ML062190066
| ML062190066 | |
| Person / Time | |
|---|---|
| Issue date: | 08/02/2006 |
| From: | Thomas E M NRC/NRR/ADRO/DIRS/ITSB |
| To: | Bradley B Nuclear Energy Institute |
| Thomas E, NRR/DIRS, 415-6772 | |
| References | |
| Download: ML062190066 (8) | |
Text
August 2, 2006Mr. Biff BradleyNuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708
SUBJECT:
SUMMARY
OF JULY 25, 2006, MEETING TO DISCUSS TSTF-409
Dear Mr. Bradley:
The purpose of this letter is to transmit the summary of a meeting with the PressurizedWater Reactor Owners Group (PWROG) and the Nuclear Energy Institute (NEI). The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on July 25,2006. The purpose of the meeting was to resolve any remaining issues associated with Technical Specification Task Force (TSTF) Change Traveler TSTF-409 (Containment Spray System Completion Time Extension) and to establish a consensus for proceeding with the consolidated line item improvement process (CLIIP) for this and other risk-informed TSTFs. The model license amendment request (LAR) and model safety evaluation (SE) forTSTF-409 were noticed for comment in the Federal Register on April 11, 2006, [71 FR 18380]. NEI provided comments in a letter dated May 10, 2006.
Sincerely,Eric M. Thomas, Reactor Engineer/RA/Technical Specifications Branch Division of Inspection & Regional (DIRS/ADRO)
Office of Nuclear Reactor Regulation
Enclosures:
- 1. Meeting Summary2. Attendance List
- 3. Agenda
- 4. PWROG Handout dated July 25, 2006cc w/encl: See attached page
DOCUMENT NAME: E:\Filenet\ML062190066.wpdOFFICEITSB:DIRS:ADROSC:ITSB:DIRS:ADRO NAMEEMThomasTJKobetzDATE8/ /20068/ /2006 Letter to Biff Bradley from E. Thomas dated August 2, 2006
SUBJECT:
SUMMARY
OF JULY 25, 2006, MEETING TO DISCUSS TSTF-409DISTRIBUTION
MJCase/PLHiland (RidsNrrAdroDirs)
TJKobetz (RidsNrrAdroDirsItsb)
MPRubin (RidsNrrAdraDraAplb)
OGC (RidsOgcRp)
ACRS/ACNW (RidsAcrsAcnwMailCenter)
WDReckley (WDR)
GSShukla (GSS)
BKVaidya (BKV)
DGHarrison (DGH)
CKDoutt (CKD)
AJHowe (AJH1)
Letter to Biff Bradley from E. Thomas dated August 2, 2006
SUBJECT:
SUMMARY
OF JULY 25, 2006, MEETING TO DISCUSS TSTF-409cc via e-mail
- Mr. Tony PietrangeloNuclear Energy Institute arp@nei.orgMr. Biff Bradley Nuclear Energy Institute reb@nei.orgMr. Alan Hackerott, Chairman Omaha Public Power District hhackerott@oppd.comMr. Ray Schneider Westinghouse Electric Company raymond.e.schneider@us.westinghouse.comMr. James Andrachek Westinghouse Electric Company andracjd@westinghouse.comMs. Nancy Chapman SERCH/Bechtel ngchampa@bechtel.com Mr. Donald HoffmanEXCEL Services Corporation donaldh@excelservices.comMr. Brian Mann EXCEL Services Corporation brianm@excelservices.comMs. Deann Raleigh Scientech draleigh@scientech.com Mr. Steven DolleyPlatts stevendolley@platts.com Mr. Gary ChungSCE-SONGS gary.chung@songs.sce.com Mr. Jerry AndreWestinghouse Electric Company andregr@westinghouse.com
SUMMARY
OF THE JULY 25, 2006, NRC/INDUSTRY MEETING TO DISCUSS THE STATUS OF TSTF-409The NRC staff met with members of the Pressurized Water Reactor Owners Group (PWROG)and the Nuclear Energy Institute (NEI) on July 25, 2006, from 1:00 p.m. to 3:45 p.m. Themeeting attendees are listed in Enclosure 2.The agenda (Enclosure 3) consisted of discussions of industry comments on the TSTF-409Federal Register Notice for Comment, and establishing a path forward to publish a FederalRegister Notice of Availability for TSTF-409. In addition, the agenda included a generaldiscussion of other pending risk-informed TSTFs (RITSTFs), and the appropriate level of probabilistic risk assessment (PRA) discussion that should be required for their adoption. Following is a brief description of the dialogue that took place, and agreements that theparticipants reached.Introduction and Backgr oundAfter a brief discussion of the history of TSTF-409 and its associated Joint Applications Report(JAR), Mr. Ray Schneider of the PWROG presented the slides in Enclosure 4. The members of the PWROG stressed that a major difference between the JAR upon which TSTF-409 is based, and the topical reports (TRs) which provide the basis for many other risk-informed TSTFs is that the JAR is based on plant-specific PRA results for nearly all Combustion Engineering plants, while a TR is based on a generic, bounding analysis of PRA data.While the PWROG members understood the reasoning behind the NRC staff's approach toTSTF-409, they stressed that this particular TSTF should not be the "poster-child" for all RITSTFs due to its low risk-significance and limited scope. They also recommended that any consolidated line item improvement process (CLIIP) notice published in the Federal Registershould acknowledge the approved JAR, and only address the PRA issues that are applicable to the containment spray system (which is the system in question for TSTF-409). The NRC staff stated that licensees with an external events core damage frequency (CDF) nearthe RG 1.174 limit should be required to justify why it is okay to implement TSTF-409, or else choose not to implement it. The staff also asked how an issue was determined to be "risk-insignificant" and how a plant adequately demonstrates whether it is aligned with a JAR or TR.Discussion of NEI Comments of May 10, 2006 (Question numbering corrsponds to NRCresponse letter of June 13, 2006)Question #2: The PWROG expressed a general consensus that the PRA expectationspublished by the staff in 71 FR 18380 were much more stringent than what was expected. The staff replied that the purpose of publishing explicit conditions and expectations in the model LAR was to eliminate the need for subsequent requests for additional information (RAIs) by the staff when plant specific LARs were later submitted by licensees. The PWROG asked how the staff expected to make a "one size fits all" set of requirements to be applied to generic issues, and asked if the TSTF-446 model LAR conditions would be similar to the RAIs generated thus far on the Wolf Creek plant specific amendment package. Question #4: NEI felt that requiring licensees to justify their use of a zero-maintenance PRAmodel was not necessary because RITSTF Initiative 4b allows for the use of a zero maintenance model, and an average maintenance model is inferior in the case of TSTF-409.
The PWROG continued by stating that change in core damage frequency (CDF) numbers foran average maintenance model in this instance are so small that they can be considered consistent with the zero maintenance model, so the requirement for licensees to justify use of a zero maintenance model should be removed. The staff responded that it considered this as a CDF rather than a configuration risk management program (CRMP) issue, and that it could beaddressed by using the guidance in RG 1.177. The PWROG agreed to provide a recommended generic comment. The staff recommended having licensees show that there is no plant-specific unavailability that would cause a spike in CDF, and that this would be sufficientto relieve them from having to show a quantitative solution.Question #5: NEI expressed the opinion that it was unnecessary to address external events inthis specific application, and that a quantitative analysis of external events would be difficult formany licensees. The PWROG recommended (and the staff agreed) that an approach similar to that of RG 1.174 would be more sensible, where a detailed quantitative approach would only berequired if the thresholds in the RG were exceeded. The PWROG stated that, while other applications (involving RITSTFs) may require a more quantitative approach, TSTF-409 should only require a qualitative approach initially. The staff stated the need to verify that licensees had met the commitments they made when validating their individual plant examinations forexternal events (IPEEEs) so that external risk could be confirmed. The PWROG felt that licensees should be able to use the latest and greatest tools to verify risk, whether or not those tools have been reviewed.ConclusionThe PWROG expressed a desire to have an additional chance to provide comments andrecommendations prior to the staff publishing a Federal Register Notice of Availability for TSTF-409. These additional comments and recommendations were provided to the NRC onAugust 1, 2006. A brief discussion of TSTF-446 ensued. Attendees agreed in principle that the TSTF-409 resultwould be used to influence the content of TSTF-446, but that TSTF-446 was a morecomprehensive RITSTF example, and would provide a better template for other RITSTF Initiative 4a submittals. The staff intends to evaluate the additional comments and recommendations received from thePWROG on August 1, 2006, and incorporate them into the TSTF-409 Federal Register CLIIPNotice of Availability. NRC/INDUSTRY MEETING OF THERISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE ATTENDANCE LISTJANUARY 19, 2006NAMEAFFILIATIONBIFF BRADLEYNUCLEAR ENERGY INSTITUTERAY SCHNEIDERWESTINGHOUSE/WOG JIM ANDRACHEKWESTINGHOUSE/WOG JERRY ANDREWESTINGHOUSE/WOG NANCY CHAPMANSERCH/BECHTEL TIMOTHY KOBETZNRC/NRR/ADRO/DIRS/ITSB ERIC THOMASNRC/NRR/ADRO/DIRS/ITSB RAVI GROVERNRC/NRR/ADRO/DIRS/ITSB DAVID ROTHNRC/NRR/ADRO/DIRS/ITSB BOB TJADERNRC/NRR/ADRO/DIRS/ITSB CLIFF DOUTTNRC/NRR/ADRA/DRA/APLA DONALD HARRISONNRC/NRR/ADRA/DRA/APLA ANDREW HOWENRC/NRR/ADRA/DRA/APLA AGENDA
SUBJECT:
FORTHCOMING MEETING WITH NEI AND INDUSTRY REPRESENTATIVES TORESOLVE REMAINING ISSUES ASSOCIATED WITH TSTF-409 AND DEFINE A PATH FORWARD FOR OTHER RISK MANAGEMENT TECHNICAL SPECIFICATIONS (RMTS) INITIATIVE 4a TSTFsJuly 25, 2006*Introductions and meeting overview
- Discussion of industry comments on TSTF-409 Federal Register Notice publishedApril 11, 2006*Public Comment
- Discussion of NRC staff responses to industry comments on TSTF-409*Discuss content of Federal Register Notice of Availability for TSTF-409 modelapplication and safety evaluation*Discuss path ahead for other RITSTFs (e.g. TSTF-446)
- Public Comment