ML011290007
| ML011290007 | |
| Person / Time | |
|---|---|
| Issue date: | 05/07/2001 |
| From: | Dennig R Technical Specifications Branch |
| To: | Schoppman M Nuclear Energy Institute |
| Hill LA, NRR/RTSB, 415-2158 | |
| References | |
| Download: ML011290007 (4) | |
Text
May 7, 2001 Mr. Michael Schoppman, Project Manager Licensing Department Nuclear Energy Institute 1776 I Street, N. W.
Suite 400 Washington, DC 20006-3708
Dear Mr. Schoppman:
This is to inform you of the disposition of TSTF-373. After discussions with CEOG, the following modifications are recommended:
1.
Proposed Condition A has an applicability Note that restricts the Condition to the containment sump supply valves to the ECCS and containment spray pumps.
The staff safety evaluation implies that those penetrations that don't meet the topical report criteria and/or the plant specific evaluations must retain the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time. The Condition A Note should be modified to reflect these additional or potential penetrations. See comment 3 for a variation of this comment.
2.
New Condition B (STS Condition A) has a bracketed exception. The bracketed exception as proposed implies that proposed Condition A has limits of some sort.
Since Rev. 2 to the STS is about to be issued, it is felt that the wording used in TSTF-207, R.5 better reflects the intent of the current and proposed exception.
The exception and the proposed change should be modified accordingly.
3.
New Condition D (STS Condition C) was revised in TSTF-30 from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. It is unclear from the staff SE if all types of configurations for penetration flow paths with only one containment isolation valve and a closed system have been evaluated by the Topical Report. If they have, this comment is moot. If they have not, then an Action similar to STS Condition C as modified by TSTF-30 needs to be proposed with an applicability Note based on Comment 1 above.
4.
Proposed Insert 2 is the Reviewer's Note to be added to the Bases which specifies the conditions for adopting the 7 day Completion Time. The Note just references the staff SE for the Topical Report. The Note should specifically state the staff conditions that must be met in order to use the 7 day Completion Time.
The reviewer implementing the TSTF at the plant and/or the staff reviewer may not have ready access to the staff SE. Also see comment 7 below. In addition the Reviewer's Note should state that if the conditions or criteria
Mr. Schoppman May 7, 2001 cannot be met then the 4/72 hour Completion Times should be used, otherwise the [7 days] in Conditions B and D would be confusing in terms of what to put in their place.
5.
The Bases changes should be compared to TSTF-207 and TSTF-30 for applicability; if there are differences or changes that are required they should be discussed in the Background portion of the TSTF.
6.
The Background portion of the TSTF discusses the change from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 7 days. TSTF-30 changed STS Condition C from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 days. While this should not affect the results of the Topical Report for that type of penetration or the TSTF, the Background should be revised to reflect the current STS (STS Rev. 2).
7.
The Background portion of the TSTF lists the conditions for acceptance of the 7 days found in the staff SE. Condition 4 does not reflect the staff's requirement that the Configuration Risk Management Program (CRMP) be found acceptable to the staff. In addition staff condition CRMP (ii) has not been addressed in the Background section. This requirement deals with common cause failures and operability verification.
Please contact me at (301) 415-1156 or e-mail rld@nrc.gov if you have any questions or need further information on these dispositions.
Sincerely,
/RA/
Robert L. Dennig, Acting Chief Technical Specifications Branch Office of Nuclear Reactor Regulation cc:
See attached list
Mr. Schoppman May 7, 2001 cannot be met then the 4/72 hour Completion Times should be used, otherwise the [7 days] in Conditions B and D would be confusing in terms of what to put in their place.
5.
The bases changes should be compared to TSTF-207 and TSTF-30 for applicability; if there are differences or changes that are required they should be discussed in the Background portion of the TSTF.
6.
The Background portion of the TSTF discuss the change from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 7 days.
TSTF-30 changed STS Condition C from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 72 days. While this should not affect the results of the Topical Report for that type of penetration or the TSTF, the Background should be revised to reflect the current STS (STS Rev. 2).
7.
The Background portion of the TSTF list the conditions for acceptance of the 7 days found in the staff SE. Condition 4 does not reflect the staff's requirement that the Configuration Risk Management Program (CRMP) be found acceptable to the staff. In addition staff condition CRMP (ii) has not been addressed in the Background section. This requirement deals with common cause failures and operability verification.
Please contact me at (301) 415-1156 or e-mail rld@nrc.gov if you have any questions or need further information on these dispositions.
Sincerely,
/RA/
Robert L. Dennig, Acting Chief Technical Specifications Branch Office of Nuclear Reactor Regulation cc:
See attached list DISTRIBUTION:
ADAMS PUBLIC RTSB r/f DMatthews FGillespie DOCUMENT NAME:C:\\TSTF 373 Disposition Letter.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RTSB/DRIP:NRR RTSB/DRIP:NRR AC:RTSB/DRIP:NRR NAME LAHill RJGiardina RLDennig DATE 05/07/01 05/07/01 05/07/01 OFFICIAL RECORD COPY
cc:
Mr. Tony Pietrangelo, Director Risk and Performance Based Regulation Nuclear Energy Institute, Suite 400 1776 I Street, NW Washington, DC 20006-3708 Mr. Biff Bradley Risk & Performance Regulation Nuclear Energy Institute, Suite 400 1776 I Street, NW Washington, DC 20006-3708 Mr. Donald R. Hoffman EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Mr. Noel Clarkson Duke Energy, Oconee Nuclear Site Mail Code ONO3RC 7800 Rochester Highway Seneca, SC 29672 Mr. Thomas Weber Palo Verde Nuclear Generating Station Mail Station 7636 5801 South Wintersburg Road Tonapah, AZ 85354-7529 Mr. Steve Wideman P.O Box 411 Burlington, KS 66839 Mr. John Arbuckle P.O. Box 968 Mail Drop PE20 Richland, WA 99352-0968 Mr. Alex Marion Programs Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708