ML103420584
| ML103420584 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 03/07/2011 |
| From: | John Jolicoeur Division of Policy and Rulemaking |
| To: | Technical Specifications Task Force |
| Bucholtz, Kristy, NRR, 415-1295 | |
| References | |
| TAC ME4809 | |
| Download: ML103420584 (3) | |
Text
March 7, 2011 Technical Specifications Task Force (TSTF) 11921 Rockville Pike Suite 100 Rockville, MD 20852
SUBJECT:
REQUEST FOR THE REVIEW OF TRAVELER TSTF-525, REVISION 0, POST ACCIDENT MONITIORING [(PAM)] INSTRUMENTATION REQUIREMENTS (WCAP-15981-NP-A) (TAC NO. ME4809)
Dear Members of the TSTF:
On August 30, 2010 (Agencywide Documents Access Management System (ADAMS)
Accession number ML102510337), the TSTF submitted Traveler TSTF-525, Revision 0, Post Accident Monitoring Instrumentation Requirements (WCAP-15981-NP-A), to the U.S. Nuclear Regulatory Commission (NRC) staff for review. We have conducted our review, including all supporting information provided with your application, to evaluate the new staff positions that would result from incorporating TSTF-525 changes in Standard Technical Specifications (STS)
NUREG-1431, Revision 3.0, Standard Technical Specifications Westinghouse Plants. As discussed during a telephone call on February 2, 2011, the NRC staff has concluded that TSTF-525 is not acceptable for review for the reasons detailed below.
TSTF-525 proposes changes to NUREG-1431 based on the technical justification in approved Topical Report (TR) WCAP-15981-NP-A, Post Accident Monitoring Instrumentation Re-Definition for Westinghouse NSSS [Nuclear Steam Supply System] Plants (ADAMS Accession number ML042660254). TR WCAP-15981-NP was submitted for NRC review on September 17, 2004, and was approved as documented in final safety evaluation (SE) dated February 28, 2008 (ADAMS Accession number ML080380379).
Specifically, TSTF-525 proposes to (1) allow the use of alternate instrumentation in NUREG-1431 STS 3.3.3, Post Accident Monitoring Instrumentation, (2) revise the generic list of PAM instrumentation on STS Table 3.3.3-1, (3) delete the Condition referenced from Required Action D.1 column from STS Table 3.3.3-1, (4) revise STS 3.3.3 Conditions D and E, and (5) delete STS 3.3.3 Condition F.
In regard to proposed change (1), TSTF-525 states, Therefore, additional justification for the use of the alternate PAM instrumentation identified in WCAP-15981-NP-A is provided to support plant specific implementation of alternate instrumentation. Specifically, TSTF-525 proposes to allow the use of alternate indications for the power range neutron flux, high head safety injection (SI) flow, containment area radiation (high range), steam generator water level (wide range), and auxiliary feedwater flow.
The NRC staff has reviewed the additional justification provided and determined it is not sufficient to begin review of the traveler. Although TSTF-525 provides generic discussion to justify and support licensees that would use alternate instrumentation, it does not provide sufficient information on the qualification of the proposed alternate instrumentation for the NRC staff to revise or modify our previous conclusion. The NRC staffs position, as stated in the final
TSTF SE for WCAP-15981-NP, is that (1) alternate instrumentation should meet the same Regulatory Guide (RG) 1.97, Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants, category as the primary instrumentation, and (2) the use of alternate instrumentation will not be considered on a generic basis. The NRC staff still believes that it is not appropriate to consider the use of alternate instrumentation on a generic basis, and TSTF-525 proposes a generic modification to NUREG-1431. If generic approval of the alternate PAM instrumentation is desired, then the PWROG may submit additional information to supplement or revise the TR WCAP-15981-NP-A. Therefore, the NRC staff will not review this proposed request.
In regard to proposed change (2), STS 3.3.3 for NUREG-1431 contains a generic list of PAM instruments for Westinghouse NSSS plants, and also contains a Reviewers Note which states that the PAM TS should include all of the plant-specific RG 1.97 Type A instrumentation and Category 1 instrumentation. During a September 20, 2007, NRC public meeting on WCAP-15981-NP (meeting summary in ADAMS at Accession number ML072750513), the NRC staff informed the Pressurized Water Reactor Owners Group (PWROG) that revising the list of PAM instrumentation in Table 3.3.3-1 of STS 3.3.3 was unacceptable because it could be misinterpreted by plants that do not plan to apply TR WCAP-15981-NP. The PWROG clarified that instead of proposing a revision to the generic list of PAM instrumentation on Table 3.3.3-1, it would propose that an additional Reviewers Note in STS Section 3.3.3 be added that would provide licensees with an option of revising their plant-specific PAM table to reflect the PAM instrumentation that satisfies Criteria 3 and/or 4 of Title 10 of the Code of Federal Regulations Section 50.36 based on the methodology contained in TR WCAP-15981. Contrary to this, TSTF-525 proposes to revise the list of PAM instrumentation and delete the Reviewers Note reference to RG 1.97 for Type A and Category 1 Non-Type A instruments in STS Table 3.3.3-1.
TSTF-525 states, The technical justification for the content of proposed Table 3.3.3-1 (selected instrument Functions and number of required Channels) is contained in WCAP-15981-NP-A.
However, based on the above discussion, the NRC staff does not believe TSTF-525 is consistent with Table 3.3.3-1 of TR WCAP-15981-NP-A. The NRC staff is not in agreement with a revised generic list of PAM instrumentation or the removal of the Reviewers Note that addresses RG 1.97, as documented in the final SE of TR WCAP-15981-NP.
In regard to proposed changes (3), (4), and (5), TSTF-525 also proposes to delete the Condition referenced from Required Action D.1 column from STS Table 3.3.3-1, revise Conditions D and E, and delete Condition F. In addition, a note is added to revised Conditions D and E. The added note to Condition D would allow the use of alternate indications for the power range neutron flux, high head SI flow, containment area radiation (high range),
steam generator water level (wide range), and auxiliary feedwater flow on a generic basis. As stated above the NRC staff does not consider it appropriate to consider the use of alternate instrumentation on a generic basis. Therefore, the use of instruments as alternates will be reviewed only on a plant-specific basis.
In summary, the NRC staff has determined that review of the above proposed changes would be a repetition of the review of WCAP-15981-NP. Since no new and/or sufficient technical justification for the changes was provided, the NRC staff position described in its SE of TR WCAP-15981-NP stands. Therefore, your request for the review of TSTF-525 is not accepted.
TSTF If you have questions, please contact Michelle C. Honcharik at (301) 415-1774 or michelle.honcharik@nrc.gov.
Sincerely,
/RA/
John R. Jolicoeur, Chief Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 753 cc: See next page
TSTF If you have questions, please contact Michelle C. Honcharik at (301) 415-1774 or michelle.honcharik@nrc.gov.
Sincerely,
/RA/
John R. Jolicoeur, Chief Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 753 cc: See next page Distribution:
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Technical Specifications Task Force Project No. 753 cc:
Technical Specifications Task Force 11921 Rockville Pike Suite 100 Rockville, MD 20852 Attention: Donald R. Hoffman E-mail: donaldh@excelservices.com Norman J. (Jack) Stringfellow Southern Nuclear Operating Company P.O. Box 1295 Birmingham, AL 35201-1295 E-mail: string@southernco.com Roy A. (Tony) Browning Duane Arnold Energy Center 3277 DAEC Rd.
PSC/Licensing Palo, IA 52324-9785 E-mail: tony.browning@nexteraenergy.com William J. (Billy) Steelman Entergy Waterford 3 17265 River Road Hwy 18 Killona, LA 70057 E-mail: wsteelm@energy.com Wendy E. Croft Exelon Nuclear 200 Exelon Way, Suite 340 Kennett Square, PA 19348 E-mail: wendi.croft@exeloncorp.com Brian D. Mann EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 E-mail: brianm@excelservices.com