ML072050146
| ML072050146 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 07/25/2007 |
| From: | Kobetz T NRC/NRR/ADRO/DIRS/ITSB |
| To: | Technical Specifications Task Force |
| Schulten C. S., NRR/DIRS, 415-1192 | |
| Shared Package | |
| ML072070202 | List: |
| References | |
| TAC MD5249, TSTF-493, Rev 2 | |
| Download: ML072050146 (11) | |
Text
July 25, 2007 Technical Specifications Task Force (TSTF) 11921 Rockville Pike Suite 100 Rockville, MD 20852
SUBJECT:
TSTF TRAVELER 493, REVISION 2, CLARIFY APPLICATION OF SETPOINT METHODOLOGY FOR LSSS FUNCTIONS.
DOCKET NO: PROJ0753; TAC MD5249
Dear Members of the TSTF:
By letter (Agencywide Document and Management Systems (ADAMS) Accession Number ML071070421), dated April 16, 2007, you requested the Nuclear Regulatory Commission (NRC) review and make available under the Consolidated Line Item Improvement Process (CLIIP),TSTF Traveler 493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions. By letter (ADAMS Accession Number ML071440183), dated May 24, 2007, the NRC staff determined the TSTF was sufficiently complete to initiate a more comprehensive review consistent with your request.
The NRC staff comprehensive review is complete and the results of this review identified a number of issues (Enclosure 1) in addition to text revisions to the Traveler (Enclosures 2 - 6),
that need to be resolved in order for the Traveler to be approved and made available as a CLIIP TSTF. The following sections of the Traveler are affected: Description (Section 1.0); Proposed Change (Section 2.0); Background (Section 3.0); Technical Analysis (Section 4.0) References (Section 7.0); and the Traveler Bases for each of the vendor NUREGs (NUREGs 1430-1434).
To assist you in responding to the scope of comments included in the comprehensive review, Enclosures 2 through 6 contain the NRC staff comments using the MS-Word Reviewer format for text additions and deletions. The changes in these enclosures emphasize consistent use and application of terminology and content of the Bases to ensure the regulatory requirements in the application of the setpoint methodology for LSSS are clarified in each of the NUREGs.
The TSTF must notify the NRC, in writing, if it requires longer than 90 days to respond to this request. If the TSTF does not respond in 90 days, and does not request an extension, the NRC staff may terminate review of TSTF-493.
TSTF If you have any questions related to this issue or action please contact Carl Schulten at (301) 415-1192 or e-mail css1@nrc.gov.
Sincerely,
/RA/
Timothy J. Kobetz, Chief Technical Specifications Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation cc: See next page
Enclosures:
As stated
ML072050146 PACKAGE NO. ML072070202 OFFICE ITSB:DIRS EICB:DE ITSB:DIRS NAME CSchulten WKemper TJKobetz DATE 7/24/07 7/24/07 7/25/07
Technical Specifications Task Force Mailing List cc:
Technical Specifications Task Force 11921 Rockville, Pike Suite 100 Rockville, MD 20852 tstf@excelservices.com George G. Yates AmerenUE Callaway Plant Junction Hwy. CC and Hwy. O Mail Code CA-460 P.O. Box 620 Fulton, MO 65251 gyates@ameren.com John Messina First Energy Nuclear Operating Company 76 South Main Street Mail Stop: Akron-GO-14 Akron, OH 44308 jmessina@firstenergycorp.com David Bice Entergy N-GSB64 Russellville, AR 72802 dbice@entergy.com Reene V. Gambrell Duke Energy Mailcode: ON03RC 7800 Rochester Highway Seneca, SC 29672 RVGambrell@duke-energy.com Donald R. Hoffman EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 donaldh@excelservices.com Brian Mann EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 brianm@excelservices.com Jim Kenny 924 Liberty Street Emmaus, PA 18049 jken@ptd.net TSTF-493 Traveler Requests for Information 1.
Identify the screening criteria used by the TSTF for deciding whether a BWR Technical Specifications (TS) Instrumentation Function is a Safety Limit related (SL-related) or non-Safety Limit (non-SL) related Limiting Safety System Settings (LSSS). For example, BWR/4 and BWR/6 instrument functions for Drywell Pressure High, Suppression Pool Water Level High and Reactor Vessel Water Level -Low Low Low are not denoted as SL-related LSSS and no justification is included in the TSTF for this determination.
2.
For each instrument function not labeled as a SL-LSSS, revise the Bases for the instrument function to include the justification for the determination. For setpoint verification surveillance tests conducted on these functions, also revise these surveillance test Bases to include performance-based acceptance criteria (similar to the Notes 1 & 2 for SL LSSS) to ensure the agreement concepts for TS non-SL LSSS safety-related instrument setpoints and allowable values are addressed. The agreement concepts referred to are those in the Nuclear Energy Institute (NEI) letter to Mr. James Lyons (NRC) from Alexander Marion (NEI) dated May 18, 2005 and the NRC letter response to Mr. Alexander Marion (NEI) from Mr. Bruce Boger, dated August 23, 2005.
3.
Correct the TSTF definition of SL-LSSS by deleting the word directly to be consistent with the requirements of 10 CFR 50.36 which specify SL LSSS as variables on which a SL has been placed. The TSTF definition must be consistent with regulatory requirements. The TSTF justification states that Notes 1 and 2 are applied to Functions which are Safety Limit Limiting Safety System Settings (SL-LSSS), considering the following definition of SL-LSSS:
Trip Setpoints for Functions which provide automatic trips that directly (emphasis added) protect against violating the Reactor core and the Reactor Coolant System (RCS) pressure boundary Safety Limits during anticipated operational occurrences (AOOs) are Safety Limit Limiting Safety System Settings (SL-LSSS).
4.
Revise the TSTF Bases Reviewers Note 3 as (changes shown in comparative text format) follows:
Notes [1] and [2] are not applied may not apply to SL-LSSS Functions and Surveillances which test only digital components. For purely digital components, (such as actuation logic and associated relays) there is no expected change in result between surveillance performances other than measurement and test errors (M&TE) and therefore, justification is needed to confirm that comparison of Surveillance results does not provide an indication of channel or component performance.
The NRC staff has issued license amendments that include modified versions of Notes 1 and 2 for Surveillances which test digital components. Similarly, the
TSTF guidance should not categorically exclude applying the notes to digital components.
5.
Include a second version (Option B) to TSTF-493, Revision 2. The format and content of Option B should be modeled after the Section 3.3 Instrumentation TS in ESBWR Design Control Document, Tier 2, Chapter 16, Technical Specifications and Bases dated 12/15/2006, ADAMS Accession Numbers ML070110098 and ML070110101, respectfully.
For this option, the TS instrument table Allowable Values are replaced with Analytical Limits for Safety Limit (SL) Limiting Safety System Settings (LSSS) and with Design Limits for non-SL LSSS. Also for this option, a Setpoint Control Program (SCP) is added to the programmatic requirements in Section 5.0, Administrative Controls. The SCP contains the TSTF Table notes 1 and 2, references to the NRC staff SE containing the approved setpoint methodology, identifies the licensee controlled document that contains the SL-LSSSs, Limiting Trip Setpoint, Nominal Trip Setpoint, Allowable Values, As-found tolerance band, and As-left setting tolerance. Each instrument surveillance requirement which verifies a LSSS (both SL and non-SL LSSSs) contains a requirement to perform the surveillance test in accordance with the SCP.
6.
Incorporate the comments on the TSTF Justification provided in Enclosure 2.
7.
Incorporate the comments of the TSTF Bases provided in Enclosures 3 through 6.
8.
Delete Appendix A, TSTF 493 History in its entirety. TSTF Appendix A contains references to non-NRC staff (i.e., TSTF) meeting notes and summaries related to the development of industry and NRC staff agreements that resulted in TSTF-493, Rev. 2.
TSTF-493 Justification ADAMS ACCESSION NUMBER:
ML072070251 TSTF-493 BWOG Bases ADAMS ACCESSION NUMBERS:
3a-ML0702070260 3b - ML0702070269 TSTF-493 BWROG Bases ADAMS ACCESSION NUMBERS:
4a - ML072070355 4b - ML072070358 4c - ML072120059 4d - ML072120076 4e - ML072120083 4f - ML072120091 4g - ML072120096 4h - ML072120100 4i - ML072120105 4j - ML0721210111 4k - ML072120119 TSTF-493 CEOG Bases ADAMS ACCESSION NUMBERS:
5a - ML072120145 5b - ML072120153 5c - ML072120162 5d - ML072120164 TSTF-493 WOG Bases ADAMS ACCESSION NUMBERS:
6a - ML072120165 6b - ML072120168