ML16113A402
| ML16113A402 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 04/27/2016 |
| From: | Kevin Hsueh Licensing Processes Branch (DPR) |
| To: | Technical Specifications Task Force |
| Honcharik M, NRR/DPR. 301-415-1774 | |
| References | |
| Download: ML16113A402 (5) | |
Text
April 27, 2016 Technical Specifications Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852
SUBJECT:
ISSUE WITH TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-490, REVISION 0, DELETION OF E BAR DEFINITION AND REVISION TO RCS SPECIFIC ACTIVITY TECH SPEC
Dear Members of the Technical Specifications Task Force:
The purpose of this letter is to inform the Technical Specifications Task Force (TSTF) of a concern that the U.S. Nuclear Regulatory Commission (NRC) staff has recently identified during a review of plant-specific license amendment requesting adoption of the subject Traveler.
Traveler TSTF-490, Revision 0, Deletion of E Bar Definition and Revision to RCS [reactor coolant system] Specific Activity Tech Spec [Technical Specification], was approved on March 8, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML070250176) (72 FR 12838 dated March 19, 2007). Traveler TSTF-490 replaces the RCS gross specific activity limit for pressurized water reactors (PWRs) with an RCS noble gas activity limit. The noble gas activity limit is based on dose equivalent Xenon-133 (DEX), instead of the indicator known as E bar.
During the NRCs review of license amendments to adopt the subject Traveler, the NRC staff has identified a need for additional information. The NRC staffs concern relates to increasing the completion time for DEX, as stated below.
TSTF-490, in part, deleted Condition C requiring gross specific activity of the coolant less than or equal to 100/ µCi/gm and replace it with DEX not within limit. Prior to the TSTF-490 approval, the Standard TS (STS) Limiting Condition for Operation (LCO) 3.4.16, when the gross specific activity of the coolant is greater than 100/ µCi/gm, the required action was to take immediate action to begin shutdown of the reactor (be in Mode 3 with Tavg less than 500°F) within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. TSTF-490 allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore DEX within limits. If DEX cannot be restored TSTF-490 allows 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in Mode 3 and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> to be in Mode 5. TSTF-490, Revision 0, provided the following justification for this change:
The Completion Time for revised TS 3.4.16 Required Action B.1 will require restoration of Dose Equivalent Xe-133 to within limit in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This is consistent with the Completion Time for current Required Action A.2 for Dose Equivalent I-131. The Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for revised Required Action B.1 is acceptable since it is expected that, if there were a noble gas spike, the normal coolant noble gas concentration would be restored within this time period. Also, there is a low probability of an accident occurring during this time period.
TSTF While it is a correct statement that the proposed change makes the Completion Times of Required Action A.2 and B.1 in the PWR STS consistent, it is not clear to the NRC staff why the Completion Times should be consistent. The plant Conditions for these Required Actions are different. TS Required Action A.2 is required when the plant is in a condition analyzed in the design basis accident (DBA) analyses (reactor coolant dose equivalent I-131 is between 1 and 60 µCi/gm). The new TS Required Action B.1 is required when the plant is in a condition not analyzed in the DBA analyses (DEX is greater than 280 µCi/gm).
Typically, the Required Action for a condition not analyzed requires the plant to take immediate actions to begin shutdown of the plant. This action is consistent with the current required action for exceeding the gross specific activity of the reactor coolant, which requires the plant be in Mode 3 with Tavg less than 500°F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The change does not take immediate actions to begin shutdown of the plant, but allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> before the plant is required to begin shutting down. Therefore, additional justification for the change to increase the Completion Time of Required Action B.1 to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and why it is acceptable to be in an unanalyzed condition for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is needed.
The issue identified above should be included with the other previous requests for additional information (RAIs) identified for TSTF-490. When requesting to adopt this Traveler it is suggested that licensees include the additional justification for the issue stated above, or maintain their current completion time associated with current Condition C (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />).
The NRC staff would consider working with the industry in addressing the issue identified. Any further changes in acceptance or review of license amendments adopting this Traveler will be communicated. The NRC staff plans to discuss the issue with the TSTF within the next few weeks. If you have any questions, please contact Michelle Honcharik at 301-415-1774 or via e-mail at Michelle.Honcharik@nrc.gov.
Sincerely,
/RA/
Kevin Hsueh, Chief Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 753 cc: See next page
ML16113A402; *via e-mail; **via internal memo (ML16092A257)
NRR-106 OFFICE DPR/PLPB/PM* DPR/PLPB/LA*
DRA/ARCB/BC** DSS/STSB/BC*
DPR/PLPB/BC NAME MHoncharik DHarrison UShoop AKlein KHsueh DATE 04/22/2016 04/25/2016 04/14/2016 04/26/2016 4/27/2016
Letter to Technical Specifications Task Force dated
SUBJECT:
ISSUE WITH TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-490, REVISION 0, DELETION OF E BAR DEFINITION AND REVISION TO RCS SPECIFIC ACTIVITY TECH SPEC DISTRIBUTION:
PUBLIC RidsNrrOd RidsNrrDpr RidsOgcMailCenter RidsOpaMail RidsACRS_MailCTR RidsNrrPMMHoncharik RidsNrrLADHarrison RidsNrrDprPlpb RidsNrrDssStsb RKuntz DWrona TTate DRender ADietrich RGrover AKlein UShoop KBucholtz
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 Michael K. Leisure Duke Energy 526 S. Church Street Mail Code EC2ZF Charlotte, NC 28202 E-mail: mike.leisure@duke-energy.com