ML20149K924

Informs That Disposition Made on Four Proposed Changes to Standard TS NUREG Made by NEI Technical Specification Task Force.Disposition & Basis for Disposition Contained in Encl

ML20149K924
Person / Time
Issue date:	07/25/1997
From:	Beckner W NRC (Affiliation Not Assigned)
To:	Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
NUDOCS 9707300249
Download: ML20149K924 (4)

Text

T July 25, 1997 j l

Mr. James Davis  !

kuclear Energy Institute 1776 Eye Street, N. W.

Suite 300 Washington, DC 20006-2496

Dear Mr. Davis:

This is to inform you that disposition has been made on four proposed changes to the Standard Technical Specification NUREGs made by the NEI Technical Specification Task Force (TSTF) (traveler numbers TSTF-105. TSTF-151. TSTF-167, and TSTF-173). In addition, I have made disposition decisions on two proposed editorial changes submitted by the NEI TSTF (traveler numbers EDIT-017 and EDIT-018). The disposition and basis for the disposition is contained in the enclosu.e.

Please contact me at (301) 415-1161 or e-mail wdb@nrc. gov if you have any questions or need further information on these dispositions.

Sincerely.

Original Signed By William D. Beckner Chief Technical Specifications Branch Associate Director for Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated

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%g***** July 25,1997 Mr. James Davis Nuclear Energy Institute 1776 Eye Street, N. W.

Suite 300 Washington, DC 20006-2496

Dear Mr. Davis:

This is to inform you that disposition has been made on four proposed changes to the Standard Technical Specification NUREGs made by the NEI Technical Specification Task Force (TSTF) (traveler numbers TSTF-105, TSTF-151, TSTF-167, and TSTF-173). In addition, I have made disposition decisions on two proposed editorial changes submitted by the NEI TSTF (traveler numbers EDIT-017 and EDIT-018). The disposition and basis for the disposition is contained in the enclosure.

Please contact me at (301) 415-1161 or e-mail wdbenrc. gov if you have any )

questions or need further information on these dispositions. 1 Sincerely,

)

i (p' & D. fp f k William D. Beckner, Chief Technical Specifications Branch Associate Director for Projects l Office of Nuclear Reactor Regulation 1

Enclosure:

As stated l

l l

DISPOSITION OF TRAVELERS TSTF 105 REJECT: The changes showed that the reference to a precision calorimetric heat balance are modified or deleted and replaced by " measured" or modified by "other means", which is unacceptable. This change usually refers to an l I

alternate means of measuring RCS flow using cold leg elbow tap flow measurement, a method not designed for as a primary flow device. Therefore, i flow uncertainties are plant-specific, requiring any change be reveiwed individually to reflect plant differences (e.g., 4-loop flow is mirror I symmetric: 3-loop flow is not symmetric).

l TSTF 151 1

MODIFY: Changes made in ACTIONS D.1. D.2. E.1. E.2. E.3. E.4. G.I. and G.2 l are not acceptable since they conflict with the Applicability in LC0 3.4.12.

THE LTOP is needed during MODES 3. 4. 5. and 6 with reactor vessel head on. l Retain MODE 5 in WDG Bases. ACTIONS Section D.1 and D.2: E.1. E.2. E.3, and 3.4: and G.i and G.2. All other proposed changes are acceptable.

TSTF-167 REJECT: Strict controls over entry into High Rad Areas must be authorized (via work pennit, dosimetry must be obtained. locked areas unlocked, etc.)

Entries not authorized are " unauthorized." " Inadvertent" can give an implication of simple mistake and a lack of responsibility.

TSTF-173 APPROVE: Changes approved as proposed.

EDIT 017 H0DIFY: It is not clear that changes to 3.4.16 RCS Specific Activity ACTIONS A., B. and C. are editorial or what the justification for the change is (no reasons given for adding " specific activity" to CONDITION and REQUIRED ACTION or replacing "of the reactor coolant not within limit." with an equation.

All other changes are acceptable.

Page 1

EDIT.018 MODIFY: 1. CEOG B 3.6.6A BACKGROUND - Containment Spray System Subsection:

The OG proposes to replace the phrase "...to reduce the concentration of fission products...' with "...to minimize the concentration of fission products..." This is characterized as an editorial correction, and it would also apply to NUREG-1430 (B&W) B 3.6.6 and NUREG 1431 (W) B 3.6.6.A, not just to the CE STS as stated in the package. Insufficient justification is provided in the change package to determine if this is an editorial change or a technical change. However, based on the first paragraph in B 3.6.6.A, BACKGROUND, which discusses reduction of fission release with regard to system design and GDC 41, the staff views the change as technical. To minimize would mean that, for all situations, a specific limit would be obtained. However, the Containment Spray System in the specification is being used to remove iodine and fission products from the containment atmosphere following a LOCA. Thus, the system was designed to meet GDC 41 " Containment Atmosphere Cleanup" which states that " systems to control fission products...which may be released into he reactor containment shall be provided to reduce...the concentration and quality of the fission products released to the environment..." The amount of reduction based on the GDC would vary depending on the conditions with the DBA being the limiting condition. Thus, based on GDC 41, " reduce the concentration of fission products" is the correct terminology that should be used, for this general statement. Therefore, the change to B 3.6.6.A BACKGROUND is rejected.

2. CEOG B 3.6.6.A LCO: The deletion of " typically" from the last paragraph in the LCO section is acceptable. The LCO section describes what constitutes an OPERABLE system, and therefore should be specific. Thus, " typically" i need not be included. However, this change also applies to NUREGs-1430 l (B&W) B 3.6.6 LCO, -1431 (W) B 3.6.6. LCO and B 3.6.6.B LCO, and -1432 l (CE) B 3.6.6. LCO.

3. CEOG B 3.7.1 SURVEILLANCE REQUIREMENTS SR 3.7.1.1: The editorial correction would make NUREGs 1431 (W) and -1432 (CE) consistent.

However, changing the "and" in the sentence to "with" would make NUREGs-1430 (B&W) and -1432 (CE) consistent. Either version-NUREG 1430 ("with") or NUPEG 1431 ("be")-is acceptable, but it should be consistent between all OGs. Make the wording consistent for all PWR OGs STS. l Page 2

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