ML20125E128

Summary of 921112 Meeting W/Owners Groups to Discuss Status of Activities to Implement Improved Std TS & Related Matters.List of Attendees & Agenda Encl

ML20125E128
Person / Time
Issue date:	12/07/1992
From:	Charemagne Grimes Office of Nuclear Reactor Regulation
To:	Grimes B Office of Nuclear Reactor Regulation
References
NUDOCS 9212160200
Download: ML20125E128 (16)

Text

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't UNITED STATES NUCLEAR REGULATORY COMMISSION I

J WASHINoToN, D.C. 20066

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December 7, 1992 MEMORANDUM FOR:

Brian K. Grimes, Director Division of Operating Reactor Support, NRR TROM:

Christopher 1. Grimes, Chief Technical Specifications Branch Division of Operating Reactor Support, NRR

SUMMARY

OF OWNERS GROUPS MEETINGS ON THE IMPROVED STANDARD TECHNICAL SPECIFICATIONS:

NOVEMBER 12, 1992 On November 12, 1992, the Technical Specifications Branch met with the Owners Groups to discuss the status of activities to implement the improved standard technical specifications (STS) and related matters.

The meeting attendees are listed in Enclosures 1.

The Owners Groups' agenda for this meeting is-presented-in Enclosure 2.

The staff had previously asked the Owners Groups how they intended to handle changes proposed by lead plants which have generic ap)1icability.

Florida Power Corporation (FPC) circulated a set of changes t1ey proposed for Crystal River that they concluded had such generic applicability.

Based on this experience, the following points were raised:

While the Owners agree that there needs to be a process to achieve consensus positions on generic issues, they are concerned tha+ the level of effort required could become a resource burden.

The Owners noted that the appropriate threshold for generic issues is dependent on the i

degree of the technical problem and the extent to which individual plants propose preferences. Mr. Bush suggested that clarifications could be made by changing the Bases instead of the LCOs; I agreed that L

the NRC should allow more latitude in the Bases changes because of the variation in licensing requirements.

Therefore, I concluded that it would be sufficient for each lead plant to screen their proposed changes for generic issues, and the NRC will rely on the Owners Groups to l

communicate and coordinate comments on these issues.

There needs to be a coordin'ated feedback mechanism for-issues raised by.

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the proposed plant-specific changes. A means_of forwarding the lead-plant screening results to NUMARC needs to be established so that they could communicate the issues broadly to the industry _ As a result of these discussions, the fc11owing steps were identified as-the basic t

elements of the lead plant review:

1.

The lead plant will screen and categorize its proposed changes i

from the STS.

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2..

The lead plant will communicate generic changes to the appropriate OwnersGroup(s)_for: comment.

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The NRC will review the lead-plant screening results and identify potential additional generic changes which are also forwarded to I

the appropriate Owners Group (s).

4.

The Owners Group (s) will coordinate with the utilities to j

establish a consensus position on the proposed generic change.

3 4

r 5.

The generic changes will be resolved in accordance with the comment resolution appeal process, like that used for the STS i

comments.

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6.

Generic changes resulting from license amendment screening and i

line-item. improvements will be coordinated with the appropriate-j Owners Groups, i

i 7.

All approved generic changes to the STS will be tracked and 1

maintained un the bulletin-board system for ready reference, and j

periodically incorporated into revisions of the STS.

8.

The NRC will review the aroposed plant-specific changes in i

accordance with establis1ed guidelines.

1 l

The timeliness of decisions on generic changes.should be prompt for the lead plant proposing the change, but deliberate for future use.

In-those cases where long-term study is warranted, the NRC will need to make a decision consistent with.the completion schedules for the lead

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plants.

1 l

The operating license review for Watts Bar should follow the same process.

l The second issue concerned means for phased implementation of new requirements after the STS conversion has been completed.

Specifically, FPC intends to implement the conversion at Crystal River in the middle' of a cycle.

They have identified 48 different surveillance requirements, and about a dozen changed surveillance practices.

Some of the changed surveillances cannot be performed l

until the subsequent refueling outage. Accordingly, the effective date for-the new technical specifications (TS) must allow for phased implementation of the new requirements.

Several alternatives to resolve this concern were discussed; the fundamental-problem is the ability to clearly demonstrate that the legal requirements of the license have been satisfied. One approach would-be to designate the effective date of each surveillance-directly in the TS, j

but that approach would unnecessarily clutter the TS.

Another approach =would i

be.to establish a license condition outside the TS that specifies the-implementation schedule, but that approach _may not have a measure of. control' l

compatible with the TS.

FPC will coordinate with the Owners Grouos and develop a specific proposal ~on phased implementation to present t'o the NRC.

The Owners Groups raised a related concern regarding the treatment of operability =for equipment under surveillance.

The 0wners had proposed, in their comments on the draft STS, to include a blanket exception to the operability requirements for equipment under surveillance. The NRC previously 1

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, December 7, 1992 rejected that proposal as part of a broader conclusion which led to the provision for an administrative control for operability:

the Safety function Determination Program (SFDP). However, the Owners continue to believe that equipment under surveillance, which is "inoperabic" but "available," should be treated differently from equipment which is " inoperable" because it is broken.

I pointed out that this issue was raised in the NUMARC comments on the operability guidance in Generic letter 91-18.

Moreover, a concern exists if existing licensee practices fail to declare equipment inoperable when it is removed from service for surveillance testing.

Because of the variations in testing times and safety significance, it is impossible to establish a blanket exception period for all surveillances.

The NRC will discuss this concern during forthcoming regional " operability workshops" to determine how to best address this issue.

In the interim, I encouraged the Owners Groups to develop a specific proposal for the NRC to consider that would address the concerns regarding adequate control and loss of safety function.

There was considerable discussion of related concerns about the treatment of operability under the improved STS, and the manner by which the licensees would be expected to implement the SFDP for " cascading" failures.

In particular, the Owners continue to believe that there should be a general delay time (before declaring certain equipment inoperable) for equipment that was relocated outside TS to compensate for the " allowed outage time" that equipment was previously allowed to have.

I pointed out that the essential reason for creating the SFDP approach was to enhance the process for evaluating equipment operability and cascading (consequential) effects by allowing the existing quality assurance programs to make timely decisions about the nature and appropriate action for any defective equipment.

Those procedures already provide a means to allow appropriate time to evaluate the nature of the defects and develop effective corrective actions.

I considered the reasoning behind the general delay time proposed by the Owners to regress to more prescriptive TS requirements and less reliance on the quality assurance programs.

I also noted that the NRC expects licensees to make " prompt" decisions regarding the ability of equipment to perform its intended safety function and, where it cannot, promptly implement the applicable TS required actions.

As a result of these discussions, I offered to have the NRC prepare a list of operability iss9es that need to be addressed by the SFDP.

In turn, I requested that the Owners Groups diagram the operability determination process as they believe it should occur.

Further, I requested that another meeting be scheduled to pursue these issues in mid-December.

The Owners Groups asked whether the NRC had established criteria for the

" programs" included in the STS administrative controls.

I indicated that we had not establish such criteria because we expected the " programs" would be

. developed in conjunction with whatever procedure changes would be necessary to implement the new STS. Moreover, I indicated that it is not clear whether there continues to be a need for a " technical requirements manual" (TRM) that is usually developed with the TS for an operating license application; the TRM seems to duplicate the procedures a utility develops to comply with all of the l

l

' December 7, 1992 other regulatory requirements. Nevertheless, this matter is fundamentally a compliance issue; the licensee must demonstrate that there are adequate procedures to accomplish the " programs" and the other aspects of the administrative controls in the TS to satisfy the requirements of the license.

There was a general discussion of the categories of " differences" associated j

with the changes to the STS for plant-specific conversions.

I noted that these categories are primarily important to the efficiency of the conversion i

i review process; that is, ensuring that the focus of the effort is directed at i

safety-related matters and satisfies the procedural requirements of the l

licensing process. As such, major areas of differences involve changes from the existing licensing requirements and plant-unique designs. While FPC has proposed 12 categories of differences, the BWR Owners envision 5 groups.

I requested that the Owners Groups compare their approaches and develop a set of

" typical" categories based on the review process they anticipated.

In parallel, the staff will develop a model safety evaluation report for an STS l

conversion to identify the information needed for the associated licensing 4

action.

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The Owners announced that the jointly-developed Writers' Guide is nearing completion.

The final version of the guide will be forwarded to NUMARC for publication.

I requested that, in concert with the issuance of the guide, the Owners Groups provide a statement regarding its intended use and future maintenance. At this point, the Owners do not expect that the style and format practices reflected in the guide are very different from Revision 0 of the STS.

The status of action items was discussed, and appropriate changes are reflected in the updated version presented in Enclosure 3.

FPC noted that their submittal schedules have been slipping, but it is too early to determine whether the overall review schedule will be substantially affected. The other lead-plant implementation schedules are generally the same as that depicted in Enclosure 4.

The BWR-6 Owners are planning on completing their submittal by October 1, 1993, with a 32-wee < review.

j Similarly, SCE is planning on completing their submittal in September 1993, with a 6-month review, 1

Christopher 1. Grimes, Chief Technical Specifications Branch Division of Operating Reactor Support NRR

Enclosures:

As stated cc:

T. Murley L. Bush, OG J. Partlow W. Hall, NUMARC W. Russell

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4-tally a Nevertheless, this matter is fundamen i

d uate st demonstrate that there are a eqother aspects other regulatory requirements. compliance issue; the lic h

ciated procedures toadministrative controls in the f the categories of " differences" assoI noted tha conversion for plant-specific conversions.

important to the efficiency of theis directed at There was a general discussion o with the changes to the STS i g that the focus of the effort ts of the these categories are primarily i fies the procedural requiremeninvolve changes from review process; that is, ensur nsafety-related matters an While FPC has As such, major areas of differences I

and plant-unique designs. 5 groups.

l p a set of fferences, the BWR Owners envision t

the existing licensing requiremen s licensing process.

compare their approaches and deve o In iew process they anticipated.t for an STS proposed 12 categories of di requested that the Owners Groups a model safety evaluation repor i ted licensing

" typical" categories based on the rev mation needed for the assoc a l

parallel, the staff will deve opconversion to identify the in

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developed Writers' Guide is near ngbe action.

l The Owners announced that the joint yThe final version of the concert with the issuance of the g future garding its intended use andct that the style 0 of and completion.

I requested that, in Owners Groups provide a statement reAt this point, the Owners publication.

format practices reflected in the gu ssed, and appro maintenance.

the STS.

The status of action items was discuresented in En reflected in the updated version p d les have been slipping, but it i bstantially FPC noted that their submittal sche uoverall review sched The BWR-6 Owners are planning on h

early to determine s. nether t eThe other lead-plant implementation iw t ber 1,1993, with a 32-week rev e

1993, 4.

same as that depicted in Enclosure affected.

completing their submittal by Oc oSimilarly, SCE is with a 6-month review.

Orldnal Rned By Christopher 1. Grimes, Chief Technical Specifications Branch t NRR See Attached DISTRIBUTION:

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L. Bush, OG

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~4-December 7, 1992 other regulatory requirements.

Nevertheless, this matter is fundamentally a compliance issue; the licensee must demonstrate that there are adequate procedures to accomplish the " programs" and the other aspects of the administrative controls in the TS to satisfy the requirements of the license.

There was a general discussion of the categories of " differences" associated with the changes to the STS for plant-specific conversions.

I noted that these categories are primarily important to the efficiency of the conversion review process; that is, ensuring that the focus of the effort is directed at safety-related matters and satisfies the procedural requirements of the licensing process.

As such, major areas of differer.ces involve changes from the existing licensing requirements and plant-unique designs. While FPC has proposed 12 categories of differences, the BWR Owners envision 5 groups.

I requested that the Owners Groups compare their approaches and develop a set of

" typical" categories based on the review process they anticipated.

In parallel, the staff will develop a model safety evaluation report for an STS conversion to identify the information-needed for the associated licensing action.

The Owners announced that the jointly developed Writers' Guide is nearing completion.

The final version of the guide will be forwarded to NUMARC for publication.

I requested that, in concert with the issuance of.the guide, the Owners Groups provide a statement regarding its intended use and future maintenance. At this point, the Owners do not expect that the style and format practices reflected in the guide are very different from Revision 0 of the STS.

The status of action items was discussed, and appropriate changes are reflected in the updated version presented in Enclosure 3.

FPC noted that their submittal schedules have been slipping, but it is too early to determine whether the overall review schedule will be substantially affected. The other lead-plant implementation schedules are generally the same as that depicted in Enclosure 4.

-The BWR-6 Owners are planning on completing their submittal by October 1,1993, with a 32-week review.

Similarly, SCE is planning on completing their submittal in September 1993, with a 6-month review.

Orkinal Sbed By Christopher I. Grimes, Chief Technical Specifications Branch Division of Operating Reactor Support, NRR

Enclosures:

As stated-DISTRIBUTION: See Attached cc:

T. Murley L. Bush, OG DOCUMENT NAME:

A:\\MTG 22 J. Partlow W. Hall, NUMARC

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W. Russell

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CIGrimes MSchwartz, OGC SAVarga JWRoe l

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GClainas JAZwolinski MJVirgilio j

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OTSB Staff 1

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I".11NG ATTENDEES 1992 Lttendee Oraanization Joan Carr Florida Power Corporation B&WOG Blair Wunderly Florida Power Corporation B&WOG Brian Woods Southern California Edison CE0G Chris Hoxie NRC/0TSB John Vorees TVA - Watts Bar Darrell Gardner TVA - Watts Bar Tom Porter TVA - Watts Bar Frank Kennedy Toledo Edison - Davis-Besse Henry Stevens Toledo Edison - Davis-Besse Bryan Ford Entergy - Grand Gulf Jim Eaton NUMARC Sheri Mahoney Entergy - Grand Gulf Dan Williamson EXCEL BWROG Lee Bush Commonwealth Edison Company WOG Don Hoffman EXCEL BWROG Jim liiller NRC/0TSB Chris Grimes NRC/0TSB Carl Schulten NRC/0TSB Bob Giardina NRC/0TSB Ed Tomlinson NRC/0TSB l

Harley Silver NRC/PD22 l

Peter Tam NRC/PD24 l

Mark Reinhart NRC/0TSB Dick Phares Illinois Power Company BWR6-0G

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'TO:NRC WHITE FLINT 60)-10 '92 TLE 10:49 IDattJC LICENSitG-CR3 TEL to 904-563-4697 EG22 P02/03 l

o Ageada for November 12,13 1992 TsIP Lead Plaat Neoting Update on Generio Issues Process At the last Lead Plant Implementation Meeting, a process was 4

tentatively agreed upon for forwarding generic issues identified during the lead's plant-specific review to a generic forum.

The purpose of the process was to make potentially generic changes (identified by one lead) available to all owner's Goup leads and thus maintain consistency, to the extent possible, between the four owner's Group NUREGs.

CR-3 has forwarded the first of these generic comments to the other leads to test the process.

This item is a discussion of the effectiveness of th.s process to date.

Impact of New Surveillance Requirement testing on Implementation l-SR 3.0.1 requires Surveillance Requirements (SR) for a given l

Specification to be met during the MODES or specified-conditions given in the APPLICABILITY of the specification.

For plants considering an on-line at-power implementation (NODE 1), this will result in a large surveillance burden on the licensee during the Refueling (or other cold shutdown) outage immediately preceding the planned implementation date.

This burden could manifest itself in terms of extended outages and the associated additional costs.

Not only will the licensee have to perform SR required by current TS, but all SR required by the new Specifications will have to be performed prior to implementation as well.

There appears to be some l

flexibility possible in requiring new SR, or those with l

signiticantly increased

' scope, to be current upon implementation.

The rationale for this flexibility is that l

continued safe operation of the unit does not depend upon their performance prior to implementation.

This item is intended to-be a discussion of _ the options available for deferring performance of some or all TSIP SR until some time l

following implementation.

c i

Alternatives to entering Required Actions during Surveillance Testing 1

• - Programs i

l Industry position is that an acceptable " Program" can be a stand-alone document or the various actions a utility takes to implement requirements.

For instance, there are a handful of requirements-for each Program described in section-5.7.2.4.

I The utility should be able to take credit for various activities already implemented at the site to satisfy the requirements of the Program.

It would seem to be added work with little benefit for the utilities to go out and create Program documents from scratch merely to put all requirements l

in one place.

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i Differences f

Establish categories of differences and set threshold on level t

of detail for Review.

This discussion should address both Should j

deviations from the Standard specifications and Bases.

include the use of alpha designators for generio differences i

within this conversation.

l Generio Issues / Problems discovered since last meeting t

l Feedback on Action Items Licensing Basis i

Writers cuide j

status of effort to finalise.

Identification of l

organization responsible for control of the document.

4 Expected submittal date to the NRC.

5.0 Program re-write Imcation of SFDP and Bases control Program f

Alternative approaches to so Tube Inspection Program Licensed operator Training Issues schedule status / Updates Neeting Minutes Will NRC create these for lead plant meetings in order to (if any) reached at the meeting?

document agreements Have the meeting minutes for the 9/11/92 Chairman / Grimes meeting been issued?

other Items-of Interest 1

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4 1

Enca.eseeE 3 ACTION ITEMS Action Descriotion Status 12 PRPB Offgas Monitor position (3.4.12 &

GENERIC:

OTSB develop proposed PAMS).

backfit to reclassify offgas menitor 4

as RCS integrity monitor.

20 OTSB pursue generic concern of tripped-GENERIC: OTSB initiate evaluation state vulnerabilities.

of tripped-state risks.

22 OG develop consensus language for " Loss SEE ITEM #59 of function" checks and a list of applicability for affected STS Sections.

24b OTSB confirm consistent requirements IMPitMENTATION: Schulten complete for automatic actuation of valves review of OG comments on proposed

[Section 3.7 runcluded that automatic changes to Section 3.3, and forward 1 solation not required when MS!Vs resolution by letter.

closed); 0d comments intended consistent " seal-closed."

30 OTSB pursue backfitting Delay LOOP /LOCA GENERIC:

OTSB initiate evaluation surveillance for all plants.

to determine whether to backfit delayed LOOP tests.

36 B&W submit written appeal for PlV COMPLETE:

B&W appeal meeting with requirements.

EMEB on 4/30/92; Weston incorporated resolution into 3.4 corrections for June issuance.

GENERIC:

OTSB confirm MODE 4-applicability resolved by Note,-

pending SRXB.

37 OG and staff develop framework for GENERIC:

Develop issues and conversion process to discuss at April alternatives for lead-plant Executive meeting. 00 scope NSHC ar.d conversions and rulemaking legal alternatives.-

approaches - NUMARC lead, i

i 42 OG develop revised Bases to explain H IMPLEMENTATION: OG provided g

control capabilities to backup suggested lists of backups, but NRC recombiners, mixing, or CAD to preclude concluded must be case-by-case loss-of-function.

review; address at first opportunity i

during lead-plants.

48 OG should consider tte. consistency of SEE. ITEM #59 shutdown actions specified in LCO, as compared to_LCO 3.0 3 applicability.

l STS Status Dated:

11/13/92

1 l

ACTION ITEMS _

1 Action Description Status i

59 OTSB resolve consistency concerns IMPLEMENTATION:

OGs provided j

regarding Operability position, and OG individual language preferences for proposal for a General Delay Time.

LC0 3.0.6 exceptions in proof-and-i review comments; staff accepted l

inconsistencies for Rev. O.

i Evaluate consistency of loss-of-j function within LCOs, including 3.7.5 (aux feed) and 3.8.9 (distribution).

OG develop list of new 3.0.3 actions by 1/93 meeting.

OG & OTSB establish complete positions on operability to resolve

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all of the related issues, including implementation of SFDP; compare j

positions and issues before 1/93 meeting.

l 60 OG develop admin controls for Tendon COMPLETE: Tendon Program.

i Surveillance and SG Tube Surveillance j

Administrative Control programs.

IMPLEME TATION:

SG Tube SRs i

evolving.

Leave " place holder" in i

Section.5.0 until policy decision -

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can be made for STS. OTSB monitor j

status of SG tube requirements.

67 OTSB trace removal of surveillance COMPLETE:. Restored SR for BWR-4 i

requirement for drywell-wetwell vacuum

-vacuum breaker surveillance.

i breakers within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after steam discharge.

GENERIC: - OTSB evaluate need for BWR-6 vacuum breaker surveillance.

4 l

69 Consider moving secondary containment IMPLEMENTATION:

Moon determine draw-down time from ventilation system whether flow and pressure l-to containment section.

requirements are needed for different SRs by-1/93 meeting.

70 B&W position on LTOP with non-G COMPLETE:

Incorporated' modified fracture mechanics.

reviewers note.

IMPLEMENTATION: -Weston confirm'LTOP Bases; no_ analyses _for small-break LOCA in Mode 4 for one-pump

' operation? Westinghouse-topical not-approved.

1 STS Status Dated:

11/13/92

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ACTION ITEMS.

Action Description Status 2

71 Evaluate status of topical reports IMPLEMENTATION:

OTSB evaluate j

referenced in STS.

consistency of reference usage.

j 75 Evaluate redundancy of turbine-drive AF IMPLEMENTATION:

0TSB address during pump to motor-driven AF pump for PWRs.

implementation on lead plants.

j 78 Reconcile actions for " faulty" GENERIC:

OTSB establish appropriate surveillance vs. missed surveillance.

ins)ection guidance for range of SR l

pro)1 ems and determine whether clarification of STS is needed.

82 Replace general references with more IMPLEMENTATION:

OTSB review STS for explicit identification, incomplete references.

86 Evaluate reformatting nesting of IMPLEMENTATION:

0TSB review final logical connectors.

Writer's Guide and. recommend action.

j 87 Consider restructuring Bases to IMPLEMENTATION: OTSB sample Bases eliminate repetition of information.

changes-during implementation and l

within a given Bases.

determine impact of restructuring.

l 98 Addition of 1% reset tolerance for IMPLEMENTATION:

OG Appeal, Miller j

safety valves to SRs in 3.4 and 3.7.

compile BWR position and forward to j

OG for lead-plant implementation.

i j

101 Determing whether requirements for RHR

- !MPLEMENTATION: OG confirm issue-i in 3.4.9 constitute existing resolve in shutdown requirements.

l requirements, i

104 Clarify _" inoperable" tor _ a _ battery with IMPLEMENTATION: Tomlinson arrange i

' a bad cell; distinction between meeting to resolve footnote "c" and equalizing charge & float charge. -

Category C " limits."

i 105 Determine applicability of 25%

IMPLEMENTATION: Dunning evaluate l

extension to DG accelerated test consistency _of applicability of j

frequency.

3.0.2 to accelerated frequencies; i

resolve position by 1/93 Exec j_

meeting..

106 Add Reviewer Note to Bases.for SRs IMPLEMENTATION: Tomlinson establish j

3.8.1.9, 3.8.1.10, 3.8.1.13, &

considerations for deleting Mode 3.8.1.18.

restrictions.

Establish criteria --

i for including reviewer notes.

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STS

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i ACTION ITEMS 1'

1 Action Description Status i

108 Clarify Required Actions for loss of IMPLEMENTATION: OG prepare modified i

i inverter power in LCO 3.8.7.

LC0 and Bases for alternate design.

109 Deletion of requirement to have a GENERIC:

Reliable RCS temperature

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shutdown cooling subsystem in monitoring is an important safety i

operation, since this requirement is function.

OG should address in i

only provided to ensure accurate comments on shutdown requirements.

I reactor coolant temperature monitoring.

4 BWR4: 3.4.8, 3.4.9, 3.9.7, and 3.9.8 j

BWR6: 3.4.9, 3.4.10, 3.9.7, and 3.9.8 f

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110 Deletion of shutdown cooling GENERIC:

There should be a requirements when heat losses to demonstrable need for.. such an ambient are sufficient to maintain exception, established on a case-by-l reactor coolant temperature (similar to '

case basis. 0G should address in Perry and Fermi-2 technical comments on shutdown requirements.

j specifications),

i BWR4: 3.4.9, 3.9.7, 3.9.8, and 3.9.9 I

BWR6: 3.4.10, 3.9.7, 3.9.8 and 3.9.9 F

111 Revision of the positive reactivity GENERIC:

In the event that there insertion Required Actions to allow are instrumentation or equipment l

normal makeup and cooldown activities, failures, all operations, including normal and cooldown, should be j

W: 3.3.1, 3.3.9, 3.8.2, 3.8.5, 3.8.8, suspended as a conservative measure, j

3.8.10, and 3.9.3 OG should address in comments on j

shutdown requirements.

OG noted action to isolate VCT example of adverse safety impact.

i 112 One hour instead of 15 minutes for GENERIC:

It is not apparent that i

securing an RHR pump in Mode 5 with the the subcooling provisiom would RCS Loops not filled, as long 'as RCS provide adequate protection over the 1

temperature is maintained 2 10 range of conditions of interest.

0G i

subcooled, should address in comments on shutdown requirements.

i 113 Required Action B of LC0 3.4.6, GENERIC:

During Mode 4 when the RCS

~ Initiate actions _to restore an DHR Loop QB place the Unit in Mode 5."

temperature is'above 206 F, if only one RHR train is operable and two required RCS loo)s are inoperable, PWR. 3.*

C-the unit should.)e brought to Mode.5 within the following 24: hours.

OG should address in comments-on j

shutdown requirements.

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Status Dated:

11/13/92 STS 1

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ACTION ITEMS 1

Action Descrintion Status 114 LC0 3.9.4, LCO note prior to proof-and-GENERIC:

The basis for allowing DHR review allowed DHR to be removed from to be removed from operation for up operation for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per 24-hour to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in a 24-hour period is period.

not clear.

The staff believes that allowing DHR to be removed from B&W: 3.9.4 operation for up to one hour in an 8-hour period is appropriate, with due consideration for decay heat removal and baron stratification concerns. 0G should address in comments on shutdown requirements.

115 Note allowing the required RHR pump to IMPLEMENTATION:

It may be be secured from operation for one hour appropriate for newly-licensed out of every eight hours for NT0Ls.

facilities,-prior to criticality, to This would be compicmented by a similar secure RHR for up to one hour in an note in LC0 3.9.7 allowing an NT0L to 8-hour period with a low vessel load fuel at a reduced-cavity water level. However, the staff should level. The provision for reduced water give careful consideration to the level loading for an NT0L is common need for a low vessel level under practice and was previously allowed such circumstances, and ensure that prior to the revision in the Mode of boron stratification is not a Applicability.

concern.

OTSB will resolve this issue on Watts Bar.

B&W: 3.9.5 W:

3.9.6 116 Establish consistent PAM requirements IMPLEMENTATION:

Schulten_ evaluate for single-channel parameters.

Watts Bar proposal and prepare for OG generic position at 1/93 meeting, 117 Reconsider required actions for axial GENERIC: OG position at 1/93 flux difference; does action impose

meeting, extreme transient for minor spec deviation 7 118 Evaluate alternate requirements for IMPLEMENTATION: -Hoxie review Zion high-radiation area admin controls, and proposal (1/93 meeting) and_PRPB impact of Part 20 changes, position on Part 20 changes.

119 Restructure Section 5.0.

IMPLEMENTATION: OG consider whether to move 5;6 and 5.8 to 5.7.2 by 12/1/92._ Hoxie prepare markup.to remove safeguards arJ EP consistent with line-item actit.n.

STS Status Dated:

11/13/92 a-.-..-

A

ACTION ITEMS f

Action Description Status 120 Determine whether initial operator GENERIC: OTSB coordinate position license exams need to be modified to with HOLB.

account for expanded Bases in the improved STS.

121 Det> aine whether guidance can be GENERIC: OTSB address issue with de'.eioped for " risk significance" proposed final policy statement, triteiion in policy statement.

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11/13/92 l

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Lead Plant Conversibn Schedules 1993 1994

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Watts Bar 1 issue with Operating License 7

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BWR-6 Plants I

IM O Cen.ersion Submittal NRC Plant-Specific Evaluation

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Licensee implementation

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