ML053050292
| ML053050292 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/18/2005 |
| From: | Boska J NRC/NRR/DLPM/LPD1 |
| To: | Distel D AmerGen Energy Co |
| Tam P | |
| References | |
| %dam200604, TAC MC6046 | |
| Download: ML053050292 (3) | |
Text
From:
John Boska To:
Distel, Dave Date:
10/18/05 12:54PM
Subject:
MC6046 Oyster Creek RWCU isolation Dave, Peter Tam is on vacation until 10/31, I am filling in. Attached are some RAIs for MC6046.
Please let me know if you want to have a phone call to discuss the RAIs with the NRC staff, or if I should just send you an RAI letter. Thanks.
John P. Boska Indian Point Project Manager, DLPM FitzPatrick Project Manager U.S. Nuclear Regulatory Commission 301-415-2901 email: jpb1@nrc.gov CC:
Helker, Dave; Laufer, Richard; Tam, Peter REQUEST FOR ADDITIONAL INFORMATION ON OYSTER CREEK GENERATING STATION, TECHNICAL SPECIFICATIONS CHANGE REQUEST REACTOR WATER CLEAN-UP HIGH ENERGY LINE BREAK DETECTION AND ISOLATION The license amendment request (LAR) proposes addition of a Reactor Water Clean-Up (RWCU) High Energy Line Break (HELB) detection/isolation instrumentation that will initiate a RWCU system isolation when RWCU pump room ambient temperature reaches a preset limit of 180 degrees Fahrenheit.
In recent public communications available on the NRC's public website in the Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML052500004, ML050870008 and ML051660447 the Nuclear Regulatory Commission (NRC) staff has identified a concern on the use of Allowable Values (AVs) as limits that are used in technical specifications (TSs) to satisfy the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical Specifications. The NRC staff has been working with the Nuclear Energy Institutes Setpoint Methods Task Force (TSTF) to revise the technical specifications to address these concerns.
To assess the acceptability of your license amendment request related to this issue, the NRC staff requests the following additional information:
- 1.
Describe the instrumentation setpoint methodology used at Oyster Creek for establishing TS limits. This discussion should include acceptable as found band, acceptable as left band, setting tolerance, and reset criteria used to determine the acceptability of the instrumentation.
2.
For the setpoint to be added, clarify whether it is a Limiting Safety System Setting (LSSS) as discussed in 10 CFR 50.36(c)(ii)(A). If you determined that it is not, explain why not.
The staff will generally use the following criteria to determine whether the instrument setpoint being changed falls within the scope of this LSSS issue or not:
(a) Instrument setpoints for TS functions in the Reactor Protection (Trip)
System.
(b) Instrument setpoints for TS functions that protect a safety limit (whether or not the Bases designates the function as an LSSS).
(c) Setpoints that are not in Instrumentation LCOs but whose function protects a safety limit (whether or not the Bases designate the function as an LSSS).
- 3.
10 CFR 50.36(c)(ii)(A) requires that if it is determined that the automatic safety system does not function as required, the licensee shall take appropriate action. Describe how the surveillance test results and the associated TS limits as determined by the plant setpoint methodology are used to establish the operability of the safety system. Include a discussion of plant processes for evaluating channels identified to be operable but degraded. If the requirements for determining operability of the instrumentation being tested are located in a document other than the TS (e.g., plant test procedure), discuss how the requirements of 10 CFR 50.36 are met.
4.
10 CFR 50.36(c)(ii)(A) requires that an LSSS be so chosen that automatic protective action will correct the abnormal situation before a SL is exceeded.
Discuss how TS limits established by the plant setpoint methodology will ensure that the SL will not be exceeded. Include in your discussion information on the controls you employ to ensure that the as left trip setting after completing periodic surveillances is consistent with your setpoint methodology.
If the controls are located in a document other than the TS (e.g., plant test procedure), discuss how those controls satisfy the requirements of 10 CFR 50.36.
5.
For setpoints that are not defined as LSSS in response to question 2, discuss what measures have been taken to ensure that it is capable of performing its specified safety functions. Include in your discussion information on the controls you employ to ensure that the as left trip setting after completing periodic surveillances is consistent with your setpoint methodology. If the controls are located in a document other than the TS (e.g., plant test procedure), discuss how those controls satisfy operability requirements.
6.
Provide commitment to assess applicability of the TSTFs TS changes pertinent to instrument setpoints, when approved by the NRC, to determine whether changes to Oyster Creeks licensing basis are necessary.
7.
By letter dated June 8, 1992, to John J. Burton, the NRC concluded that the methodology the licensee used to calculate pressure sensor setpoints in LAR dated May 29, 1990, did not show conclusively adherence to Regulatory Guide 1.105, Revision 2, Instrument Setpoints for Safety-related Systems, Instrument Society of America (ISA) standard, ISA-S67.04-1982, Setpoints for Nuclear Safety-related Instrumentation Used in Nuclear Plants or licensees Engineering Standard, ES-002, Instrument Error Calculation and Setpoint Determination. Furthermore, the NRC terminated review of the LAR, and recommended appropriate modifications to ES-002 and recalculation of the setpoints. Describe the measures taken to address the NRCs comments in the letter dated June 8, 1992.
Mail Envelope Properties (435528C3.A1F : 14 : 2186)
Subject:
MC6046 Oyster Creek RWCU isolation Creation Date:
10/18/05 12:54PM From:
John Boska Created By:
JPB1@nrc.gov Recipients exeloncorp.com david.distel (Dave Distel) david.helker CC (Dave Helker) nrc.gov owf4_po.OWFN_DO PST CC (Peter Tam)
RJL CC (Richard Laufer)
Post Office Route exeloncorp.com owf4_po.OWFN_DO nrc.gov Files Size Date & Time MESSAGE 970 10/18/05 12:54PM MC6046 draft RAIs.wpd 9813 10/18/05 12:50PM Options Expiration Date:
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