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MONTHYEARML24262A1132024-09-18018 September 2024
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2024-09-18
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U.S. Nuclear Regulatory Commission Staff Disposition of Comments to May 4, 2010 (75 FR 23822), Federal Register Notice, Notice of Opportunity for Public Comment on the Proposed Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-500, 'DC Electrical Rewrite - Update to TSTF-360' The U.S. Nuclear Regulatory Commission (NRC) staff evaluated the public comments received on the model application and safety evaluation (SE) published in the Federal Register on May 4, 2010 (75 FR 23822). The comments were received from the Technical Specifications Task Force (TSTF) on June 2, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML101550255). The comments and the NRC staff disposition of each comment are as follows.
Comments on the Proposed Model Application:
The TSTF recommended in the comment cover letter and the enclosure that NRC staff rewrite the model application using the model application provided by the TSTF in the November 5, 2008, submittal of TSTF-500, Revision 1 (ADAMS Accession No. ML083110123). Specifically the TSTF stated that the model application is inconsistent with the draft Safety Evaluation Disposition:
NRC staff reviewed the model application submitted as part of TSTF-500, Revision 1, and comments made in the enclosure regarding the short comings of the proposed model application. The NRC staff agrees with the TSTFs comments that the proposed model application was inconsistent with the proposed draft SE. The NRC staff has rewritten the model application to address the inconsistencies and incorporated applicable parts from the TSTF-prepared model application.
Comments on the No Significant Hazards Consideration Determination
- 1. To facilitate plant-specific publication in the Federal Register of the No Significant Hazards Consideration Determination, all acronyms should be defined. We recommend the response to Question 1 be revised to define "TS" and "FSAR."
Disposition:
NRC staff agrees with this comment. Question 1 is revised to define TS (Technical Specifications) and FSAR (Final Safety Analysis Report).
- 2. In response to Question 1, second paragraph, the proposed determination states, "The integrity of fission product barriers, plant configuration, and operating procedures as described in FSAR [insert appropriate chapter/section number] will not be affected by the proposed changes." The description of "fission product barriers, plant configuration, and operating procedures," encompasses a large fraction of the FSAR content and it is impractical and unnecessary to reference every location in the FSAR that contains this information. We recommend that the bracketed phrase be removed.
Disposition:
NRC staff agrees with this comment. The bracketed phrase is removed.
Comments on the Proposed Model Safety Evaluation
- 1. Section 2.0, "Regulatory Evaluation," references Station Blackout, 10 CFR
[Title 10 of the Code of Federal Regulations] 50.63(a)(1). Station Blackout is not part of the "specified safety functions" required for battery operability under the Technical Specifications. Therefore, this reference is not relevant to the proposed TS change and should be removed.
Disposition:
NRC staff agrees that reference to Station Blackout, 10 CFR 50.63(a)(1) is not pertinent to TSTF-500. The reference to Station Blackout and 10 CFR 50.63 has been deleted from Section 2.0, Regulatory Evaluation.
- 2. Section 2.0, "Regulatory Evaluation," and Section 5.0, "References," refer to Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis,"
and Regulatory Guide 1.177, "An approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications." These references are only applicable if the licensee is proposing a CT [completion time] longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for Specifications 3.8.4, Required Action A.3, and 3.8.5, Required Action A.3, or a CT longer than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for Specification 3.8.4, Required Action B.1 and C.1.
These references should be bracketed with a Reviewer's Note describing when they are applicable.
Disposition:
NRC staff agrees with the comment. A bracketed reviewer note was added describing the applicability of Regulatory Guides 1.174 and 1.177.