ML113220179

11/17/2011 Summary of Meeting with TSTF Revision to TSTF-523

ML113220179
Person / Time
Site:	Technical Specifications Task Force
Issue date:	11/30/2011
From:	Michelle Honcharik NRC/NRR/DPR/PSPB
To:	John Jolicoeur Licensing Processes Branch (DPR)
References
TSTF-523
Download: ML113220179 (6)

Text

November 30, 2011 MEMORANDUM TO: John R. Jolicoeur, Chief Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation FROM: Michelle C. Honcharik, Senior Project Manager /RA/

Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation

SUMMARY

OF THE NOVEMBER 17, 2011, U.S. NUCLEAR REGULATORY COMMISSION MEETING WITH THE TECHNICAL SPECIFICATIONS TASK FORCE REGARDING REVISION TO TRAVELER TSTF-523 On November 17, 2011, the U.S. Nuclear Regulatory Commission (NRC) staff met with members of the Technical Specifications (TS) Task Force (TSTF) regarding Traveler TSTF-523, "Generic Letter 2008-01, Managing Gas Accumulation." The meeting was held at NRC offices in One White Flint North, 11555 Rockville Pike, Rockville, Maryland 20852. A list of the meeting attendees is enclosed. The meeting notice dated October 24, 2011, is available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML112940302.

Members of the TSTF provided the NRC with a sample of the proposed TS and TS Bases changes in advance of the meeting, which is available in ADAMS at Accession No. ML113220171. Members of the TSTF also gave a presentation during the meeting. The presentation is available in ADAMS at Accession No. ML113220164.

Mr. Jack Stringfellow, TSTF, reviewed background information and the basics of the surveillance frequency control program (SFCP). He noted that the proposed revision to TSTF-523 will not reference the Nuclear Energy Institute (NEI) Topical Report, NEI 09-10, Guidelines for Effective Prevention and Management of System Gas Accumulation. However, information proposed to be included in the TS Bases with TSTF-523 is similar to some of the information contained in NEI 09-10.

Mr. Stringfellow reviewed the proposed changes to Westinghouse TS. Mr. Tony Browning, TSTF, discussed the proposed revisions to boiling water reactor (BWR)/4 plant TS.

Mr. Browning noted that the changes will be similar in the BWR/6 TS.

Mr. Sheldon Stuchell, NRC, asked about completion times for required actions. Mr. Browning, TSTF, responded that they are not proposing to change the required actions. If the completion time was 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before, it will still be 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

Mr. Stringfellow, TSTF, reviewed the proposed surveillance requirement (SR) wording changes, specifically, the use of sufficiently filled with water. He stated that the principal is consistent

J. Jolicoeur with the NRC staff proposal in the May 25, 2011, letter (ADAMS Accession No. ML111430832) and with what industry does today. The proposed phrasing in TS provides a nexus to system operability. He noted that the intent of wording in TS Bases is to be consistent with wording in NEI 09-10.

Mr. Stringfellow, TSTF, asked if the NRC staff had any questions/comments regarding the TS Bases wording. He commented that they tried to capture the essential elements of gas management. Mr. Robert Elliott, NRC, asked if there were any problems with TSTF-425 SFCP process being used in conjunction with gas accumulation. Mr. Browning, TSTF, answered that the TSTF-425 program works well with TSTF-523. Mr. Stringfellow, TSTF, commented that a lot of the issues particular to gas management are captured with the TSTF-425 program: if doing quarterly SRs and start seeing gas, then the licensee would ratchet it back; if they needed to shorten SRs because of failures, then thats controlled by the licensees corrective action program. Even if they find gas, but are still operable (within limits) - the licensee would have to evaluate to see if they can wait until the next SR (i.e., if they do nothing, will it still pass the SR next time?).

Mr. Stuchell, NRC, asked when does the licensee perform the analysis to determine where they may have gas. The TSTF members replied that every plant has already done that analysis in response to the GL 2008-001. Ms. Jennifer Gall, NRC, asked the TSTF to confirm that the surveillance procedures will include the list of susceptible locations. The TSTF members answered - yes. Mr. Elliott, NRC, asked - what if they decide to change the list of susceptible locations? The TSTF members replied that the locations are in the surveillance procedures, which cannot be changed without a Title 10 of the Code of Federal Regulation 50.59 review.

Mr. Stuchell, NRC, asked about where sufficiently filled with water is defined. Mr. Stringfellow, TSTF, answered that a lot of analysis was done to determine what an acceptable void would be at a given location. Mr. Browning, TSTF, commented that the value/definition will be in the surveillance procedures. Mr. Stringfellow, TSTF, commented that licensees performed design reviews and made the determinations in response to GL 2008-001. Mr. Mann, TSTF, commented that the TS Bases state that if gas is found, the licensee has to be able to quantify it.

In answer to Mr. Elliotts concern with respect to system operability if they find gas during a surveillance, Mr. Mann, TSTF, explained that if a licensee performs the surveillance and finds gas that exceeds the acceptance criteria, then the surveillance fails and the system is declared inoperable. The licensee can then perform an operability determination and if it passes - the SR is met and any entered actions can be exited.

Mr. Matthew Hamm, NRC, stated that some of the questions the proposed TS and TS Bases elicited are whether or not the language is really going to fix the problem, and whether or not it is inspectable. Can a licensee and inspector open the TS Bases and agree on what procedures are applicable? Mr. Hamm asked if the TSTF had considered making explicit references in the TS Bases to the locations of plant-specific data and procedures. Mr. Stringfellow, TSTF, replied that he did not think it would add value to list the procedures in the TS or in the TS Bases. He pointed out that every surveillance has an associated procedure, and that the procedure would list the parts of the system that needed to be evaluated, as well as, provide the relevant references to the engineering analyses. Listing the information in the TS Bases would,

J. Jolicoeur therefore, be redundant, and create problems when procedures were revised because licensees would need to remember to revise the references in the TS Bases as well.

Mr. Warren Lyon, NRC, asked why is there an option for 31 days or in accordance with SFCP in SR 3.5.2.3. It was explained that the in accordance with SFCP is for licensees that have already adopted TSTF-425. Mr. Mann commented that a plant without TSTF-425 would have 31 days. He added that the or is only for the purpose of the standard TS, actual plant TS will not have the or, they would have one or the other. Mr. Lyon also commented that sometimes 31 days may be too long or too short. It was explained that the flexibility is there to lengthen the periodicity, but the licensee cannot jump from monthly to every outage; they need to step it out in accordance with the SFCP of TSTF-425. Mr. Stringfellow commented that if 31 days is too long, the licensees corrective action program will require them to go to a shorter time frame.

The NRC staff will review the material presented and provide any feedback/comments to the TSTF by mid-December. The TSTF plans to submit the revision to TSTF-523 in March 2012.

No members of the public attended or participated via teleconference. No public meeting feedback forms were received.

Please direct any inquiries to me at 301-415-1774 or at Michelle.Honcharik@nrc.gov.

Project No. 753

Enclosure:

List of Attendees cc w/encl: See next page

Package: ML113220178 Meeting summary: ML113220179 Meeting notice: ML112940302 Meeting handouts: ML113220171, ML113220164 OFFICE PLPB/PM PLPB/LA PLPB/BC PLPB/PM NAME MHoncharik DBaxley JJolicoeur MHoncharik DATE 11/30/11 11/29/11 11/30/11 11/30/11

Technical Specifications Task Force Project No. 753 cc:

Technical Specifications Task Force 11921 Rockville Pike Suite 100 Rockville, MD 20852 Attention: Donald R. Hoffman E-mail: donaldh@excelservices.com Norman J. (Jack) Stringfellow Southern Nuclear Operating Company P.O. Box 1295 Birmingham, AL 35201-1295 E-mail: string@southernco.com Roy A. (Tony) Browning Duane Arnold Energy Center 3277 DAEC Rd.

PSC/Licensing Palo, IA 52324-9785 E-mail: tony.browning@nexteraenergy.com William J. (Billy) Steelman Entergy Waterford 3 17265 River Road Hwy 18 Killona, LA 70057 E-mail: wsteelm@energy.com Wendy E. Croft Exelon Nuclear 200 Exelon Way, Suite 340 Kennett Square, PA 19348 E-mail: wendi.croft@exeloncorp.com Brian D. Mann EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 E-mail: brianm@excelservices.com

Attendees at the TSTF-523 Meeting November 17, 2011 Name Organization John Jolicoeur NRC/Office of Nuclear Reactor Regulation (NRR)/Division of Policy and Rulemaking (DPR)/Licensing Processes Branch (PLPB)

• Michelle Honcharik NRC/NRR/DPR/PLPB Sheldon Stuchell NRC/NRR/DPR/PLPB Robert Elliott NRC/NRR/ Division of Safety Systems (DSS)/Technical Specifications Branch (STSB)

Matthew Hamm NRC/NRR/DSS/STSB

• Warren Lyon NRC/NRR/DSS/Reactor Systems Branch (SRXB)

Jennifer Gall NRC/NRR/DSS/SRXB Joshua Miller NRC/NRR/DSS/SRXB Zeechung (Gary) Wang NRC/Office of Nuclear Regulatory Research Tony Browning Technical Specifications Task Force (TSTF)

Brian Mann TSTF Jack Stringfellow TSTF Jim Riley Nuclear Energy Institute (NEI) Gas Accumulation Team (GAT)

Ken Petersen Strategic Teaming and Resource Sharing (STARS)

(NEI GAT)

Henry Hegrat FirstEnergy Nuclear Jim Andracheck Westinghouse Les England Entergy Services

• Participated via teleconference.

ENCLOSURE