ML20244B695

Final Rept on Review of Proposed Tech Specs for Philipine Nuclear Power Plant

ML20244B695
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Issue date:	11/30/1984
From:	Office of Nuclear Reactor Regulation
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FOIA-89-99 NUDOCS 8904190337
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FIflAL REPORT ON THE REVIFW OF :j PROPOSED TECHNICAL SPECIFICATI0f'S FOR THE PHILIPPINE NUCLEAR POWEP. PLANT i

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hTSC Vienna t'ovember 1984 _j y

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ABSTRACT 1

Pare n# Expert: Donald S. Brinkman November 1084

Title:

Section Leader Standard Technical. Specification Section Office o# Nuclear Reactor Regulation U. S. Nuclear Peaulatory Commission I

l At the reauest of the Philippine Government, an IAEA expert undertook-a two week mission (October 20 - November 5, 1084) tn the Philippine Atomic Energy Commission'(PAEC) and to the Philionine Nuclear Powar Plant Unit No. 1 (PPNP-1) site within the framework of the project " Nuclear Licensing and Regulation" (C2-HPI-9.013-01). The expert provided advice to the PAEC staff members in the methods for reviewina propnsed technical specifications and assisted the PAEC staf' members in reviewing the proonsed technical specifications for PHPP Tha expert alsn met with representatives from the apol4 cant's nraanizatio: (National Power Corporation) and recommended reviaw orncesses ,

+n ba usad hv the app 14 car + during its review of +he prnposed technical l specifications.

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I Tha expert concluded that al+houah snma certain modifications to the technical  !

specifications proposed for PNPP-1 should be made, the PNPP-1 proposed technical speci#ications address nearly all of the topics considerad necessary to be  ;

included in the technical specifications #nr similar plants to ha licensed in the United States ir acenrdance with current USNRC licensing requirements.

The recommandad modifications to the prnonsad technical specifications for PNPP 1. are considered minor and are discussed in this recort.

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'i Tha expert made the following recommendations: -l f

1. PAEC staff members should review the SER they are prepardna i

ralated to tha operation of PNPP-1 and verifv that all' plant-specific requirements identified therein as requirire technical 1 I

speci'ications are actually included in the.PNPP-1 technical  !

I specifications, i

i P. PAEC staff members should review and verify that all the l plant-specific values are correct and consistent with the assumptions used in the sa'ety analyses for PNPP-1. The ,

l PNPP-1 safety analyses should be used as the acceptance l l

criteria for these values rather than the example values in NUREG-0452. l f

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3. Prior tn issuance of the operating license, PAEC shnuld i

reouire the applicant to review the proposed technical l specifications and certify that the pronosed technical l specifications accurately reflect the as-built plant, that  :

l the proposed +echnical specifications are consistent with  !

the se#ety analyses, and that the requirements of the l I

proposed technical specifications can be complied with.

4 A PAEC ste#' member should be provided with training in preparing i l and issuing license amendments to er oparating license.

4 I. INTRODUCTION )

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1 A. Terms of Raference f

'I The expert's +eres nf reference #or the mission were:

la) To orovide advica and training #ar the PAEC staff members  !

regarding the development and review of reauiraments l l

gnverning the operatinn of.PNPP 1. rather than to per#crm i a complete detailed review of the proposed technical speci-

'l fications.

(b) To advise the applicant's representatives regarding their role in the development and review of proposed technical specifications.

A. 9ackground Information  !

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i The expert had bean prnvided with a conv of and had reviewed the proposed technical specifications for PNPP-1 prior to his ..

departure nn this missinn. These proposad technical specifications included revisions through FSAR Amendment No. 3. Cnoies n#

proposad technical speci#ication revisions associated with

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4- i FSAR Amendment Nos. 4, 5, and 6 were provided to the expert upon his arrival at the PAEC offices. The expert used these revisions to complete'his review o' the propnsed technical specifications for PNDP-1.

The.PAFC staff members had reviewed the PNPP 1 pronosed technical specifications during their mission to the llSNRC in March-April lop 4 and had aa4ned sone familiarity with the PNPP-1 proposed' technical speci#ications as a result of that mission; however, they had sevaral questions regarding certain technical specifications. The expert responded to their questions and provided additional background information relating to technical specifications during this mission.

l C. Staffino and Trainino To date, the PAEC review of the PNDP-1 penoosed technical specifications has been conducted on a part time basis. The PAEC staff members received some training in the review of technical specificaticne during their Additional train 4na wa< provided I March-April 1984 mission to the USNPC.

to the PAEC staff members by the exoert during this mie.sinn. The com-i hination of these missions aopears to have provided the PAEC ste#f members with sufficient training to enable them to complete their review of the PNPP-1 proposed technical specifications. However, tha PAEC staff nenbers will be required to devote significant additional amounts of time to complete i

their review of and issue the PNPP '. proposed technical specifications.

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.- D . Eautoment and Facilities 1

i Tha eauipment and faci'ities. ornvided for use by the exoert to conduct this mission were adequate, although it would have been helpful if FSAP. Amandment Nos. d, 5, and 6 would'have been available to the expert prior to his departure nn this mission.

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.  ; 1 II. WORK PROGRAMME t

1 The expert was provided with and reviewed a copy of the PNPP-1 oroposed technical specifications as revised through FSAR Amandmant No. 3 orior to departura on this missinn. The expert was provided with a copy of FSAR  ;

i Amandment Nos. 4, 5, and 6 upon arrival in the PAFC offices in Quezon City.

The expert, together with the PAEC staff nerbers, reviewed the proposed J technical specifications against the guidance provided in the USNPC's Standard Technical Specifications for Westinghouse Pressurized Water Reactors Q'-STS) (NUREG-0452, Rev. 4) and changes to the }!-STS which had been aporoved  ;

by'the USNRC subsequent to the issuance of Revision 4 to the W-STS._

The proposed technical specifications were reviewed against the guidance provided in the W-STS since the proposed technical specifications had been preparad based upon the guidance contained in the W-STS. During this review, the expert responded to various cuestions posed by the PAEC staff mambers concerning the proposed technical specifications and recommended  !

that PAFC require certain changas be made in the proposed technical speci-

'ications. A draft list of these recommended changes was provided to the export's PAEC counterpart (Mr. Vicente V. Nacarioi prior to the expert's departure from the Philippines. The recommended charces are considered ninor changes. These changes have resulted primarily from operatino experiences qained by the USNPC since NilREG-0452, Revision a was issued.

The expert marked-up a copy of the PNPP-1 proposad technical i

specifications to shnw the recommended chances; the marked-up copy was left NithPAEC. The racommanded chanaes are:

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1. Consideration should be given to revisino Definition 1.25 (Reportable Occurrences) and propos9d technical. specifications 6.6.1 and 6.9.1 j

to ba consistent with the changes described in USNRC Generic Letter  !

No. 83-43 which was issued to provide guidance in imolamenting the rac.ent (ef#ective January 1, 1984) changas to in CFR 50.72 and i

10 CFR 50.73.

2. Definition 1.27 (Shutdown Marcin) should he revised to require that +he highest reactivity worth control rod cluster assembiv  ;

always be considered fully withdrawn (rather than assumed to remain at its present position) and unavailable for insertion, i This allowence is considered necessary to account for an uncontrolled i

control red cluster assembly withdrawal event. l

3. All figuras in the technical specifications should be printed I

on grid paper sn that limits can be accurately determined. The

1. 40uras should also note recinns o# acceptable and unacceptable nparation. l I

4 The instrumentation tables should be reviewad to veri #y that f the spec 4#ied setooints are consistent with tha values used in the safety analyses and that valuas he provided for all runctinnal Units. Also, surveillance frequencies should

! ba specified for all 'Furc'innal Units.

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5. Tha Action Statements for croposed technical specifications 3.1.1.1 I and 3.1.1.2 should-ba modified to clarify that equivalent (decreased ,

' #1nwrate but increased boron concentration nr vice versa) bnration rates are acceptable. j

6. Re#nre the Safety injection Pumps are considerad an acceptable bnration oath in proposed technical specification 3.1.2.?. +hasa pumos shnuld be verified capable 0 # injecting water from the RMST l into the Reactor Coolant System while it is at normal noeratina pressure. The concern beina that the discharae head nf these pumps may be insufficient to inject water while the Reactor Coolant System is at its normal operating pressure.

7 Appropriate Surveillance Requirements should be addad to proposed technical specifications 4.1.2.3 and 4.1.2.4 to demonstrate the I i

operability of +he Safety Injection Pumps which are required operable by proposed technical specifications 3.1.2.3 and 3.1.2.4 l l

8. The minimum temperature requirements for the PWST could ba deleted from pronnsed technical specification'ns 3.1. 2. 5, 3.1. 2. 6, a nd 4.1. . :' . 5.  !

These reovirements were imposed to ensure that the PWST water does not freeza; however, since there is no danger of freezing at PNPP-1, these requirements could be deleted.

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9. Action a. n# proposed technical specification 3.1.3.1 should be revised to require that the Shutdown Margin be promptly determined upon detection of a stuck control rod. It was also noted that Actinn 3.bi

.of 3.1.3.1 could be deleted provided the recommended change in the dafinition of Shutdown Maroin is made.

10. Functional Uri+ 8 (Loss of Power) of Table 3.3-3 of the pronosed technical specifications references Action 19; however, the Table Notation of Table 3.3-3 does not include an Action 19. This inconsistency should be corrected by addino an apornpriate Action 10 to the Table Notation, i

11. The Table Notation for Table 3.3-4 of the proposed technical specifications includes notation (6) which does not appear in

( Table 3.3-4. Notation (6) should either be appropriately noted I

on Table 3.3-4 or deleted from the Table Potation.

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17. Table 3.3-6 of the proposed technical specifications includes several. area radiation monitors which would not be required to be included in the PNPP-1 technical specifications per the criteria used in W-STS. The criterinn for use in the W-STS vould reouire that the only radiation monitoring instruments tn be includad in Table 3.3-6 would be those that (1) initiate 1

EFS actions, (2) are used to monitor RCS leakage, (3) are used to monitor for inadvertent criticality in fual storage areas, (4) are post accident nonitors, and (5) are used for effluent monitoring, i

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13. Action 30'nf Table 3.3-6 of the proposed technical soecif4 cations 1 should be modified ~to permit plant operation to continua provided alternative preplanned methnds are implemented (within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) for monitoring when tha containment area monitors or noble gas.

monitors are innperable. This change to tha W-STS has been approved by the IISNPC. l

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la. Table 3.2-9 and 4.3-6 should be revised to include all the instruments needed to achieve and maintain reactor shutdown from outside the control room. Also, Tables 3.3-10 and 4.3-7 .i should be modified to list the PNPP-1 instruments rather than the instruments listed as examples in the W-STS.

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15. The minimum number of fire detection instruments listed in Tabla 3.3-11 of the proposed technical specifications should be chenged from "All" to the number assumed in the Fire l Pazards Analysis. -[

16. Since Westinghouse has recently channed its recommended frequency for testing tha +urbine control valves from once per seven davs to once per 31 days, consideration should be given to changina the recuired testing frequency o' nroposed surveillance requirement I 4.3.4.2.a accordingly, i I

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... 17. PAEC should require veri cation from the applicant (to be confirmed by West 4nahouse) that proposed technical specification 3.4.1.2.b which only requires one reactor coolant loop to be in operation in Mode 3 is still a valid assumption and requirement.

This comment was made in light of a recent notification by Westinghouse that for its three and four loop plants, et least two reactor coolant innos must be in operation in Mode 3 to orevant DNP during an inadvertent control rod withdrawal transient.

18. Proonsed technical specification 3.4.6.1 should be clarifiad to require three reactor coolant system leakage detection systems to ba operable and the Action Statement should permit operation' for up to 30 days with only two systems coerable. Proposed techrical specification 4.d.6.1.a should also he clarified accordingly ,

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10 Since noaretion of the chargina pumos is assumed in a steam

generatnr tuba rupture event, a controlled leakage limit nf coproximataly 50% of the capacity of one charging oumo shnuld be

. included as a limit in oroposed tachnical specification 3.4.6.P.

This orecludas permitting all the capacity of a charoing pump 'rnm being usad to make up reactor coolant Dumo seal leakaoe. An appropriate surveillance requirement for this leakace limit should l

alsn be added to oroonsed technical specification 4.4.6.2.

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20 A maximum water volume limit should be added to nroposed technical specification 3.5.5.a. Such a limit is recessary for pH contral in the containment sump during post accident conditions.

71. Proposed technical specifica+ ion 3.6.1.0.a should be deleted since a reduced pressure Typo A containment leakage rata test has not been nerformed and there#cra L cannot be properl.v spacified in t

i accordance with the provisions of 10 CFR 50, Appendix J.

1?. Technical specifications 3.6.1.7 and 4.6.1.7 (Structural Inteority) of the W-STS should be added to the PNPP-1 proposed technical specifications to assura that the structural integrity of the PNPP-1 containment is maintained.

P3. PAEC should have the applicant veri #y that PNPP-1 can be operated in accordance with proposed technical specification 3.6.6 which prohibits use of the containment purge system during Modes 1-4 It is unlikely that the olant can be operatad without beina nermitted at least some limited use of the purae system to ad.iust containment internal pressure. Normally, plants are allowed at least some limited (up to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year or longer if a qualified mini-purge system is availablel use of the purge system.

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H 74 Proposed technical specification 4.6.2.?.d'should be modified to. periodically (at least once per five years) dennrstrate flow (eithar water or NaOH solution) through the entire Na0H flow path..

25 Prooosad technical specification 4.6.8.1 and all other surveillance raquiraments for charcoal and HEPA filter systers should be modified to be consistant with USNRC Generic Letter 83-13.

'?6. In an attempt to reduce future license amendments due to chanoes l

in snubber incations, etc., proposed technical specification 3.7.9 f

should be modified in accordance with llSNRC- Generic l'etter 84-13 which deletes Tablas 3.7-4A and 3.7-48. This change will permit future changes to the list of snubbers after an appropriate evaluation per 10 CFR 50.59 by the licensee without a license amendment.

?7 Proposed technical specifications 4.8.1.1.2.a.4 and 4.8.1.1.?.a.5 I

should be modified in eccordance with USNRC Genaric Let+er 84 15.

This change raducas the nu er of required cnid, #ast starts o' {

the emeraency diesel gererators sn as to improve the overal'

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diesel oeneratnr_ reliability by reducino unnecessary strest and wear on the- diesels.

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28 FSAR Amendment No. 4 deleted material which had creviously been in proposed technical specification 4.8.2.3.b. Tha reason for deleting this material is not readily apparent. PAEC shculd reouest that the reason for this deletion be, determined and perhaps reevaluated. It appears that the noted material should not have been deleted.

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29. PAEC and the anplicant should independently review all the various trip setpoints and other parameter limits in the proposed technic'al specifications aoainst the safety analyses assumptions and verify that all of these values are consistent.

This review should verify that the proposed technical specification limits are consistent with the safety analyses rather than with the example values presented in the W-STS. _

The proposed j . technical specif4 cations should also ba revised as necessary to assure that any other requirements deemed necessery by PAEC are alsn included.

I 30 The need for prnoosed technical speci#ication 6.2.3 should be reevaluated by DAEC.

i 31 Table 6.2-1 of the procesed technical specifications should be mcdified per USNP.C Generic Letters 82-12 and 89-14 tn note l .

i that the limits on overtime apply to more parsonnel than just the licensed operators. l

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32. The once per 24 nonth audit frequencies specified in proposed

. technical specifications 6.5.2.8.9 and 6.5.2.8.f should be changed to once per 12 months to be consistent with NRC Generic Letters 82-23 and 82-17.

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33. Proonsed technical specification 6.5.2.10.a, 6.5.2.10.b and 6.5.2.10.c shnuld be modified to soecify to whom the specified j records ara +o ha #orwarded.

3a. Saction e. should be added to proposed technical specification 6.7.1. to state that critical operation of the unit shall not be resumed following violation of a Safety Limit until authorized by PAEC.

35. Sections 6.8.4.d and 6.8.4.e of the W-STS should bs added to Section 6.8.a o' the PNPP-1 proposed technical specifications to require the licensee to have a backup program for determining subcoolino narain and a program for postaccident sampling.

36 The detailed listing of the varinus Special Deports in nroposed technical speci#ication 6.9.2 could be deleted since this listing is redundant to the reauiremant?. listed in the  !

individual af#ected technical specifications.

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. As part of this mission, the expert also visitad the PNPP-1 site and met with representatives of the applicant's Operations Division and PAEC staff members.

Durina this meeting, the importance of technical specifications was discussed with the anplicant's representatives. The expert emphasized that technical specifications must be adhered to since they are mandetnry requirements.

1 Tha aoplicant's representatives were uraed to care #ully review the proposed technical speci#ications and verify that the proposed technical specifications accurately reflect tha as-built plant and the safety analyses. The applicant's  !

i representatives were also urged to verify that the various raouirements of the pronosed technical specifications can be performed and implemented. The expert  ;

advised that i' any inconsistencies are noted during thes'a reviews, the in- l consistencies should be brought to PAFC's attention for resolution before the operating license is issued. The expert responded to several questions from the apolicant's representatives during this meetina and explained the back-i around and intent of various proposed technical specifications.

In his various discussions with PAEC representatives, the exper+ noted that t'io PAEC representatives were uncertain as to the procedures to be followed in prepering and issuing changes to technical specifications after issuance of technical specifications as part of an operating license. The expert described the procedures used by the USNRC in issuing such changes as license amendments; however, it was apparert that further traininq nf the PAEC sta#f in issuing technical specification changas would be a very valuable training j experience for the PAFC staff members. Therefore, it is recommended that I a PAEC staff member be sent to the USNRC to obtain two to thrae months of on-the-job traininq in preparino license amendments with an Operating Reectors Pro.iect Manager.

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III. CONCLilSIONS AND RECOMMENDATIONS A, Governmant i

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1. PAEC should be aggressive-in resolving any open issues relative to the ornonsed technical specifications for

'PNPP-!. PAEC should take the lead in resolvino such issues and not wait for the applicant to propose resolutions, i

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2. PAEC should not be reluctant to impose any reautrements in the proposed technical specifications determinad I necassary by PAEC's review to assure the continued validity-of the safety analyses, B. Counterpart Institutions

.1. PAEC staff members should review tha SEP they ara preparing .

related to the operation of PNPP-1 and either verify that all requirements identified therein as renuirino technical specifications are actually included in the PNPP-1 technical l specifications or add any requirements to the PNPP-1 proposed tachnical specifications deemed necessary by PAEC.

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2; PAEC' staff members sbculd review and verify that all the plant-specific values (e.g., reactor trip setpoints, engineered se#ety feature actuation setpnints, parameter 'imits erd acceptance criteria, valve identi#ications, etc.) are correct and consistent with both the as-built plant and the assumptions used in the safety analyses #nr PHPP-1. Any  !

requirements for additional technical specifications identi#ied during this review should be added to the I

proposed te"brical specifications prior to issuance of the operating license. I l

3. The.apolicant should be required to review the proposed technical specifications and certify that the proposed technical specifications accurately reflect the as-built plant, that the proposed technical specifications are {

consistent w th the safety analyses, and that the i i requirements of the proposed technical specifications can be complied with. Any inconsistencies noted durinn the applicant's review should he promptly brought to PAEC's attention and be resolved prior +n issuance of the operating license.

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- 19 C. Aaency

1. A PAEC staff member should be provided with training in the preparation and issuance of changes to technical specifications for an operating plant since such changes.will certainly'be required durino the operption of PNPP-1 and at present the DAEC~ staff members do no+ appear tn he faniliar with prepardna ard issuing such changes. This training could nrchably bast ba accomplished as on-the , job training, working with a tlV'RC Operatina Reactor Prn.4act Manager. It is estimated that such training would reouire an assignment o' approximately two to three months.

2. Arrangements should'be made for PAEC and the aoplicant to receive copies of USHRC Generic. Letters since they ara commonly used to notify licensees of chances to the W-STS.

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. IV. ACKf!0tlL EDGEMENTS Inapplicable.

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to ANNEX LIST OF PERSONS CONTACTED AND INSTITUTIONS VISITED Name Position Affiliation Mr. Vicente V. Nacario PAEC Staff PAFC Mr. Antonin M. Portugal. PAEC Staff PAEC Ms. Porpetua. Rodriguez PAFC Staf# PAEC Mr. Benito C. Bernardo PAEC Staff PAEC Mr. Willien G. Albert IAEA IAEA Mr. Lucian E. Vordenbruggen IAEA IAEA Col. A. Ver Albano- Associate Commissioner PAEC Dr.. Manual R. Eugenio Commissioner PAEC Mr. Guillermo C. Corpus Associate Commissioner PAEC Dr. Ouirino 0. Navarro Associate Commissioner PAEC Dr. Antonin E. Refre PAEC Staff PAEC Mr. Romeo Rara PAEC Staff PAEC i Mr. Tomas G. Jimenea PAEC Staff PAEC Ms. Lilia Da La Paz PAEC Staff PAEC i

Mr. Alfredo A. nrquia PNPP-1 Site Manaaer NPC Mr. Antonio T. Corouz PNPP-1 Plant Mera' gar NPC Mr. Crisanto C. Candelaria PNPP 1. Asst. Plant Manager NPC Mr. Gregario G. Garces Manaaer, Operations Div. NPC Mr. Francis B. Sarmiento . Shift Operatinns Super. NPC Mr. Domingo D. Rodrigo, Jr. Chief Engineer 'or Padwaste NPC Maraaement & Surveillance Control l

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- 22 Institution Location PAEC Offices Diliman, Quezon City, Republic of Philiocines 1

PNPP-1 site Morong, Bataan, Republic -

of Philippines  !

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