ML20209B314
| ML20209B314 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/1999 |
| From: | Beckner W NRC (Affiliation Not Assigned) |
| To: | Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9907060376 | |
| Download: ML20209B314 (4) | |
Text
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,,,,, June 28, 1999 Mr. James Davis Nuclear Energy institute l
1776 Eye Street, N. W.
Suite 300 Washington, DC 20006-2496
Dear Mr. Davis:
l l Based on recent discussions with Dan Williamson, EXCEL Services, Inc., it has come l to our attention that while a disposition on TSTF-052, Rev.1, was forwarded to NEl by letter l . dated January 13,1999, the staff's comments may not have been officially transmitted to the l Owner's Group. Therefore, I am transmitting the staff's eight comments and addendum to you l with this letter. These comments were provided to and discussed with Bryan Ford, former l BWR Owner's Group Chairman, at a December 15,1999 Focus Group meeting, then i
supplemented in our January 13,1999 letter to you.
l Should the TSTF have any comments or questions, please do not hesitate to contact l me on 301-415-1161 or by e mail at wdb@nrc. gov.
Sincerely, Wf db l William D. Beckner, Chief )
Technical Specifications Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation 1
Enclosure:
As stated cc- N. Clarkson, BWOG H. Pontious, BWROG T. Weber, CEOG I D. Buschbaum, WOG i D. Hoffman, EXCEL mJ {&) j f1 odd 3 Va'k8%$8*Qc m.
TSB STAFF COMMENTS ON TSTF-052, REVISION 1
- 1. NURUG-1433 SR 3.6.1.3.12 and NUREG-1434 SR 3.6.1.3.9 have a NOTE 2 which states that the results of the SR are to be evaluated against the acceptance criteria of SR 3.6.1.1.1.
The Bases for these two SRs do not contain a discussion of NOTE 2. NUREGs-1431 and
-1432 have similar SRs (SR 3.6.3.11 and SR 3.6.3.9, respectively) but the SRs do not have a similar NOTE. The NOTE was deleted per BWR-14 in NUREG-1433 and -1434. The NOTE should be dropped.
- 2. The Bases inserts for WOG and BWR/6 are not included in the package.
- 3. The [ Primary) Containment Leakage Rate Testing Program does not include the following statement which was in the November 2,1995 letter from the NRC to D. J. Modeen: "The provisions of SR 3.0.2 do not apply to the test frequencies specified in the [ Primary]
Containment Leakage Rate Tssting Program." The statement was incorporated into the Bases discussion for SR 3.0.2. This is unacceptable (see Comment Number 4). Retain the statement in the Program Description.
- 4. In the responses to the NRC Comments to TSTF-052, Rev. O, items 3 and 4, the Owners Group states that the Bases changes for SR 3.0.2 are consistent with the November 2,1995 letter from the NRC to D. J. Modeen. Insert D is not consistent with the changes made by the November 2,1995 letter. In addition, insert D makes the statement that "SR 3.0.2 does not apply to any requirements in Section 5, Administrative Controls, unless otherwise stated." This is unacceptable to the staff. This change is beyond the scope of TSTF-052 in that it affects more than just the Containment Leakage Rate Testing Program. It is the staff position that SR 3.0.2 does apply to the frequencies that are explicitly stated in Section 5.0 (i.e., " Diesel Fuel Oil Testing Program") or encompassed within a special program (i.e., " Radioactive Effluent Controls Program"), revise the Bases for SR 3.0.2 to conform to the November 2,1995 letter.
- 5. In NUREG-1431 B 3.6.1 - Bases Containment (Ice Condenser) the first paragraph in APPLICABLE SAFETY ANALYSES should include "(DBA)" after " Design Basis Accident" since this is the first time that Des Jn Basis Accident is used and the acronym (DBA) is used in the succeeding paragraphs.
- 6. In NUREG-1431 B 3.6.1 Bases Containment (Dual) SR 3.6.1.1 shows the addition of Insert A, at the bottom of page B 3.6-19. This is the incorrect location for this insert. It should go at the end of SR 3.6.1.1 on page B 3.6-20.
- 7. In the responses to the NRC comments to TSTF-052, Rev. O, item 7, the Ownofs Group stated that " NOTE 2 was added to NUREG-1433 SR 3.6.1.2.1. Additionally, the Bases were revised to reflect this change." Even though the Bases change was in accordance with the November 2,1995 letter from the NRC to D. J. Modeen, it is inconsistent with the NOTE description provided for the other NUREGs. Make NUREG-1433 consistent with the other NUREGs.
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- 8. In the responses to the NRC comments to TSTF-052, Rev. O, item 1, the Owners Group states that "the TSTF and the NRC reached agreement that the current revisions of the NUREGs provide the required guidance for Option A. Thus, if a utility utilizes Option A, it could ,
refer to Revision 1 of the NUREGs. If a utility utilizes Option B, then they could utilize this traveler." This staff reviewer has been' unable to confirm this agreement. However, even if the above agreement had been made, the staff does not now believe this agreement is workable. l This is based on staff intentions to issue a Revision 2 to the NUREGs which would supersede i Revision 1 and incorporate TSTF-052 and recent conversion submittals which tried to implement TSTF-052, Rev. O when it was not applicable to the facility. It was the staffs intention in its comments to TSTF-052, Rev. O and in subsequent discussions with industry representatives (D. Hoffman) that TSTF-052 address all possible combinations of Appendix J particularly the mixed combination of Option A/ Option B since a substantial number of plants have this mix in their current TS. The combinations are: a) Type A, B, and C testing performed :
in accordance with Option A; b) Type A, B, and C testing performed in accordance with Option B; c) Type A testing performed in accordance with Option A while Type B and C testing is performed in accordance with Option B; and d) Type A testing performed in accordance with Option B while Type B and C testing is performed in accordance with Option A. Therefore, TSTF-052 should be revised to address the above combinations, it should be noted that the responses to the above comments will be affected by this change. In particular, Comment ,
Numbers 1,5, and 7 apply to all combinations, while Comment Numbers 2,3,4, and 6 !
definitely apply to Option B but may have an impact on combinations c) and d). In addition, the other proposed changes in TSTF-052 need to be evaluated for their applicability to the various combinations. For example, the change in SR 3.6.1.1 (PWRs)/3.6.1.1.1 (BWRs)
Bases of "< 0.75La" to "=< 0.75 La" is acceptable only for Option B; Option A must remain "<
0.75La".
'1/7/99 l
- 8. (ADDENDUM) Based on discussions with the OG and NRC on December 15,1998 on this subject, the staff still requires all combinations to be addressed. However, combinations e and i d can be addressed by a Reviewers Note, telling the reviewer / user that a combination of Option A and Option B must be used. For the Option A and Option B format in the SR and Bases, a format similar to the ono used in NUREG-1432, CEOG STS B3.6.2, "Cantainment Air Locks (Atmospheric and Dual) Bases - APPLICABLE SAFETY ANALYSES is acceptable to the staff.
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Dune 28, 1999 Mr. James Davis Nuclear Energy institute 1776 Eye Street, N. W.
Suite 300 .
Washington, DC 20006-24961
Dear Mr. Davis:
Based on recent discussions with Dan Williar6 son, EXCEL Services, Inc., it has come '
to our attention that while a disposition on TSTF-052, Rev.1, was forwarded to NEl by letter I dated January 13,1999, the staffs comments may not have been officially transmitted to the Owners Group.' Therefore, I am transmitting the staff's eight comments and addendum to you !
with this letter. These comments were provided to and discussed with Bryan Ford, former BWR Owners Group Chairman, at a December 15,1999 Focus Group meeting, then ;
supplemented in our January 13,1999 letter to you. ,
Should the TSTF have any comments or questions, please do not hesitate to contact me on 301415-1161 or by e-mail at wdb@nrc. gov.
Sincerely, Original signed by:
William D. Beckner, Chief TechnicafSpecifications Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation 1
Enclosure:
As stated cc: N. Clarkson, BWOG DISTRIBUTION:
H. Pontious, BWROG FILE CENTER T. Weber, CEOG PUBLIC D. Buschbaum, WOG DMatthews D. Hoffman, EXCEL SNewberry TSB ShN TSB R/F DOCUMENT NAME: G:VRTSBUOHNSON\0623NEl LTR.WPD *See previouAoncurren::e OFFICE NRR/ DRIP /RTSB NRR/ProJ. SS9 NRg/DAP)lUtB NRR/ DRIP /RTSB NAME DLJohnson* SMagrude/f6 '
RLb6nnig WDBecknerWS DATE. 06/23/99 06/2f/99 06/2ff99 06/8 /99 OFFICIAL RECORD COPY
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