ML22298A217
| ML22298A217 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 10/24/2022 |
| From: | Technical Specifications Task Force |
| To: | NRC |
| References | |
| Download: ML22298A217 (16) | |
Text
Technical Specifications Task Force A Joint Owners Group Activity TSTF 1
Strategic Improvements to TS and TS-Related Processes October 24, 2022 Kevin Lueshen, Constellation TSTF Member
Technical Specifications Task Force A Joint Owners Group Activity TSTF Introduction
- The industry and the NRC worked together on the improved standard Technical Specifications (TS) (1992) and risk-informed TS initiatives (1999).
- Over the last three decades, initiatives have become well established:
- 78% of plants have TS based on the standard TS, with four additional units converting.
- All plants have adopted the Surveillance Frequency Control Program, and risk-informed SR 3.0.3 (missed Surveillances). Other risk-informed changes are widely adopted.
- Risk-Informed Completion Time adoption is approaching 50%.
- Standard TS and risk-informed TS improvements will continue to be pursued and are now routine.
- With subsequent licensing renewal, many plants are planning for an additional 20 to 40 years of operation.
- Industry looking at continued improvement during extended operation.
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Technical Specifications Task Force A Joint Owners Group Activity TSTF Introduction
- The PWROG and BWROG Licensing Committees initiated a project to consider medium-and long-term improvements to TS and TS-related regulatory processes to improve plant safety and reduce operational burden.
- These improvements will be pursued in parallel with existing TSTF traveler process and other improvements.
- The project solicited big ideas, radical out-of-the-box thinking, and long-term projects (such as regulation changes) that can be assembled into a strategic plan for TS improvement to be executed in a coordinated fashion over the next decade.
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Technical Specifications Task Force A Joint Owners Group Activity TSTF Industry Brain-Storming
- The TSTF surveyed the industry in February and held a workshop in May.
- Over 60 ideas were put forward.
- The recommendations were categorized, similar ideas were combined, and in August a subset of ideas were selected for further consideration.
- The recommendations fall into three categories:
- Revise Regulations
- Improvements to the License Amendment Process that do not Require a Rule Change
- TS Improvements that do not Require a Rule Change 4
Technical Specifications Task Force A Joint Owners Group Activity TSTF Industry Brain-Storming
- These recommendations provide an industry-only perspective, and many are only conceptual.
- Some are mutually exclusive or represent different approaches to the same goal.
- Just like with the development of the standard TS and the risk-informed TS initiatives, the industry would like to work with the NRC to identify, refine, and pursue projects of mutual benefit.
- We are presenting these ideas today to spur NRC interest and internal discussion in hopes of future meetings to discuss NRC ideas and to develop initiatives of mutual interest.
- We are not requesting NRC agreement on the industrys ideas.
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Technical Specifications Task Force A Joint Owners Group Activity TSTF RULE CHANGES 6
Brian Mann, EXCEL Services Corporation TSTF Program Manager
Technical Specifications Task Force A Joint Owners Group Activity TSTF Update 10 CFR 50.36, Technical Specifications
- When 10 CFR 50.36 was promulgated in 1968, only a few commercial nuclear power plants had been operating for a short time.
- The main goal of the regulation change was to streamline the AECs review of future license applications.
- Lacking any operational experience and with limited analytical capability, the TS regulation was based on protecting barriers.
- The existing regulation is out-of-step with the current state of practice, for example:
- Little consideration of risk or risk-management actions,
- An assumption that a plant shutdown is always the safest action, and
- No integration with later regulations, such as the Maintenance Rule, and 10 CFR 50.69.
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Technical Specifications Task Force A Joint Owners Group Activity TSTF Update 10 CFR 50.36, Technical Specifications
- Industry proposes to update 10 CFR 50.36 to create a new framework for TS:
- Risk-informed,
- Focused on risk-significant systems
- Risk managed actions
- Integration with Maintenance Rule and 10 CFR 50.69,
- If needed, development of new risk metrics not limited to severe accidents (e.g.,
operator dose),
- Examine need for LSSS, Design Features, and Administrative Controls, and
- Reexamine NRCs 1982 proposal to move some requirements to licensee-controlled TS
- We recognize this is an ambitious project, but the existing 50-year-old requirements are impeding improvements in safe, efficient plant operation.
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Technical Specifications Task Force A Joint Owners Group Activity TSTF IMPROVEMENTS TO THE LICENSE AMENDMENT PROCESS THAT DO NOT REQUIRE A RULE CHANGE 9
Drew Richards, South Texas Project TSTF member, PWROG LC Chair
Technical Specifications Task Force A Joint Owners Group Activity TSTF Improvements to the License Amendment Process
- The License Amendment process is mired in 50-year-old, paper-based processes.
- Updating the process could reap benefits to the industry and NRC without compromising safety or hindering regulatory oversight.
- Ideas include:
- LAR process improvement workshop.
- Hold a workshop and table-top the LAR process from initiation to implementation looking for efficiencies, with the goal of making normal LAR reviews 6 months or less.
- Make the RAI and supplement process more interactive.
- Permit NRC to make recommendations that would make a submittal acceptable.
- Establish a consistent plant-specific audit file exchange site for use in any LAR review.
- Permanent versus a case-by-case basis.
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Technical Specifications Task Force A Joint Owners Group Activity TSTF Improvements to the License Amendment Process
- Move the implementation period for a LAR from the amendment to the transmittal letter so it can be altered without an additional amendment.
- Treat the TS as Data Versus a Document
- The presentation of the words on the page (spacing, line breaks, fonts, etc.)
should be immaterial.
- TS revisions should focus on the changes to the information. Page roll-overs, reformatting, etc. should not be a concern in amendments.
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Technical Specifications Task Force A Joint Owners Group Activity TSTF TS IMPROVEMENTS THAT DO NOT REQUIRE A RULE CHANGE 12 Kevin Lueshen, Constellation TSTF Member
Technical Specifications Task Force A Joint Owners Group Activity TSTF Improvements to TS
- The industry identified structural improvements to TS that would not require a regulation change
- These could be nearer-term improvements while working on the 10 CFR 50.36 update.
- Ideas
- Replace TS requirements for Cold Shutdown and Refueling with a performance-based Shutdown Safety Program that maintains defense-in-depth and safety while providing flexibility.
- Reexamine Actions to suspend fuel movement.
- Provide a Completion Time similar to at-power TS Actions.
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Technical Specifications Task Force A Joint Owners Group Activity TSTF Improvements to TS
- Develop guideline for TS required shutdown Actions
- Work with NRC to develop guidance on when a TS-required shutdown is necessary and in what time frame based on level of degradation. Implement the guideline with travelers.
- RICT Program Enhancements
- Extend the 30-day RICT backstop.
- Evaluate RICT application to Mode 3 and Mode 4.
- Reexamine application of RICT to loss-of-function conditions.
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Technical Specifications Task Force A Joint Owners Group Activity TSTF Improvements to TS
- Expand the Surveillance Frequency Control Program
- NRC determined regulations do not require Frequency to be in the TS
- Revise NEI 04-10 methodology to address other types of Frequencies (event driven, event driven with time component, etc.)
- Relocate Low-Risk System LCOs from the TS
- May require a rule change.
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Technical Specifications Task Force A Joint Owners Group Activity TSTF WRAP-UP 16 Drew Richards, South Texas Project TSTF member, PWROG LC Chair