ML110660285

Implementation of Travelers TSTF-363, Revision 0, Revise Topical Report References in Its 5.6.5, COLR (Core Operating Limits Report), TSTF-408, Revision 1, Relocation of LTOP (Low-Temperature Overpressure Protection) Enable Temperature.

ML110660285
Person / Time
Site:	Technical Specifications Task Force
Issue date:	08/04/2011
From:	John Jolicoeur NRC/NRR/DPR/PSPB
To:	Technical Specifications Task Force
References
Download: ML110660285 (5)

Text

August 4, 2011 Technical Specifications Task Force (TSTF) 11921 Rockville Pike, Suite 100 Rockville, MD 20852

SUBJECT:

IMPLEMENTATION OF TRAVELERS TSTF-363, REVISION 0, REVISE TOPICAL REPORT REFERENCES IN ITS 5.6.5, COLR [CORE OPERATING LIMITS REPORT], TSTF-408, REVISION 1, RELOCATION OF LTOP [LOW-TEMPERATURE OVERPRESSURE PROTECTION] ENABLE TEMPERATURE AND PORV [POWER-OPERATED RELIEF VALVE] LIFT SETTING TO THE PTLR [PRESSURE-TEMPERATURE LIMITS REPORT], AND TSTF-419, REVISION 0, REVISE PTLR DEFINITION AND REFERENCES IN ISTS

[IMPROVED STANDARD TECHNICAL SPECIFICATION] 5.6.6, RCS

[REACTOR COOLANT SYSTEM] PTLR

Dear Members of the TSTF:

The purpose of this letter is to inform you of the U.S. Nuclear Regulatory Commission (NRC) staffs plan for resolving issues related to the subject travelers. The NRC staff previously communicated concerns to you via letters dated November 2 and December 11, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML092151016 and ML093100498). Additionally, the plan outlined in this letter was discussed with you during a public meeting on February 9, 2011 (meeting summary is available in ADAMS at Accession No. ML110560630).

The NRC staff will no longer accept license amendment requests (LARs) to implement technical specification (TS) changes in accordance with Traveler TSTF-363. The standard TS (STS) in NUREGs-1430, -1431, -1432, -1433, and -1434 will be revised in Revision 4 to reflect the TS the way they were prior to approval of TSTF-363.

The NRC staff will continue to accept LARs to implement the TS changes in accordance with Travelers TSTF-408 and TSTF-419 with modification. Currently the STS show the full topical report or methodology citation as located in the PTLR. In order for NRC staff to approve LARs for these two travelers, the full topical report or methodology citation will need to be included in the TS, not in the PTLR. The STS in NUREGs-1430, -1431, -1432, -1433, and -1434 will be revised in Revision 4 to reflect this change.

The NRC staff understands that the inclusion of topical report or methodology citations in the COLR and PTLR afforded the industry flexibility and reduced the need for LARs associated with updated topical reports used during refueling. The NRC staff is willing to consider alternatives to the inclusion of the full citation in the TS, so long as the alternatives support the NRC staffs ability to protect the health and safety of the public and environment. However, until a mutually agreed upon alternative can be reached and approved, the full citations will need to be included in the TS for the reasons discussed below.

Maintaining a list of the methodologies in the TSs requires licensees to obtain NRC approval prior to editing the reference list. Among others, one reason that NRC approval is required prior

TSTF to editing the reference list is so that the NRC staff can review the methodology and ensure that it is applicable to the facility of a given licensee. Additionally, the NRC staff can verify that the licensee has properly satisfied all implementation conditions and limitations associated with a given methodology. Because there is no inherent requirement to ensure that the implementation conditions and limitations associated with methodology revisions are maintained the same as previous revisions to the same methodology, or that the applicability of subsequent methodology revisions remains the same as earlier methodologies, the NRC staff finds that affording licensees the administrative flexibility to transition between or among methodology revisions is inappropriate.

The NRC staff does not intend to backfit licensees that have these travelers already in their TS.

There is not a substantial increase in the overall protection of the public health and safety to be derived from backfitting licensees that have already adopted these travelers. A desire for additional clarity in the safety analysis is not indicative of an immediate safety concern.

Therefore, backfitting would not be justified under Title 10 of the Code of Federal Regulations Section 50.109 because the safety benefit is not supported by the financial costs. As a result, these changes will not impact plants that already have TSTF-363, or previous versions of TSTF-408 or TSTF-419, approved and implemented in their plant-specific TS.

As discussed during the February 9, 2011, meeting with the TSTF, this situation is irregular in that the NRC staff has never changed the STS NUREGs without that change being made as a result of a traveler. Therefore, we agreed to provide an opportunity for the TSTF to submit travelers to make these changes to the STS. The travelers would need to be submitted in a timely fashion to allow for them to be used as part of the STS Revision 4 which is currently in process.

If you have any questions, please contact Michelle 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

ML110660285 OFFICE PLPB/PM PLPB/LA ITSB/BC SRXB/BC NAME MHoncharik DBaxley RElliott AUlses DATE 3/11/11 3/10/11 3/18/11 3/24/11 OFFICE OGC PLPB/BC NAME MSmith JJolicoeur DATE 4/20/11 8/4/11 DISTRIBUTION for letter to TSTF dated August 4, 2011 :

PUBLIC PLPB Reading File RidsNrrAdro Resource RidsNrrDpr Resource RidsOgcMailCenter Resource RidsOpaMail Resource RidsAcrsAcnwMailCenterResource RidsNrrPMMHoncharik RidsNrrLADBaxley RidsNrrPlpbResource RidsNrrItsbResource RidsNrrSrxbResource Ulses, Anthony Chernoff, Harold Hughey, John Parks, Benjamin Grover, Ravinder

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