ML19029A016: Difference between revisions
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{{#Wiki_filter:/RA by Andrea Russell for/}} | {{#Wiki_filter:V. Cusumano August 26, 2019 MEMORANDUM TO: Victor G. Cusumano, Branch Chief Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation FROM: Michelle C. Honcharik, Senior Project Manager /RA by Andrea Russell for/ | ||
Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation | |||
==SUBJECT:== | |||
==SUMMARY== | |||
OF JANUARY 28, 2019, TELECONFERENCE CALL WITH THE TECHNICAL SPECIFICATIONS TASK FORCE RE: | |||
IMPLEMENTATION OF TSTF-542, REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL On January 28, 2019, a Category 2 public teleconference call was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of the Technical Specifications Task Force (TSTF). The purpose of the call was to discuss the implementation guidance of TSTF-542, "Reactor Pressure Vessel Water Inventory Control," as it relates to the use of limiting condition for operation (LCO) 3.0.8. The notice is available in the Agencywide Documents Access and Management System at Accession No. ML19015A109. A list of attendees is enclosed. | |||
NRC staff was concerned that licensees may have been misinterpreting the implementation guidance, specifically the following sentence: Therefore, LCO 3.0.8 may be applied to exclude penetration flow paths with nonfunctional snubbers that could result in a limiting drain rate due to common mode failure from the Drain Time calculation. Technical Specification (TS) | |||
LCO 3.0.8 provides either a 12-hour or 72-hour delayed time allowance or time relaxation for snubber(s) when the snubbers are unable to perform their associated support function. The NRC staff informed the TSTF that they had an elevated sensitivity regarding the potential impacts that outage-related activities could have on the bounding Drain Time calculation of record. Non-seismic-related initiating events on critical piping pathways, which are not bounded by the Drain Time calculation, could result in reduced operational flexibilities. The requirements of TS LCO 3.5.2 (i.e., Conditions C, D, and E) may establish more restrictive plant conditions as compared to the applicability statements included in TS LCO 3.0.8. | |||
CONTACT: Michelle C. Honcharik, NRR/DSS 301-415-1774 | |||
V. Cusumano The NRC staff and TSTF representatives agreed that LCO 3.0.8 is not an exception to performing a surveillance requirement. In addition, both parties agreed the conditions described in LCO 3.0.8 need to be met to invoke the delayed time allowed. The TSTF representatives will provide a document clarifying the intended implementation of TSTF-542 to industry. | |||
There were no handouts for the meeting. | |||
No members of the public had comments. | |||
Project No. 753 | |||
==Enclosure:== | |||
As stated cc: See next page | |||
Package: ML19029A017, Meeting summary: ML19029A016; Meeting notice: ML19015A109 | |||
*concurred via e-mail NRR-106 OFFICE NRR/DSS/STSB NRR/DSS/STSB/BC NRR/DSS/STSB NAME MHoncharik VCusumano MHoncharik (ARussell for) | |||
DATE 8/22/2019 8/22/2019 8/26/2019 | |||
LIST OF ATTENDEES Brian Mann TSTF, EXCEL Services Corporation Jana Bergman Curtiss-Wright/Scientech Tracy Orf Tennessee Valley Authority Ozzie Vidal Certrec Corporation Lee Marabella PSEG Nuclear Mitchel Mathews Exelon Nuclear Dennis Pereira Entergy, River Bend Station Patrick Simpson Exelon Generation Company Paul Duke PSEG Nuclear Ryan Joyce TSTF, Southern Nuclear Operating Company Chris Smith Energy Northwest, Columbia Generating Station NRC Staff: | |||
Caroline Tilton Victor Cusumano Michelle Honcharik Jennifer Whitman Diana Woodyatt Bob Tjader Russ Haskell Michael Marshall Larry Wheeler Enclosure | |||
Technical Specifications Task Force Project No. 753 cc: | |||
Technical Specifications Task Force c/o EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Attention: Brian D. Mann E-mail: brian.mann@excelservices.com James P. Miksa Entergy Nuclear Operations, Inc. | |||
Palisades Nuclear Power Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Email: jmiksa@entergy.com Jordan L. Vaughan Duke Energy EC07C / P.O. Box 1006 Charlotte, NC 28202 Email: jordan.vaughan@duke-energy.com Ryan M. Joyce Southern Nuclear Operating Company 3535 Colonnade Parkway / Bin N-274-EC Birmingham, AL 35243 Email: rmjoyce@southernco.com David M. Gullott Exelon Generation 4300 Winfield Road Warrenville, IL 60555 Email: David.Gullott@exeloncorp.com Wesley Sparkman Southern Nuclear Operating Company 3535 Colonnade Parkway / Bin N-226-EC Birmingham, AL 35242 Email: wasparkm@southernco.com}} |
Revision as of 07:05, 20 October 2019
ML19029A016 | |
Person / Time | |
---|---|
Site: | Technical Specifications Task Force |
Issue date: | 08/26/2019 |
From: | Michelle Honcharik NRC/NRR/DSS/STSB |
To: | Victor Cusumano NRC/NRR/DSS/STSB |
Honcharik M, NRR/DSS, 301-415-1774 | |
Shared Package | |
ML19029A017 | List: |
References | |
TSTF-542 | |
Download: ML19029A016 (5) | |
Text
V. Cusumano August 26, 2019 MEMORANDUM TO: Victor G. Cusumano, Branch Chief Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation FROM: Michelle C. Honcharik, Senior Project Manager /RA by Andrea Russell for/
Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JANUARY 28, 2019, TELECONFERENCE CALL WITH THE TECHNICAL SPECIFICATIONS TASK FORCE RE:
IMPLEMENTATION OF TSTF-542, REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL On January 28, 2019, a Category 2 public teleconference call was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of the Technical Specifications Task Force (TSTF). The purpose of the call was to discuss the implementation guidance of TSTF-542, "Reactor Pressure Vessel Water Inventory Control," as it relates to the use of limiting condition for operation (LCO) 3.0.8. The notice is available in the Agencywide Documents Access and Management System at Accession No. ML19015A109. A list of attendees is enclosed.
NRC staff was concerned that licensees may have been misinterpreting the implementation guidance, specifically the following sentence: Therefore, LCO 3.0.8 may be applied to exclude penetration flow paths with nonfunctional snubbers that could result in a limiting drain rate due to common mode failure from the Drain Time calculation. Technical Specification (TS)
LCO 3.0.8 provides either a 12-hour or 72-hour delayed time allowance or time relaxation for snubber(s) when the snubbers are unable to perform their associated support function. The NRC staff informed the TSTF that they had an elevated sensitivity regarding the potential impacts that outage-related activities could have on the bounding Drain Time calculation of record. Non-seismic-related initiating events on critical piping pathways, which are not bounded by the Drain Time calculation, could result in reduced operational flexibilities. The requirements of TS LCO 3.5.2 (i.e., Conditions C, D, and E) may establish more restrictive plant conditions as compared to the applicability statements included in TS LCO 3.0.8.
CONTACT: Michelle C. Honcharik, NRR/DSS 301-415-1774
V. Cusumano The NRC staff and TSTF representatives agreed that LCO 3.0.8 is not an exception to performing a surveillance requirement. In addition, both parties agreed the conditions described in LCO 3.0.8 need to be met to invoke the delayed time allowed. The TSTF representatives will provide a document clarifying the intended implementation of TSTF-542 to industry.
There were no handouts for the meeting.
No members of the public had comments.
Project No. 753
Enclosure:
As stated cc: See next page
Package: ML19029A017, Meeting summary: ML19029A016; Meeting notice: ML19015A109
- concurred via e-mail NRR-106 OFFICE NRR/DSS/STSB NRR/DSS/STSB/BC NRR/DSS/STSB NAME MHoncharik VCusumano MHoncharik (ARussell for)
DATE 8/22/2019 8/22/2019 8/26/2019
LIST OF ATTENDEES Brian Mann TSTF, EXCEL Services Corporation Jana Bergman Curtiss-Wright/Scientech Tracy Orf Tennessee Valley Authority Ozzie Vidal Certrec Corporation Lee Marabella PSEG Nuclear Mitchel Mathews Exelon Nuclear Dennis Pereira Entergy, River Bend Station Patrick Simpson Exelon Generation Company Paul Duke PSEG Nuclear Ryan Joyce TSTF, Southern Nuclear Operating Company Chris Smith Energy Northwest, Columbia Generating Station NRC Staff:
Caroline Tilton Victor Cusumano Michelle Honcharik Jennifer Whitman Diana Woodyatt Bob Tjader Russ Haskell Michael Marshall Larry Wheeler Enclosure
Technical Specifications Task Force Project No. 753 cc:
Technical Specifications Task Force c/o EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Attention: Brian D. Mann E-mail: brian.mann@excelservices.com James P. Miksa Entergy Nuclear Operations, Inc.
Palisades Nuclear Power Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Email: jmiksa@entergy.com Jordan L. Vaughan Duke Energy EC07C / P.O. Box 1006 Charlotte, NC 28202 Email: jordan.vaughan@duke-energy.com Ryan M. Joyce Southern Nuclear Operating Company 3535 Colonnade Parkway / Bin N-274-EC Birmingham, AL 35243 Email: rmjoyce@southernco.com David M. Gullott Exelon Generation 4300 Winfield Road Warrenville, IL 60555 Email: David.Gullott@exeloncorp.com Wesley Sparkman Southern Nuclear Operating Company 3535 Colonnade Parkway / Bin N-226-EC Birmingham, AL 35242 Email: wasparkm@southernco.com