ML22298A217

TSTF Meeting Handout Strategic Improvements to TS and TS-Related Processes

ML22298A217
Person / Time
Site:	Technical Specifications Task Force
Issue date:	10/24/2022
From:	Technical Specifications Task Force
To:	NRC
References
Download: ML22298A217 (16)

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Strategic Improvements to TS and TS-Related Processes Kevin Lueshen, Constellation TSTF Member October 24, 2022 1

Technical Specifications Task Force TSTF A Joint Owners Group Activity Introduction

• The industry and the NRC worked together on the improved standard Technical Specifications (TS) (1992) and risk-informed TS initiatives (1999).

- Over the last three decades, initiatives have become well established:

• 78% of plants have TS based on the standard TS, with four additional units converting.

• All plants have adopted the Surveillance Frequency Control Program, and risk-informed SR 3.0.3 (missed Surveillances). Other risk-informed changes are widely adopted.

• Risk-Informed Completion Time adoption is approaching 50%.

• Standard TS and risk-informed TS improvements will continue to be pursued and are now routine.

• With subsequent licensing renewal, many plants are planning for an additional 20 to 40 years of operation.

- Industry looking at continued improvement during extended operation.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Introduction

• The PWROG and BWROG Licensing Committees initiated a project to consider medium- and long-term improvements to TS and TS-related regulatory processes to improve plant safety and reduce operational burden.

• These improvements will be pursued in parallel with existing TSTF traveler process and other improvements.

• The project solicited big ideas, radical out-of-the-box thinking, and long-term projects (such as regulation changes) that can be assembled into a strategic plan for TS improvement to be executed in a coordinated fashion over the next decade.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Industry Brain-Storming

• The TSTF surveyed the industry in February and held a workshop in May.

- Over 60 ideas were put forward.

• The recommendations were categorized, similar ideas were combined, and in August a subset of ideas were selected for further consideration.

• The recommendations fall into three categories:

- Revise Regulations

- Improvements to the License Amendment Process that do not Require a Rule Change

- TS Improvements that do not Require a Rule Change 4

Technical Specifications Task Force TSTF A Joint Owners Group Activity Industry Brain-Storming

• These recommendations provide an industry-only perspective, and many are only conceptual.

- Some are mutually exclusive or represent different approaches to the same goal.

• Just like with the development of the standard TS and the risk-informed TS initiatives, the industry would like to work with the NRC to identify, refine, and pursue projects of mutual benefit.

• We are presenting these ideas today to spur NRC interest and internal discussion in hopes of future meetings to discuss NRC ideas and to develop initiatives of mutual interest.

- We are not requesting NRC agreement on the industrys ideas.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity RULE CHANGES Brian Mann, EXCEL Services Corporation TSTF Program Manager 6

Technical Specifications Task Force TSTF A Joint Owners Group Activity Update 10 CFR 50.36, Technical Specifications

• When 10 CFR 50.36 was promulgated in 1968, only a few commercial nuclear power plants had been operating for a short time.

- The main goal of the regulation change was to streamline the AECs review of future license applications.

- Lacking any operational experience and with limited analytical capability, the TS regulation was based on protecting barriers.

• The existing regulation is out-of-step with the current state of practice, for example:

- Little consideration of risk or risk-management actions,

- An assumption that a plant shutdown is always the safest action, and

- No integration with later regulations, such as the Maintenance Rule, and 10 CFR 50.69.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Update 10 CFR 50.36, Technical Specifications

• Industry proposes to update 10 CFR 50.36 to create a new framework for TS:

- Risk-informed,

• Focused on risk-significant systems

• Risk managed actions

- Integration with Maintenance Rule and 10 CFR 50.69,

- If needed, development of new risk metrics not limited to severe accidents (e.g.,

operator dose),

- Examine need for LSSS, Design Features, and Administrative Controls, and

- Reexamine NRCs 1982 proposal to move some requirements to licensee-controlled TS

• We recognize this is an ambitious project, but the existing 50-year-old requirements are impeding improvements in safe, efficient plant operation.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity IMPROVEMENTS TO THE LICENSE AMENDMENT PROCESS THAT DO NOT REQUIRE A RULE CHANGE Drew Richards, South Texas Project TSTF member, PWROG LC Chair 9

Technical Specifications Task Force TSTF A Joint Owners Group Activity Improvements to the License Amendment Process

• The License Amendment process is mired in 50-year-old, paper-based processes.

• Updating the process could reap benefits to the industry and NRC without compromising safety or hindering regulatory oversight.

• Ideas include:

- LAR process improvement workshop.

• Hold a workshop and table-top the LAR process from initiation to implementation looking for efficiencies, with the goal of making normal LAR reviews 6 months or less.

- Make the RAI and supplement process more interactive.

• Permit NRC to make recommendations that would make a submittal acceptable.

- Establish a consistent plant-specific audit file exchange site for use in any LAR review.

• Permanent versus a case-by-case basis.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Improvements to the License Amendment Process

- Move the implementation period for a LAR from the amendment to the transmittal letter so it can be altered without an additional amendment.

- Treat the TS as Data Versus a Document

• The presentation of the words on the page (spacing, line breaks, fonts, etc.)

should be immaterial.

• TS revisions should focus on the changes to the information. Page roll-overs, reformatting, etc. should not be a concern in amendments.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity TS IMPROVEMENTS THAT DO NOT REQUIRE A RULE CHANGE Kevin Lueshen, Constellation TSTF Member 12

Technical Specifications Task Force TSTF A Joint Owners Group Activity Improvements to TS

• The industry identified structural improvements to TS that would not require a regulation change

- These could be nearer-term improvements while working on the 10 CFR 50.36 update.

• Ideas

- Replace TS requirements for Cold Shutdown and Refueling with a performance-based Shutdown Safety Program that maintains defense-in-depth and safety while providing flexibility.

- Reexamine Actions to suspend fuel movement.

• Provide a Completion Time similar to at-power TS Actions.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Improvements to TS

- Develop guideline for TS required shutdown Actions

• Work with NRC to develop guidance on when a TS-required shutdown is necessary and in what time frame based on level of degradation. Implement the guideline with travelers.

- RICT Program Enhancements

• Extend the 30-day RICT backstop.

• Evaluate RICT application to Mode 3 and Mode 4.

• Expand RICTs to systems not modeled in PRA because of no impact on CDF or LERF.

• Reexamine application of RICT to loss-of-function conditions.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Improvements to TS

- Expand the Surveillance Frequency Control Program

• NRC determined regulations do not require Frequency to be in the TS

• Revise NEI 04-10 methodology to address other types of Frequencies (event driven, event driven with time component, etc.)

- Relocate Low-Risk System LCOs from the TS

• May require a rule change.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity WRAP-UP Drew Richards, South Texas Project TSTF member, PWROG LC Chair 16