ML20135D788
| ML20135D788 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/1996 |
| From: | Charemagne Grimes NRC (Affiliation Not Assigned) |
| To: | Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| Shared Package | |
| ML20134E038 | List: |
| References | |
| NUDOCS 9612100139 | |
| Download: ML20135D788 (8) | |
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December 3, 1996 ,
Mr. James Davis Nucisar Energy Institute '
1776 Eye Street, N. W.
Suite 300 Washington, DC 20006-2496 _
Dear Mr. Davis:
The purpose of this letter is to transmit a sumary of the Technical Specifications. Task Force (TSTF) meeting, which took place at the U.S. l Nuclear Regulatory Comission in Rockville, Maryland, on October 29-30, 199E.
I am also enclosing a sumary description of those Traveller Packages that were Modified and Rejected, as was discussed at our meeting on October 29, as well as a copy of all hand-outs distributed during the meeting. l l
Sincerely, i Original Signed by:
l C. I. Grimas !
Christopher I. Grimes, Chief Technical Specifications Branch Associate Director for Projects !
Office of Nuclear Reactor Regulation
Enclosures:
- 1. Meeting Summary
- 2. Disposition Summary
- 3. Handout: 10/28/96 Letter to C. Randy Hutchinson Entergy Operations, Inc.
- 4. Handout: SGML Technical Specifications
- 5. Handout: Writers Guide Issues, " Differences Between WP51 and SGML Formatted STS" cc: D. Hoffman, EXCEL B. Mann, BG&E Co.
A. Maron, PP&L 3 H. Pontious, CECO C. Szabo, Entergy Ops.
B. Ford, Entergy Ops. I
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NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. - "1 4 , , , , , ,& December 3, 1996 l
Mr. James Davis l Nuclear Energy Institute i 1776 Eye Street, N. W. '
Suite 300 Washington, DC 20006-2496
Dear Mr. Davis:
The purpose of this letter is to transmit a summary of the Technical Specifications Task Force (TSTF) meeting, which took place at the U.S. I Nuclear Regulatory Commission in Rockville, Maryland, on October 29-30, 1996.
I am also enclosing a summary description of those Traveller Packages that were Modified and Rejected, as was discussed at our meeting on October 29, as well as a copy of all hand-outs distributed during the meeting. i Sincerely, 0
Christopher I. Grimes, Chief Technical Specifications Branch J Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosures:
- 1. Meeting Summary
- 2. Disposition Summary
- 3. Handout: 10/28/96 Letter to C. Randy Hutchinson Entergy Operations, Inc.
- 4. Handout: SGML Technical Specifications
- 5. Handout: Writers Guide Issues, " Differences Between WP51 and SGML Formatted STS" cc: D. Hoffman, EXCEL B. Mann, BG&E Co.
A. Maron, PP&L H. Pontious, CECO C. Szabo, Entergy Ops.
B. Ford, Entergy Ops.
L-_
Enclosure 1 TSTF OWNER'S GROUP MEETING SupMARY October 28-29, 1996 The meeting of the Technical Specifications Task Force convened on October 28, 1996 at 8:00 a.m. Chris Grimes opened the meeting by asking for any comments or corrections to the Traveller Package Status Report transmitted via letter to James Davis at the Nuclear Energy Institute; none were given.
Following are highlights of the topics discussed.
Philosophy, Resources and Thresholds (Administrative Letter 96-04)
NRC resources are being shifted from licensing actions (amendments) to licensing activities (inspection and enforcement) to improve the NRC's oversight of licensee performance as resources decline. Accordingly, the priority for STS changes and license amendments needs to be updated to provide more meaningful criteria for particular actions and give-generic changes a higher priority than plant-specific actions. NRC is currently considering such criteria and process changes, and requested that TSTF comment specifically on the appropriate priorities for STS changes relative to plant-specific licensing actions.
NRC renewed a long-standing request for a standard industry practice to better identify and justify requests for amendments. In particular, the TSTF was asked to comment on a more meaningful criteria for Cost-Beneficial Licensing Actions (CBLAs) than the $100,000 plant lifetime savings.
Data Sharing Transmittal of meeting notices, summaries, and other correspondence will continue to be sent via electronic mail to the TSTF. NRC will also send approved change packages to the TSTF for their review; if comments and/or corrections are not received from TSTF within 10 days of receipt, NRC will assume the changes have been incorporated properly and post the changes to the Bulletin Board System.
Clarification of post-disposition actions was resolved as follows:
" Modify" indicates TSTF action, while "Pending" indicates NRC action.
Further, the group agreed that, during the Owner's Group meeting, TSTF would acknowledge NRC's disposition at the time each Traveller package is discussed. '
Traveller Status See TSB Traveller Summary (Enclosure 2).
Representatives of the Reactor Systems Branch joined the meeting in :
order to resolve Traveller Package numbers TSTF-107, -108, -109, -110, !
and -112. TSTF-107 was Rejected because differences in PWR specs were not shown. TSTF-108 is to be Modified to provide more clarification !
and address the consistency across all PWRs. TSTF-109 was Approved. l 1
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TSTF-110 is to be Modified to expand the justification to include
- background information for removing the alarm and support frequency changes. TSTF-ll2 is to be Modified to more clearly justify changes.
STS and ITS Processing Agreement was reached that NRC will only maintain the paginable Bases
! electronic version of the Standard Technical Specifications (Rev. IA),
i A presentation, with handouts, was made on the benefits of using Standard Generalized Mark-up Language (SGML) for the Standard Technical Specifications rather than Wordperfect or other word processing software.
Mr. Szabo commented that software costs and administration may preclude SGML as an effective exchange medium because creating two different versions of the technical specifications may be less expensive in the i short-term.
A list of Writer's Guide issues which must be resolved in conjuction with SGML usage was provided by NRC to the meeting attendees. These ;
issues will be used by the TSTF and NEI to compile a list of electronic information exchange policy issues to be provided to NRC.
Commitments and Actions The next Owner's Group meeting is tentatively scheduled for Friday, December 6, 1996.
Debby Johnson agreed to send the TSB Access database of STS changes to Jim Davis via e-mail. ;
Debby Johnson agreed to send the approved change files that are currently posted to the FedWorld BBS to the TSTF.
The TSTF will provide input to NRC regarding new traveller package review criteria, along with proposed schedule.
Donald Hoffman will provide the TSTF Access database structure and an updated status report to Debby Johnson in 2 to 3 days.
l Enclosure 2 TSB TRAVELLER
SUMMARY
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There are 37 Traveller Packages that have been approved by NRC. In addition
, to those Traveller Packages listed in the attachment to my letter to you dated September 27, 1996, Traveller Package numbers TSTF-012, R. 1, TSTF-096,
, and TSTF-109 are approved.
During the meeting, the TSTF withdrew two Traveller Packages; these were 2
TSTF-049 and TSTF-050. There are 18 Traveller Packages that will be approved 4
with a Modification, and 17 Traveller Packages that are Rejected. The Traveller Package numbers with a summary of the disposition follows in numerical order.
t TSTF-04 1 REJECT: The proposed change to the definition of PTLR does not rise to the l 1evel of detail warranting a change to the NUREGs. The definition does not 4
have to be exactly like the COLR. Generic Letter 96-03 was revised based on
] public comments to provide clarification and flexibilit.v for the various i
applications of PTLR to LTOP, PORV setpoints and enabling temperatures. The staff believes that the guidance in the Generic Letter is sufficient, and the definition is not the appropriate means to resolve these issues.
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- TSTF-22 I l
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! REJECT: The proposed change to bracket the RHR flow in the SR does not l warrant change to the STS. Generally, it should be understood that plants that do not have particular requirements in their existing technical specifications do not have to add the requirements to conform with the STS, unless such requirements are needed for completeness. If the RHR flow is not l included in the existing licensing basis, as the justification for the change
! states, we would expect conversion applications to cite the licensing basis l as justification for departing from the STS because the flow rate is not j needed for the SR.
J TSTF-52 MODIFY: The staff has concluded that, because some licensees have selectively adopted the optional provisions of Appendix J, the STS changes
, need to provide guidance for both Option A and Option B. Accordingly, TSTF-i 52 should be revised to include Option B as alternative requirements. In addition, the following comments should be explicitly addressed in the justification for the STS changes, relative to the model technical
- specifications in NRC's November 2,1995 letter, if the TSTF intended to take
- exception to that model. The following comments are applicable to all
! NUREGs, except where noted.
- 1. is not deleted in TSTF-52. Since L is adequately The definition defined in Appendix of L,J and in the Program description, it,is not clear i whether this definition is needed for either option, or should be j retained in the technical specifications for convenience.
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4 2 TSTF-52 (continued) l 2. The Bases for 3.0.2 did not include the addition in the NRC letter and i
deleted the existing statement about overriding compliance with the regulations. While it may be believed that such a motherhood statement is self-evident, the staff believes it is still a particularly useful reminder relative to Appendix J.
- 3. The proposed Inserts C and D for Bases 3.6.1.1 are confusing and unnecessary.
- 4. The Bases changes failed to include NES 94-01 and ANSI /ANS 56.8-94 in the references, as recommended in the NRC model. The staff believes that these are useful and should either be added to the Bases text or acknowledged as a departure from the Writers Guide.
- 5. The proposed Insert E for Section 3.6.2 of the Bases deletes "as L,"
! from the reference to Appendix J. The staff believes that this clarification is useful.
- 6. NUREG-1433 changes to Section SR 3.6.1.2.1 did not add " Note 2." This
, note is equally applicable to the BWR/4 design, and should also be j included in the Bases description.
- 7. NUREG-1432 is missing the program description in Section 5.5.
i 8. NUREG-1433/4 did not move the hydrostatic testing requirements in Sections SR 3.6.1.3.14 and SR 3.6.1.3.11 to the Bases description.
- 9. NUREG-1433 did not delete the reduced pressure testing provision from I
- the Bases for Section 3.6.1.1. P criteria are not applicable to Option B, and the BWR/4 design is,not unique in this respect.
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- 10. NUREG-1433/4 did not add " design basis LOCA" to the Applicable Safety
] Analysis description of the Bases for Section 3.6.1.1. It is not clear l l that the BWR/4 and BWR/6 designs are unique in this respect. ;
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- 11. TSTF-52 did not include changes to page B 3.6-31 from NUREG-1433/4, '
which appears to be an administrative oversight.
TSTF-87 MODIFY: The proposed changes to the LC0 are acceptable. However, the proposed bases statement needs to be supplemented to explain why this change
, is necessary. For example, describe the testing mentioned in your justification that could now be achieved in MODE 3 with this change, also
, describe the circumstances that would give rise to this situation, and i describe or identify the more specific actions that may makeup the general action of placing the Rod Control system in a condition incapable of rod withdrawal as you refer to in your justification.
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! TSTF-90 1 MODIFY: Moving the note is acceptable. However, the proposed changes would l also delete four SRs on the basis that they address single failure capability that is not required during this MODE of operation. These SRs all deal with l maintaining system OPERABILITY and should be applied to the components associated with the train required to be OPERABLE during MODE 4. Therefore, the four SRs should be retained.
TSTF-93 MODIFY: The proposed change in the Frequency and associated Bases are
, acceptable, provided that the explanation in the Bases is incorporated into the following insert in the SR:
Reviewer's Note------
$ The frequer,cy for performing Pressurizer heater capacity testing shall be either 18 months or 92 days, depending on whether or not j the plant has dedicated Safety related heaters. For dedicated
' safety-related heaters, which do not normally operate, 92 days is applied. For non-dedicated safety-related heaters, which normally operate,18 months is applied. ,
This note will provide consistent application of the SR and ensure that the distinction in design differences is not overlooked during the application of the STS.
TSTF-94 MODIFY: The proposed changes are acceptable, provided that the bracketed provision for "and capable of being powered from an emergency power supply" is retained in the STS. This requirement is a reflection of a TMI action plan requirement that can not be adequately controlled by 10 CFR 50.59. This requirement is included in the licensing basis where it is important to maintain the reactor coolant in a subcooled condition with natural circulation for an extended time period after a loss of offsite power.
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