ML24324A178

Summary of Public Meeting with the TSTF TSTF-585

ML24324A178
Person / Time
Site:	Technical Specifications Task Force
Issue date:	12/11/2024
From:	Michelle Honcharik Office of Nuclear Reactor Regulation
To:	Shivani Mehta NRC/NRR/DSS/STSB
References
EPID L-2023-PMP-0000
Download: ML24324A178 (4)

Text

December 11, 2024 MEMORANDUM TO: Shivani Mehta, Chief Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation FROM:

Michelle C. Honcharik, Senior Project Manager

/RA/

Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation

SUMMARY

OF NOVEMBER 13, 2024, PUBLIC MEETING WITH THE TSTF RE: TSTF-585 (EPID L-2023-PMP-0000)

On November 13, 2024, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and members of the Technical Specifications Task Force (TSTF) at NRC headquarters in Rockville, Maryland. The meeting notice and agenda, dated October 29, 2024, are available in the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML24303A237. A list of attendees is provided in the enclosure.

The purpose of the meeting was for the NRC staff and TSTF members to discuss scenarios of how a licensee would implement the TS changes proposed in Draft Revision 3 to TSTF-585, Revise LCO [limiting condition for operation] 3.0.3 to Require Managing Risk (ML24016A270).

Prior to the meeting, the NRC provided the TSTF with proposed scenarios to discuss during the meeting (ML24302A210) and the TSTF provided the NRC staff with meeting slides (ML24318B831).

During the meeting, the TSTF representatives described the changes (e.g., additions, deletions) to TSTF-585, Draft Revision 3, and noted that there were some errors in the draft revision 3 that will be corrected. The TSTF members also explained the reason why they were requesting the proposed changes. They then ran through several hypothetical situations and how a licensee would operate the plant if the proposed changes were adopted. The TSTF also ran through the same explanation with the scenarios that the NRC provided. NRC staff explained that the traveler would need to be revised so that the staff would have regulatory and safety justifications to prepare the safety evaluation. The TSTF stated that they plan to submit a revision to the traveler in early 2025. The TSTF and NRC discussed the following changes in the traveler:

1. Expand the discussion to justify why the change from a 1-hour to a 6-hour delay in LCO 3.0.3 is safe and continues to protect the public health and safety.

2. Earlier versions of the traveler stated that a level of risk for continued operation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was normal work controls (that is, < 1E-6 ICDP). The TSTF plans to change the traveler to an acceptable risk of < 1E-5 ICDP if risk management actions are taken, and non-quantifiable factors are assessed. The NRC requested:

a. That the traveler more fully explains how risk is determined (i.e., starting with the baseline risk), including the time when additional risk is being accumulated.

b. A more complete discussion of Risk Management Actions (RMAs).

c. That the TSTF consider adding a threshold for instantaneous risk to avoid high-risk failures that should result in shutdown.

d. That the TSTF discuss the basis for conservative operation actions to shut down the plant in less than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if appropriate.

3. Discuss planned LCO 3.0.3 entries.

4. The Bases discuss the scenario of risk being acceptable and the 24-hour delay period be applied and a subsequent change in plant conditions resulting in the risk being unacceptable and a plant shutdown being initiated immediately (if past the initial 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after LCO 3.0.3 entry).

5. Discuss cross-unit dependencies resulting from shared systems at multi-unit sites.

6. Clarify that the quantitative limit means that the condition must be evaluated quantitatively.

a. This led to a discussion of obvious low-risk conditions, such as all RCS leakage monitors being inoperable, but which are not modeled in the PRA.

b. To not permit the use of the 24-hour delay time in those situations is inconsistent with the intent of the traveler and plant safety.

c. The TSTF will examine developing criteria for those low-risk conditions which cannot be quantitively modeled.

7. Require documentation of the determination that the risk of continued plant operation is acceptable. For example, the SR 3.0.3 Bases state, The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

8. Revise the proposed LCO 3.0.3 wording to refer to appropriate risk management actions instead of required risk management actions.

9. Revise the proposed LCO 3.0.3 to state, If the risk assessment determines that continuing operation is not acceptable, the risk assessment was not completed performed,... to not imply that the risk assessment is not required to be performed.

10. Provide the Event Report and LER data described in the traveler.

11. The NRC asked if the LCO 3.0.3 Bases should be revised to include a Reviewers Note that captures the same verification as included in the model application, [LICENSEE] confirms Section 11 of NUMARC 93-01, including the action thresholds under normal work controls, will be used to perform the LCO 3.0.3 risk assessment to determine whether continued plant operation is acceptable. The TSTF will evaluate the request.

No regulatory decisions were made during the meeting. No public meeting feedback or feedback forms were received. Please direct any inquiries to me at 301-415-1774 or michelle.honcharik@nrc.gov.

Project No: 0753

Enclosure:

List of Attendees

Enclosure LIST OF ATTENDEES NOVEMBER 13, 2024, MEETING WITH THE TSTF RE: DRAFT REVISION 3 TO TSTF-585 Name Organization Michelle Honcharik U.S. Nuclear Regulatory Commission (NRC)

Tarico Sweat NRC Khadijah West NRC Michelle Kichline NRC David Gennardo NRC Rob Elliott NRC Shivani Mehta NRC John Hughey NRC George Gerond NRC Antonios Zoulis NRC Mihaela Biro NRC Craig Harbuck NRC Ed Miller NRC Ravi Grover NRC Edmund Kleeh NRC Clint Ashley NRC Luke Haeg NRC Matthew Hamm NRC Derek Scully NRC Chris Rojas NRC Joshua Wilson NRC Andrea Russell NRC Norbert Carte NRC Mark Schwieg NRC Vijay K Goel NRC Bob Pascarelli NRC Zach Turner NRC Wendell Morton NRC Steve Smith NRC April Pulvirenti NRC Adrienne Brown NRC Brian Mann Technical Specifications Task Force (TSTF)

Drew Richards TSTF Shane Jurek TSTF Jordan Vaughan TSTF Wes Sparkman TSTF Kevin Lueshen TSTF Rebecca Steinman TSTF Jim Lynde Pressurized water reactor owners group (PWROG)

Jim Andrachek PWROG Keith Vincent PWROG Victoria Anderson Nuclear Energy Institute (NEI)

Phil Couture Entergy Timothy Falkiewicz Industry Chad Holderbaum PWROG Kristin Kaspar Industry

Package: ML24324A176 Meeting Notice: ML24303A237 Meeting handouts: ML24302A210, ML24318B831 Meeting Summary: ML24324A178 OFFICE NRR/DSS/STSB/BC NRR/DSS/STSB/PM NAME SMehta MHoncharik DATE 12/11/2024 12/11/2024