TSTF STATUS REPORT. February 26, 2017

Transcription

1 Recent Meetings 2/8-9 / 2/16 /NEI/ on -505 Upcoming Meetings 3/13-16 Regulatory Information Conference 4/ Implementation Workshop 4/25-27 PWROG Licensing Committee 5/2-3 BWROG Licensing Committee 5/10-11 & / Current Issues Mike Leisure of Duke Energy, who represented Babcock & Wilcox plants on the for the last year, has retired. Jordon Vaughan, also of Duke Energy, has replaced Mike on the. We thank Mike for his service on the and wish him a happy retirement! On January 31, the provided a draft letter to the responding to the 's November 13, 2016 letter regarding -505-A, Revision 1, "Provide Risk-Informed Extended Completion Times." -505 was approved in March, 2012, and is applicable to all plant types. On February 16, the, NEI, and met to discuss the draft letter. The was not ready to provide comments on the letter, but committed to do so and to schedule a follow-on meeting in March. The does not want to take generic action until the Vogtle license amendment request to adopt -505 is approved. ( 1277) At the February 9 / meeting, the shared an anonymous projection of licensee submittals to adopt -542-A, Revision 2, "Reactor Pressure Vessel Water Inventory Control." -542 is applicable to BWR plants and all BWRs not scheduled for permanent shutdown are planning to submit in Four submittals are planned in the first quarter (two are already submitted), nine in the second quarter, four in the third quarter, and three in the fourth quarter. The projected schedule is provided to assist the in scheduling their resources. The requested that all licensees hold a presubmittal meeting or teleconference prior to submittal of their -542 license amendment request. ( 1331) STATUS REPORT The BWROG has formed a new committee to facilitate BWR fleet adoption of The first of two implementation workshops is planned for April 4-5, 2017 at Exelon's Kennett Square, PA headquarters. ( 1331) At the February 9 / meeting, the asked the why the review times for the last nine approved amendments to adopt -425-A, "Relocate Surveillance Frequencies to Licensee Control - RI Initiative 5b," required greater than a year (review times ranged from 13 months to 23 months). Given that the has approved 45 amendments to adopt -425, an review within the 's one-year metric would be expected. The asked if the repeated nonconcurrences on the amendments resulted in the extended reviews. The agreed to investigate and discuss it at the next meeting. At the February 9 / meeting, the rescheduled the issuance of the draft safety evaluation for -551, Revision 2, "Address Transient Secondary Containment Conditions," from March 2 to March 27. This is the fifth reschedule of the -551 review. On January 20, 2017, the alerted the that in one day, three LERs and one event notification were filed on secondary containment conditions that would not have been necessary if -551 was implemented. At the February 9 / meeting, the stated there are twelve travelers scheduled for submittal to the in The will work with the to establish review priorities for the travelers. Status at a Glance Active s 3 s with Action 3 s with Industry Action 0 s Approved in s Approved in s Approved in s Approved in Total s Approved 353 Technical Specifications Task Force () Jim Morris (PWROG/W) (805) Lisa Williams (BWROG) (509) Otto Gustafson (PWROG/CE) (269) Jordon Vaughan (PWROG/B&W) (980) Jason Redd (APOG) (205) Brian Mann (EXCEL) (804) The is a jointly sponsored activity of the Pressurized Water Reactor s Group, the Boiling Water Reactor s' Group, and the AP1000 s Group that is administered by EXCEL Services Corporation.

2 -541, Rev. 0 B&W W CE BWR4 BWR6 : 1249 Originally Submitted: 9/10/2013 Age: 41 Months Originally Scheduled for Approval: 9/30/2016 Active s Summary Report (See s Report for More Information) Description Add Exceptions to Surveillance Requirements When the Safety Function is Being Performed Review Fees To Date: $82, (Shared) of Times Approval Date has been Rescheduled: 1 Actions and Schedule Responsibility Date -541 submitted to the on September 10, /10/2013 transmitted the acceptance and schedule letter on August 13, /13/2015 transmitted a Request for Additional Information on August 13, /11/2015 responded to request for additional information on November 11, to provide revised review schedule. 12/3/ a new review schedule was provided: Second round RAIs to be provided in mid-february, Draft safety evaluation to be provided by November 7, provided a second round RAI on February 26, Of the 21 questions, approximately half appear to be repetitive of the first round RAI. A management meeting was held on July 28 to discuss the RAIs. to prepare additional explanation of the use of the existing and proposed SR notes. The and will discuss the additional explanation prior to submittal of a revised traveler in lieu of the responding to the RAIs. 1/12/ White paper provided to. 11/12/ /3/2015 7/28/2016 1/12/2017 to provide feedback on the white paper. 3/31/2017 Page 1 of 3 26-Feb-17

3 -546, Rev. 0 : 1350 BWROG Active s Summary Report (See s Report for More Information) Description Revise APRM Channel Adjustment Surveillance Requirement Originally Submitted: 4/21/2016 Age: 10 Months Review Fees To Date: $37, (BWROG) Originally Scheduled for Approval: 9/21/2017 of Times Approval Date has been Rescheduled: 0 Actions and Schedule Responsibility Date provided acceptance and review schedule letter on 8/12/2016. RAI by September 30, 2016 Draft SE by 6/7/2017 Final SE by 9/21/2017 provided RAI on 10/3/2016. A teleconference to discuss the RAIs was held on November 14, responded to the RAI on February 2, /15/2016 2/2/2017 to provide draft SE. 6/7/2017 Page 2 of 3 26-Feb-17

4 -551, Rev. 3 : 1386 BWROG Active s Summary Report (See s Report for More Information) Description Revise Secondary Containment Surveillance Requirements Originally Submitted: 10/30/2014 Age: 28 Months Review Fees To Date: $156, (BWROG) Originally Scheduled for Approval: 3/8/2016 of Times Approval Date has been Rescheduled: 5 Actions and Schedule Responsibility Date -551, Revision 0, "Address Transient Secondary Containment Conditions" was submitted on October 30, On March 12, 2015, the provided a revised review schedule. to provide RAIs 5/8/15 response 8/6/15 Notice for Comment 1/3/16 Notice of Availability 5/2/16 On a May 7, 2015 teleconference, the agreed to revise the in lieu of sending a formal RAI. 10/30/2014 5/8/2015 6/30/2015 submitted -551, Revision 1, on September 3, /3/2015 to provide RAI. Teleconference to discuss RAIs held on 10/19/15. On 11/5/15, agreed to a 45 day response time for the RAI. RAI provided on 11/18/2015. It included a new review schedule: Issue Draft Safety Evaluation by May 26, 2016 Issue Final Safety Evaluation by July 23, /30/2015 The responded to the RAI on January 26, /26/2016 and held a teleconference to discuss the wording of the proposed SR Note. The agreed to submit a revision to address the staff concerns. 5/12/ Revision submitted. and held a teleconference to discuss the content of the model application on 7/6/16. to revise traveler. 5/13/2016 7/29/ , Revision 3, submitted to on 10/3/ /3/2016 On 10/6/2016, provided a revised schedule : Draft Safety Evaluation by 2/2/2017 Final Safety Evaluation by 5/8/2017 2/2/2017 On February 9, 2017, the rescheduled the draft SE to March 27. 3/27/2017 On January 12, 2017, provided a new schedule. Draft SE by 3/2/2017 Final SE by 6/8/2017 3/27/2017 Active s: 3 Page 3 of 3 26-Feb-17

5 STATUS REPORT s Recently Approved by the Title Date of Approval or Notice of Availability 12/20/ , Rev. 2 Reactor Pressure Vessel Water Inventory Control Boiling Water Reactor Plants -529, Rev. 4 Clarify Use and Application Rules All plant designs 4/21/ , Rev. 1 Clarification of Rod Positon Westinghouse Plants 3/4/2016 Requirements -545, Rev. 3 TS Inservice Testing Program All plant designs 12/11/15 Removal & Clarify SR Usage Rule Application to Section 5.5 Testing -523, Rev , Rev , Rev , Rev , Rev , Rev , Rev , Rev , Rev , Rev , Rev. 3 Generic Letter , Managing Gas Accumulation Revise or Add Actions to Preclude Entry into LCO RI Initiatives 6b & 6c Revise Shutdown Margin Definition to Address Advanced Fuel Designs Revise Ventilation System Surveillance Requirements to Operate for 10 hours per Month Change in Technical Specifications End States (WCAP-16294) Provide Risk-Informed Extended Completion Times - RI Initiative 4b Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection DC Electrical Rewrite - Update to -360 Change in Technical Specifications End States (CE NPSD-1186) Technical Specifications End States, NEDC A Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation All plant designs 1/15/14 Combustion Engineering Plants 5/30013 Boiling Water 2/26/13 Reactor Plants All plant designs 9/20/12 Westinghouse Plants 5/11/12 All plant designs 3/15/12 Pressurized Water Reactor Plants 10/27/11 All plant designs 9/1/11 Combustion Engineering Plants Boiling Water Reactor Plants Pressurized Water Reactor Plants 4/7/11 2/18/11 1/3/11 Page 2

6 Executive Report All s owned by PWROG, BWROG, and. Actions Only. High Priority s Position on What Constitutes an OPDRV & New Reactor Pressure Vessel Water Inventory Control TS Fees BWROG BWRs Issue Review Exempt issued a violation to Clinton over a procedural change made under regarding what constitutes Operations with a potential for draining the reactor vessel (OPDRVs). "OPDRV" is an undefined term in the BWR TS, but is used in in many TS. On October 4, 2011, the issued an Enforcement Guidance Memorandum (EGM) that provides interim relief while a is being prepared. The BWROG and held meetings in July 2011, October 2012, February 2013, September 2013, and June 2014 to discuss the issue. -542, "Reactor Pressure Vessel Water Inventory Control", which replaces the OPDRV requirements in the BWR TS, was submitted December 31, BWRs using the EGM are committed to adopt the after approval. -542, Revision 2, was approved by the on December 20, /2/2016: -542, Revision 2, approved on 12/20/ /1/2017: The Licensing Committee will support the creation of a BWROG Operations-centered committee to facilitate -542 adoption. 2/26/2017: First -542 Implementation Workshop scheduled for April 4-5, /26/2017: BWROG formed -542 Implementation Committee. BWROG BWROG BWROG 12/31/2016 5/2/2017 4/5/2017 2/28/2017 Page 1 of 26

7 Non-TS Room Cooler Effect on Equipment Operability 1337 None PWROG PWRs&BWRs Operational Improvement Fees Several s Group members have experienced operational challenges due to the failure of room coolers that provide cooling for TS required systems. Because the room cooler is not a TS system, when it is not functional it may render the supported TS equipment inoperable. Depending on the plant design, a nonfunctional room cooler can lead to a plant shutdown. The PWROG evaluated a generic TS approach to provide time to repair a nonfunctional room cooler before requiring a plant shutdown, but did not identify a generic solution. In 2015, this topic was reopened by the PWROG. BWROG to participate with core team of Phil Lashley, Ed Schrull, Ken Nicely, Brittany Sprung, and Ryan Joyce. Draft project authorization PA-LSC-1386 was presented to the LSC in December More information is requested. Noted that plants that have adopted -505, Risk Informed Completion Times, might not need this change. This could result in the PA being a cafeteria project instead of a generic project. PWROG,, and met on November 16, 2016 to discuss the approach. 11/16/2016: PWROG,, and met on November 16, 2016 to discuss the approach. The PWROG LSC Chairman and LSC HVAC TS Core Team will decide if the project should proceed with revision 1 based on the feedback provided at the meeting. 12/1/2016: Based on the PWROG survey, provided by Chad Holderbaum, Brian Mann to determine if the PWROG ESF Room Cooler approach would work for BWRs. 2/16/2017: Project on hold pending discussion at the next PWROG LSC meeting. PWROG 4/25/2017 B. Mann 3/1/2017 PWROG 4/25/2017 Page 2 of 26

8 Questions on -490, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec" PWROG PWRs Issue Issue -490, "Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec," was approved in March Licensees requesting adoption of the received questions from the. The and identified the additional information needed to satisfy the staff's questions. Licensees are including this information in their amendment requests. The PWROG is monitoring whether this satisfies the concerns. On April 27, 2016, the sent a letter to the requesting that all future LARs to adopt -490 provide justification for the 48 hour Completion Time or retrain the existing 6 hour Completion Time. Fees 4/27/2016: On April 27, 2016, the sent a letter to the requesting that all future LARs to adopt -490 provide justification for the 48 hour Completion Time or retrain the existing 6 hour Completion Time. to keep informed of their review of the Exelon response to the same request on the Gina LAR. to respond after accepts Exelon response. Gina amendment approved on 2/9/ /28/2017 Page 3 of 26

9 Increased Reporting Under NUREG-1022, Revision BWROG BWRs Operational Improvement This topic tracks concerns that changes in NUREG-1022, Revision 3, will result in "nuisance" LERs. Revision 3 of NUREG-1022 states, "There are a limited number of single-train systems that perform safety functions (e.g., the HPCI system in BWRs). For such systems, inoperability of the single train is reportable even though the plant TS may allow such a condition to exist for a limited time." Example: the TS require secondary containment pressure 0.25 inch of vacuum water gauge, which may not be met momentarily during high wind conditions; or both secondary containment airlock doors briefly open simultaneously. The BWROG LSC pursued three actions: Clarification of the NUREG-1022 guidance: Closed. The will not revise NUREG-1022 and requires reporting of these events. Clarification of the ROP guidance: Closed. The pointed out the guidance allows a licensee to demonstrate that there was no loss of safety function with an engineering evaluation. No other changes will be made. TS Changes related to the secondary containment vacuum SR: The is developing a to allow momentary opening of the secondary containment without declaring it inoperable. At the April 10, 2014 / public meeting, the stated they are preparing an Enforcement Guidance Memorandum that will allow both secondary containment doors to be open simultaneously for normal entry and exit without considering the secondary containment inoperable. At the November 13, 2014 / public meeting, the stated that the Office of Enforcement will not issue an EGM as it would have avoided only approximately 10 of the 70+ LERs on this topic. -551, Revision 1, submitted on September 3, Fees 10/30/2014: -551, Revision 0, "Address Transient Secondary Containment Conditions" was submitted on October 30, /5/2015: On March 12, 2015, the provided a revised review schedule. to provide RAIs 5/8/15 response 8/6/15 Notice for Comment 1/3/16 Notice of Availability 5/2/16 Page 4 of 26 10/30/2014 5/8/2015

10 5/5/2015: On a May 7, 2015 teleconference, the agreed to revise the in lieu of sending a formal RAI. 7/23/2015: submitted -551, Revision 1, on September 3, /1/2015: to provide RAI. Teleconference to discuss RAIs held on 10/19/15. On 11/5/15, agreed to a 45 day response time for the RAI. RAI provided on 11/18/2015. It included a new review schedule: Issue Draft Safety Evaluation by May 26, 2016 Issue Final Safety Evaluation by July 23, /20/2015: The responded to the RAI on January 26, /19/2016: and held a teleconference to discuss the wording of the proposed SR Note. The agreed to submit a revision to address the staff concerns. 5/12/ Revision submitted. 6/9/2016: and held a teleconference to discuss the content of the model application on 7/6/16. to revise traveler. 9/30/2016: -551, Revision 3, submitted to on 10/3/ /3/2016: On 10/6/2016, provided a revised schedule : Draft Safety Evaluation by 2/2/2017 Final Safety Evaluation by 5/8/2017 1/12/2017: On January 12, 2017, provided a new schedule. Draft SE by 3/2/2017 Final SE by 6/8/2017 2/9/2017: On February 9, 2017, the rescheduled the draft SE to March 27. 6/30/2015 9/3/ /30/2015 1/26/2016 5/13/2016 7/29/ /3/2016 2/2/2017 3/27/2017 3/27/2017 Page 5 of 26

11 Clarification of Pressure Boundary Leakage TS PWRs&BWRs Issue Issue Fees Based on operating experience from Diablo Canyon in 2006 and Byron in 2009, the position regarding Reactor Coolant Pressure Boundary (RCPB) leakage is that the definition of Pressure Boundary Leakage requires that leakage through a fault in an RCS component body, pipe wall, or vessel wall be considered Pressure Boundary Leakage if there is any leakage past the isolating device. In a November 18, 2009 letter to Exelon, the stated: "The staff does believe that the Standard Technical Specifications should be clarified to avoid future confusion on this issue. Accordingly, the [] staff will engage the Technical Specifications Task Force, and work with them to provide a solution, which can be made available for adoption by licensees through the 's Consolidated Line Item Improvement process." After meeting with the, the submitted -534, "Clarify Application of Pressure Boundary Leakage Definition," on September 19, The did not accept the and the requested additional clarification from the. At the July 18, 2013, / quarterly meeting, the stated they had changed their position. The stated that two valves should be used to isolate a fault in the RCPB, consistent with the definition in 10 CFR The also stated that normal leakage past the isolation valves should be considered RCS Leakage, not Pressure Boundary Leakage. The will consider the 's proposal. A teleconference was held on January 16, 2014 to discuss the paper. At the March 9, 2014 PWR/ Executive meeting and the April 10, 2014 / meeting, the stated they were developing a Regulatory Issue Summary (RIS) stating their position on pressure boundary leakage (i.e., the fault must be isolated by two devices with no leakage past the first isolation device). The draft RIS is on the proposed generic communication schedule under TAC MF4346. It should be available for public comment in June 2015 and final in September On January 28, 2015, the sent a letter to the requesting that they not issue the draft RIS. The discussed a proposed to resolve issues with reactor coolant leakage at the February, April, and July, 2015, and February 2016 / meetings. Project put on hold until 2017 due to budget limitations. 8/5/2016: Project put on hold until 2017 due to budget limitations. B. Mann 3/31/2017 EXCEL to revise traveler to only require evaluation for non-isolated pressure boundary leakage. Page 6 of 26

12 Questions on Diesel Generator Frequency and Voltage Surveillance Requirements Fees PWROG PWRs&BWRs Issue Issue PWROG The has raised the issue of Diesel Generator frequency and voltage variation during several Component Design Basis Inspections (CDBIs) with respect to how the Technical Specification allowed tolerance in DG frequency and voltage is addressed in the emergency core cooling system (ECCS) performance. The PWROG has developed a generic approach and the methodology was submitted to the for review and approval as WCAP NP. The PWROG will allow BWR plants to utilize the al Report. The current approach will require changes to the Specification Surveillances. On the February 6, 2014 / status call, the informed the that they do not consider waiting for approval of WCAP and an associated to be timely corrective action and that licensees should take action to address the issue. A public meeting occured on 9/14/16 with the management to discuss PWROG concerns with the draft SE related to the WCAP NP DG Tech Spec Frequency and Voltage Tolerance Methodology In December 2016, the PWROG is preparing a revision to PA-LSC-0681 to address final resolution of WCAP NP. 5/15/2012: Following issuance of a draft Safety Evaluation for WCAP NP, the will develop a to implement the TS changes. 11/26/ a draft has been created. Finalization is awaiting issuance of the draft SE. 12/15/ Preliminary SE received on December 15, The PWROG is addressing questions on the topical report SE with the. 4/25/2017 Page 7 of 26

13 Questions on -471, -286, and None PWRs&BWRs Issue Issue Fees In August 2013, the informed the they had technical concerns with -471, "Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes," (approved in 2006), -286, "Define 'Operations Involving Positive Reactivity Additions'," (approved in 2000), and -51, "Revise containment requirements during handling irradiated fuel and core alterations" (approved in 1999) and -286 are only applicable to PWRs. -51 is applicable to all plant types. Many plants have adopted these s and they have been incorporated into the Improved Standard Technical Specifications. The will work with the to resolve their concerns with these beneficial s. The provided a letter describing their concerns dated 11/7/2013. On February 2, 2017, the submitted a letter requesting that the withdraw the November 2013 letter. 11/13/2013: The provided a letter describing their concerns dated 11/7/2013. to respond. 1/9/2014: At the January 9, 2014, April 10,2014 and November 13, 2014 / quarterly meetings, the provided their preliminary responses. The discussion resulted in a better understanding of the concerns and the provided a revised response on April 10. At the November 13, 2014 / meeting, the Reactor Systems Branch Chief stated the proposed approach resolved his concerns. 2/5/2015: At the 2/5/15 / meeting, the Reactor System Branch representative accepted the proposed actions. The Accident Dose Branch representative provided verbal comments but was generally supportive of the approach. The PM will provide markups from the Accident Dose Branch representative. comments were received on April 13, The and will hold a 1/31/2014 1/30/2015 5/22/2015 Page 8 of 26

14 teleconference to discuss the comments the week of May 18. 2/5/2015: The evaluated the comments and determined the proposed approach was inconsistent with the design and basis of the ISTS. At the July 23, 2015 / meeting, the provided a presentation describing the concerns. to be prepared to discuss at the next meeting. 11/15/2015: At the November 12 / meeting, the stated that the reviewer is preparing a description of his concern for internal review. 2/2/2017: At the 2/8/2017 / meeting, will provide their technical conclusions in a letter on -51 and -471 and hold a teleconference with the to discuss. Since -51 does not have a Safety Evaluation, the letter will be similar to an SE. The position will be vetted by management. to respond to the request to withdraw the November 2013 letter in one to two weeks after the meeting. 11/15/2015 2/26/2016 2/28/2017 Page 9 of 26

15 GSI PWROG PWRs Regulatory Requirement Review PWROG There are four GSI-191 resolution paths being implemented by the Pressurized Water Reactor (PWR) fleet. Option 1 and Option 2a are deterministic approaches, and Option 2b and Option 3 are risk-informed approaches. Regardless of the resolution path being implemented, all licensees will benefit from revising their TS "ECCS - Operating," and TS "Containment Spray and Cooling Systems," (or equivalent) to include an Action for LOCA-induced debris related ECCS and CSS inoperability. Meeting were held with the on November 17, 2016 and January 31, 2017 to discuss the proposed approach. Fees 12/22/2016: PWROG LSC members to review and comment on two white papers drafted by EXCEL: A guidance document for incorporating the Required Action with a 90 day Completion Time in the TS for non-its plants (excluding custom TS plants Surry and TMI). Documentation of the logic and choices for using the single containment sump TS instead of adding the requirements to the ECCS-Operating, ECCS-Shutdown, and Containment Spray and Cooling TS. 2/20/2017: and PWROG to review PWROG LSC PWROG 1/31/2017 3/7/2017 Page 10 of 26

16 Industry Implementation of 10 CFR 50.69, Risk Informed Engineering Fees 1443 None PWROG PWRs&BWRs Operational Review PWROG Improvement The PWROG is working with NEI to pursue industry-wide adoption of 10 CFR 50.69, "Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors," as a cost-saving activity. 4/29/2016: PWROG and BWROG to support the NEI Risk-Informed Engineering (50.69) Task Force. Delivering the Nuclear Promise Support Activites PWROG BWROG 1444 None PWRs&BWRs Operational None Improvement The PWROG and BWROG are pursuing several activities to support the industry initiative, "Delivering the Nuclear Promise." EXCEL created a project plan for the s Groups to support RE-010, "Share Industry Resources Associated with Regulatory Activities." 4/25/2017 A revised NEI 06-02, "License Amendment Request Guidelines," was completed and provided to NEI on December 16, It was distributed to industry on January 9, Medium Priority s Fees 11/23/2016: Two teleconferences were held regarding the draft Efficiency Bulletin. Bulletin going through approval process. 12/1/2016: Jamie Coleman (SNC) to organize the RE-010 proposed review processes team and hold a meeting with the on February 8. 2/8/17 - Meeting held with. Preparing an example application and will meet with again. B. Mann 3/31/2017 J. Coleman 3/31/2017 Page 11 of 26

17 Revision to TS , MCPR Safety Limit BWROG BWRs Operational Review Improvement The Safety Limit Minimum Critical Power Ratio (SL MCPR) value frequently changes with each fuel cycle, resulting in the need for license amendments with quick turnaround times. The submitted -357 in In 2004, the stated that they had concerns with the vendor methodologies and if those concerns were resolved, the would approve The and the vendors were unable to satisify the and -357 was withdrawn. In 2016, the BWROG developed -564, "Safety Limit MCPR" that changes the methodology for determining the SL to only be dependent on the fuel type. As an alternative, GNF developed a standard submittal template for SLMCPR TS changes to reduce need for RAIs. This was successful for a time, but eventually the started asking multiple RAIs on every submittal. See 358. In 2015, the BWROG decided to develop a new to establish a SL MCPR that would not change for each cycle. Fees A public meeting with the to discuss the traveler was held on November 16, /1/2016: A presubmittal meeting to discuss -564, "SL MCPR" with the was held on November 16., GEH, and Westinghouse to provide responses to questions. 3/31/2017 Page 12 of 26

18 Revise SR to Address SRs that Cannot be Performed or are Not Met Fees PWROG PWRs&BWRs Safety Improvement Review Shared -541 will revise SRs by adding notes or exceptions for valves and dampers that are locked, sealed or otherwise secured in the actuated position, in order to consider the SR met when the subject structure, system or component is Operable (i.e., is capable of performing its specified safety function). This will prevent declaring systems inoperable and potential plant shutdowns for conditions that do not affect plant safety submitted to the on September 10, /10/2013: -541 submitted to the on September 10, /13/2015: transmitted a Request for Additional Information on August 13, /13/2015: transmitted the acceptance and schedule letter on August 13, /11/2015: responded to request for additional information on November 11, /12/2015: to provide revised review schedule. 12/3/ a new review schedule was provided: Second round RAIs to be provided in mid- February, Draft safety evaluation to be provided by November 7, /9/2016: provided a second round RAI on February 26, Of the 21 questions, approximately half appear to be repetitive of the first round RAI. A management meeting was held on July 28 to discuss the RAIs. 7/28/2016: to prepare additional explanation of the use of the existing and proposed SR notes. The and will discuss the additional explanation prior to submittal of a revised traveler in lieu of the responding to the RAIs. 9/10/ /11/2015 8/13/ /12/ /3/2015 7/28/2016 1/12/2017 Page 13 of 26

19 1/12/ White paper provided to. 1/12/2017: to provide feedback on the white paper. RI Initiative 4b, Risk Informed Completion Times 3/31/ PWROG PWRs&BWRs Safety Improvement Issue -505, "Provide Risk-Informed Extended Completion Times - RI Initiative 4b," was approved by the on March 15, In a June 9, 2014 Request for Additional Information (RAI) to Southern Nuclear Operating Company regarding their LAR to adopt risk informed Completion Times, the staff included two RAIs of concern to the. Both RAIs stated that an oversight occurred during the review of On September 10, 2014 the provided additional RAIs to Vogtle that the industry believes are inconsistent with NEI and At the July 23, 2015 / public meeting, the raised questions regarding how Westinghouse plants determine if a function is PRA Functional when multiple instrument channels are inoperable. NEI has formed a Risk Informed Completion Time (RICT) Task Force to address the positions on The is participating. The first meeting with the was held on February 3, Fees On November 15, 2016, the transmitted a letter to the stating that they had issues with -505 would not accept further submittals to adopt the traveler until the issues were resolved. On December 13, a meeting was held between the, NEI, and to discuss the concerns. The industry proposed a path forward to be documented in a letter to the. 12/13/2016: The provided a draft letter to the on January 31, 2017 addressing the concerns with and met with on February 16 to discuss. 2/16/2017: to provide comments on draft letter. Another meeting will be scheduled in late March. 2/16/2017 3/31/2017 Page 14 of 26

20 APRM Recalibration Limit Fees BWROG BWRs Operational Review BWROG Improvement This topic tracks a to revise Technical Specification (TS) , "Reactor Protection System (RPS) Instrumentation," in the BWR ISTS to provide additional time to adjust the gain on the APRM channels if the instrument channels are discovered with a calibrated power value outside the acceptance band. The proposed change allows the APRM channel to not be considered inoperable if the indicated power is within 2% of the calibrated power. 4/21/2016: provided acceptance and review schedule letter on 8/12/2016. RAI by September 30, 2016 Draft SE by 6/7/2017 Final SE by 9/21/ /3/2016: provided RAI on 10/3/2016. A teleconference to discuss the RAIs was held on November 14, responded to the RAI on February 2, /15/2016 2/2/2017 2/2/2017: to provide draft SE. 6/7/2017 Page 15 of 26

21 Technical Specifications on Fuel Storage Pool Neutron Absorber Density PWRs&BWRs Issue Review Fees NEI 12-16, "Guidance for Performing Criticality Analyses for Fuel Storage at Light- Water Reactor Power Plants," is under review. At the May 2, 2013 Technical Specifications Task Force ()/ quarterly meeting, the stated the Technical Specifications should include requirements to monitor spent fuel pool neutron absorber materials, and requested that the propose appropriate controls. At the July 18, 2013 / meeting, the stated they are working with the NEI Spent Fuel Pool Criticality Task Force. The attended an /NEI Spent Fuel Criticality Task Force meeting on October 31 and briefly discussed the applicability of Technical Specifications. The provided a white paper to the NEI task force on January 10, On March 11, 2014, the issued a draft Generic Letter for comment regarding monitoring of neutron-absorbing materials in spent fuel pools. On November 17, 2014, NEI,, and reached agreement on a Technical Specifications approach T was approved on May 2, NEI submitted NEI on May 10, 2016 for endorsement via Reg Guide. The granted the requested fee waiver to review and endorse NEI on July 14, Additionally, the agreed to perform an expedited review on the document by November /3/2016: Brian to scope traveler and bring to the next meeting. Changes are needed to TS , TS 4.1, "Design Features" and new program language in Section 5.5. B. Mann 4/25/2017 Page 16 of 26

22 Inadequate Actions for Inoperable RHR/SDC 1401 None BWROG BWRs Operational Review Improvement Fees The BWR ISTS Actions for inoperable RHR/SDC subsystems requires use of an alternate system, which may not exist under all plant conditions. The BWROG wants to develop more appropriate Actions. Phil Lashley and Rick Loeffler to champion the issue. SSPS General Warning Alarm Modification 1/9/2017: BWROG LC members to review draft traveler and provide comments. 1/27/2017: Brian M. to revise traveler to address comments. BWROG 1/27/2017 B. Mann 3/31/ None PWROG PWRs Issue Issue Fees This task, PA-LSC-0820, includes generic actions to create a 10 CFR screening and evaluation for the SSPS General Warning Alarm modification for Westinghouse plants. The primary function of this project is to support implementation of SSPS reliability improvements developed under WCAP P, Revision 0, Solid State Protection System Life Cycle Management Planning Sourcebook, [PA-SEE-0656] and to support extension of the Technical Specifications Actuation Logic Test surveillance frequency (interval) that was justified in WCAP P, Risk-Informed Evaluation of Surveillance Test Interval Extensions to the Westinghouse Solid State Protection System Actuation Logic and Master Relays, [PA-SEE-0413]. A topical report is scheduled to be submitted to the in April, /5/2016: PWROG met with in March agreed to a 12 month review schedule. The PWROG will complete the the functional requirements list, obtain consensus on which requirements are needed, and develop input for the al Report. Jim to update the LSC at the next meeting. Page 17 of 26 J. Andrachek 4/25/2017

23 Industry Guidance on Identification, Reporting, and Correction of Nonconservative Technical Specifications 1408 None PWRs&BWRs Issue Review Fees The has requested that the create industry guidance on identification, reporting, and correction of nonconservative TS. The will work with the s Groups, NEI, and other industry groups. The guidance will be reviewed and endorsed by the in lieu of an -created replacement for Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety." Two members spoke at the 2014 Regulatory Information Conference on nonconservative TS. A meeting to develop draft guidance was held September 24-25, The created a generic guidance document, -GG-15-01, "Licensee Actions to Address Nonconservative Technical Specifications." The has requested that NEI pursue the document as an endorsed, NEI document. NEI submitted NEI to the for review and endorsement on May 11, /11/2015: The will support NEI in obtaining an -endorsed, NEI guidance document. At the July 23, 2015 / meeting, the stated they had no comments on the document and were pursuing a Regulatory Guide to endorse the document. 2/23/2016: At the February 28, 2016 / meeting, the stated that they would pursue a Regulatory Guide to endorse NEI The technical staff stated they would support a fee waiver. The volunteered to support NEI by drafting a fee waiver request. 3/1/ Draft letter provided to NEI. 3/1/2016: to endorse NEI has not provided a schedule for completion. 12/31/2016 3/1/2016 Page 18 of 26

24 Proposed Rule Change: Performance-Based Emergency Core Cooling Systems Cladding Acceptance Criteria (50.46c) 1412 None PWROG PWRs Issue None Fees The has issued 10CFR50.46c for public comment on 3/24/14. There are a large number of logistical and licensing concerns that remain in the proposed rulemaking and a greater voice is needed by the licensing community. The LSC has funded activities (PA-LSC-1273) to fund monitoring and participation in this issue. Revision 2 of the PA was approved in December 2015, extending funding through Create a for a Mode 3 End State 12/15/2015: Westinghouse to update the committee at the next meeting. As of December 2016, it was unclear whether the will issue the new rule. Westinghouse 4/25/2017 Fees 1428 None PWROG PWRs Safety Improvement Review PWROG During review of the PWR Mode 4 End State s (-422, -431, and -432), the recommended that the industry investigate whether a Mode 3 end state would be a safer condition for short shutdowns to perform maintenance. There are more heat removal mechanisms available and ECCS is required to be Operable. At the 2/5/2015 / meeting, the asked the if the staff would entertain such a proposal. Westinghouse determined that the existing analysis cannot be used as the basis of the new change. The PWROG LSC approved PA-LSC-1222 R0 at the December 2016 meeting. 12/3/2016: Westinghouse to develop an example change and justification and meet with the. Westinghouse 4/25/2017 Page 19 of 26

25 Westinghouse 7300 New Design Board Replacement under None PWROG PWRs Operational None Improvement Fees A question of whether there are any digital licensing issues with new design 7300 analog boards that are similar to new design SSPS board licensing issues. WEC will investigate whether the use of PAL ICs on new design NLL board is a licensing issue similar to the SSPS boards. Project Authorization SEE-1395 R0 pursuing the issue. This project is a continuation of the effort authorized on September 1, 2015 by OG , "PWROG EIG Chairman Approval of Emerging Issue Group (EIG) Funds to Develop a Generic Operability Determination for Westinghouse Plants with Installed New Design Digital Boards." The PA provides funding for Westinghouse to complete a generic Operability Determination and generic 10 CFR Screen/Evaluation for plants that have installed revised design (redesigned) 7300 printed circuit boards in process protection, control and/or indication system instrument channels that contain embedded digital devices. 12/3/2016: Westinghouse to provide the draft al Report for PWROG review and comment. Turbine Stop/Control Valve Closure RPS Function 1436 None BWROG BWRs Standards Improvement Westinghouse 4/25/2017 Fees BWR standard Technical Specifications include Reactor Protection System Functions in LCO for Turbine Stop Valve Closure and Turbine Control Valve Fast Closure. Both Functions are required at or above certain Reactor Thermal Power (RTP), e.g. [30% RTP]. The standard Tech Spec LCO Bases include the following statement: a) This Function must be enabled at THERMAL POWER [40% RTP]. This is normally accomplished automatically by pressure transmitters sensing turbine first stage pressure; therefore, to consider this Function OPERABLE, the turbine bypass valves must remain shut at THERMAL POWER [40% RTP]. The administrative requirement to consider this Function OPERABLE, the turbine bypass valves must remain shut is too conservative and does not belong in the TS Bases. 8/9/2016: Brian M to create a T to revise the Bases as a low priority item. B. Mann 5/1/2017 Page 20 of 26

26 Allow Differing Frequencies for Components in a Channel Calibration PWROG PWRs&BWRs Operational Review Improvement The PWROG SEE Committee is investigating allowing a longer Surveillance Frequency for pressure and differential pressure transmitters than for the Channel Calibration of the remainder of the instrument channel (Project Authorization SEE-0625). This would require a change to the Technical Specifications. The PWROG Licensing Committee is supporting this project. A teleconference was held on June 17 and several approaches were discussed. A second teleconference was held on October 26. At the November 12, 2015 / meeting, the mentioned the potential for a but determined the issue was not sufficiently understood to discuss specifics. Discussed with the at the February 18, 2016 meeting. At the February 18, 2016 / meeting, the discussed the two options for addressing this issue. The had no objections to revising the SFCP and Channel Calibration definition and made several suggestions to support the change. Fees 2/1/2017: to arrange presubmittal meeting. Request sent on February 2, /9/2017 Page 21 of 26

27 Revise Reponse Time Testing Definition Fees 1440 None PWROG PWRs&BWRs Operational Review PWROG Improvement The purpose of this project is to evaluate the applicability of WCAP P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing", CEOG al Report CE NPSD-1167-A, "Elimination of Pressure Sensor Response Time Testing Requirements", and EPRI NP-7243 Revision 1, "Investigation of Response Time Testing Requirements" to the Rosemount 3150 series transmitters. The transmitters evaluated in these reports are becoming obsolete and need to be replaced with newer components, but the ability to not perform Response Time Testing in the ISTS definition limits the option to transmitters that have been specifically reviewed and approved by the. The options are to request review of all of the new transmitter types or to revise the definition to allow other transmitters to be used. Only applicable to W and CE plants as B&W plants never eliminated response time testing. The PWROG met with the Staff to discuss the submittal of a Technical Specifications Task Force () that would revise the definitions for Engineered Safety Feature (ESF) Response Time and Reactor Trip System (RTS) Response Time that are contained in NUREG-1431 and NUREG-1432, to allow the approved methodology to be applied to new devices. The provided comments. A traveler to revise the TS will be pursued. 12/3/2016: Westinghouse to prepare the traveler justification. EXCEL to draft traveler for PWROG LSC review. Westinghouse EXCEL 4/25/2017 Page 22 of 26

28 PIRT 16-07, Part Length Fuel Rod Exposure Limits Fees 1445 None Issue Issue BWROG RG 1.183, Alternative Source Term, establishes a 62 GWD/MTU fuel pin peak burnup limit. Two considerations - thermal design and radiological exposure Peak fuel rod burnup is higher on part length rods because there is no fuel in the lower power regions of the core to lower the average burnup. While, there is no concern from a thermal/mechanical design aspect, there are potentially radiological effects from exceeding the fuel pin burnup limit. Several Exelon plants are close to the limit or may exceed the limit. 12/1/2016: Licensing Committee to work with the responsible committee to arrange a meeting with to present the argument and ask for the preferred regulatory approach: (a)licensee-specific letter (b)vendor-specific letter (c)s Group letter 12/1/2016: PIRT to assign a committee to write a technical justification for not applying the footnote to part-length fuel rods. LC BWROG PIRT Increased Cooperation Between the BWROG and PWROG Licensing Committees 3/31/2017 3/31/2017 Fees 1446 None Operational None Shared Improvement The BWROG and PWROG Licensing Committees are investigating additional methods to cooperate on issues of mutual interest. 12/2/2016: BWROG Licensing Committee co-chairman, Phil Lashley, to work with the PWROG to explore activities. P. Lashley 5/1/2017 Page 23 of 26

29 Correct for BWR and Fees 1447 None Issue Review BWROG At the September / meeting, the raised a concern with TS , Drywell-to-Suppression Chamber Differential Pressure, and TS , Primary Containment Oxygen Concentration. For both TS, the states: MODE 1 during the time period: a. From [24] hours after THERMAL POWER is > [15]% RTP following startup, to b. [24] hours prior to reducing THERMAL POWER to < [15]% RTP prior to the next scheduled reactor shutdown. The terminal action in both TS is to reduce Thermal Power to [15]% RTP. The Bases for the Action state, "the plant must be placed in a MODE in which the LCO does not apply. This is done by reducing power to [15]% RTP within 12 hours." In a recent violation, the took the position that the TS is incorrect. The position is that the is Mode 1, not Mode 1 > 15% RTP. The Bases shouldn't state that being below 15% RTP exits the 12/1/2016: EXCEL to draft a traveler to revise the TS to implement an applicability of 15% RTP. Make the 24 hour allowance applicable to other shutdowns and startups. Eliminate undefined terms. to Allow Rod Worth Measurement in Mode 3 B. Mann 5/1/2017 Fees 1448 None Operational Review PWROG Improvement PGE has suggested that a traveler be created to allow rod worth measurement in Mode 3 vice Mode 2 to reduce outage duration. 12/3/2016: PEG to send information on proposed change to the LSC. J. Morris 4/25/2017 Page 24 of 26

30 Develop industry position regarding the relationship between TS operability and external events None Operational Review Shared Improvement The current position that TS systems must be capable of responding to design basis external events in order to be operable is inconsistent with the historical and industry position and previous actions, such as the relocation of fire protection equipment and flooding doors from the TS. The PWROG is interested in developing a supporting argument and working with NEI and the BWROG to pursue changes to the position. The PWROG formed a core team with Brian Mann, Jim Morris, Bruce Montgomery, Dave Gullott, Tom Elwood, Nichole Good, John Caves, and Ryan Joyce (BWROG). Fees 2/26/2017: Talking points paper to be provided to PWROG and BWROG chairmen following resolution of core team comments. 2/1/2917: Core team call held for February 6. B. Mann tasked with developing talking points. License Amendments to Adoption Multiple Pre-CLIIP s B. Mann 2/28/2017 PWROG BWROG 2/6/2017 Fees 1450 None All Issue Issue Shared A number of licnesees have submitted license amendments to adopt pre-cliip travelers (i.e., travelers without model applications and model safety evaluations) using a similar format. At the February 8, 2017 / meeting, the expressed concern with the practice and requested a discussion with the on ways to improve the process. Low Priority s 2/9/2017: Add topic to May 11 / meeting agenda. 5/11/2017 Page 25 of 26

31 Overlapping Between ECCS (3.5.3) and RHR (3.4.6) 1360 None PWROG PWRs Operational Improvement Fees Generic Letter pointed out a problem with the Note in ECCS that allows an RHR train to be credited as an ECCS train. This topic tracks the actions to resolve this issue. The current approach is tied to ASC-0536 R1, Shutdown LOCA Basis Review. ASC-0536 will include a report, Shutdown LOCA scoping studies, and an initial meeting. Plan is to hold the initial meeting with the in May, Output would be an established licensing basis for a SDLOCA and revised Mode 4 ECCS TS requirements. 12/15/15 - Analysis is proceeding. 4/5/2016: ASC to keep the LSC informed of the progress. 12/3/2016: The LSC formed a core team to support the ASC. Brian Mann, Dave McCreary, Jim Andrachek. Administrative topics are omitted from this report. s in this Report: 31 K. Lowery 12/6/2016 LSC 4/25/2017 Page 26 of 26