-LIS Edward Tomlinson, NRC/TSB Alan Hester, Xerox Corporation ^

John Marshall, Texas Utilities j Steve Katradis, NUS-LIS The Attendees List is Attachment 1.

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Mr. Grimes opened the meeting by announcing his reassignment as Director,

~; License Renewal and Environmental Review Project Directorate, Division of Reactor Program Management. The date of this reassignment has not yet been established.

Meetina Summary of March 18. 1997 Meetina Mr. Grimes asked for comments on the meeting summary. Mr. Davis, indicated that NEI would provide separate correspondence regarding the need for configuration management controls described for the CEOG Risk-Informed Technical Specification Pilot.

Status of Pendina Travelers The status of all pending travelers was discussed and a summary is included as Attachment 2.

Traveler Discussion The status of all travelers was discussed and a summary of those that were Modified or Rejected as of 3/18/97 is included as Attachment 3.

NRC received three un-numbered EDIT packages from the TSTF. NRC raised the question of how the TSTF tracked these packages and how NRC would identify whether any purely editorial changes should be rejected or modified. The TSTF assumes that editorial changes would be incorporated into the STS unless the NRC rejects the changes, in which case they would be returned to the TSTF with an explanation. Mr. Grimes noted that two of the three EDIT packages  :

included language changes which substantially exceeded simple typographical errors. Accordingly, the TSTF was asked to reconsider their practice of submitting undesignated packages of editorial change, because the NRC staff would have to apply the same controls and effort as that required for the TSTF travellers.

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Page 2 Conversion Guidance Consistency NEI requested a discussion of this subject. Mr. Davis stated that plants may not always be able to achieve the level of detail in amendment applications i comparable to the conversion guidance in NEI 96-06, because of the 12 to 15 l months it takes to prepare an application. He also stated that questions i from NRC regarding conversions are sometimes inconsistent. Mr. Grimes stated that the NRC staff understands the time and effort required to prepare a conversion application; nevertheless, the scope of information described in l NEI 96-06 reflects that information needed to complete the safety evalunion.

Licensees can submit the information in different forms, but that will hamper the review process and consistency. Mr. Grimes noted that the NRC staff expresses similar complaints, and he suggested that there should be continued efforts to provide more refined justifications and that more formal feedback should be established to ensure consistent feedback, i Use of 50.59 Process for Relocated Items 4

There continues to be some confusion regarding the removal of details from current technical specifications. Mr. Grimes explained that the NRC has identified particular details that must be controlled in the Bases or the FSAR. While the category of " Relocated" requirements is used in the conversion guidance to describe those Limiting Conditions for Operation that do not satisfy the criteria in 550.36, there are also details that warrant control under the Bases Control Program or 550.59 that are also " relocated,"

even though they are categorized as "Less Restrictive" (designated Lr for relocated). Other details can be " deleted" where there is no need for such controls, which are typically categorized as "Less Restrictive" (designated La for administrative). The NRC believes that, while these categorizations have been used to various degrees of detail, the approach has been reasonably consistent for all of the conversions thus far. In addition, the applicable category (Lr or La) is usually self-evident. The NRC requested that, if the TSTF had particular concerns or suggested guidance for clarifying this distinction, they should submit those comments or concerns formally to the NRC for action.

TSTF Processina Procedures' In a letter to NEI dated April 8,1997, " Review of Working Draft STS Changes," the NRC outlined procedures to ensure TSTF review of changes made to the Technical Specifications prior to uploading the Draft Rev. 2 files to the NRC Home Page. The TSTF agreed to this procedure, but expressed some concern about whether it will be apparent that the files are posted for their review. Ms. Johnson indicated that this concern was taken into consideration when the procedures were being created, and it should be clear in the notification when the review files are posted. ,

Mr. Davis raised a question regarding how new traveler packages that affected sections changed by previously-approved travelers were processed. Once changes to a section have been approved and are made into a Draft Rev. 2 file, new traveler packages affecting the same section will always contain the previously-approved changes. The markup packages usually identify any

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Page 3 dependent, related travellers so that such dependencies can be resolved if a j related change was rejected or modified, or is still pending.

l Mr. Davis inquired whether NRC could provide a report that showed which i traveler packages have been made into. Draft Rev. 2 files and were posted to the NRC Home Page. Mr. Dunning agreed to include a summary file on the BBS.

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Ms. Johnson indicated that some traveler packages were unreadable because the

{ photocopies were too light. She suggested that the TSTF send the original l instead of copies, but was assured that darker copies would be sent. Mr. i 3 Grimes indicated that should any traveler packages be unreadable in the future, they would be rejected.

Status of SGML Tech Soecs i Mr. Dunning addressed the changes to the document type definition (DTD) and

associated entities for the SGML Tech Specs Pilot Project. The changes, with l some modifications, were subsequently posted to the NRC Home Page for Tech I

Specs (http://www.nrc. gov /NRR/sts/sts.htm) and a summary of changes were j i - distributed to the TS-NRR electronic mail list to keep all interested parties informed of changes and current status. j l

l Aaenda for Future Meetina I The next meeting of the NEI-TSTF and NRC will be held sometime in May 1997,  !

but a specific date for the meeting will have to be arranged later. l 9- .

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Attachment 1 A

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i ATTENDEES LIST a NRC/TSTF OWNER'S GROUP MEETING APRIL 17,1997 4

NAME ORGANIZATION ADDRESS PHONE # E-Mall ID Edward NUS-LIS 11140 Rockville Pike 301-468-6425 ewenzinger@

WQnzinger (Scientech) -

Rockville, MD 20852 X524 SCIENTECH.

com Bob Tjader NRR/TSB U.S. Nuclear Regulatory 301-415-1187 trt@nrc. gov Comm Washington, DC 20555 -

Mary Lynn NRR/TSB NRC 301-415-1177 mir2@nrc.

Reardon ,

gov Angela Chu NRR/TSB NRC 301-415-2937 atc@nrc. gov i

Christopher 1. NRR/TSB NRC 301-415-1161 cig@nrc. gov

! Grimes 1

James Davis Nuclear Energy 1776 Eye Street, NW 202 739-8105 jwd@nei.org Institute (NEI) Washington, DC 20006 Brian Mann BGE/CEOG 1650 Calvert Cliffs Plant 410-495-6517 brian.d.mann Lusby, MD 20657 @bge.com Tom Dunning NRR/TSB NRC 301-415-1189 tgd@nrc. gov Donald Hoffman EXCEL /TSTF 11921 Rockville Pike 301 984-4400 donaldh@

Suite 100 excelsves.

Rockville, MD 20852 com Alan Hester Xerox Corporation 780 Salt Road, #84517S 716 265-7333 Alan _Hester Webster, NY 14580 @wb. xerox.

com Bryan Ford Entergy/BWROG P.O. Box 756 601-368 5792 bford@

Port Gibson, MS 39150 entergy.com Lee Bush Comed /CEOG 101 Shileh Blvd 847 746-2084 ZINLB@

Zion, IL 609? x2890 ccmail. ceco, com Clinton Szabo Entergy/BWOG 1448 S. R. 333 501 858-4622 cszabo@

Russellville, AR 72801-0967 entergy.com John S. Marshall TU Electric P.O. Box 1002 817 897-0133 jmarsha2@

Glen Rose, TX 76043 tuelectric.

com Page 1 of 1

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., ATTENDEES LIST l j NRC/TSTF OWNER'S GROUP MEETING l APRIL 17,1997 i

NAME ORGANIZATION ADDRESS PHONE # E-Mall ID NRCfrSB NRC 301-415-3137 ebt@nrc. gov Ed Tomlinson

Steve Katradis NUS LIS 910 Clopper Road 301-258 2448 skatradis@ l

! Gaithersburg scientech. j com  !

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i. TSB PENDING TRAVELLERS I I April 1997 i

! TSTF # Action i

2, R.1 Tomlinson j 7 Withdrawn; TSB action to remove the one-hour provision of the standard i

shutdown track.

14, R.4 Tjader recommends approval: 4/15 to Grimes 2

i 1 16, R.1 Tomlinson & Harbuck 36, R.1 .

j 37, R.1 Tomlinson j 51 Awaiting Action Plan approval

58 Awaiting Commission approval of the RI-TS pilot 4

59 65 Weston

! 67 Tjader meet w/SRXB and CEOG to try to resolve shutdown margin def.

j 136 Tjader discuss need for changes during TSTF-67 meeting.

68, R.1 Giardina j 69 Schulten & HICB

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73 l 75

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{ 70, R.1 Giardina recommends approval: 4/15/97 to C. Grimes t

76 Note to HICB 3/24/97 l 98, R.1 Tjader

105 Weston?

', 108, R.1 Tjader 1 110, R.1 112, R.1 l

120 Tomlinson & EMCB .

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] 127 Tjader & HICB i 128 Weston to reconsider modify recommendation

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135 Schulten - HICS memo 4/9/97 agreed review is worthwhile and projects

completion by 5/21/97.  !

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TSTF # Action i

139, R.1 Giardina recommends approval; 4/15/97 to C. Grimes

140 Giardina recommends approval

4/15/97 to C. Grimes J

141 Tjader & SRXB j 142 l

J 145, R.1 Giardina recommends modify-staff comments not included: 4/15/97 to C.

Grimes l 4

l 151 Weston to clarify modification and SRXB basis 3

164 Tjader recommends approval: 4/15 to Grimes i 167 Tjader recommends reject; 4/15 to Grimes

] 174 Giardina recommends approval: 4/15/97 to C. Grimes

175 Giardina recommends approval: 4/15/97 to C. Grimes l 176 Tjader recommends reject; 4/15 to Grimes J

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TSB TRAVELLER DISPOSITIONS I APRIL 1997 TSTF 39 TSTF-64 TSTF 124 MODIFY: The proposed changes to all of the STS related to l&C surveillance and testing i should be revised to incorporate the revised definition of Channel Function Test provided ,

by the Instrumentation & Controls Branch during the TSTF meeting on 3/18197, as l follows

l REVISED STS DEFINITION FOR CHANNEL FUNCTIONAL TEST l A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal into l 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 OPERABILITY 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 steps, so that the entire channel is tested.

The following other STS definitions should be reviewed for corresponding language changes to ensure consistencyin allof the terms used for testing ofinstrumentation and controls systems:

NUREG-1430 CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST NUREG-1431 CHANNEL CALIBRATION CHANNEL OPERATIONAL TEST TRIP ACTUATING DEVICE OPERATIONAL TEST NUREG-1432 CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST AllB ATION LOGIC SYSTEM FUNCTIONAL TEST NUREG-1434 CHANNEL FUNCTIONAL TEST CHANNEL CALIBRATION LOGIC SYSTEM FUNCTIONAL TEST TSTF 41 TSTF-48 REJECT: A detailed response to these changes and the LCO 3.0.7 White Paper will be addressed in a separate letter from TSB to NEl.

.TSTF-67 MODIFY: SRXB comments on CE definition of shutdown margin were discussed on 3/18/97. The CEOG will arrange a separate meeting with SRXB to discuss the purpose of  ;

the change further.

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! TSTF 71 i

MODIFY: Although it is not clear to TSB why the addition of another matrix of supported 1

, systems is needed in the Bases for LCO 3.0.6, the staff will accept the changes if the l example discussions proposed in Insert 2 immediately follow each of the example cases described in Insert 1. The diagram associated with the examples con follow the i discussion. In addition, brackets are not necessary in the Bases unless the material discusses an option or alternate design basis.

TSTF-79 l MODIFY: Reference the topical report in 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.

J TSTF 80 4

REJECT: The proposed changes to eliminate the Mode 2 requirements for the Axial Power and Loss of Load RPS functions are rejected because the justification does not include an adequate explanatic:. Of the need for or technical sufficiency of the changes. In addition, the package is incomplete; it did not include markups of all affected Table and LCO pages.

l i TSTF 82 l

{ MODIFY: The package is incomplete because it lacks conforming Bases changes. The '

l' proposed changes do not agree in format and substance to the statement of Allowable l

Value requirements used in the STS surveillance requirements. Proposed changes should i be submitted that agree with format of SR 3.3.7.2 (Analog): " Verify the Power Rate of l Change--High setpoint Allowable Value is.s. [2.6] dpm."

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I TSTF 85 i REJECT: The proposed changes are related to TSTF-80, and are similarly rejected because j

. the justification does not adequately explain the need for or technical sufficiency of the  !

j change, and the package included incomplete TS markups.

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TSTF 86 i

TSTF 121 i

! MODIFY: All of the changes to the Administrative Controls related to staffing, overtime

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l j and Part 20 changes will be addressed separately in a letter from TSB to NEl. l 2

j TSTF-87 i

MODIFY: SRXB discussed their comments on the Rev 1 package at the meeting on 1

3/18/97, so that the staff's concerns can be adequately considered in the Rev 2 package already being developed by the TSTF.

i TSTF 88 '

1 MODIFY: Based on other experience, the staff believes that replacing "All" and "One or i more" with " Required" will not clarify the Mode definitions, as intended. Instead, TSB i recommends putting brackets around the terms and adding a reviewers note to include the j appropriate licensing basis for vessel head removal.

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- i TSTF 91 l REJECT: The STS change proposes to eliminate TS Allowable Value voltage and time

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delay limits for DG loss of power instrumentation. TS 3.3.5 meets 10CFR50.36(c)(2)(ii)C.

LCOs establish the lowest functional capability or performance levels of equipment required for safe operation of the facility. On this basis, the staff concludes that the proposed change does not retain appropriate regulatory limits.  ;

TSTF 103 4

MODIFY: it is not clear why the proposed changes only apply to NUREG-1431 and 1432, unless it is intended that only the Westinghouse and CE plant designs would not adopt the

} 3.0.4 changes described in the Reviewer's Note. If this was intent, then there should be i corresponding changes in the Reviewer's Note to explain the options more completely. In l

addition, the justification should explain why these changes should not be made in the l BWOG and BWR STS. .

l TSTF-111

] MODIFY: Incorporate the approval basis for the response time testing topical report into

! the proposed change, as discussed at the TSTF meeting on 3/18/97.

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TSTF 113 4

MODIFY: SRXB discussed PORV & LTOP design considerations at the TSTF meeting on i 3/18/97, as they relate to temperature limits and the consequences of SGTR events.

j These comments should be considered in supplementing the justification for the changes being considered for the Rev. 2 package. If necessary, a separate meeting should be arranged between SRXB and the TSTF to clarify the need for these changes.

TSTF 123 TSTF 125 MODIFY: The proposed changes are intended to establish consistent terminology in the l B&W STS. However, it is not clear from the justification how the changes achieve j consistency both within the B&W STS, and between B&W and the other STS, relative to l the proper terminology and use of defined terms.

l TSTF-130 MODIFY: The proposed changes will be approved providing a modification to the Bases  !

language usage is made as follows: instead of "A Note excludes the neutron..." use "A  ;

Note allows exclusion of the neutron..." in SR 3.3.11.2 Bases.

TSTF-131 REJECT: Insufficient generic justification. Plant conversion TS have been issued which incorporate the setpoint setdown and bypass features proposed to be deleted by this TSTF j package and which delete the ESFAS function this package retained. Plants wanting to adopt the items of this TSTF may do so on a plant specific basis.

TSTF-133  :

MODIFY: Addition of Criterion 3 is acceptable, but the addition of 50.36(c)(2)(ii) must be resolved consistently.

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l TSTF-134 MODIFY: The proposed changes would add a Note to the SR for verifying that each CEA 1 not fully inserted is capable of full insertion when tripped from at least 50% power. As j discussed on 3/18/97,it appears that the justification and proposed Note refer to SR 3.i.5.6 instead of SR 3.1.5.7. In addition, the Note is incomplete because it does not specify when the SR "has been met." i TSTF-138 REJECT: The proposed change is to TS on leakage, but the problem TSTF is addressing l has to do with missed SG surveillance, which is another TS. Change confuses the issue. j Either fix existing problem by inserting LCO or address with fix in SR 3.4.13.2 since a  !

missed surveillance is the issue, not leakage.

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TSTF 147 l REJECT: LCO 3.0.2 states that the required actions of the associated conditions are to be met upon discovery of failure to meet the LCO. Therefore,if required testing renders equipment inoperable, the appropriate conditions are to be met. Thus, for matrix logic (LCO 3.3.3, CE analog /LCO 3.3.4, CE digital), Condition A allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to complete required testing. For the initiation logic, Condition B allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to complete required testing. Notes are provided for Condition B to close TRCBs associated with inoperable channels to perform channel functional testing. The proposed Bases provide an exception to application of LCO 3.0.2 and the TS requirements for 6 operable initiation logics by stating that trip capability still exists since testing one initiation logic affects only one matrix logic combination. These defacto exceptions to application of the required operable channels and LCO 3.0.2 are not acceptable.

1 TSTF 154  !

MODIFY: The proposed changes to the Bases for the Physics and Special Test Exceptions in the B&W and CE STS would add a reference to LCO 3.0.7 and change references from the criteria the Final Policy Statement to 550.36(c)(2)(ii). However, all of the Bases in the ,

STS still refer to the Final Policy Statement rather than 150.36: if the references to the criteria are to be changed, they should be changed throughout the STS.

EDIT TRAVELLER DISPOSITIONS APRIL 1997  ;

EDIT-9 REJECT: Proposed changes to LCO 3.5.2 Applicability Notes do not constitute editorial changes and therefore are rejected.

EDIT-10 REJECT: Proposed changes to LCO 3.5.2 Applicability Notes do not constitute editorial 3 changes and therefore are rejected.

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i EDIT-16  ;

REJECT: Changes involve much more than simple edits. If TSTF wishes to pursue

removal of setpoints from the TADOT, these changes should be included, with appropriate justification, in the set of proposed changes resulting from the resolution of the CFT definition.

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