ML091740042

Requested Revision of Risk-Informed End States in Standard Technical Specifications

ML091740042
Person / Time
Site:	Technical Specifications Task Force
Issue date:	07/13/2009
From:	Boger B NRC/NRR/ADRO
To:	Technical Specifications Task Force
References
Download: ML091740042 (4)

Text

July 13, 2009 Technical Specifications Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852

SUBJECT:

REQUESTED REVISION OF RISK-INFORMED END STATES IN STANDARD TECHNICAL SPECIFICATIONS

Dear Members:

This letter requests that the Technical Specifications Task Force (TSTF) prepare and submit revisions to the Standard Technical Specifications (STS). The U.S. Nuclear Regulatory Commission (NRC) staff plans to use these revisions to address a potential safety issue identified during plant-specific reviews. The staffs review efforts will be conducted on a fee exempt basis, in accordance with Title 10 of the Code of Federal Regulations (10 CFR)

Section 170.11(a)(1)(ii). The basis for this request is described below.

Risk-Informed Technical Specification (RITS) Initiative 1, Technical Specification Actions End States Modifications, proposes to modify the Technical Specifications (TS) to permit a licensee to remain in hot shutdown rather than cold shutdown while repairing equipment for selected systems. When TS direct a reduction in reactor power to a lower Mode, the lower Mode is referred to as an End State.

The NRC staff approved TSTF-423, Technical Specification End States, NEDC-32998-A, For BWR [boiling water reactor] Plants, on March 26, 2006. TSTF-423 implements RITS Initiative 1 for the BWR STS, NUREGs-1433 and -1434, modifying the Required Actions of approximately twenty TSs to allow a plant to remain in Mode 3 (Hot Shutdown) to complete repairs instead of proceeding to Mode 4 (Cold Shutdown) when a licensee is unable to restore an inoperable system or component within the TS Completion Time. The intent of the change in end state is to allow the plant personnel to repair the inoperable equipment as quickly as possible, and then proceed back up into a higher Mode. A similar change for Combustion Engineering pressurized water reactors (PWRs), TSTF-422, Risk-Informed End States For CEOG [Combustion Engineering Owners Group], was approved on July 5, 2005. The staff is also reviewing TSTF-431, Risk-Informed Justification For LCO [limiting condition for operation] End-State Changes for Babcock & Wilcox Plants, which was submitted on November 2, 2006.

During its review of plant-specific license amendments requesting the adoption of TSTF-423, the staff discovered that revising the TS to allow licensees to remain in Mode 3 indefinitely with inoperable systems, would also permit a licensee to start up with inoperable systems using the allowance of LCO 3.0.4(a). This outcome is inconsistent with the intent of RITS Initiative 1 and most plant TS. Plant TS typically do not allow the use of LCO 3.0.4(a) to ascend in mode with these systems inoperable. LCO 3.0.4(a) does not require licensees to perform an evaluation of plant risk with inoperable equipment prior to commencing a reactor plant startup under such circumstances. Furthermore, the use of LCO 3.0.4(a) during startup with one of more of these systems inoperable has not been evaluated by the NRC staff. The use of LCO 3.0.4(a) could allow licensees to perform a startup without the lowest function capability or performance levels of equipment required for safe operation of the facility as required in 10 CFR 50.36(c)(2)(i).

Upon further review, the NRC staff discovered the same safety issue exists in TSTF-422 and TSTF-431.

The staff discussed the above concerns with members of the TSTF in a public meeting on January 9, 2009. Based on those discussions, the staff requests that the TSTF revise TSTF-422, TSTF-423, and TSTF-431 to prevent inappropriate use of LCO 3.0.4(a) during startup to go up in Mode with inoperable systems or equipment. These revisions would assist the staff in developing revisions to the STSs to address NRC identified safety concerns. The NRCs review of changes to these TSTF travelers will be exempt from NRC fees, in accordance with 10 CFR 170.11(a)(1)(ii).

NRC is required by law to recover 90% of its operating expenses through user fees. While the effort described in this letter is exempt from direct fee assessment, NRC resources expended to resolve these issues will be included in fees assessed in accordance with 10 CFR 171.

If you have any questions or need additional information regarding this request, please contact the TSTF Project Manager, Michelle Honcharik, (301)415-1774, or by electronic message to michelle.honcharik@nrc.gov.

Sincerely,

/RA by FBrown for/

Bruce A. Boger, Associate Director for Operating Reactor Oversight and Licensing Office of Nuclear Reactor Regulation cc: TSTF Members Project No. 753

Upon further review, the NRC staff discovered the same safety issue exists in TSTF-422 and TSTF-431.

The staff discussed the above concerns with members of the TSTF in a public meeting on January 9, 2009. Based on those discussions, the staff requests that the TSTF revise TSTF-422, TSTF-423, and TSTF-431 to prevent inappropriate use of LCO 3.0.4(a) during startup to go up in Mode with inoperable systems or equipment. These revisions would assist the staff in developing revisions to the STSs to address NRC identified safety concerns. The NRCs review of changes to these TSTF travelers will be exempt from NRC fees, in accordance with 10 CFR 170.11(a)(1)(ii).

NRC is required by law to recover 90% of its operating expenses through user fees. While the effort described in this letter is exempt from direct fee assessment, NRC resources expended to resolve these issues will be included in fees assessed in accordance with 10 CFR 171.

If you have any questions or need additional information regarding this request, please contact the TSTF Project Manager, Michelle Honcharik, (301)415-1774, or by electronic message to michelle.honcharik@nrc.gov.

Sincerely,

/RA by FBrown for/

Bruce A. Boger, Associate Director for Operating Reactor Oversight and Licensing Office of Nuclear Reactor Regulation cc: TSTF Members Project No. 753 DISTRIBUTION:

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DATE 06/ /09 06/26/09 06/4/09 06/8/09 06/10/09 7/13/09 OFFICIAL RECORD COPY

Technical Specifications Task Force Distribution Technical Specifications Task Force 11921 Rockville Pike Suite 100 Rockville, MD 20852 Attention: Donald Hoffman E-mail: donaldh@excelservices.com Kenneth Schrader Diablo Canyon Power Plant Building 104/5/21A P.O. Box 56 Avila Beach, CA 93424 E-mail: kjse@pge.com John Messina First Energy Nuclear Operating Company 76 South Main Street Mail Stop: Akron-GO-14 Akron, OH 44308 E-mail: jmessina@firstenergycorp.com Thomas Raidy Southern California Edison Mail Stop D-3-E P.O. Box 128 San Clemente, CA 92672 E-mail: Tom.Raidy@sce.com Wendy E. Croft Exelon Nuclear 200 Exelon Way, Suite 340 Kennett Square, PA 19348 E-mail: Wendi.Croft@exeloncorp.com Brian Mann EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 E-mail: brianm@excelservices.com