ML110420530

ITSB Resolution of Excel Services Corporation Proposed TSTF-426 Wording

ML110420530
Person / Time
Site:	Technical Specifications Task Force
Issue date:	02/09/2011
From:	Division of Policy and Rulemaking
To:
References
TSTF-426
Download: ML110420530 (2)

Text

ITSB Resolution of Excel Services Corporation Proposed TSTF-426 Wording Regulatory Analysis Technical specifications, at a minimum, must set forth the specific characteristics of the facility and the conditions for its operation that are required to provide adequate protection of the health and safety of the public. Specifically, § 50.36 requires the following:

Each license authorizing operation of a production or utilization facility of a type described in § 50.21 or §50.22 will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to § 50.34.

The Commission may include such additional technical specifications as the Commission finds appropriate.

WCAP-16125 Perspective The TR (WCAP-16125) is based [on] the analysis on the purpose of the Condition (corrective maintenance), not the circumstances for entering the Condition. There was no explicit assumption regarding voluntary entry or emergent conditions except for the infrequent use of the Condition. (emphasis added)

Excel TSTF-426 Proposal B. Two ICS trains B.1 Verify at least one train of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable due to unplanned containment spray is OPERABLE.

conditions.

AND B.2 Restore at least one ICS train to OPERABLE status.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> NRC Staff Safety Evaluation Findings The Safety Evaluation (SE) condition that states:

"All the changes are acceptable only assuming that appropriate TS notes are provided which assure that the loss of safety function action requirements are not applicable for operational convenience and that voluntary entry into these action requirements in lieu of other alternatives that would not result in redundant systems or components being inoperable are prohibited." (emphasis added)

February 9, 2011 Technical Specifications Branch, NRR

ITSB Resolution of Excel Services Corporation Proposed TSTF-426 Wording ITSB Staff Conclusion The NRC staff basis for approving TR WCAP-16125 is dependent on the circumstances for entering the Condition, and prohibits relying on required actions for loss of safety function conditions for any reason, including corrective maintenance.

Proposal

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NOTE---------------

The Condition, Required B.1 Verify at least one train of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Actions and associated containment spray is Completion Times are not OPERABLE.

applicable when the LCO is not AND met for one ICS train and a second ICS train is removed B.2 Restore at least one ICS 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from service intentionally for train to OPERABLE any reason. status.

B. Two ICS trains inoperable.

Bases for Required Action B.1 and B.2 would state:

B.1 and B.2 This Condition applies when the LCO is not met for one ICS train and a second ICS train is discovered to be in a degraded or nonconforming condition and the subsequent operability determination concludes the ICS train is inoperable. This condition is not applicable if a second ICS train is intentionally removed from service for operational convenience, or for reasons including but not limited to performing Surveillances, preventive maintenance, corrective maintenance or investigation of operational problems. At least one train of containment spray must be verified to be OPERABLE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to ensure radioactive releases from containment following an accident with the ICS trains not operable will be reduced by the operable containment spray train. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is based on the defense-in-depth provided by one train of the CS system, the low frequency of condition entry and potential challenge, and the small incremental risk associated with continued operation (Reference 4).

February 9, 2011 Technical Specifications Branch, NRR