ML19267A159

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TSTF Handout for October 16, 2019, Meeting: TSTF-493 Questions
ML19267A159
Person / Time
Site: Technical Specifications Task Force
Issue date: 09/24/2019
From:
Technical Specifications Task Force
To:
Honcharik M
References
Download: ML19267A159 (1)


Text

Response to NRC Staff Questions Regarding Industry Position on Adoption of TSTF-493 The TSTF has recommended that licensees not volunteer to adopt the TSTF-493, Option A, footnotes in license amendment requests (LARs) to revise applicable setpoints. See the attached letter from the TSTF to licensees. The TSTF is not requesting any generic action from the NRC staff regarding this recommendation. The TSTF notified the NRC about this change in position from the TSTF's February 23, 2009 letter to the NRC that stated that licensees would adopt TSTF-493 (ADAMS Accession No. ML090540849).

The NRC staff had the following questions:

a) How would a licensee propose to commit to the use of As-Found and As-Left Tolerances for Limiting Safety System Settings in the Technical Specifications to determine whether an instrument channel is functioning as required, and where will the licensee commitment for performance monitoring using these tolerances be recorded?

Response

In lieu of adopting the TSTF-493, Option A, footnotes, the TSTF has recommended to licensees that LARs proposing a change to an instrumentation setpoint discuss how their approach addresses the specific concerns in RIS 2006-17. This approach is consistent with that taken in the recently approved LAR for Hatch Units 1 and 2, dated July 8, 2019, ADAMS Accession No. ML19177A166, and in particular the June 12, 2019 RAI response (ADAMS Accession No. ML19163A180).

b) What is the Owners Group specific proposal for making changes to the standardized Technical Specifications NUREGs?

1.) For TSTF-493 Option A (Section 3 of the Tech Specs) 2.) For TSTF-493 Option B (Section 5 of the Technical Specifications)

Response

The TSTF is not proposing to make any changes to the Standard Technical Specifications regarding TSTF-493, Option A.

No Part 50 licensees have adopted TSTF-493, Option B (Setpoint Control Program), and a survey of licensees determined that none are considering adoption of Option B.

Approximately 10% of the ISTS NUREG Word files are for "B" specifications (with Setpoint Control Program), and these files are revised with every applicable traveler.

This is a waste of industry and NRC resources.

The TSTF proposes removal of the "B" version Section 3.3 Specifications and Bases in Revision 5 of the STS NUREGs. We would retain the bracketed (i.e., optional) Setpoint Control Program in Section 5.5 and add a Reviewer's Note pointing to TSTF-493 for guidance on the other TS changes needed to adopt the program should a licensee desire to do so.

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