ML20236T184

Informs That Disposition Made on twenty-seven Proposed Changes to Standard TS NUREGs Made by NEI Technical Specification Task Force.Travelers Approved,Rejected & Dispositioned as Modified,Listed

ML20236T184
Person / Time
Issue date:	07/16/1998
From:	Beckner W NRC (Affiliation Not Assigned)
To:	Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
NUDOCS 9807280010
Download: ML20236T184 (8)

Text

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N' July 16, 1998 Mr. James' Davis Nuclear Energy Institute 1776 Eye Street, N. W.

Suite 300 Washington, DC 20006-2496

Dear Mr. Davis:

This is to inform ynu that disposition has been made on twenty-seven proposed changes to

. the Standard Technical Specification (STS) NUREGs made by the NEl Technical Specification Task Force (TSTF). ' Those travelers approved are TSTFs-002, R.1; 206; -209, R.1; -233;-268;-269;-278;-279; and -289. Those travelers dispositioned as modify are

. TSTFs-229; -235; -240; -255; -258; and -287. Those recommended for rejection are TSTFs-204, -238, -239, 241, -250, -254, -260, -273, -274, -275, -276, and -281. Upon

- your request, NRC staff will be available to discust their recommendations at the next joint NRC/TSTF Owner's' Group meeting. The disposition summary for those travelers that were dispositioned as modify or recommended for rejection is enclosed.

. As the first orde. of business at the next Owner's Group meeting, the staff would like the industry to provide a status of TSTF-205, which revised definitions of Channel Calibration, Chunnel Functional Test, and related definitions. The NRC is awaiting Bases for the revised' definitions. This change affects the Byron /Braidwood STS conversion.

- 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, Origimi Siged b William D. 3eckner, Chief ~

Technical Specifications Branch Associate Director for Projects Office of Nuclear Reactor Regulation

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July 16, 1998 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 twenty-seven proposed changes to the Standard Technical Specification (STS) NUREGs made by the NEl Technical Specification Task Force (TSTF). Those travelers approved are TSTFs-002, R.1; 206;-209, R.1; -233; -268; -269; -278; -279; and -289. Those travelers dispositioned as modify are TSTFs-229;-235;-240;-255;-258; and -287. Those recommended for rejection are TSTFs 204, -238, -239, -241, -250, -254, -260, -273, -274, -275, -276, and -281. Upon your request, NRC staff will be available to discuss their recommendations at the next joint NRC/TSTF Owner's Group meeting. The disposition suntmary for those travelers that were dispositioned as modify or recommended for rejection is enclosed.

As the first order of business at the next Owner's Group meeting, the staff would like the

-industry to provide a status of TSTF 205, which revised definitions of Channel Calibration, Channel Functiorial Test, and related definitions. The NRC is awaiting Bases for the revised definitions. This change affects the Byron /Braidwood STS conversion.

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,

& sal b. &A William D. Beckner, Chief Technical Specifications Branch Associate Director for Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated cc:

N. Clarkson, BWOG D. Wuokko, BWOG l

g B. Ford, BWROG

~

J. Volkoff, CEOG L. Bush, WOG D. Hoffman, EXCEL L_-____-__-__-__.

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DISPOSITION

SUMMARY

TETF.99e, aa Ash, Modify to make applicable to NUREG-1434. Requirement is ADDED to determine MCPR after performing work on CRDs, consistent with SR 3.1.4.1/2/4.

TETF.9'4R. mands6, The proposed STS Section 3.7.1 is acceptable, with the exception of Action item B which allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for reducing the power range nutron flux - high reactor trip setpoint in scordance with STS Table 3.7.1-1.

We believe that the required completion time to reset the powei range nutron flux - high reactor trip shoud be consistent with the allowable time for reducing thermal power in scordance with STS Table 3.7.1-1 which is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This is because the reactivity related transient initiated from a partial power level will need a reactor trip from the power range nutron flux - high netpoint to prevent overpressurization of the main steam system (this fact is stated in the propsed TS bases B 3.7.1). Therefore, the required Actions B.1 and B.2 should have the same safety significance with respect to overpressure protection.

TETF.2an. mand:#v l

The proposed changes to the LCOs are acceptable, and most of the Bases changes are acceptable. However, the Bases for B 3.2.2, ACTIONS, A.1.1, (p. B 3.2-24) proposes to delete the second and third paragraphs. These paragraphs provide the Bases for a note which remains; therefore, these paragraphs should remain.

TRTF.9KRe RaadI#y j

Even though the spent fuel assembly storage pool can store both new and spent fuel, the j

design, the postulated accidents, and the calculation of Kaff are based on the spent fuel pool containing only spent fuel assemblies. Since most plants normally have a separate pool or area for new fuel assembly storage, this specification was developed for only the spent fuel storage and not the new fuel storage or the plant area which contains both the new and spent fuel stvage areas. Therefore, the staff believes that the titts to BWOG STS

.j 3.7.16, WOG STS 3.7.17, and CEOG STS 3.7.18, " Spent Fuel Assembly Storage" is correct and that the Bases clianges are unacceptable. However, the staff does agree, based on Figure STS 3.7.16-1, that the STS LCO statement, as modified in the TSTF, is

! acceptable ~and would allow new fuel to be stored in the pool,' which the current wording may not.

TRTF. San. aand:#v The propose'd change to 5.7.2d.2 and 5.7.2d.3(ii) is not acceptable for high radiation areas with dose rates in excess of 1 R/hr. The standard TS provides several options for licensees to use and provides adequate flexibility while still maintaining an adequate level of control i

over workers in high radiation areas. The proposed changes will reduce the level of control maintained by the TS.

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The proposed change to 5.7.1e and 5.7.2e on "...when the snowledge of the dose rates must be made to the worker."is unacceptable. The standard TS provide appropriate controls to ensure workers are soequately controlled and protected while working in high radiation areas. - The TS allows time for the RP technician to evaluate the radiological hazard 1

and brief the workers about the radiological conditions in the work area prior to the workers entering the high radiation area. The controlis required to ensure that workers do not focus l

solely on the work to be performed but remain informed about radiological conditions.

i However, there has been alternate wording to the standard TS proposed by a licensee that was accepted by the staff in a licensee amendment. The approved alternate wording follows: "Except for individuals qualified in radiation protection procedures or personnel continuously escorted by such individuals, entry into such areas shall be made only after i

dose rates in the area have been determined and entry personnel are knowledgeable of l

' them. These continuously escorted personnel will receive a pre job briefing prior to entry into such areas. This dose rate determination and knowledge does not require documentation prior to initial entry." This alternate wording may be proposed by licensees

' in lieu of the standard TS. However, the wording of the standard TS will remain as issued.

We agree with the comment in 5.7.2.a.1, however, we do not fully understand it since the pro, nosed words are the same as the standard TS (perhaps the standard TS was missing the

[ ] for the designated positions).

The proposed change to 5.7.2a to substitute the word " inadvertent" for " unauthorized"is unacceptable. High radiation area controls are divided into distinct modes of control; areas below 1 R/hr where barricades are acceptable to prevent inadvertent entry, and areas above l

1 R/hr where the radiation is significantly greater and thus requires the use of locked doors which are not only intended to prevent inadvertent but to ensure that unauthorized entry is prevented. The use of the word " unauthorized"is expressly used to denote the extra controls that are required for high radiation areas greater than 1 R/hr. Regulatory Guide 8.38 does discuss the use of physical barriers to prevent unauthorized entry. The word

" unauthorized" will continue to be used.

In 5.7.2a.2, the standard TS does not imply that an area would be locked so as to prevent personnel from exiting the area. The standard TS is designed to be very clear and literal that the NRC recognizes that a locked door will be " unlocked" when workers enter or exit the area and that this will not result in a NOV. The standard TS wording will not be changed.

We do not understand the comment for 5.7.2f. The standard TS controlis offered to licensees as a " relief" from 10 CFR Part 20. tf a licensee has a special need, a custom TS con be proposed and justified for the staff's consideration. The standard TS wording will not be changed.

- TRTF.2A7. saantW The change has merit; however, the staff does not believe that the proposed change has l

been fully evaluated by the OG. The SR that supposedly tests the integrity of the roomiDarrier has two acceptance criteria -- a pressure limit (positive or negative) and a system flow limit. While failure of the pressure liioit alone would indicate boundary

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degradation, failure of the pressure and flow limit while performing the SR could indicate system degradation and/or bnundary degradation. Under these circumstances, it is conceivable that both Actions A and B would have to be entered. A number of concerns arise from this:

1) What is to prevent the entering and exiting of Actions A or B over an indefinite period of time? Maybe there should be an overall completion time similar to the completion times specified in Actions for STS 3.7.5.

2) In this situation, the implication is that, in order to verify if it is a boundary inoperability or just a system inoperability resulting in the exiting of Action B, the opposite train would be tested. This is something that has been deleted from TS, and not a prudent thing to do.

Do we went to' bring this back in this case?

3) The wording of the Condition "Two trains inoperable due to inoperable boundary" could lead to confusion as to which Action to enter (Action B or LCO 3.0.3) under the situation in which both trains are inoperable for other reasons as well as failure to meet this SR and the boundary is inoperable. LCO 3.0.3 should probably be entered, but the wording could lead one to enter Action B.

An additional concern with the change involves the Actions associated with an inoperable boundary during movement of irradiated fuel assemblies and core alteratims, The staff does not believe that, in this situation, fuel movement should be allowed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

With this potentialloss of radiation filtering, Actions should be taken to immediately 1

suspend fuel movement and/or Core Alterations. This change is applicable to the Control Room and Fuel Building Ventilation Specifications.

TETF 2nd. R-------d P '- ^

The proposed change is unacceptable on the basis that it is a change in the NRC requirements that is beyond approved staff positions, presents a possible increase in plant risk, and is not supported by adequate justification. The intent of the proposed change appears also to revise the LCOs format such that they will reflect more specific requirements (i.e., LCOs for DC Sources-Shutdown and inverters-Shutdown) similar to that of LCOs for the AC Sources-Shutdown. The OGs (TSTF) indicated in the traveler that the proposed change is consistent with the initial philosophy of the ITS NUREG, but no supporting justification was'provided.

Additionally, the staff finds that: (1) For PWRs, the NUREG LCOs require multiple trains / divisions of DC sources and inverters if multiple trains / divisions of safety systems are required to be OPERABLE during shutdown. Conversely, if the plant is configured such that l

all required safety systems are on one train / division, only one train / division of DC sources l

and inverters must be OPERABLE. The proposed change does not appear to address this.

Specifically, they have not explained how less than a full complement of DC sources and inverters will " continue to assure that sufficient power is available to support the response to events postulated during shutdown conditions in the event of a loss of offsite power or a

4 single failure." For example, it is not explained how an AC vital but powered from a regulated AC source will perform its intended function in the vent of a LOOP, or how a DC distribution subsystein powered from a battery charger will perform its intended function under the same circumstances. In addition, the proposed change does not appear to be compatible with LCO 3.8.2, and it does not provide any assurance that a DG will be aligned to a train / division with a full compliment of DC sources and inverters. (2) For BWRs, the proposed change does not provide any justifications for allowing Div 3 DC power and inverter to be less than a full compliment.

1ra rF. van. B.====a n

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Purpose is to make Required Action C.1 exactly consistent with the LCO applicability; going to MODE 3 is in reality a less confusing action and operationally more correct.

TETF.2'tSt Raeammand na,

There is a misunderstanding about when MODE 2 is entered. MODE 2 is with Keff >.99, which is prior to criticality. The proposed Bases sentence to bo deleted is intended to clarify about when MODE 2 is entered.

TETF.2d1 ? Raeammand R,r.,

The proposed changes are unnecessary; changes to A.1 and A.2 are merely ar.ather way of presenting the same sequence of actions.

TSTF.2 floe Rae= =. =d R '--e it has been NRC practice to review any changes to the criticality analysis used to determine the fuel storage k-effective acceptance limit (e.g., enrichment increases, reracking, Boraflex degradation, etc.), including the uncertainties assumed. Therefore, even a potential misinterpretation that the referenced discussion in the FSAR could not be changed wnhout a license amendment would not be inappropriate, since the staff would wish to review such changes anyway. Therefore, the specific FSAR reference to uncertainties in the Criticality Section of Design Features should remain.

TETF.2 Eat Raeammand Re mee i

Water in the fuel oil storage tank and the day tank contributes to microbiological grov t' and presents an operability consideration. The staff would consider, however, another submittal by the TSTF to extend the current surveillance frequency requirement from 31-days to perhaps 92-days.

i' TETF.2 Ant Racammand n r_.,

A system may have one or more operational configurations, depending on the plant's operating condition. As a minimum, a system will have a normal operational alignment and I

a safety function operational alignment. In some cases, these two alignments may be the same; in other cases, there may be more than one normal operational alignment. The SRs

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l specified in the TSTF serve a valid purpose: to verify that the system alignment (correct valv6 oosition) is appropriate for the plant conditions. Even though an automatic valve may be in its safety alignment, if this alignment is different than its normal operating alignment (e.g., valve closed when it should be open), the system cannot function properly and, therefore, the system is inoperable. Therefore, the subject SRs need to verify the correct

. position of all valves (automatic and non-automatic).

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ISIf.271 Rmeammand R 2--e The proposed adaitions are not necessary; what " misinterpretations" have resulted from the current wording of LCO 3.0.6 and the SFDP7 The SFDP should take into consideration a complete loss of power. The proposed additions to the SFDP do not appear to be incorrect, thopgh they also do not appear to be necessary. Likewise the first paragraph of the LCO 3.0.6 insert appears correct. However, the second paragraph of the LCO 3.0.6 insert is incorrect; it is not true for all circumstances. The following two sentences are not always true: "Where a loss of function is solely due to a single TS support system... the 9ppropriate LCO is the LCO for the support system. The ACTIONS for a support system LCO adequately addresses the inoperabilities of that system...'. For a loss of function, the above two sentences contradict LCO 3.0.6.

TSTF.27d* Raeamm=.d P-l--t The proposed change is not consistent with the purpose of the Bases. The Bases are intended to provide a discussion of the reason as to why a particular SR is in the TS and, as necessary, exl. lain why certain specific criteria are included. The Bases are not intended to I

establish acceptance criteria. The proposed chenge would tie the SR duectly to the Bases because the SR would state "...each battery charger supplying the required voltage and current..." Thus, then, the Bases would be the only place the values of voltage and current would appear, thereby linking the SR and the Bases. In addition, the proposed change would delete any reference to the time requirement from the SR. The Bases would be the only place a reference to the required time would appear. This, also is not acceptable.

I The proposed change is also not consistent with the SRs in other 3.8 LCOs because acceptance criteria in 3.8 are normally stated in the SRs. SR 3.8.4.7 is an exception because it would be very impractical to attempt to include all the details of the battery load profile for the service test in the SR. Consequently, the load profile is maintained outside of TS. Since SR 3.8.4.7 is an exception, however, it is not a justification for making changes to other SRs.

TETF.27& Raeammand R gmee The proposed change would add ECCS cross references to Table 3.3.5.1 and associated Bases, and to the Baser for LCO 3.8.2. The use of cross references in LCOs was considered during the development of the NUREGs. The idea, however, was rejected. In

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light of this, inclusion of the proposed cross references in Table 3.3.5.1 would make this L

LCO inconsistent with the rest of the NUREG and create a potential for confusion or misinterpretation of other LCOs. With regard to the Bases, cross references are aiready t

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6 included. The proposed Bases changes would be redundant to what is already in the Bases

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and are, therefore, not necessary.

TETF.27Es Raenmmand Rq=gg 1

The staff has reviewed the proposed change and finds that it does not appear to be

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necessary. The SR in question is the fullload reject test. It is the staff's view that fullload on a DG can only be obtained while parallel with offsite power grid; i.e., there is not enough j

load on the cafety bus to fully load the DG. When paralleled with offsite power, the power j

factor can be controlled, and the SR is correctly worded in its present form.

- The staff '.:an re review the proposed change if the OGs can provide an example of a plant f

that can fully load a DG using only loads on the safety bus when disconnected from offsite j

power network.

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TETF.2B1 e R aen m..T. r.d R '-

• k The proposed technical specifications modification would require plant-specific and possibly j

Owner's Group-specific risk information and is beyond the scope of the TSTF process.

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