ML003760349

Summary of Meeting with Risk-Informed Technical Specification Task Force

ML003760349
Person / Time
Issue date:	10/16/2000
From:	Beckner W Technical Specifications Branch
To:	Bradley B Nuclear Energy Institute
gilles n
References
Download: ML003760349 (7)

Text

October 16, 2000 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708

SUBJECT:

OCTOBER 10, 2000:

SUMMARY

OF MEETING WITH RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE Mr. Bradley:

The purpose of this letter is to transmit the summary of a meeting with the Risk-Informed Technical Specification Task Force. The meeting was held at the Nuclear Energy Institute (NEI) offices in Washington, DC, on October, 10, 2000.

Sincerely,

/RA/

William D. Beckner, Chief Technical Specifications Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation

Enclosures:

1. Meeting Summary

2. Attendance List cc: See attached list

ML003760349 TEMPLATE: NRC-001 OFFICE NRR/DRIP/RTSB NRR/DRIP/RTSB NRR/DRIP/RTSB NAME NVGilles NVG RLDennig RLD WDBeckner WDB DATE 10/16/00 10/16/00 10/16/00

Multiple Addressees cc via e-mail:

Mr. Tony Pietrangelo Nuclear Energy Institute Mr. Tony Brooks Nuclear Energy Institute Mr. Alan Hackerott, Chairman Omaha Public Power District Mr. Jerry André Westinghouse Electric Company Mr. James Andrachek Westinghouse Electric Company Mr. Jack Stringfellow Southern Nuclear Operating Company Mr. Donald McCamy Browns Ferry Nuclear Plant Mr. Ray Schneider Westinghouse Electric Company Mr. James Riccio Public Citizen Mr. Gary Chung Southern California Edison Mr. Brian Woods Southern California Edison Mr. Rick Hill General Electric Nuclear Energy Mr. Michael S. Kitlan, Jr.

Duke Energy Corporation Mr. Noel Clarkson Duke Energy Corporation Mr. Donald Hoffman EXCEL Services Corporation Mr. Mike Epling Framatome Technologies Mr. Dusty Rhoads Energy Northwest

Multiple Addressees DISTRIBUTION:

SCollins/RPZimmerman JJohnson BWSheron DBMatthews CEAder GMHolahan WDBeckner RJBarrett RLDennig FMReinhart MLWohl NTSaltos TSB Staff JAZwolinski JFWilliams AWMarkley SLMagruder MACunningham, RES MMarkley, ACRS Staff ADAMS PUBLIC TSB R/F 1

SUMMARY

OF OCTOBER 10, 2000 NRC/INDUSTRY MEETING OF THE NEI RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE NRC staff met with the NEI Risk-Informed Technical Specification Task Force (RITSTF) on October 10, 2000, from 2 to 4 pm. Two of the NEI project managers for the group, Tony Pietrangelo and Biff Bradley, provided some background on the groups activities and some preliminary plans for industry coordinated activity to further develop risk-informed technical specifications. A formal plan is under development and will likely be available by the end of the year.

The RITSTF has had the benefit of two meetings of the guiding NEI Technical Specification Working Group in July and September of this year. Basic principles guiding the RITSTF include: (1) Build in as much flexibility as possible to allow some benefit for various degrees of PSA sophistication; advanced organizations should be able to benefit commensurate with their capabilities, (2) Develop approaches that are as simple as possible and which can be practically implemented/expressed within the framework of Standard Technical Specifications (STS), and (3) Acknowledge dependence on other risk-informed activities such as PSA quality standard development while not duplicating those efforts.

The RITSTF is pursuing eight initiatives:

I.1 Technical Specification actions end states I.2 Missed surveillances - SR 3.0.3 I.3 Increase flexibility in mode restraints - Limiting Condition for Operation (LCO) 3.0.4 I.4.a Individual risk-informed allowed outage times (AOTs)

I.4.b Risk-informed AOTs with Configuration Risk Management Program (CRMP)

/Maintenance Rule (MR) backstops I.5.a Relocate surveillance requirements not related to safety to licensee control I.5.b Relocate surveillance test intervals (STIs) of all surveillance requirements to licensee control I.6.a Modify LCO 3.0.3 actions and timing - 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AOT to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AOT I.6.b Provide Conditions in the LCOs for those levels of degradation where no Condition currently exists I.6.c Provide specific times for those Conditions that require entry into LCO 3.0.3 immediately I.7 Define actions to be taken when equipment is not operable but still functional I.8 Remove/relocate all non-safety systems/non-risk-significant systems out of TS The staff has been reviewing generic submittals for the first three initiatives. The Combustion Engineering Owners Group topical report for I.1 (end states) has been reviewed and the staff is currently drafting a safety evaluation. The staff plans to use this safety evaluation in the Consolidated Line Item Improvement Process (CLIIP) to offer adoption of the associated changes to STS, once the industry provides the proposed STS mark-ups for staff review. The RITSTF indicated that follow-on work from other owners groups was in progress, with the BWR work the most advanced. In response to process questions, the staff indicated that the packaging and sequencing was at industry discretion and that no obvious advantages or disadvantages accrued to simultaneous PWR/BWR submittal or to packaging as topical reports.

2 I.2 (missed surveillances) has been packaged as TSTF-358. Staff and industry have interacted during review since November 1999, and a revised version was submitted in September 2000.

The staff owes the industry a schedule for completion of that review.

I.3 (mode restraint flexibility) has been packaged as TSTF-359 and is undergoing revision in response to staff comments. The RITSTF expects to resubmit sometime in December. The general approach was outlined:

(1) Identify the set of system/equipment LCOs that an LCO 3.0.4 exception could apply to, (2) Determine that subset that is highly risk significant and to which a generic exception would not apply; plants could make specific cases for these, (3) For the remainder, establish within STS the requirement for a maintenance rule type of review by the licensee before taking the exception, and (4) Take out the existing exceptions now written into STS with the understanding that plants could separately do a one-time analysis to codify in procedures (i.e., take the exception without having to do the maintenance rule type review).

Some individual risk-informed AOTs (I.4.a) should be forthcoming throughout the next year, possibly from the WOG, and there is continuing interest by CEOG in their battery submittal.

The more ambitious scope of I.4.b, i.e., risk-informed AOTs with CRMP/MR backstops, will be under development for presentation to the staff late in 2001. The current approach is to treat the current deterministic AOT as a default and to embed a process to extend the AOT up to a backstop value. EPRIs more revolutionary concept is still under development, with a report due shortly. The EPRI concept would probably be pursued with a pilot plant.

I.5.a will be handled in the future as a deterministic change to the STS since there is no risk-informed aspect. I.5.b will be taken up in the next year. The RITSTF does not believe that a rule change is needed to relocate STIs outside the technical specifications.

Initiative 6.b and c are being worked with one owners group ready to proceed, another funded, and two others having reviewed the methods. There may be some activity by the end of the year. There are some questions about the cost/benefit that may determine whether all groups eventual invest in the effort. I.6.a is receiving little attention and may have the lowest priority of any of the initiatives.

I.7 addresses concerns about how equipment not literally in STS is nonetheless virtually in STS because it somehow factors into the OPERABILITY determination for equipment that is in technical specifications. The approach is that these kinds of equipment (e.g., barriers) should have administratively controlled outage times based on a risk argument that relies on initiator likelihood. Staff expressed interest in further development but pointed out past practice of always requiring some degree of mitigative capability and not relying on low accident likelihood as the sole basis for acceptance of a condition.

Finally, I.8 was recently added, but it has not yet received much attention at the working level.

Meeting Attendees Name Affiliation Ray Schneider Westinghouse/CEOG Alan Hackerott Omaha Public Power District/CEOG Brian Woods Southern California Edison/CEOG Biff Bradley Nuclear Energy Institute Tony Pietrangelo Nuclear Energy Institute Tony Brooks Nuclear Energy Institute Donald Hoffman EXCEL Services Jerry André Westinghouse/WOG Jim Andrachek Westinghouse/WOG Don McCamy Tennessee Valley Authority/BWROG J. E. Rhoads Energy Northwest/BWROG Mike Kitlan Duke Power/BWOG Frank Rahn Electric Power Research Institute Michael Epling Framatome Technologies/BWOG Thomas Morgan Scientech Millard Wohl NRC/NRR/SPSB Nick Saltos NRC/NRR/SPSB Bob Dennig NRC/NRR/RTSB