ML19056A424

TSTF-568 Proposed Path Forward from 2/21/2019 Meeting

ML19056A424
Person / Time
Site:	Technical Specifications Task Force
Issue date:	02/21/2019
From:	Michelle Honcharik NRC/NRR/DSS/STSB
To:
Honcharik M, NRR/DSS, 301-415-1774
Shared Package
ML19056A435	List: ML19056A423 ML19056A424 ML19056A425 ML19056A426 ML19056A427 ML19058A023 ML19078A269
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Download: ML19056A424 (9)

Text

Technical Specifications Task Force TSTF A Joint Owners Group Activity Proposed Path Forward on TSTF-568, "Clarify Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2" 1

Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF-568 Background

• TSTF-568, Rev. 0, "Clarify Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2,"

- Applicable to BWR plants with Mark I and Mark II containments (BWR/2, /3, /4, and /5 plants)

- Submitted December 19, 2017

- NRC issued acceptance letter and review schedule on March 8, 2018 2

Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF-568 Status

• At the August 9, 2018 TSTF/NRC public meeting, the NRC stated that they support the change to TS 3.6.2.5, Drywell-to-Suppression Chamber Differential Pressure

- Only applicable to three BWR plants (Dresden, Fitzpatrick, and Quad Cities) 3

Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF-568 Status

• NRC stated they cannot support the change to TS 3.6.3.2, Primary Containment Oxygen Concentration

- Applicable to all BWR/2, BWR/3, BWR/4, and BWR/5 units

• The NRC does not agree with the existing justification of "As long as reactor power is < 15% RTP, the potential for an event that generates significant hydrogen is low and the primary containment need not be inert."

• While the risk to the public is too small to warrant a backfit on the issue, the NRC staff is not comfortable with issuing a change to the TS that relies on that justification.

- The TSTF was unable to find supporting analysis for the statement and accepts the NRC position.

4

Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF-568 Proposed Revision

• The TSTF has revised the traveler to address the staff concerns:

- Revise the TS 3.6.2.5, "Drywell-to-Suppression Chamber Differential Pressure," Applicability to Mode 1 with thermal power > [15]%

• Supported by the analysis referenced in TSTF-568.

- Revise the TS 3.6.3.2, "Primary Containment Oxygen Concentration," Applicability to Mode 1.

• Addresses the NRC staff concern.

- TS 3.6.3.2 Required Action B.1 is revised to require being in Mode 2 in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 5

Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF-568 Proposed Revision

- For both TS:

• The existing Applicability exceptions are eliminated.

• Required Action A.1 (restore the value to within limit) is changed from 8 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

• A Note is applied to Required Action A.1 permitting the use of LCO 3.0.4.c to enter the Applicability with the LCO not met.

• The Required Action A.1 and the Note will be used instead of the existing Applicability exceptions to permit entering the Applicability with the limit not met during a startup, and to enter the action prior to exiting the Applicability on a shutdown

• The Bases will state that entering Required Action A.1 prior to a shutdown without intention to restore compliance prior to exiting the Applicability is acceptable in this case.

6

Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF-568 Proposed Revision

- The Required Action A.1 Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is based on:

• The time to perform on-line maintenance at low power (typically

< 15% RTP) requiring primary containment or suppression pool entry.

- De-inert the primary containment and suppression pool while reducing power to permit containment entry (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)

(existing allowance),

- Perform on-line maintenance in containment (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />), and

- Re-inert the primary containment and suppression pool while increasing to full power (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) (existing allowance).

• The low probability of an event that would generate significant hydrogen and require primary containment to be inert.

7

Technical Specifications Task Force TSTF A Joint Owners Group Activity 8

Technical Specifications Task Force TSTF A Joint Owners Group Activity TSTF-568 Proposed Revision Discussion 9