1. PWR Sump Performance (GSI-191) Workshop
Addressing Sump Performance Challenges Through Plant Technical Specifications
Robert Elliott, Branch Chief
Technical Specifications Branch
U.S. Nuclear Regulatory Commission
October 19, 2012
All generic changes to Standard Technical Specifications are developed between industry and NRC staff

2. PWR Sump Performance (GSI-191) Workshop
The Challenge
What is the best approach for implementing fiber limits in resolving GSI-191.

3. PWR Sump Performance (GSI-191) Workshop
Operability
A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).
Risk cannot be considered in determining Operability.
No gray area. A system or component is either operable or it is not.

4. PWR Sump Performance (GSI-191) Workshop
Why Technical Specifications (Tech Specs)?
If tech specs do not address fibrous material remedial measures, and the more fiber than expected is discovered in containment during power operation, then the licensee will assess operability of the ECCS.
If the ECCS is determined to be inoperable, then a 72 hour tech spec completion time to restore the ECCS to operable status is entered.

5. PWR Sump Performance (GSI-191) Workshop
Why consider Tech Specs?
If, however, tech specs were to specifically address fibrous material remedial measures, and the licensee finds that the ECCS is inoperable solely for having too much fiber in containment, then
The remedial measures allowed by the tech specs could be taken within the associated Completion Times (CTs).
The specified remedial measures and associated CTs would provide regulatory certainty.
Remedial measures can be linked to plant-specific TS Administrative Controls Programmatic Requirements.

6. PWR Sump Performance (GSI-191) Workshop
Conclusion
Tech specs can provide a degree of regulatory certainty in dealing with fiber material concerns.
Regardless whether tech specs are used to specifically address fibrous material limits and associated remedial measures, or not:
Licensees still need fibrous material controls.
ECCS operability may still be affected by excessive fiber in containment.
Non-availability of the ECCS under the MSPI is still counted. However, entry into the tech specs for excessive fiber should be very rare.

7. PWR Sump Performance (GSI-191) Workshop
Questions?