ML113040028

10/27/2011 - Summary of Public Teleconference Call with the Technical Specifications Task Force Regarding Enforcement Guidance Memorandum Related to Surveillance Requirement 3.0.3 Application to the in Service Testing Program

ML113040028
Person / Time
Site:	Technical Specifications Task Force
Issue date:	11/10/2011
From:	Michelle Honcharik NRC/NRR/DPR/PSPB
To:	John Jolicoeur Division of Policy and Rulemaking
References
Download: ML113040028 (6)

Text

November 10, 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 OCTOBER 27, 2011, PUBLIC TELECONFERENCE CALL WITH THE TECHNICAL SPECIFICATIONS TASK FORCE REGARDING ENFORCEMENT GUIDANCE MEMORANDUM RELATED TO SURVEILLANCE REQUIREMENT 3.0.3 APPLICATION TO THE IN-SERVICE TESTING PROGRAM On October 27, 2011, the U.S. Nuclear Regulatory Commission (NRC) staff held a public teleconference call with the Technical Specifications (TS) Task Force (TSTF) to discuss the enforcement guidance memorandum (EGM) related to Surveillance Requirement (SR) 3.0.3 application to the in-service testing (IST) program. The meeting notice dated July 15, 2011, is available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML112800484.

Members of the public who participated in the teleconference are listed with the teleconference participants in the enclosure. No public meeting feedback forms were received.

The NRC staff distributed a white paper to all participants. The white paper is available in ADAMS at Accession No. ML113040026. Subsequent to the meeting on November 2, 2011, the TSTF provided comments on the white paper via e-mail. The TSTF comments and e-mail are available in ADAMS at Package Accession No. ML11307A238.

The NRC staff reviewed the pertinent parts of the EGM as listed in the white paper, emphasizing that the purpose is to establish a proper generic application of SR 3.0.2 and SR 3.0.3 allowances in Standard TS (STS) 5.5 programs and a uniform basis for continued operation of nuclear power plants consistent with TIA 2010-001 "Evaluation of Application of Technical Specification Surveillance Requirement 3.0.3, "Surveillance Requirement Applicability" at Clinton Power Station." The TIA 2010-001 is available in ADAMS at Accession No. ML101100101.

The NRC staff noted this regulatory position has shown us that restructuring TS chapters during development of the improved STS resulted in unintended consequences: that SR 3.0.2 and SR 3.0.3 do not apply when the general rules for SRs are as they were made applicable to TS 5.5 program tests. The NRC staff discussed its finding that STS 5.5 programs SR applicability provisions fall into three groups:

(1) One group is defined for TS 5.5 programs to which one or both SR applicability provisions apply and the TS 5.5 program tests are associated with a limiting condition for operation (LCO) SR. Program testing performed in accordance with a TS 5.5 program and a TS SR would make SR 3.0.2 and SR 3.0.3 available without a license amendment to change the TSs.

(2) A second group is defined for TS 5.5 programs to which one or both SR applicability provisions apply, but the TS 5.5 programs are not associated with an LCO SR. Program tests performed under these programs are not associated with SRs. The NRC staff intended, as shown by the precedent set forth in improved STS, that SR 3.0.2 and SR 3.0.3 be made available to TS 5.5 programs and consequently to their tests.

(3) A final group is defined for TS 5.5 programs to which the SR applicability provisions do not apply. These programs are unaffected by the NRC staff position in TIA 2010-001, therefore the EGM would not apply.

The NRC staff also discussed development of American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM) Code Cases in parallel with the EGM to apply the 25 percent test extension of SR 3.0.2 and the SR 3.0.3 test allowance to IST, noting that SR 3.0.3 provisions were not approved. The TSTF members inquired about the EGM position on applying the 25 percent test frequency extension to IST components that are not related to SRs. The NRC staff stated that enforcement guidance would retain the current improved STS position that SR 3.0.2 would apply to TS 5.5 programs not associated with SRs. The TSTF members offered to submit comments on the white paper that specifically will address the scope issue for applying SR 3.0.2 and SR 3.0.3 to TS 5.5 testing. The TSTF submitted the comments on November 2, 2011 (ADAMS Package Accession No. ML11307A238).

Mr. Carl Schulten, NRC, commented that the projected date to issue NUREG-1482 is summer of 2012, not fall 2011 as indicated in the white paper.

Mr. Russell Stroud, APS, asked about the timeline for issuance of the EGM. Mr. Robert Elliott, NRC, stated that if the NRC receives feedback from the TSTF by November 4, 2011, then we anticipate issuance of the EGM in mid-December. No other questions or comments were received from members of the public.

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: ML113040025, Meeting summary: ML113040028; Notice: ML112800484; Meeting Handout: ML113040026; TSTF comments to handout: Package ML11307A238 OFFICE PLPB/PM PLPB/LA STSB/BC PLPB/BC PLPB/PM NAME MHoncharik DBaxley RElliott JJolicoeur MHoncharik DATE 11/4/11 11/3/11 11/7/11 11/10/11 11/10/11 DISTRIBUTION FOR

SUMMARY

OF OCTOBER 27, 2011, TELECONFERENCE CALL WITH TECHNICAL SPECIFICATIONS TASK FORCE

DATED: NOVEMBER 10, 2011

PUBLIC PLPB Reading File RidsNrrDpr RidsNrrDprPlpb RidsNrrLADBaxley Robert Elliott RidsNrrPMMHoncharik RidsNrrDssStsb Carl Schulten RidsNrrDeEptb Anthony McMurtray John Huang Lauren Gibson EXTERNAL DISTRIBUTION

ngchapma@bechtel.com tony.browning@nexteraenergy.com njstring@southernco.com wsteelm@energy.com brianm@excelservices.com wendi.croft@exeloncorp.com William.Mctigue@pseg.com jbergman@curtisswright.com

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

ENCLOSURE Participants in the Public Teleconference Call with the Technical Specifications Task Force Regarding Enforcement Guidance Memorandum Related to Surveillance Requirement 3.0.3 Application to the In-Service Testing Program October 27, 2011 Name OrganizationMichelle Honcharik NRC/Office of Nuclear Reactor Regulation (NRR)/Division of Policy and Rulemaking (DPR)/Licensing Processes Branch (PLPB) John Jolicoeur NRC/NRR/DPR/PLPB Robert Elliott NRC/NRR/Division of Safety Systems (DSS)/Technical Specifications Branch (STSB) Carl Schulten NRC/NRR/DSS/ITSB Anthony McMurtray NRC/NRR/Division of Engineering (DE)/Component Performance and Testing Branch (EPTB) John Huang NRC/NRR/DE/EPTB Emily Maguire PSEG, Licensing Edward Maloney PSEG, Engineering Services Russell Stroud APS William McTigue PSEG, Licensing Jana Bergman Scientech Nancy Chapman Bechtel Wendy Croft TSTF Tony Browning TSTF Brian Mann TSTF Jack Stringfellow TSTF Dennis Swan Southern Nuclear Rick Graham Southern Nuclear