ML20206A926
| ML20206A926 | |
| Person / Time | |
|---|---|
| Issue date: | 04/21/1999 |
| From: | Beckner W NRC (Affiliation Not Assigned) |
| To: | Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9904290086 | |
| Download: ML20206A926 (12) | |
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Mr. James Dsvis April 21, 1999 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 un twenty-one travelers containing proposed changes to the Standard Technical Specification (STS) NUREGs made by the NEl I Technical Specification Task Force (TSTF). Those travelers that were Approved are TSTFs - )
239, -300, -301, -307 and -311. Thore travelers that were Modified, after discussion with the respective Owner's Group Chairman, were TSTFs -092, R.1; -207, R.1; -242; -266; -271; -272;
-280; -283; -288; -309; and -322. In my letter to you dated July 16,1998, the following travelers were recommended for Rejechon: TSTFs -204, -254, -274, -275, and -276. After )
discussion with the respective Owner's Group Chairmen, these travelers are officially l Rejected Please see the enclosure for NRC comments with regard to the travelers that were modified, and the enclosure to my July 16,1998 letter for comments with regard to the travelers that were rejected.
For your information, the followmg travelers are awaiting evaluation by a technical branch: 1 TSTFs -212, R.1 (EICB); -226 (SRXB), -262 (SRXB), -263, R.1 (SRXB), -264 (SRXB), -265 I (SRXB), -287, R.2 (SPLB & SPSB); -298 (SPLB); -313 (MCEB); -315 (EICB); -318 (SRXB); l and -321 (EMCB).
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, Odpad R"d D l
William D. Beckner, Chief Technical Specifications Branch Division of Reguistory improvement Programs Office of Nuclear Reactor Regulation 9
Enclosures:
As stated cc: N. Clarkson, BWOG D. Wuokko, BWOG B. Ford, BWROG l T. Webber, CEOG D. Bushbaum, WOG D. Hoffman, EXCEL f DISTRIBUTION H
\ ard copy: E-mail: ^S0073 File Center PUBLIC WDBeckner TSB Staff TSB Reading File
)OCUtENT W thK: 01DLJ\0499 DIS WPD A OFFICE RTSB/ DRIP /NRR RTSEV6fW/plR% RTSB/ DRIP /NRR j NAME DLJohnson MI. RLDdpriin ' WDBeckner (#F)_ i DATE 04/20/99 0 04/-)J /99 04/J/ /99 ,
OFFICIAL RECORD COPY
'9904290086 990421 PDR REV0P ER C { p[9 N ,
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. SneeHoo1
\,a..,*/ April 21, 1999 I
Mr. James Davis i 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 twenty-one travelers containing proposed changes to the Standard Technical Specification (STS) NUREGs made by the NEl Technical Specification Task Force (TSTF). Those travelers that were Approved are TSTFs -
239, -300, -301, -307 and -311. Those travelers that were Modified, after discussion with the respective Owner's Group Chairman, were TSTFs -092, R.1; -207, R.1; -242; -266; -271; -272;
-280; -283; -288; -309; and -322. In my letter to you dated July 16,1998, the following travelers were recommended for Rejection: TSTFs -204, -254, -274, -275, and -276. After discussion with the respective Owner's Group Chairmen, these travelers are officially Rejected. Please see the enclosure for NRC comments with regard to the travelers that were modified, and the enclosure to my July 16,1998 letter for comments with regard to the travelers that were rejected.
For your information, the following travelers are awaiting evaluation by a technical branch:
TSTFs -212, R.1 (EICB); -226 (SRXB), 262 (SRXB), -263, R.1 (SRXB), -264 (SRXB), -265 (SRXB), -287, R.2 (SPLB & SPSB); -298 (SPLB); -313 (MCEB); -315 (EICB); -318 (SRXB);
and -321 (EMCB).
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, Q d 2-< & (4,&
William D. Beckner, Chief Technical Specifications Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation
Enclosures:
As stated cc: N. Clarkson, BWOG D. Wuokko, BWOG B. Ford, BWROG T. Webber, CEOG D. Bushbaum, WOG D. Hoffman, EXCEL l l
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DISPOSITION
SUMMARY
TSTF-092. R.1: Modifv Per telephone conference with Denny Buschbaum on April 1,1999, this proposed change, which falls under the category of " met vs performed" issue, is Modified to address this issue if revised.
TSTF-207. R.1: Modifv 1
After discussion with Bryan Ford, BWROG Chairman and the Containment Systems
' Branch, NRC is Modifying this proposed change to accept the change to the Note to Condition A and B. However, the change to ACTION D with regards to purge valve leakage is not sufficiently justified in the justification, but a valid justification is provided in the Reviewer's Note of Insert 3 to the Bases. . The concern is valid, but it should be made part of ACTION E rather than D.
In addition, failure of the STS 3.6.1.3 PCIV Leakage SRs would render those PCIVs inoperable and require entry into STS 3.6.1.3 ACTION A or C for hydrostatically tested valves or EFCVs, ACTION D for secondary containment bypass and MSIV leakage, ACTION E for purge valves, and STS 3.6.1.1 if total valve leakage exceeds Appendix J limits in addition, the justification states that Required Action A.1, B and C would allow isolation using the leaking valve. Based on the staff interpretation above, it would not allow this since the valve / penetration would not meet the SR leakage requirement, and i isolation would have to be accomplished using another valve. Furthermore the Completion
. Time proposed for EFCVs is based on TSTF-323 which is still under review by the staff.
TSTF-242: Modifv -
The TSTF fails to make a strong case that the 4-hour test AOT is an inadequate standard for testing. The staff will consider plant specific justifications for the proposed change if' they substantiate that the plant is somehow limited by their designs or surveillance practices (e.g., one technician performs all testing) from complying with the NUREG 4-hour-limit. Additionally, the proposed frequency needs to substantiate the proposed change with data recorded during plant COT testing for the PRNM and IRNM channels.
The staff will accept a change that puts the SR 3.3.1.8 4-hour test frequency in braces, i.e., [Four] hours after reducing power below P-10 for power and intermediate range instrumentation.
L TSTF-266: Modifv Modify the proposed changes to relocate the Remote Shutdown System instrumentation and Controls Table to the Remote Shutdown System TS Bases and move the " Reviewer's Note" in each LCO section of the Bases to the table of required Remote Shutdown System Instrumentation and Controls as a footnote. The Bases table footnote shall state "For channels that fulfill GDC 19 requirements, the number of OPERABLE channels required is based on the plant licensing basis as described in the NRC unit specific Safety Evaluation Report (Reference [4]). - Generally, two divisions are required OPERABLE. However, only J.__
en2 channsiis requirrd if ths unit his justifitd such a drsign and ths NRC's SER acceptsd tha justification."
TSTF-271: Modifv The proposal to change the statement in CEOG and WOG SR 3.4.12.5 Bases from "The passive vent arrangement must only be open to be OPERABLE' to "Any passive vent path arrangement must only be open to be OPERABLE" is not necessary. Moreover, the proposed wording for this item could be misleading. Keeping the word "The" instead of the proposed word "Any" ensures that this statement is in reference to only the vent paths required by this LCO. Therefore, SRXB recommends that this change not be made.
The proposed wording for the BWOG should be modified accordingly (use "The" in place of the proposed "Any"). This concern was discussed with an industry representative at which time it was agreed that the word "The" will be retained.
j TSTF-272: Modifv The staff agrees with the statement that while in MODE 6, the refueling canal and the refueling cavity are isolated from the RCS, and that no potential path for boron dilution in j these components exist. However, since the applicant has not demonstrated to the staff )
that these component (s) (the refueling cavity and the refueling canal), can be maintained at the same concentration as they were in MODE 6 while they are isolated, the staff finds the proposed change is unacceptable. After relaying this information to the CEOG Chairman, it was agreed that TSTF-272 would be modified to provide additional j justification and Bases words. Also, the CEOG Chairman agreed to consider modifying the l Applicability to add the words "For refueling canal and cavity only when connected to the RCS." i l
. TSTF-280: Modifv The staff accepts the proposed changes except for the change in the note in the SR for performing a COT on each required PORV. This change would modify the wording of the note to "not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after..." instead of the current wording of "not required to be met until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after..." This is a " met vs performed" issue, which will not be resolved in the near future.
TSTF-283: Modify The staff rejects the TSTF proposal to delete all Mode restrictions on Surveillance Requirements in Section 3.8 of all 5 NUREGs. However, the staff recognizes that, in certain situations, SRs must be performed to reestablish system / component OPERABILITY.
In these cases, the risk associated with performance of the SRs at power may be less than the risk associated with a plant shutdown to perform the SRs. Therefore, the staff recommends that TSTF-283 be modified to retain the Mode restrictions, but to allow performance of some SRs at power when necessary to reestablish OPERABILITY following corrective maintenance. (Note: this will not be applicable to some SRs which can not be performed at power for any reason.)
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TSTF-288: Modifv s Th3 proposed wording is not claar in that it could be interpreted to mean that the test may be performed in MODES 1 or 2: when, in fact, the intent is for the test to be performed soon after establishing appropriate temperature and pressure conditions (i.e., as high as MODE 3 for some plants). In addition, as discussed in NRC Generic Letter 90-06 and in order to minimize the likelihood of a stuck open PORV, stroke testing of the PORVs should not be performed during power operation. We have discussed these concerns with industry representatives at which time the following wording was verbally proposed and agreed to: "Not required to be performed prior to entry into MODE 3." With this wording, plants'would be allowed to enter MODE 3 prior to performing the test in order to establish
= the required temperature and pressure conditions. However, since the applicability of the corresponding LCO includes MODES 1,2, and 3, SR 3.0.4 will not allow a plant to enter MODE 2 unless the test has been performed. Therefore, SRXB finds the agreed upon words acceptable to be included as notes to SRs 3.4.11.1 and 3.4.11.2. The changes to the Bases sections were also reviewed and found acceptable.
TSTF 309: Modifv The staff accepts the addition of the NOTES indicating that Required Actions C1, C2, F1, F2, and F3 do not apply when block valve is inoperable solely as a result of complying with Required Actions B2, and E2 ( e.g., as a result of a failed control power fuse (s) for control switch malfunctions). However, the associated Bases changes must include language to the effect that "It is preferable to have the block valve in manual control, however, this may not always be possible for all causes of entry into Condition B or E with the PORV(s) inoperable and not capable of being manually cycled ( e.g., as a result of a failed control power fuse (s) or control switch malfunctions)." The basis of SRXB acceptance is that when the associated block valve is closed with power removed (need two operator actions to open the block valve), a potential PORV-LOCA is unlikely. In a teleconference with WOG on January 19,1999, WOG agreed to add words in the associated TS Bases which would provide reasons for which to place the PORVs in manual control may not be possible.
- TSTF-322: Modifv The proposed changes to the SR Frequency is confusing when one considers the definition of STAGGERED TEST BASIS. The staff suggests that the SR wording be changed to be
- more consistent with the wording of the STS 3.7 SRs and that the frequency not be modified (NRC has made appropriate pen-and-ink changes to CEOG section 3.6.11 (Dual),
WOG 3.6.19, BWR/4 3.6.4.1, and BWR/6 3.6.4.1, and are attached to this enclosure).
In general, the Bases changes seem acceptable. However, consideration should be given j to making the Bases wording similar to the wording found in the Bases for STS 3.7 for i similar SRs, or consider making the same Bases changes in STS 3.7, SRs. In addition, one I
. sentence is the one that states that; since this SR is a shield building / secondary - :
containment integrity test, the inoperability of the Shield Building Air Cleanup System i (SBACS)/ Standby Gas Treatment System (SGTS) train does not constitute a failure of this i
' SR. This SR serves two purposes: it verifies the shield building / secondary containment integrity and, along with other SRs, it verifies the capability of the SBACS/SGTS to limit -
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, o r:dioactiva rsl::s:s. Th3 szntencs cnly impli2s one purposa. Th3 santance ciso impliss th:t o syst2m fcilure does n:t ccnstituta a frilura cf tha SR. This is not entirely true. J There are three failure modes for this SR and the failure mode will determine which actions are to be taken. The failure modes are: a system inoperability, a building integrity inoperability, and both a system and building integrity inoperability. The sentence should be modified to address these failure modes or deleted.
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TECHNICAL BRANCH NAMES AND ACRONYMS Division of Enaineerina (DE)
Materials and Chemical Engineering Branch (EMCB)
Mechanical and Civil Engineering Branch (EMCB)
Electrical and instrumentation Controls Branch (EICB)
Division of Systems Safety and Analysis (DSSA)
Plant Systems Branch (SPLB)
Reactor Systems Branch (SRXB)
Probabilistic Safety Assessment Branch (SPSB) i
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/2C (JM4s 73TF-32L Shield Building (Dual)
. 3.6.11 SURVEILLANCE REQUIREMENTS (continued) ,
SURVEILLANCE FREQUENCY SR 3.6.11.2 Verify each door in each access opening is 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> closed, except when the access opening is being used for normal transient entry and exit ;; then, at least one door shall be closed).
SR ,3.6.11.3 Verify shield building structural integrity During shutdown by performing a visual inspection of the for SR 3.6.1.1 exposed interior and exterior surfaces of Type A tests the shield building.
SR 3.6.11.4 Verify Shield Building Exhaust Air (18)sonthsy Cleanu stem tra 4 trna 1 ylpw ratje C
more negative than resj3re equal to or
.25 i W water gauge in the annulus with n [1]) minute'after a ^
start signal. '
(w orn A F,a n u h 0" ^
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CE0G STS 3.6-34 Rev 1, 04/07/95
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UW 73TF-32L Shield Building (Dual cnd Ice Crndenser) 3.6.19 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.19.2 Verify each door in each access opening is 31 days closed, except when the access opening is being used for normal transient entry and exit [; then, at least one door shall be closed).
SR 3.6.19.3 Verify shield building structural integrity During by performing a visual inspection of the shutdown for exposed interior and exterior surfaces of SR 3.6.1.1 the shield building. Type A tests SR 3.6.19.4 Verify SN eld Buildina Air Cleanup [18] months on J System train (d "t? Thd ;/[ / ] ;;O a STAGGERED
@M a pressure equal to or more TEST BASIS negative than [-0.5:1 inch water gauge in
[y the annulus within ll22] seconds after a start signa .
h rw m Tw siiint ns.6d.,se, g i
un A f .a A s fuw
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l WOG STS 3.6-65 Rev 1, 04/07/95
T.STF- 627-(Al(L L C M 4 0 }
[ Secondary] Containment 3.6.4.1 ACTIONS )
CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2 Suspend CORE Immediately ALTERATIONS.
AtEl C.3 Initiate action to Immediately suspend OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1.1 Verify [ secondary) containment vacuum is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 1 [0.25] inch of vacuum water gauge. ,
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l SR 3.6.4.1.2 Verify all (secondary) containment 31 days equipment hatches are closed and sealed.
SR 3.6.4.1.3 Verify each 1; secondary) containment 31 days access door 1s closed, except when the access opening is being used for entry and exit [. then at least one door shall be closed).
e-h3.6.4.1.4 Verify tand as treatment [181monthso$
(SGT) stem raw down the a 5"AGGERED
[ secondary) conta< nment to TEST BASIS 1 [0.25L inch of vacuum water % gauge in s [120] seconds.
(continued)
BWR/4 STS 3.6-48 Rev 1, 04/07/95
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C. C4I.444r3 75TF- 32 L
[ Secondary) Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.4.1.5 Verify td SGT subsystem can maintajah (18] months on 2 [0.25 neh of vacuulm w ter gauge a STAGGERED
@e [stconsary)conuinmeUt for I ho@ur at TEST BASIS a flow rate 5 J,4000) cra.
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9 BWR/4 STS 3.6-49 Rev 1, 04/07/95
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MILC CtwGe6 13TF- 52h
-- 3.6.4.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.4.1.3 31 days Verify accesseach door[ is secondary containment) closed, except when t he access opening is being used for entry and exit [, then at least one door shall be closed).
SR 3.6.4.1.4 Verify ndby gas treatment (SGT) [18] months on subsyst draw down the Isecondary a STAGGERED containmen to 2 [0.25) inch of vacuu TEST BASIS water gauge in 5 [120) seconds.
on SR 3.6.4.1.5 Verify GTsubsystemcanmaintainh [18] months on h [0.2 ch of vacuum water gauge @ a STAGGERED gnr I(ee' onery /contvinment/Dfor 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at TEST BASIS a flow rate s [4000; cts.
tcaaheet Con %anM] A
]
BWR/6 STS 3.6-46 Rev 1, 04/07/95
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