TSTF-17-02, Technical Specifications Task Force - Request for NRC to Withdraw November 7, 2013 Letter to TSTF Concerning TSTF-51, TSTF-286, and TSTF-471
| ML17033A212 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 02/02/2017 |
| From: | Gustafson O, Leisure M, Morris J, Redd J, Linda Williams Technical Specifications Task Force |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TSTF-17-02, TSTF-286, TSTF-471, TSTF-51 | |
| Download: ML17033A212 (4) | |
Text
TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY February 2, 2017 TSTF-17-02 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Request for NRC to Withdraw November 7, 2013 Letter to TSTF concerning TSTF-51, TSTF-286, and TSTF-471
REFERENCE:
Letter Anthony Mendiola (NRC) to the TSTF, "Potential Issues with Plant-Specific Adoption of Travelers TSTF-51, Revision 2, 'Revise Containment Requirements During Handling of Irradiated Fuel and Core Alterations,' TSTF-286, Revision 2, 'Operations Involving Positive Reactivity Additions,' and TSTF-471, Revision 1, 'Eliminate Use of Term Core Alterations in Actions and Notes'," dated November 7, 2013 (ADAMS Accession No. ML13246A358)
In the referenced letter, the NRC raised potential issues with the subject travelers. The letter stated:
The issues identified above are preliminary. The NRC staff needs additional time to complete a thorough review. Therefore, it is suggested that licensees should not submit amendments to adopt these three Travelers until a final resolution is achieved. The NRC staff would consider working with the industry in getting the concerns resolved.
The TSTF requests that the NRC withdraw the letter and allow licensees to adopt these approved travelers.
As of the thirteenth quarterly TSTF/NRC public meetings held since the letter was received, the NRC has yet to provide a final position on why the subject travelers are unacceptable. TSTF has tried to address the NRC concerns, which have continued to change.
- 1. At the November 21, 2013 TSTF/NRC public meeting, the letter was discussed so the TSTF could obtain a full understanding of the staff concerns.
- 2. At the January 9, 2014, public meeting, the TSTF provided a white paper with proposed actions that licensees could take to when adopting the travelers to address the staff concerns.
The NRC and TSTF discussed the paper and the TSTF agreed to address additional staff concerns raised at the meeting.
11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation
TSTF 17-02 February 2, 2017 Page 2
- 3. At the April 10, 2014 public meeting, the TSTF provided a revised paper and the NRC agreed to review it.
- 4. At the next TSTF meeting held on July 10, 2014,, the NRC was not prepared to discuss the paper. The Accident Dose and Reactor Systems Branch Chiefs committed to being prepared to discuss the paper at the next meeting, scheduled for November 13, 2014.
- 5. At the November 13, 2014 public meeting, the Reactor Systems Branch chief stated that the TSTF's proposed action resolved their concern regarding the Technical Specifications (TS)
Actions for an inoperable source range detector. No one from the Accident Dose branch was present and no comments had been provided. The Technical Specifications Branch chief committed to arrange a separate meeting in January 2015, but no meeting was held.
- 6. The TSTF provided a revised position paper prior to the February 2, 2015 public meeting (ADAMS Accession No. ML15041A062). The Reactor Systems Branch confirmed that the proposed resolution addresses their concerns. The Dose Assessment branch provided verbal comments on the proposed actions to make them acceptable. The NRC project manager committed to provide written comments from the Dose Assessment Branch.
- 7. The Dose Assessment Branch's comments were received by email just prior to the April 16, 2015 TSTF/NRC public meeting. Because of the late arrival and the significance of the comments, the TSTF was not prepared to discuss them.
- 8. At the July 23, 2015 TSTF/NRC public meeting, the TSTF provided a presentation expressing concerns that the licensee actions suggested by the Dose Assessment Branch comments would reverse long-standing and well established provisions of NRC guidance, the Technical Specifications, and plants' licensing basis, and would have far-reaching effects on licensees. The NRC agreed to consider the TSTF concerns.
- 9. At the November 12, 2015 TSTF/NRC public meeting, the NRC stated that the Dose Assessment Branch lead reviewer has been tasked with writing a description of his concerns for management consideration.
- 10. At the February 18, 2016 TSTF/NRC public meeting, the NRC stated that the Dose Assessment Branch lead reviewer is actively working on a study which should be completed in the next 3 months to determine if there are any safety issues.
- 11. At the April 28, 2016 TSTF/NRC public meeting, there was no change in status.
- 12. At the September 1, 2016 TSTF/NRC public meeting, there was no change in status.
- 13. At the November 3, 2016 TSTF/NRC public meeting, there was no change in status.
In over three years, the NRC has been unable to provide a justification for withholding approval of plant license amendments to adopt these travelers. These three travelers are very beneficial, both to nuclear safety and to plant operation. TSTF-51 and TSTF-286 were incorporated into
TSTF 17-02 February 2, 2017 Page 3 Revision 2 of the ISTS (published in 2001) and have been incorporated into the TS of many plants.
Since the letter was provided, four licensees have withdrawn amendment requests to adopt these travelers due to the as-yet unsubstantiated staff concerns. The wasted NRC review fees for just two of these unsuccessful requests exceeded half a million dollars. A license amendment request to convert to the improved Standard Technical Specifications was delayed by almost a year over these same issues.
We request that the NRC withdraw their November 7, 2013 letter and allow licensees to adopt these travelers as presented in the ISTS NUREGs until such time that the NRC provides a documented safety case on why the changes are inadequate. It is not reasonable for the staff to raise an issue and then fail to act for over three years while licensees await a decision of whether there is or isn't a concern.
Should you have any questions, please do not hesitate to contact us.
James R. Morris (PWROG/W) Lisa L. Williams (BWROG)
Otto W. Gustafson (PWROG/CE) Michael K. Leisure (PWROG/B&W)
Jason P. Redd (APOG)
Enclosure cc: Robert Taylor, Division of Safety Systems Michelle Honcharik, Technical Specifications Branch Alex Klein, Technical Specifications Branch