ML20217C978
| ML20217C978 | |
| Person / Time | |
|---|---|
| Issue date: | 10/06/1999 |
| From: | Beckner W NRC (Affiliation Not Assigned) |
| To: | Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| PROJECT-689 NUDOCS 9910140127 | |
| Download: ML20217C978 (8) | |
Text
'... a0 October 6', 1999
- Mr. James Davis, Director Operations Department l Nuclear Energy Institute
' 1776 i Street, N, W.
- Suite 400 *
.. Washington, DC 20006-3708.
p
Dear Mr. Davis:
- This is to' inform you of our decisions on changes to the Standard Technical Spe# cation f (STS) NUREGs proposed by the NEl Technical Specification Task Force (TSTF) those travelers Approved are TSTFs -329 and -353. .Those travelers Modified are TST7 s -263, R.2;
- -265, R.1; -272; and -287, R.2.= Those travelers Rejected are TSTFs -113, R.4 and -282. Our comments on those travelers Modified or Rejected are enclosed.
- For your information, the following travelers are pending evaluation by a technical branch:
- TSTFs -052, R.2 (SPLB); -207, R.3 (SPLB); -226 (SRXB); -264 (SRXB); -295 (EICB); -296 (SRXB); -297 (SPLB); -306 (EICB); -313 GMEB); -332 (EICB); -334 (SPLB & SPSB); -335
- (SPLB); -336 (SPLB); -337 (SRXB); ~-343 (EMEB); -344 (SRXB); -345 (SRXB); -350 (SRXB);
. and -352 (SRXB)
- Please contact me at (301)'415-1161 or e-mail wdb@nrc. gov, if you have any questions or need furtherinformation.
' Sincerely,
" Original Signed by R.L. Dennig for" William D. Beckner, Chief Technical Specifications Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation Project No. 689 .
Enclosures:
As stated j cc: N. Clarkson, BWOG DISTRIBUTION:
\ FILECENTER TSB R/F /
L H. Pontious, BWROG ' \ PUBLIC TSB Staff T. Weber, CEOG DMatthews/SNewberry D. Buschbaum, WOG D. Hoffman, EXCEL WDBeckner RLDennig 9 foj
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% ..... p' ' Oct.ober 6,1999 Mr. James Davis, Director Operations Department Nuclear Energy Institute 1776 l Street, N. W.
Suite 400 Washington, DC 20006-3708
Dear Mr. Davis:
This is to inform you of our decisions on changes to the Standard Technical Specification (STS) NUREGs proposed by the NEl Technical Specification Task Force (TSTF). Those travelers Approved are TSTFs -329 and -353. Those travelers Modified are TSTFs -263, R.2;-265, R.1;-272; and -287, R.2. Those travelers Rejected are TSTFs -113, R.4 and -
282. Our comments on those travelers Modified or Rejected are enclosed.
For your information, the following travelers are pending evaluation by a technical branch:
TSTFs -052, R.2 (SPLB); -207, R.3 (SPLB); -226 (SRXB); -264 (SRXB); -295 (EICB); -296 (SRXB); -297 (SPLB); -306 (EICB); -313 (MCEB); -332 (EICB); -334 (SPLB & SPSB); -335
-- (SPLB); -336 (SPLB); -337 (SRXB); -343 (EMEB); -344 (SRXB); -345 (SRXB); -350 (SRXB);
and -352 (SRXB).
Please contact me at (301) 415-1161 or e-mail wdb@nrc. gov, if you have any questions or need furtherinformation.
Sincerely, William D. Beckner, C Technical Specifications Branch F Division of Regulatory improvement Programs i Office of Nuclear Reactor Regulation
~ Project No. 689
Enclosures:
As stated
- cc: N. Clarkson, BWOG H. Pontious, BWROG T. Weber, CEOG D. Buschbaum, WOG D. Hoffman, EXCEL L
~
Nuclear Energy Institute Project No. 689 cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute-Nuclear Energy institute Suite 400 Suite 400 1776 l Street, NW 1776 l Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineering, Inc.
Suite 400 12300 Twinbrook Parkway, Suite 330 1776 l Street, NW Rockville, Maryland 20852 Washington, DC 20006-3708 !
Mr. David Modeen, Director
{
Engineering 1 Nuclear Energy institute I Suite 400 1776 l Street, NW l Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Licensing j Nuclear Energy Institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 Mr. Hank Sepp, Manager Regulatory and Licensing Engineering -
Westinghouse Electric Corporation P.O. Box 355 Pittsburg, Pennsylvania 15230 Mr. Jim Davis, Director .
Operations Nuclear Energy Institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 i
l DISPOSITION
SUMMARY
I TSTF-263. R.2: Modifv
. Except for the items listed below, the' proposed changes are acceptable because they are clarifying in nature and do not reduce any of the intended technical requirements.
~
I
- 1. For all three vendors, the proposed wording for LCO 3.4.7, Action A.2 should be changed to use the same wording as proposed for Action B.2. This change is
, required to ensure that the operability of the steam generators is tied to the limits on secondary side waterlevel.
- 2. For all three vendors, a bases section needs to be provided for LCO 3.4.7, Action A.2.
- 3. For Westinghouse only, the proposed wording of the second part of LCO 3.4.5, Condition D, should be modified as follows to maintain consistency with the LCO
.wording which, on a plant specific basis (i.e., bracketed), could require more than one
_ loop to be in operation: Required RCS loop (s) not in operation.
3-
- 4. For Westinghouse only, the proposed placement of the word "not"in the first sentence of the bases section for LCO 3.4.7, Actions C.1 and C.2 is incorrect. SRXB recommends that placement of the word "not" be changed as follows: "If a required RHR loop is not in operation...."
,5. For Combustion Engineering only, the second part of LCO 3.4.5, Condition C is missing the word "not". SRXB recommends that the word not be added as follows to address the condition of a required RCS loop not being in operation: " Required RCS
. loop not in operation."
6.. For Combustion Engineering only, the first sentence of the bases section for LCO
. 3.4.6, Actions B.1 and B.2 should be modified as follows to address the co .dition of a required loop not being in operation: "If two required loops or trains are iruperable or a required loop or train is not in operation..."
e
' TSTF-265. R.1: Modify This request is acceptable provided thet the proposed note is modified as follows: "not i required to be met until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after a required pump is not in operation." Allowing a licensee 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to meet these SRs and using " met" in place of " performed" are both >
consistent with SR 3.0.3. SR 3.0.3 requires that, for a missed SR, a licensee either successfully complete (i.e., show that it meets) the SR within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the specified
. frequency of the SR or declare the corresponding limiting condition for operation not met.
The specified frequency for the subject SRs is 7 days, therefore 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would apply to SR 3.0.3.; The note proposed in the TSTF would allow a licensee to not start the SR until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the pump is not in operation which is inconsistent with SR 3.0.3.
i i
. . l TSTF-272: Modify
{
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 I 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 find the proposed change is unacceptable. The staff would agree to a modification whereby the j TSTF would submit a revision to include the phrase "For refueling canal and cavity only when connected to the RCS."
TSTF-287. R.2: Modify The staff has completed its review of the latest markup of the Bases for Action B.1 of the (Control Room STS contained in this TSTF and conclude that it is acceptable with one exception. Removal of the reference to GDC is unacceptable. _We believe that compensatory measures should have some fundamental technical basis, and that for the control room, GDC 19 is the standard for the fundamental technical bases we find acceptable; Compensatory measures that are not consistent with the intent of GDC 19 will ,
likely not provide the protection we believe is necessary. In addition, while this is an acceptable plan for the control room, we believe that a similar compensatory action plan
~s hould be provided for all the other buildings, should be consistent with the applicable regulations (GDC 19, Part 100, etc.), and that a similar Bases description should be provided in the other specifications modified by TSTF-287, Revision 2. Following is the proposed Insert 1.
L
' B.1
[ Reviewer's Note: Adoption of Condition B is dependent on a commitment from the licensee to have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into Condition B.)
If the control room boundary is inoperable in MODES 1,2,3, and 4, the CREVS trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE control -
room boundary within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the period that the control room boundary is
. inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) ;
should be utilized to protect control room operators from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature and relative humidity, and physical security. Preplanned measures should be available to address these concems for l
. intentional and unintentional entry into the condition. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is l reasonable based cA the low probability of a DBA occurring during this time period, and the ~
use of compensatory measures. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is a typically reasonable time to diagnose, plan and possibly repair, and test most problems with the control room
' boundary.
' TSTF-113. R.4: Relect The staff rejects the proposed changes for the following reasons:
m a) The statement regarding Mode 3 with the RCS average temperature <500*F that indicates that the leak flo:v through ruptured tube will stop after the SG is filled to capacity is not valid. Since the RCS temperature <500* F may/can be associated with a higher RCS pressure (around 2000 psia), following a SGTR, the leak flow will not stop because of a high delta P across the ruptured tube, caused by pressurization of the secondary side and will release the reactor coolant to atmosphere via lifted main steam safety valves.- Even if the RCS pressure is not higher than the main steam safety valve lift setpoint at the SGTR initiation point, having the main steam line filled with liquid water following a SGTR is still not acceptable.
b) There is margin between the temperature at Mode 4 (350' F) and the enable temperature of the LTOP system. The current STS will not cause any operational problems.
c) The proposed changes could lead to the loss of mitigation capability during a SGTR at a temperature less than 500* F.
Required Safety Analysis to support The Proposed TSTF-113 10 CFR 50.36(b) requires, in part, that the technical specifications (TS) must be derived from analyses and evaluation included in the safety analysis report (SAR), and amendments thereto, submitted pursuant to 10 CFR 50.34.10 CFR 50.36(c)(2)(ii)((B), Criterion 2 requires that TS limiting conditions for operation (LCOs) must be established for process variables, design features, or operating restrictions that are initial conditions of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.-
In TSTF-113, industry proposed TS changes that would reduce the operability requirement for power operated relief valves (PORVs) from the Modes 1 and 2 and the entire temperature range of Mode 3 to Modes 1 and 2 and Mode 3 with reactor coolant system (RCS) average temperature greater than or equal to 5009F. The proposed TS changes would allow plants to stay in Mode 3 with RCS temperature under 500 F (no restriction to RCS pressures) with both PORVs inoperable. PORVs were incorporated in plant designs as a design feature to, in part, mitigate the consequences of steam generator tube rupture (SGTR) events. SGTR events are design basis events that assume failure of the steam generator tubes (fission product barriers). Therefore, pursuant to 10 CFR 50.36(c)(2)(ii)(B), Criterion 2, LCOs on PORVs must be established. Furthermore, pursuant to 10 CFR 50.36(b), these LCOs must be derived from analyses and evaluations included in the SAR.
10 CFR 50.34(a)(4) and 10 CFR 50.34(b)(4) require, in part, that the SAR must include analyses and evaluations of the design and performance of structures, systems, and components of the facility with the objective of assessing the risk to public health and safety resulting from operation of the facility and including a determination of (i) the margins of safety during normal operations and transient conditions anticipated during the life of the facility, and (ii) the adequacy of structures, systems, and components provided for the prevention of accidents and the mitigation of the consequences of accidents. To rephrase i the relevant parts of these requirements, the analysis of the SGTR event (the event of l interest for the proposed change) must determine the margins of safety during normal operations and transient conditions anticipated during the life of the facility. Therefore, since l
1 u__..___
i normal operations' during the life of the facility include the entire temperature range of Mode 3, the analysis must also cover the entire temperature range of Mode 3.
Based on the above discussion, a_ licensing analysis supporting the requested change must -
be performed to demonstrate that radiological consequences will remain within acceptable limits. Current analyses cover plant operations with the PORVs operable. Therefore, the analysis supporting the requested change must address plant configuration with RCS average temperature between 3509F and 5009F and with the PORVs inoperable. Pursuant to 10 CFR 50.36, the staff can not approve the proposed change without such an analysis. A qualitative argument may not be used as' a substitute to the required analysis. In the analysis, a specific scenario and specific operating procedures should be considered and only safety grade equipment may be credited for mitigation of the event. Abnormal Operating Procedures (AOPs) used for mitigating this event should be described to show how they would be entered and used for RCS cooldown and depressurization which would be required to stop the leak from RCS to the secondary side of the steam generator with a ruptured tube.
Radiological consequences should be assessed and should consider all contaminated steam released to environment starting from the event initiation.
TSTF-282: Reiect The staff has reviewed the justification submitted by the TSTF in support of the change from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 days, and finds it inadequate. This is because no technical justification was submitted in support of its implication on a generic bases.
- O E
a TECHNICAL BRANCH NAMES AND ACRONYMS Division of Enoineerina (DE).
Materials and Chemical Engineering Branch (EMCB)
Mechanical and Civil Engineering Branch (MCEB)
Electrical and instrumentation Controls Branch (EICB)
' Division of Systems Safety and Analysis (DSSAY i
Plant Systems Branch (SPLB)-
)
Reactor Systems Branch (SRXB)
Probabilistic Safety Assessment Branch (SPSB)
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