ML20206Q605
| ML20206Q605 | |
| Person / Time | |
|---|---|
| Issue date: | 02/16/1999 |
| From: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Burrows F NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20206Q280 | List: |
| References | |
| NUDOCS 9905190175 | |
| Download: ML20206Q605 (2) | |
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February 16, 1999 MEMORANDUM TO: Fr$derick H. Burrows, Efectrical Engineer Electrical EngineerinD Branch
.DMalon of Engineering Office of Nuclear Reactor Regulation FROM:
Wimam D. Travers Alb e
Executive Director for Operations
SUBJECT:
FINAL DECISION: DIFFERING PROFESSIONAL OPINION ON TECHNICAL SPECIFICAT!ON SETPOINTS AND All 'J'VABLE VALUES FOR INSTRUMENTATION Your memorandum to the previous Executive Director for Operations, Mr. L.J. Callan, dated August 5,1998, expressed your view that the resolution of your Differing Professional View on technical specification setpoints and allowable values as expressed in a memorandum to you from Samuel Collins, dated July 24,1998, was unsatisfactory and requested that the issue be considered a Differing Professional Opinion (DPO). The review of your issue has been completed and this memorandum documents my final decision.
As part of that resolution process, Mr. Callan chartered, by memorandum dated August 24, 1998, an ad hoc panel to review the issue. Margaret V. Federline was appointed chair of the panel and Charles E. Rossi and Virgil L. Beaston were members. Mr. Beaston was one of the staff members recommended by you to serve on the panel.
Attached is a copy of the report, dated January 15,1999, that was issued by the ad hoc panel.
The ad hoc panel agreed with the Differing Professional View panel and the staff that use of i
either the trip setpoint or allowable valuo as the Limiting Safety System Setting required by 10 CFR 50.38 does not pose a safety issue. The ad hoc panel further concluded that if a trip occurs at the allowable value, or at a setting more conservative than the allowable value, the applicable safety limits will not be exceeded. Therefore, it is possible to justify the use of allowable values in the technical specifications to satisfy the requirement (in 10 CFR 50.36) that the technical specifications contain the limiting safety system setting. I concur with these conclusions.
The ad hoc panel believes that the staff's current approach of including allowable values in improved Standard Technical Specifications (ISTS) to satisfy the requirements of 10 CFR 50.36 is technically adoquate. However, the panel also believes that the staff should more clearly document its basis for accepting the inclusion of allowable values rather than trip setpoints as Limiting Safety System Settings in ISTS such that automatic protective devices function as required ensuring that safety limits are met. The panel, therefore, recommended that the staff clearly document this basis, make it available to you and the public, and include it in the bases section of future plant ISTS.
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2 I concur with the ad hoc panel's recommendation. Therefore, I have requested that the Director of the Office of Nuclear Reactor Regulation (NRR) provide a schedule for preparing the basis, for providing that basis to you and the public, and for the first ISTS that will contain that basis.
Given that this is not a safety issue, the schedule must cor. sider other priority tasks in'the office.
I have attached a copy of my memorandum to the Director for your information.
I want to thank you for your participation in the Differing Professional Opinion process. Open and thorough debate on how we perform our regulatory programs is essential to keeping these programs effective and efficient.
Attachments: As stated cc:
Margaret Federline Charles E. Rossi Virgil L. Beaston Samuel Collins J. David Woodend i
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