TSTF-10-13, Change in Fee Exemption for TSTF-513 & TSTF-514

Change in Fee Exemption for TSTF-513 & TSTF-514

ML101720430
Person / Time
Site:	Technical Specifications Task Force
Issue date:	06/21/2010
From:	Gambrell R, Gregoire D, Raidy T, Schrader K Babcock & Wilcox, BWR Owners Group, Combustion Engineering, PWR Owners Group, Technical Specifications Task Force, Westinghouse
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TATF-513, TSTF-10-13, TSTF-514
Download: ML101720430 (2)

Text

TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY June 21, 2010 TSTF-10-13 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Change in Fee Exemption for TSTF-513 and TSTF-514

REFERENCES:

1. Letter from TSTF to NRC Chief Financial Officer, "Request for Fee Exemption for TSTF-513, 'Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation,' and TSTF-514, 'Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation,'

dated February 18, 2009.

2. Letter from J. E. Dyer (NRC) to TSTF dated March 27, 2009.

3. RIS 2009-02, "Use of Containment Atmosphere Gaseous Radioactivity Monitors for Reactor Coolant System Leakage Detection Equipment at Nuclear Power Reactors," January 29, 2009.

4. Memorandum to NRC Regional Administrators, Eric J. Leeds, Michael R.

Johnson, Charles L. Miller, Michael F. Weber, Roy P. Zimmerman, from Cynthia A. Carpenter, "Enforcement Guidance Memorandum -

Dispositioning Violations of NRC Requirements for Operability of Gaseous Monitors for Reactor Coolant System Leakage Detection,"

January 30, 2009.

In Reference 1, the TSTF requested a fee exemption for NRC review of TSTF Travelers TSTF-513, "Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation," and TSTF-514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation." In Reference 2, the NRC granted the fee exemption. The request and approval were based on supporting the resolution of containment atmosphere gaseous radioactivity monitor operability concerns described in Reference 3.

The Notices for Comment for TSTF-513 and TSTF-514 were published in the Federal Register on October 9, 2009 and April 13, 2010, respectively. The Notices for Comment included model Safety Evaluations for the Travelers.

On June 11, the NRC informed the TSTF that one proposed change in TSTF-513 and TSTF-514 should not have been included in the fee exemption. TSTF-513 and TSTF-514 proposed to revise the actions taken when there are no operable Reactor Coolant System (RCS) leakage 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation

TSTF 10-13 June 21, 2010 Page 2 detection instruments. The TSTF included this change in order to address "inoperable containment atmosphere gaseous radioactivity monitoring systems in an integrated fashion," as stated in Reference 3. However, the NRC has concluded these changes are not necessary to address the issues discussed in Reference 3.

The NRC issued an Enforcement Guidance Memorandum (EGM) (Ref. 4) to exercise enforcement discretion and not cite licensees for TS violations while a generic solution was developed. The TSTF understands the NRC interest in resolving the issue and closing the EGM as soon as possible.

The NRC review of TSTF-513 and TSTF-514 is substantially complete (as evidenced by the publication of the Notices for Comment). In order to facilitate the timely resolution of this issue and expeditious closure of the EGM, the TSTF does not object to excluding from the fee exemption the NRC review of the proposed actions for no operable leakage detection instruments. Excluding the actions from the fee exemption will allow prompt publication of the Notices of Availability. The alternative would be for the TSTF to develop and submit revised Travelers without the actions, which would require the NRC to revise the model Safety Evaluations and republish the Notices for Comment. This would extend the closure of the EGM into FY 2011.

NRC review of the TSTF-513 proposed change to the actions for no operable leakage detection instruments (Condition D in NUREG-1430, Condition F in NUREG-1431 and NUREG-1432) should be billed to the Pressurized Water Reactor Owners Group.

NRC review of the TSTF-514 proposed change to the actions for no operable leakage detection instruments (Condition F in NUREG-1433 and NUREG-1434) should be billed to the Boiling Water Reactor Owners' Group.

Should you have any questions, please do not hesitate to contact us.

Kenneth J. Schrader (PWROG/W) Donald W. Gregoire (BWROG)

For Thomas W. Raidy (PWROG/CE) Reene' Gambrell (PWROG/B&W) cc: James Dyer, Chief Financial Officer, NRC Frederick Brown, Director, Division of Inspection and Regional Support Robert Elliott, Technical Specifications Branch, NRC Barry Miller, Licensing Processes Branch, NRC