ML120200484
| ML120200484 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 03/07/2012 |
| From: | John Jolicoeur Licensing Processes Branch (DPR) |
| To: | |
| Honcharik M | |
| Shared Package | |
| ML120200485 | List: |
| References | |
| TSTF-505, Rev 0 | |
| Download: ML120200484 (4) | |
Text
U.S. Nuclear Regulatory Commission Staff Disposition of Comments to November 29, 2011 (76 FR 73737), Federal Register Notice, Notice of Opportunity for Public Comment on the Proposed Model Safety Evaluation for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4B The U.S. Nuclear Regulatory Commission (NRC) staff evaluated the public comments received on the proposed model safety evaluation (SE) published in the Federal Register on November 29, 2011 (76 FR 73737). Comments were received from Mr. Ted Woodruff on December 28, 2011 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML12004A075) and the Technical Specifications Task Force (TSTF) on December 28, 2011 (ADAMS Accession No. ML12006A204). The TSTFs and Mr. Woodruffs comments along with the NRC staff disposition of each comment are as follows.
Mr. Woodruff Comment:
The public has recieved judgements of billions of dollars in liabilities for injuries to nuclear workers from exposure and accidents. We are obligated to pay individual states for thier on going storage of nuclear waste. Ecosystems distroyed, trillions already in clean up cost with a new design being approved that has substantial concern as to its ultimate safety, We have to stop nuclear proliferation and hold government officials accountable for advocating for this industry. The population has been mis-led to believe that this is a safe and clean tecnology. It really is a criminal government propaganda crime. Stop, before more activists around the world are put in prisons, or there is a major melt down here. This whole situation is insanity, as I've watched the NRC exposed as working for this industry and a number of congressman who advocate for them. Crimes against humanity NRC disposition:
No changes were made to the SE, because the comment did not request any changes.
TSTF Comment 1:
Section 3.4 of the model Safety Evaluation states:
[3.4 Evaluation of Plant-Specific Changes]
{NOTE: Under certain conditions specified in NEI 06-09 it is acceptable to operate for short periods of time with all trains of equipment, which are required by a TS LCO, inoperable, provided that one or more trains are considered to be PRA functional. The number and identity of instrumentation and control (I&C) channels (or functions) required to be PRA [probabilistic risk assessment]
functional is highly dependent on the specific plant and associated equipment design. Since NEI [Nuclear Energy Institute] 06-09 did not address the required actions related to I&C, licensees choosing to adopt these specific changes may need to provide plant-specific implementation guidance for NRC staff review. If
these changes were included in the LAR [license amendment request], insert NRC staff technical evaluation here. Be sure to modify Regulatory Evaluation Section and Conclusions Section appropriately.}
The section is unnecessary and misleading and should be eliminated.
- a. This additional requirement to provide plant-specific I&C implementation guidance for NRC staff review is unnecessary as it already exists for all proposed changes to the Technical Specifications, including those related to I&C:
- Enclosure 1 of the model application requires licensees to list each TS Required Action to which the Risk Informed Completion Time (RICT) Program may be applied and, for each Required Action, describe the corresponding structure, system, or component (SSC) and the associated function modeled in the Probabilistic Risk Assessment (PRA), and
- Enclosure 10 of the model application requires a licensees to provide a description of the implementing programs and procedures regarding the plant staff responsibilities for the RICT Program implementation.
- b. The section is misleading and incorrectly implies that I&C requirements are somehow unique and should be treated differently than other systems. This is not consistent with NEI 06-09, "Risk-Informed Technical Specifications Initiative 4B, Risk-Managed Technical Specifications (RMTS) Guidelines:
- The proposed Required Actions that are applicable when all trains of equipment are inoperable provided that one or more trains are considered to be PRA functional are no more or less plant-specific than any other changes proposed by TSTF-505 or that will be proposed by a licensee adopting TSTF-505.
- NEI 06-09 does not discuss system-specific aspects of any structures, systems, or components and recognizes that all evaluations of RICT and PRA functionality are highly dependent on the specific plant and equipment design.
Requirements associated with I&C are treated no differently under NEI 06-09 than other systems.
In summary, the paragraph implies a weakness in NEI 06-09 when none exists and the need for additional information to be
provided by the licensee when none is needed. The section should be removed.
NRC Disposition:
The NRC staff agrees this section could be misleading. The NRC staff requests that the following be added to Enclosure 1 of the Model Application:
This enclosure should provide a description of PRA functionality for each associated specified safety function that corresponds to each proposed Required Action that is applicable when all trains of equipment are inoperable as discussed in Section 2.3.1.10 of NEI 06-09. For example, the number and identity of instrumentation and control channels (or functions) required to be PRA functional is highly dependent on the specific plant and associated equipment design.
Additionally, the NRC staff has revised the Section 3.4 of the model SE to state:
{NOTE: If plant-specific changes were included in the LAR, insert NRC staff technical evaluation here. Be sure to modify Regulatory Evaluation Section appropriately.}
TSTF Comment 2:
The TSTF suggests the following editorial improvements:
- a. The use of NEI 06-09 is required by the proposed Technical Specifications RICT Program. Therefore, it is not correct to refer to a commitment to NEI 06-09, as the term commitment has a specific regulatory meaning that is not applicable in this circumstance. In the model Safety Evaluation, Section 3.2.4.1.6, Page 14, the following sentence should be revised as shown by removing the words that have been struck through and inserting the word in italics:
"The licensee has committed to incorporated NEI 06-09, Revision 0, in the RICT Program of TS [5.5.18], and therefore calculates the RICT consistently with its criteria, and assesses the RICT Program to assure any risk increases are small per the guidance of RG 1.174."
- b. Not all of the new Conditions and Required Actions which permit application of a RICT when multiple trains are inoperable currently require entry into LCO [limiting condition for operation] 3.0.3. Therefore, in the model Safety Evaluation, Section 3.1, Page 7, last paragraph, the following sentence should be revised as shown by the inserted word in italics:
"Under the existing TS, such configurations would typically result in applicability of LCO 3.0.3 and an immediate reactor shutdown."
- c. NEI 06-09, Revision 0, Section 2.3.1, Step 11, makes clear that the concept of PRA functionality can be applied and a Risk Informed Completion Time (RICT) can be calculated when a single train or subsystem of a structure, system, or component can be shown to have PRA functionality. Therefore, in the model Safety Evaluation, Section 3.1, Page 7, last paragraph, the following sentence should be clarified as shown by the inserted word in italics:
"In accordance with NEI 06-09, the use of a RICT when all trains of a TS system are inoperable is restricted to conditions in which at least one train of the TS system retains PRA functionality and the CRMP can discern which TS functions are available and which are failed due to the inoperability."
NRC disposition:
The NRC staff agrees that the recommendations are editorial improvements and the changes have been incorporated as requested.