ML101530401

Acceptance for Review and Request for Additional Information for TSTF-432, Revision 0, Change in Technical Specifications End States (WCAP-16294).

ML101530401
Person / Time
Site:	Technical Specifications Task Force
Issue date:	07/07/2010
From:	Barry Miller NRC/NRR/DPR/PSPB
To:	Technical Specifications Task Force
References
TAC ME3469, WCAP-16294
Download: ML101530401 (6)

Text

July 7, 2010 Technical Specifications Task Force (TSTF) 11921 Rockville Pike, Suite 100 Rockville, MD 20852

SUBJECT:

ACCEPTANCE FOR REVIEW AND REQUEST FOR ADDITIONAL INFORMATION FOR TRAVELER TSTF-432, REVISION 0, CHANGE IN TECHNICAL SPECIFICATIONS END STATES (WCAP-16294), (TAC NO.

ME3469)

Dear Members of the TSTF:

By letter dated December 22, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093570241), you submitted to the U.S. Nuclear Regulatory Commission (NRC) for review and approval Traveler TSTF-432, Revision 0, Change in Technical Specifications End States (WCAP-16294). Your submission noted that the review of this Traveler is exempt from review fees under 10 CFR Part 170 because it is a risk-informed Traveler. In accordance with the January 10, 2003 letter (ADAMS Accession No. ML030100090) from William D. Beckner (NRC) to Tony Pietrangelo (Nuclear Energy Institute), a fee waiver for this Traveler will apply.

The NRC staff has completed a preliminary review of your submission and determined it is sufficiently complete and appropriate to initiate a more comprehensive review.

Since completion of the preliminary acceptance review, the NRC staff has begun the comprehensive review and determined that additional information is needed to complete the comprehensive review. Enclosed is the NRC staffs request for additional information.

The TSTF-432, Revision 0, review schedule has been planned as shown in the table below. If circumstances should lead to anticipated or actual schedule slippage, the causing party should promptly notify and coordinate with the other party. Early completion of a milestone would not require further coordination.

MILESTONE SCHEDULE DATE Application 12/22/2009 Requests For Additional Information (RAIs) 7/15/2010 RAI Response from TSTF 8/16/2010 Issue Notice For Comment on Model Safety Evaluation 10/15/2010 and Model Application Issue Notice of Availability for Model Safety Evaluation and 2/15/2011 Model Application

TSTF Please contact me at 301-415-4117 or at Barry.Miller@nrc.gov if you have any questions.

Sincerely,

/RA/

Barry W. Miller, Senior Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 753

Enclosure:

As stated cc: See next page

TSTF 2 Please contact me at 301-415-4117 or at Barry.Miller@nrc.gov if you have any questions.

Sincerely,

/RA/

Barry W. Miller, Senior Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 753

Enclosure:

As stated cc: See next page DISTRIBUTION:

PLPB r/f NRR_Dirs_Itsb staff RidsNrrAdro RidsNrrDirsItsb RidsNrrDprPlpb RidsNrrDpr KBucholtz ADAMS ACCESSION NO: ML101530401 OFFIC LA:PLPB:DPR PM:PLPB:DPR BC:PLPB:DPR NAME EHylton BMiller JJolicoeur (TMensah for)

DATE 6 / 3 /10 7/6/10 7/7/10 OFFICIAL RECORD COPY

Technical Specifications Task Force Mailing List cc:

Technical Specifications Task Force Reene' V. Gambrell 11921 Rockville Pike Duke Energy Suite 100 Mailcode: ON03RC Attention: Donald Hoffman 7800 Rochester Highway Rockville, MD 20852 Seneca, SC 29672 Telephone: 301-984-4400 Telephone: 864-885-3364 E-mail: donaldh@excelservices.com E-mail: RVGambrell@duke-energy.com Kenneth Schrader Brian Mann Diablo Canyon Power Plant EXCEL Services Corporation Building 104/5/21A 11921 Rockville Pike, Suite 100 P.O. Box 56 Rockville, MD 20852 Avila Beach, CA 93424 Telephone: 301-984-4400 Telephone: 805-545-4328 E-mail: brianm@excelservices.com E-mail: kjse@pge.com Donald W. Gregoire Energy Northwest Columbia Generating Station Mail Drop PE20 PO Box 968 Richland, WA 99352-0968 Telephone: 509-377-8616 E-mail: dwgregoire@energy-northwest.com Thomas Raidy Southern California Edison Mail Stop D-3-E P.O. Box 128 San Clemente, CA 92672 Telephone: 949-368-7582 E-mail: Tom.Raidy@sce.com Wendy E. Croft Exelon Nuclear 200 Exelon Way, Suite 340 Kennett Square, PA 19348 Telephone: 610-765-5726 E-mail: Wendi.Croft@exeloncorp.com

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING TSTF-432, REVISION 0, CHANGE IN TECHNICAL SPECIFICATIONS END STATES (WCAP-16294), (TAC NO. ME3469)

The Technical Specifications Task Force (TSTF) proposed changes to the Standard Technical Specifications (STS) NUREG-1431, Standard Technical Specifications Westinghouse Plants, Revision 3.0. The proposed changes implement Risk-Informed Technical Specification Initiative 1, Technical Specifications Actions End States Modification in NUREG-1431. The NRC staff requests the following additional information from the TSTF to complete its review of the proposed Traveler TSTF-432.

Basis For Request for Additional Information #1 The NRCs final safety evaluation for Topical Report (TR) WCAP-16294-NP, Revision 0, Risk-Informed Evaluation to Technical Specification Required Endstates for Westinghouse Nuclear Steam Supply System Pressurized Water Reactors, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100770146) found the proposed revisions to the STS and Bases acceptable subject to the limitations and conditions shown in Section 4.0.

Section 4.0 states, Licensees requesting the TS changes to operate their plants in accordance with TR WCAP-16294-NP must include the following in the TS Bases to ensure that the implementation of this TR will be consistent with the NRC staffs evaluation:

1. The primary purpose for entry into Mode 4 end states is to accomplish short duration repairs to restore inoperable equipment.

2. The availability of the TDAFW pump is assured while the plant remains in Mode 4 in accordance with the assumption of the TR.

3. Operational procedures have been established to ensure long-term decay heat removal, should the SG cooling be lost while operating in Mode 4.

4. Include the NRC approved-TR as a reference in the TS Bases.

In the Submittal of TSTF-432, Revision 0, each Limiting Condition for Operation (LCO) with modified TS Required Action(s), to a new endstate of MODE 4, has a TS Bases reference to the NRC approved TR and the following paragraphs are added to the TS Bases Actions section:

Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. ). In MODE 4 there are two means ENCLOSURE

of decay heat removal, which provides diversity and defense in depth. However, voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

These proposed TS Bases changes meet item 4 of the limitation and conditions section in the NRCs final safety evaluation for TR WCAP-16294-NP.

A reviewers note is added to the TS Bases LCO section in the auxiliary feedwater (AFW) system, TS 3.7.5.

Reviewers notes are useful to NRC reviewers and are available to all licensees. However, the NRC staff has a couple of concerns with the reviewers note. The first concern is the statements, The requirement to maintain the TDAFW train available in order to remain in MODE 4 will be addressed by a licensing commitment to include a requirement that will be located in the Technical Specification Bases, a Licensee Controlled Document, or implementing procedures and The additional requirement to maintain the TDAFW train available in MODE 4 in accordance with WCAP-16294-NP-A, Rev. 1, may be included in this Bases or a reference to the location of this requirement (e.g., a specific location in the Technical Requirements Manual, other licensee controlled document, or the implementing procedure may be included in this Bases. The proposed statements in the reviewers note allow the licensee the option to place the requirement outside of the TS Bases, which is not consistent with the NRCs final safety evaluation. The NRCs final safety evaluation requires licensees requesting the TS changes to operate their plants in accordance with TR WCAP-16294-NP and must include in the TS Bases, the assurance of the Turbine Driven (TD) AFW pump availability while the plant remains in Mode 4.

The second concern is that the requirement is only being placed in the AFW system TS Bases and is not being placed in the TS Bases Actions section(s) for each modified required action. In order to utilize the Mode 4 endstate, a requirement must be established to maintain the TDAFW train available in MODE 4 and it is appropriate to place this requirement in the TS Bases Actions section(s) for each modified required action since it is applicable to each modified required action.

Request for Additional Information #1 Explain how the proposed TS Bases in Traveler TSTF-432 meet Section 4.0, Limitations and Conditions, items 1, 2 and 3 in the NRC staffs final safety evaluation for TR WCAP-16294-NP.