ML18134A075

Request for Additional Information (RAI) Technical Specifications Task Force (TSTF) Traveler TSTF-569, Revise Response Time Testing Definition

ML18134A075
Person / Time
Site:	Technical Specifications Task Force
Issue date:	05/21/2018
From:	Michelle Honcharik NRC/NRR/DSS/STSB
To:	Technical Specifications Task Force
Honcharik M
References
EPID L-2018-PMP-0002
Download: ML18134A075 (5)

Text

May 21, 2018 Technical Specifications Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RE: TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-569, REVISE RESPONSE TIME TESTING DEFINITION (EPID: L-2018-PMP-0002)

Dear Members of the Technical Specifications Task Force:

By letter dated February 8, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18039A003), you submitted to the U.S. Nuclear Regulatory Commission (NRC) for review Technical Specifications Task Force (TSTF) Traveler TSTF-569, Revise Response Time Testing Definition. Upon review of the information provided, the NRC staff has determined that additional information is needed to complete the review. On May 14, 2018, Mr. Brian Mann, Vice President of Industry Programs, EXCEL Services Corporation, agreed that the NRC staff will receive your response to the enclosed request for additional information (RAI) questions within 30 calendar days of the date of this letter (or the next business day if 30 days falls on a weekend).

The review schedule that was provided in the acceptance letter dated March 26, 2018 (ADAMS Accession No. ML18057A160), has not changed.

MILESTONE SCHEDULE DATE Issue Draft Safety Evaluation November 5, 2018 Issue Final Safety Evaluation February 8, 2019

If you have any questions, please contact me at (301) 415-1774 or via e-mail to Michelle.Honcharik@nrc.gov.

Sincerely,

/RA by Margaret Chernoff for/

Michelle C. Honcharik, Senior Project Manager Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation Project No. 753

Enclosure:

Request for Additional Information cc: See next page

ML18134A075;

• concurred via memo (ML18123A555)

• • concurred via e-mail NRR-106 OFFICE NRR/DSS/STSB/PM NRR/DORL/LSPB/LA** NRR/DE/EICB/BC* NRR/DSS/STSB**

NAME MHoncharik (by JBurkhardt MWaters VCusumano MChernoff for)

DATE 05/21/2018 5/16/2018 5/4/2018 5/15/2018 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 P. Miksa Entergy Nuclear Operations, Inc.

Palisades Nuclear Power Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Email: jmiksa@entergy.com Jordan L. Vaughan Duke Energy EC2ZF / P.O. Box 1006 Charlotte, NC 28202 Email: jordan.vaughan@duke-energy.com Lisa L. Williams Energy Northwest Columbia Generating Station PO Box 968 Mail Drop PE20 Richland, WA 99352-0968 E-mail: llwilliams@energy-northwest.com David M. Gullott Exelon Generation 4300 Winfield Road Warrenville IL 60555 Email: David.Gullott@exeloncorp.com Wesley Sparkman Southern Nuclear Operating Company 42 Inverness Center Parkway / Bin B237 Birmingham, AL 35242 Email: wasparkm@southernco.com

REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-569, REVISE RESPONSE TIME TESTING DEFINITION (EPID: L-2018-PMP-0002)

By letter dated February 8, 2018, the Technical Specifications Task Force (TSTF) submitted Revision 0 of Traveler TSTF-569, Revise Response Time Testing Definition (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18039A003). The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c)(3),

Surveillance requirements, states that [s]urveillance requirements are requirements relating to test, calibration, or inspection to assure that necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. The U.S. Nuclear Regulatory Commission (NRC) staff requires the following additional information to confirm that Response Time Testing (RTT) surveillance tests, excluded for previously unanalyzed components, will be based on verifiable methodologies:

1. Traveler TSTF-569 refers to performance of a similarity analysis of NRC-approved methodologies as a basis for allowing licensees to modify RTT requirements. The NRC staff notes that the approved methodologies, though similar, were not found to be identical. It will therefore be necessary for licensees to perform an evaluation of similarity between different verification methods using an established set of criteria.

Describe the criteria that will be used when comparing new, but unapproved methodologies, to methodologies that have been approved by the NRC.

As an example, topical reports WCAP-13632-P-A, Elimination of Pressure Sensor Response Time Testing Requirements, and CEOG NPSD-1167-A, Elimination of Pressure Sensor Response Time Testing Requirements, reference the Electric Power Research Institute (EPRI) topical report EPRI Report NP-7243, Investigation of Response Time Testing, and its associated methodology. However, both of these topical reports provide additional evaluations for sensors that were not within the scope of the EPRI report. These additional analyses included different amounts of supporting plant data and, in some cases, included similarity of design analyses instead of using the methodology established in the EPRI document. While these alternate methodologies were ultimately deemed acceptable by the NRC, they included changes to the methodology that had originally been applied. If licensees are to compare methodologies to determine if a new methodology is consistent with an approved methodology, then a set of comparative criteria should be established.

2. In addition to approving the methodology used for EPRI Report NP-7243, the NRCs safety evaluation of WCAP-13632-P, Elimination of Pressure Sensor Response Time Testing Requirements," dated September 5, 1995 (ADAMS Accession No. ML18023A067), includes several conditions for its use in eliminating RTT requirements. Specifically, there are four actions required when licensees reference the WCAP report for elimination of RTT surveillance requirements. Explain whether or not these or other similar conditions will be included in prospective methodologies. If so, then explain how these conditions will be implemented and verified to assure acceptable application of the selected methodologies.

Enclosure