ML12279A134
| ML12279A134 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 10/19/2012 |
| From: | Michelle Honcharik Licensing Processes Branch (DPR) |
| To: | Technical Specifications Task Force |
| Honcharik M | |
| References | |
| NEDC-33046, TAC ME8198, TSTF-454, Rev 2 | |
| Download: ML12279A134 (6) | |
Text
October 19, 2012 Technical Specifications Task Force (TSTF) 11921 Rockville Pike, Suite 100 Rockville, MD 20852
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RE: TRAVELER TSTF-454, REVISION 2, EXTEND PCIV COMPLETION TIMES (NEDC-33046).
Dear Members of the TSTF:
By letter dated February 22, 2012 (Agencywide Documents Access and Management System Accession No. ML12054A060), the TSTF submitted for U.S. Nuclear Regulatory Commission (NRC) staff review Traveler TSTF-454, Revision 2, Extend PCIV [Primary Containment Isolation Valve] Completion Times (NEDC-33046). Upon review of the information provided, the NRC staff has determined that additional information is needed to complete the review. On October 5, 2012, Brian Mann, Vice President of Industry Programs, EXCEL Services Corporation, and I agreed that the NRC staff will receive your response to the enclosed request for additional information (RAI) questions within 90 days of the date of this letter. If you have any questions regarding the enclosed RAI questions, please contact me at 301-415-1774 or via e-mail at Michelle.Honcharik@nrc.gov.
Sincerely,
/RA/
Michelle C. Honcharik, Sr. Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 753
Enclosure:
As stated cc w/encl: See next page
ML12279A134; *via memo (ML12251A391); **via memo (ML121670397)
NRR-106 OFFICE PLPB/PM PLPB/LA STSB/BC (A)
AADB/BC (A)
PLPB/BC (A)
PLPB/PM NAME MHoncharik DBaxley MHamm*
BBeasely**
SStuchell MHoncharik DATE 10/5/2012 10/16/2012 9/17/2012 8/1/2012 10/18/2012 10/19/2012
ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION TRAVELER TSTF-454, REVISION 2, EXTEND PCIV [PRIMARY CONTAINMENT ISOLATION VALVES] COMPLETION TIMES (NEDC-33046)
TECHNICAL SPECTIFICATIONS TASK FORCE (TSTF)
PROJECT NO. 753 The Traveler TSTF-454, Revision 2, proposes to revise the Standard Technical Specifications for boiling water reactors. Specifically, the Traveler proposes to revise Specification 3.6.1.3, Primary Containment Isolation Valves (PCIVs), to incorporate conditions and a commitment from the U.S. Nuclear Regulatory Commission (NRC) staffs safety evaluation of TSTF-454, Revision 1, published in the Federal Register on December 13, 2005 (70 FR 73802).
- 1. Traveler TSTF-454, Revision 2, assumes that the Topical Report (TR) NEDC-33046-A, dated January 20, 2005 (Agencywide Documents Access and Management System Accession No. ML050240360), provides a bounding analysis. The Traveler also assumes that the TRs supporting probabilistic risk analysis (PRA) is still applicable for current plant operation and design. Given that the TR was completed a number of years ago, discuss whether it still provides a bounding analysis, or if consideration of current plant operation and design would require updating the TR PRA to be used for this application. In addition, since generic unreliability and unavailability data can change over a long period of time, discuss whether containment isolation valve performance based on data since the completion of the TR is consistent with assumptions made in the supporting TR PRA.
Provide the basis for the conclusions.
- 2. Condition 5 from the NRC staffs model safety evaluation of TSTF-454, Revision 1 states:
The licensees application must provide supporting information that it will verify the operability of the remaining PCIVs in the associated penetration flow path before applying an extended Completion Time (CT) for an inoperable PCIV.
TSTF-454, Revision 2, addresses Condition 5 in proposed Required Action A.1 by determining whether a common cause failure exists.
However, the guidance is to confirm the operability of the remaining PCIVs. Confirming the operability is broader than considering only the potential for common cause failure. Provide clarification how this will be addressed for TSTF-454.
- 3. During the extended CT, the drywell must remain inerted for Mark I and Mark II containment designs. Describe how TSTF-454, Revision 2, addresses monitoring drywell inertion during the extended CT and how it is consistent with the supporting TR.
- 4. TSTF-454, Revision 2, changes the 8-hour CT for the main steam line to the main steam line isolation valves for Condition A. Confirm that other main steam line PCIVs were included in the scope of the TR. If there are other main steam line PCIVs not included in the scope of the TR, describe which ones.
- 5. The model application for TSTF-454, Revision 2, should be consistent with applicable staff safety evaluations. The following information is missing from the model application, which should be explicitly addressed for clarity. Please revise the model application as appropriate.
There is no mention of verifying that: 1) the PCIV configurations for the specific plant match the TR and 2) the risk parameter values used in the TR are bounding for the specific plant. Note that the TSTF-454, Revision 2, states that the TR used bounding values such that the risk assessment was applicable to all boiling water reactor plants, but it does not mention representative or bounding values.
There is no mention that licensees application must provide plant-specific Tier 3 information.
There is no mention that the licensees application must provide supporting information that verifies that a penetration remains intact during maintenance activities, including corrective maintenance.
There is no mention of Regulatory Guide 1.174, which is important for PRA quality considerations and other information for risk-informed considerations.
There is no mention that licensees adopting TSTF-454, Revision 2, must confirm plant-specific implementation and monitoring in accordance with the guidance in Regulatory Guide 1.174 and Regulatory Guide 1.177.
There is no mention of the commitment from the NRC safety evaluation of TSTF-454, Revision 1. Line item 4 does not sufficiently reflect the commitment which involves enhancing the configuration risk management program.
There is no mention of Tier 2 in the model application.
Line item 3 is missing (Section 2.3).
Line item 5 references NUMARC 93-01, Revision 2; however, the most current revision should be referenced, Revision 4A.
- 6. One of the proposed changes to Specification 3.6.1.3 concerns addition of a new Required Action A.1 to determine whether the Operable PCIV in the affected penetration flow path is inoperable due to a common cause failure.
For limiting condition for operation (LCO) 3.6.1.3 Required Action A.1 Completion Time, (page, 3.6.1.3-1), the TSTF proposes the following: 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of potential common cause failure mechanism.
Section 3.0, Technical Evaluation, of Traveler TSTF-454, Revision 2, at the top of Page 8, states: Should a new or different failure be discovered, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is provided to determine whether a common cause failure exists.
Section 2.0, Detailed Description, item 1.b., of Traveler TSTF-454, Revision 2, at the bottom of Page 2 states: Should a new or different common cause mechanism is identified, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time clock is restarted.
- a. Please explain why the proposed common cause failure (CCF) determination is not required to be completed within the LCOs Required Action Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (i.e., within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of declaring the PCIV inoperable). As proposed it could be interpreted that the 4-hour CT would start from the time after reaching a conclusion that the failure mechanism of the first inoperable PCIV is a CCF mechanism.
- b. Please explain new or different common cause mechanism stated in the Traveler as the bases for the restart of the initial 4-hour CT clock. This approach would allow an unlimited number of revisions of the common cause until a correct resolution and/or action is determined and that the initial 4-hour CT could be extended up to 7 days (proposed PCIV CT) with 2 or more PCIVs inoperable during this time.
The NRC staff recommends the following:
(a) Required Action A.1 new Note 2 should state as follows:
Separate one time entry into Required Action A.1 is required for any new or different common cause failure mechanism identified subsequent to initial entry into Condition A.
(b) LCO 3.6.1.3 Required Action A.1 Completion Time should simply state, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
The phrase from discovery of potential common cause failure mechanism, is not needed and should be deleted.
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 Robert A. Slough Comanche Peak Nuclear Power Plant P. O. Box 1002, Mail Code A08 Glen Rose, Texas 76043 E-mail: robert.slough@luminant.com Roy A. (Tony) Browning Duane Arnold Energy Center 3277 DAEC Rd.
PSC/Licensing Palo, IA 52324-9785 E-mail: tony.browning@nexteraenergy.com Wendy E. Croft Exelon Nuclear 200 Exelon Way, Suite 340 Kennett Square, PA 19348 E-mail: wendi.croft@exeloncorp.com Otto W. Gustafson Entergy Nuclear Operations, Inc.
Palisades Nuclear Power Plant 27780 Blue Star Memorial Highway Covert, MI 49043 E-mail: ogustaf@entergy.com Brian D. Mann EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 E-mail: brianm@excelservices.com