ML15281A291
| ML15281A291 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 11/18/2015 |
| From: | Michelle Honcharik NRC/NRR/DPR/PSPB |
| To: | Technical Specifications Task Force |
| Honcharik M, NRR/DPR, 301-415-17741 | |
| References | |
| TAC MF5125 | |
| Download: ML15281A291 (5) | |
Text
November 18, 2015 Technical Specifications Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING TRAVELER TSTF-551, REVISION 1, "REVISE SECONDARY CONTAINMENT SURVEILLANCE REQUIREMENTS" (TAC NO. MF5125)
Dear Members of the Technical Specifications Task Force:
By letter dated September 3, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15246A131), you submitted to the U.S. Nuclear Regulatory Commission (NRC) for review and approval Traveler TSTF-551, Revision 1, Revise Secondary Containment Surveillance Requirements.
Upon review of the information provided, the NRC staff has determined that additional information is needed to complete the review. On October 8, 2015, 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 45 days of the date of this letter.
The review schedule provided in the acceptance letter, dated February 24, 2015 (ADAMS Accession No. ML15022A187), has been revised as follows:
MILESTONE SCHEDULE DATE Issue Draft Safety Evaluation May 26, 2016 Issue Final Safety Evaluation July 23, 2016 If you have any questions, please contact me at (301) 415-1774 or via e-mail to Michelle.Honcharik@nrc.gov.
Sincerely,
/RA Brian Benney for/
Michelle C. Honcharik, Senior Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
Enclosure:
As stated Project No. 753 cc: See next page
- concurred via e-mail internal memo (ML15274A161)
NRR-106 OFFICE DPR/PLPB DPR/PLPB*
DSS/SCVB*
DSS/STSB DPR/PLPB DPR/PLPB NAME MHoncharik DHarrison RDennig RElliott KHsueh MHoncharik (BBenney for)
DATE 10/8/2015 10/13/15 10/1/15 11/17/2015 11/17/15 11/18/15
Technical Specifications Task Force Project No. 753 cc:
Technical Specifications Task Force c/o EXCEL Services Corporation 11921 Rockville Pike Suite 100 Rockville, MD 20852 Attention: Brian D. Mann E-mail: brian.mann@excelservices.com James R. Morris Diablo Canyon Power Plant Building 104/5/21A P.O. Box 56 Avila Beach, CA 93424 E-mail: JY1E@pge.com Joseph A. Clark Entergy Nuclear South 5485 Highway 61 St. Francisville, LA. 70775 E-mail: jclark@entergy.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 Henry L. Hegrat FirstEnergy Nuclear Operating Company P. O. Box 97 Perry, OH 44081 Mail Stop A-210 E-mail: hlhegrat@firstenergycorp.com
Enclosure OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION TSTF-551, REVISION 1, ADDRESS TRANSIENT SECONDARY CONTAINMENT CONDITIONS TAC NO. MF5125 By letter dated September 3, 2015 (Agencywide Documents Access and Management System Accession Number ML15246A131), Technical Specifications Task Force (TSTF) submitted Traveler TSTF-551, Revision 1, Revise Secondary Containment Surveillance Requirements, which requests to amend the Standard Technical Specifications (STS) in NUREG-1433 and NUREG-1434. TSTF-551 proposes to revise Specification 3.6.4.1, Secondary Containment, in the Boiling Water Reactor (BWR) STS.
TSTF-551 proposes to add a Note to Surveillance Requirement (SR) 3.6.4.1.1 to allow the SR to not be met if an analysis demonstrates one standby gas treatment subsystem is capable of establishing the required secondary containment vacuum. In addition, it proposes a modification to BWR/4 STS SR 3.6.4.1.3 to be consistent with the BWR/6 STS by allowing that secondary inner and outer containment access openings to be simultaneously open for entry and exit.
Existing STS SR 3.6.4.1.1 states, Verify [secondary] containment vacuum is [0.25] inch of vacuum water gauge. TSTF-551 proposes to add a note to STS SR 3.6.4.1.1 that states:
Not required to be met if analysis demonstrates one Standby Gas Treatment (SGT) subsystem is capable of establishing the required [secondary] containment vacuum.
RAI-1
The technical justification provided in the TSTF states that conditions affecting [secondary]
containment pressure may occur that do not affect the ability of the [secondary] containment to be able to perform its safety function. Wind gusts and normal ventilation system configuration changes are cited as examples.
Please provide a definition of conditions affecting [secondary] containment pressure that do not affect the ability of [secondary] containment to be able to perform its safety function. How is it determined and documented whether a condition would prevent fulfillment of the safety function?
RAI-2
Existing STS SR 3.6.4.1.4 states, Verify the [secondary] containment can be drawn down to
[0.25] inch of vacuum water gauge in [120] seconds using one SGT subsystem.
Existing STS SR 3.6.4.1.5 states, Verify the [secondary] containment can be maintained
[0.25] inch of vacuum water gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> using one SGT subsystem at a flow rate of
[4000] cfm.
Since the requirements of SR 3.6.4.1.4 and 3.6.4.1.5 must be met between performances of the surveillance, and these SRs specify criteria for [secondary] containment vacuum conditions, why is a Note being proposed that would require an analysis to demonstrate one SGT subsystem is capable of establishing the required [secondary] containment vacuum? Wouldnt the requirements of SR 3.6.4.1.4 and 3.5.4.1.5 be sufficient?
Additionally, the staff notes that TSTF-551s technical evaluation does not address programmatic requirements for the proposed analysis, such as time limits for performing the analysis and documentation requirements for the analysis. Please submit the programmatic requirements for the proposed analysis or revise the SR note to address the specific concerns.
For example, the SR note could state:
Not required to be met during wind gusts and repositioning of normal non-emergency ventilation if SR 3.6.4.1.4 and SR 3.6.4.1.5 are met.
RAI-3
With respect to the proposed BWR/4 SR 3.6.4.1.3 revision, please provide assurance that an adequate administrative control will be implemented to control over secondary containment access door openings, specifically, to address how the door will be controlled in terms of frequency and time duration. Furthermore, provide assurance that the functional capability of the secondary containment will still be maintained when the access doors are simultaneously opened. Note that the frequency and door opening time of both planned activity and inadvertent event involved with simultaneous door openings should be subject to control. Provide justification for such a control.