ML20217E976
| ML20217E976 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/1997 |
| From: | Beckner W NRC (Affiliation Not Assigned) |
| To: | Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9710070331 | |
| Download: ML20217E976 (6) | |
Text
'
October 1, 1997 l
Mr. James Davis
' Nuclear Energy Institute 1776 Eye Street, N. W.
Suite 300 Washington, DC 20006 2496 l
Dear Mr. Davis:
i This is to inform you that disposition has been made_on ten proposed changes to the Standard Technical Specification NUREGs made by the NEI Technical Specification Task Force (TSTF). Enclosed is the disposition and a summary for travelers TSTF 030. R.2, 016, R.1, -064, 081 088. -093, R.2, 094, R.1, 123 R.1, 128, and 196.
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 Siped By William D. Beckner, Chief Technical Specifications Branch AssociateDirectorforProjects Office of Nuclear Reactor Regulation
Enclosure:
As stated
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% ,,,,, October 1, 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 ten proposed _ changes to the Standard Technical Specification NUREGs made by the NEl Technical Specification Task Force (TSTF). Enclosed is the disposition and a summary for travelers TSTF-030 R.2, -016, R.1, -064, -081, -088, -093, R.2, -094, R.1, -123, R.1, -128, and -196.
Please contact me at (301) 415-1161 or e-mail wdb9nrc. gov if you have any questions or need further information on these dispositions.
Sincerely.
(,4/ L O. $L William D. Beckner, Chief Technical Specifications Branch Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosures:
As stated cc: D. Hoffman, EXCEL L. Bush, WOG J. Volkoff, CE0G
- 8. Ford, BWROG C. Szabo, BWOG D. Wuokko, BWOG
DISPOSITION
SUMMARY
TSTF 30. R.2: Approve TSTF 16, R.1: Reject The proposed change is Rejected. If allowed, this change could mean that a (typical 2 train /div.) plant could have both 4160 VAC safety busses de energized for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> without requiring a plant shutdown (This assumes that the plant has not already tripped because of the multiple distribution subsystem inoperabilities.).
This is rot acceptable. NRC 02 should have been rejected for the same reason (The exagle is an extreme case, and there may be valid reasons why a plant shutdown in this scenario would not be the most prudent action. However, this is nct the issue at hand and should not enter into the discussion.).
This proposed change. as well as NRC 02 is a direct result of the apparent dissatisfaction with the co m romise reached on distribution systems during development cf the NUREGs. The appropriate action would be to revert to the distribution formet initially proposed by the staff and rejected by the OGs. That
! -format providcd an A0T for each electrical power distribution subsystem based on the impact of its inoperability. The OGs rejected this idea on the grounds that establishing the igatt of each inoperable distribution subsystem entailed an excessive amount of effort. Hc sever, this problem has apparently resolved itself because the OGs now indicate a willingness to evaluate the impact of multiple distribution subsystem inoperabilities for loss of function. Obviously, one can not I assess the igact of mitiple inoperabilities without thorough knowledge of the igact of all individual inoperabilities, Therefore, with this knowledge in hand, it is but a small step to assigning A0Ts for each distribution rubsystem.
In light of the fact that the staff does not accept the OGs proposal, the fact that the OGs are not satisfied with the NUREGs. and considering that' the issue of assessing the igact of each distribution subsystem has apparently been resolved, reverting to the initial staff proposal appears to be the logical solution.
TSTF 64: Modify The proposed changes to all of the STS related to I&C surveillance and testing should be revised to incorporate the revised definition of Channel Function Test provided by the Instrumentation & Controls Branch during the TSTF meeting on 3/18/97 ;
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2 TSTF 81: Approve TSTF 88: Modify Based on other experience. the staff believes that replacing "All" and *0ne or more" with Required
- Will not clarify the Mode definitions, as intended. Instead. TSB 1 recomends putting brackets around the terms and adding a reviewers note to include the appropriate licensing basis for vessel head removal.
TSTF 093, R.2: Modify Insert I should also be in the Bases, as approved for TSTF-093, R.I. Also, the statement regarding consistency is not needed in the Bases.
T5TF 094. R.1: Approve .
TSTF 123. R.1: Approve TSTF 128: Modify
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Modified to include the term " hydrated" because it is important to clearly specify that a hydrated form of TSP is used. From pt=t experience in many cases, licensees did not specify which form of TSP they were using and then inade the mistake in determining the required amount by either using ahydrous instead of hydrated TSP or vice versa. The justification should be changed to: "The chemical industry defines hydrated TSP as having 45 758 moisture content. The theoretical moisture content of TSP dodecahydrate is SSR and the theoretical moisture content of TSP decahydrate is 513. The basis for using the TSP 1r. a hydrated form is to ensure that it will not absorb large amounts of water. The word " granular" is removed because after the TSP has been in the containment baskets and absorbed some moisture from the containment atmosphere. it is no longer granular, but is still capable of performing its safety function."
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c 3 TSTF 1%: Rejected The STS (NUREG 143v to -1434 Revision 1) requires, in the REQUIRED ACTIONS (ras) and, in certain SURVEILLANCE RE0VIREMENTS (SRs) in STS 3.6.3 (PWRs) and 3.6.1.3 (BWRs), that penetrations be isolated by the use of at least one closed and denttivated automatic valve, closed manual valve, blind flange, or check valve with the flow through the valve secured, The proposed change would also allow isolation !
via " equivalent" isolation methods. The basis for the change is that equivalent isolation methods are alltswed in LCO 3.9.3 (B&W and CE STS) and LCO 3.9.4 (W STS) and would be limited to those methods approved by ASME/ ANSI Codes. The basis for allowing rgivalent isolation methods in the PWR refueling specifications (3.9) is stated in tne Bases BACKGROUND Section for LCO 3.9.3/3.9.4 and in other staff docunents. The intent is to provide a leak tight barrier, but not necessarily a pressure resistant barrier. In MODE 6 the potential for containment pressurization as a result of an accident is not likely; therefoie, requirement to isolate the
- i. containment from the outside atmosphere can be W stringent. Thus, the STS allows the practice of using te morary sealants to clote penetrations during refueling if no pressurization is predicted. This is not the case for PWR LCO 3,6.3 and BWR LCO 3.6.1.3 where pressurization of containment can occur in MODES 1, 2, 3. and 4 for PWRS, and MODES 1, 2, and 3 for BWRs. In addition. 10 CFR 50. Appendix A, GDC 55, 56 and 57 specify what constitutes acceptable containment isolation: equivalent isolation methods are not mentioned, furthermore, the staff has not reviewed or approved the ASME/ ANSI Codes for equivalent isolation methods in a pressure
- environment. Therefore, the proposed char , is rejected.
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l : Attachment REVISED STS DEFINITION FOR CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated or actual signal irito the channel as close to the sensor as practicable to verify OPERABILITY of all required conponents (e.g..- bustables master relays and slave relays) in the .
channel, and other conponents that could affect OPERABILITY of the channel such as !
alarms, displays, and channel failure trips. Channel relay OPERABILITY shall be verified by demonstrating that at least one contact associated with _the relay has-changed position. -All remaining required relay contacts shall be tested during the LOGIC SYSTEM FUNCTIONAL TEST. The CHANNEL FUNCTIONM TEST may be performed by means of any series of sequential, overlapping, or total channel steps, so that the entire channel is tested.
The followtng other STS definitions should be reviewed for corresponding language changes to ensure consistency in all of the terms used for testing of instrwnentation and controls systems:
NUREG 1430 CHANNEL CALIBRATION CHANNEL FUNCTIONAL TEST NUREG-1431 CHANNEL CAllBRATION CHANNEL OPERATIONAL TEST TRIP ACTUATING DEVICE OPERATIONAL TEST NUREG 1432 CHANNEL CAllBRATION CHANNEL FUNCTIONAL TEST NUREG 1433 CHANNEL FUNCTIONAL TEST CHANNEL CALIBRATION LOGICAL-SYSTEM FUNCTIONAL TEST NUREG 1434 CHANNEL FUNCTIONAL TEST CHANNEL CAtlBRATION LOGICAL SYSTEM FUNCTIONAL TEST
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