ML063130309
| ML063130309 | |
| Person / Time | |
|---|---|
| Issue date: | 11/27/2006 |
| From: | Kobetz T NRC/NRR/ADRO/DIRS/ITSB |
| To: | Bradley B Nuclear Energy Institute, Technical Specifications Task Force |
| Tjader T NRR/DIRS/ITSB 415-1187 | |
| References | |
| TSTF-426, Rev 0, WCAP-16125-NP-A, WCAP-16446 | |
| Download: ML063130309 (4) | |
Text
November 27, 2006 Mr. Biff Bradley Technical Specifications Task Force (TSTF)
Nuclear Energy Institute 11921 Rockville Pike 1776 I Street, N. W. Suite 100 Suite 400 Rockville, MD 20852 Washington, DC 20006-3708
Dear Members of the TSTF and Mr. Biff Bradley:
The proposed Risk Management Technical Specification (TS) Initiative 6, Risk-Inform Requirements Regarding Conditions Leading to Exigent Plant Shutdown, change was noticed in the Federal Register (71 FR 41264, July 20, 2006) requesting comment. Comments were received. During the comment disposition process it became apparent to the staff that changes to the Technical Specification Task Force (TSTF) proposed TS change, TSTF-426, Revision 0, would be necessary. In order to be acceptable, the following changes need to be incorporated into TSTF-426 and the associated implementation guidance, WCAP-16446, and the topical report, WCAP-16125-NP-A needs to be revised to be consistent with the associated safety evaluation of July 9, 2004.
- 1. Voluntary entry into the proposed TS Conditions is not permitted. A note needs to be added to each affected TS Condition, in TSTF-426, limiting application of the proposed TS Conditions to emergent conditions.
2 End states changes not approved by the safety evaluation of July 9, 2004, such as for the Control Room Emergency Air Cleanup System (CREACS) and Control Room Emergency Air Temperature Control System (CREATCS) TS sections, need to be removed from TSTF-426.
- 3. The proposed change in TS 3.6.6.A, Containment Spray and Cooling System, to allow shutdown to Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> versus immediate entry in to LCO 3.0.3 has not been approved and should be removed from TSTF-426.
- 4. The proposed change to delete TS 3.5.2 Condition D has not been approved and should be removed from TSTF-426. WCAP-16125 proposed three changes to TS 3.5.2, ECCS - Operating, only two of which were accepted by the staff in its safety evaluation. Condition D requires immediate entry into TS 3.0.3 if the total available ECCS flow would be less than 100% of the equivalent of a single operable ECCS train, and this is retained in TS 3.5.2. The approved changes added new conditions to TS 3.5.2 governing conditions with two inoperable LPSI trains or two inoperable HPSI trains. Therefore, with two LPSI trains inoperable, the new condition would apply only if the system remains capable of delivering the equivalent of 100% of the flow of one LPSI train. Similarly, with two HPSI trains inoperable, the new condition would apply only if the HPSI system remains capable of delivering the equivalent of 100% of the flow of one HPSI train. Conditions involving a total loss of function of the LPSI or HPSI system would still require immediate entry into TS 3.0.3 by application of Condition D of TS 3.5.2. In its safety evaluation of WCAP-16125, the
B. Bradley, et.al. staff identified the scope of information and analyses required to potentially justify deletion of TS 3.5.2 Condition D, which included the requirement for alternate injection systems and backup accident management strategies to be available and effective. Since this information was not provided for staff review, the safety evaluation stated that the proposed change was unacceptable without further justification. Any further justification in support of deleting TS 3.5.2 Condition D would have to be reviewed and accepted by the staff in a safety evaluation on a plant-specific basis, unless a generic analysis is provided and accepted by the staff in a revised safety evaluation. The staff notes that the approved version of the topical report, WCAP-16125-NP-A, retains the rejected deletion of TS 3.5.2 Condition D, even though this was not approved by the staff in its safety evaluation.
- 5. The bases section to the Pressurizer TS needs to include, in TSTF-426, a discussion on plant pressure control constraints as stated in the associated section of the safety evaluation.
The staff intends to publish a Notice of Availability in accordance with my letter dated November 16, 2006, provided the TSTF revises TSTF-426 to include these changes and it is received within 60 days of this letter. The TSTF must notify the NRC, in writing, if it requires longer than 60 days. If the TSTF does not respond in 60 days, and does not request an extension, the NRC will terminate our review of TSTF-426.
If you have any questions please contact Bob Tjader at 310-415-1187 or at trt@nrc.gov.
Sincerely,
/RA/
Timothy J. Kobetz, Branch Chief Technical Specifications Branch Division of Inspection & Regional Support Office of Nuclear Reactor Regulation cc: D. Hoffman, Excel Services (donaldh@excelservices.com)
B. Mann, Excel Services (brianm@excelservices.com)
M. Crowthers, BWROG (mhcrowthers@pplweb.com)
W. Sparkman, WOG (wasparkm@southernco.com)
P. Infanger, BWOG (paul.infanger@pgnmail.com)
B. Woods, WOG/CE (woodsbl@songs.sce.com)
ML063130309 OFFICE ITSB:DIRS:ADRO BC:SPWB:DSS:ADES BC:APLB:DRA:ADRA BC: APLA:DRA:ADRA BC:ITSB:DIRS:ADRO NAME TRTjader JANakoski LAMrowca MPRubin TJKobetz DATE 11/17/06 11/21/06 11/17/06 11/17/06 11/27/06 Letter to B. Bradley, et. al., from T. Kobetz Dated:
DISTRIBUTION:
ADAMS PUBLIC TSS R/F TSS Staff BABoger (RidsNrrAdro)
GMHolahan) (RidsNrrAdra)
JELyons/MDTschiltz (RidsNrrAdraDra)
MJCase/PLHiland (RidsNrrAdroDirs)
TJKobetz (RidsNrrAdroDirsItsb)
MPRubin (RidsNrrAdraDraAplb)
OGC (RidsOgcRp)
ACRS/ACNW (RidsAcrsAcnwMailCenter)
AJHowe (AJH1)
NSaltos (NTS)
CKDoutt (CKD)]
SDAlexander (SDA)
DHShum (DHS)
GWParry (GWP)
LAMrowca (LXM4)
RPGrover (RPG2)
SCDinsmore (SCD1)
JANakoski (JAN1)
SBSun (SBS)
LWWard (LWW)