ML102700373
| ML102700373 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 02/02/2011 |
| From: | John Jolicoeur Division of Policy and Rulemaking |
| To: | |
| Honcharik M, NRR/DPR/PSPB, 415-1774 | |
| Shared Package | |
| ML102920619 | List: |
| References | |
| Download: ML102700373 (3) | |
Text
NRC Staff Disposition of Comments to December 14, 2005 (70 FR 74037), Federal Register Notice, Notice of Opportunity To Comment on Model Safety Evaluation on Technical Specification Improvement for Boiling Water Reactor Plants; to Risk-Inform Requirements Regarding Selected Required Action End States Using the Consolidated Line Item Improvement Process
{NOTE: No changes are made in this revised Notice of Availability (NOA) to the Nuclear Regulatory Commission (NRC) disposition of industrys comments as published in the Federal Register on March 23, 2006 (71 FR 14726-14745). The disposition of comments is simply restated here, for completeness.}
The NRC staff evaluated the public comments received on the model Safety Evaluation (SE),
model no significant hazards consideration (NSHC) determination, and model license amendment request (LAR) published in the Federal Register on December 14, 2005 (70 FR 74037). The comments were received from the Technical Specifications Task Force (TSTF) on January 13, 2006 (ADAMS Accession No. ML060130291). The comments and the NRC staff disposition of each comment are as follows.
Comment 1:
We commend the staff for adopting a draft Safety Evaluation format that simplifies the application of the model Safety Evaluation for TSTF-423 to individual licensees. For example, providing blanks for plant name, operating license number, etc. We encourage the staff to follow this example for future CLIIP model Safety Evaluations.
Disposition:
The NRC staff acknowledges the comment; no action taken.
Comment 2:
The "Applicability" portion of the notice states that each licensee applying for the changes proposed in TSTF-423 should include Bases for the proposed Technical Specifications (TS) consistent with the Bases proposed in TSTF-423. We request that the section be revised to not require licensees to submit Bases changes. The Bases changes in TSTF-423 are not integral to the change and both licensee and NRC resources could be saved by allowing licensees to adopt the necessary Bases changes using the Technical Specifications Bases Control Program. As a precedent, the CLIIP for TSTF-460 (Notice of Availability published in the Federal Register on August 23, 2004) allowed licensees to commit to updating their TS Bases under the TS Bases Control Program instead of requiring licensees to submit their Bases changes for NRC review. We propose that the TSTF-423 CLIIP take a similar approach.
Disposition:
The NRC staff does not agree with the comment. The associated TS Bases changes are an essential and integral element of the change, must be consistent with the Bases in TSTF-423, and should be submitted by the licensees with the LAR for adoption of TSTF-423.
Comment 3:
Section 1.0 of the model Safety Evaluation, in the first paragraph, states that TSTF-423 was proposed by the Nuclear Energy Institute Risk Informed Technical Specification Task Force. That is incorrect. TSTF-423, Revision 0, was submitted by the Owners Group Technical Specifications Task Force in a letter to the NRC dated August 12, 2003.
Disposition:
The NRC staff agrees with the comment. The correction has been made.
Comment 4:
Section 1.0 of the model Safety Evaluation, the last sentence of section, states, "Short duration repairs are on the order of 2-to-3 days, but not more than a week."
We recommend replacing this sentence with the statement from the Implementation Guidance (TSTF-IG-05-02), which states, "A 'short duration' is envisioned to be the duration that boiling water reactors (BWRs) are most physically and practicably able to remain in the hot shutdown condition (i.e., from a few days to approximately one week)." This clarifies that the time frames are a statement of fact rather than a restriction which must be incorporated in plant operating controls.
Disposition:
The NRC staff does not agree with the comment. This issue was discussed thoroughly and the one week limit was determined appropriate. The one week limit is explicitly stated in the Implementation Guidance (Reference 8 to the SE) submitted by industry, agreed to by the NRC staff, and to which the licensees must commit. Section 1, Paragraph 6 of the Implementation Guidance (TSTF-IG-05-02) states, Any entry into Mode 3 using this TS allowance must be limited to no more than seven days. No action has been taken.
Comment 5:
In Section 3.2, "Assessment of TS Changes," of the model Safety Evaluation, each subsection is titled with the applicable Topical Report section number and the ITS LCO number. The abbreviation "TS" is used to indicate the Topical Report section number (e.g., "TS 4.5.1.2 and LCO 3.4.3 (BWR/4); TS 4.5.2.2 and LCO 3.4.4 (BWR/6), Safety/Relief Valves (SRVs)." The labels "4.5.1.2" and "4.5.2.2" are the Topical Report sections associated with these LCO changes.
These references also appear in the text of Section 3.2. This presentation is confusing as "TS" is defined in the model Safety Evaluation as "Technical
Specifications" and non-ITS plants have Technical Specification requirements with numbers similar to the Topical Report numbers. We recommend replacing this use of the abbreviation "TS" with either "Topical Report section" or defining another acronym, such as "TR."
Disposition:
The NRC staff agrees with the comment. The abbreviation for the Topical Report Section was poorly chosen, in that it was easily confused with the abbreviation for Technical Specification.
The Topical Report Section abbreviation has been changed to TRS.
Comment 6:
In Section 3.2.4 of the model Safety Evaluation, in the title and in the first paragraph, the LCO name "Low-Low Set Logic (LLS) Valves" is used. The word "logic" should not appear in the LCO name. The document should be revised to state "Low-Low Set (LLS) Valves."
Disposition:
The NRC staff agrees with the comment. The correction has been made.
Comment 7:
Section 5.0, "Environmental Consideration," of the model Safety Evaluation states that the amendments meet the eligibility criteria for categorical exclusion set forth in "10 CFR 51.22(c)(9) [and (c)(10)]." 10 CFR 51.22(c)(10) pertains to issuance of an amendment pursuant to "parts 30, 31, 32, 33, 34, 35, 36, 39, 40, 50, 60, 61, 70 or part 72 of this chapter which (i) changes surety, insurance and/or indemnity requirements, or (ii) changes recordkeeping, reporting, or administrative procedures or requirements." Paragraph (c)(10) is not applicable to this change and the reference should be deleted.
Disposition:
The NRC staff agrees with the comment. The correction has been made.
Comment 8:
Section 7.0, "References," of the model Safety Evaluation, Reference 1, states the date of NEDC-32988-A, Revision 2, as September 2005. The correct date of the document is December 2002.
Disposition:
The NRC staff agrees with the comment. The correction has been made.