ML20244E099
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April 11,1986 MEMORANDUM FOR: Charles E. Rossi, Assistant Director !
for PWR-A Division of PWR Licensing-A, NRR FROM: William T. Russell, Director Division of Human Factors Technology
SUBJECT:
SEABROOK TECHNICAL SPECIFICATIONS By memoranda dated February 28, 1986, and March 6, 1986, you requested that j the TSCB review a number of deviations from the STS proposed by Public i Service of New Hampshire for the Seabrook Station Technical Specifications.1 It is our understanding that the staff had agreed to consider any such proposals ' hat the applicant wished to make on a plant specific basis as part of our efN, t to explore ways to improve Technical Specifications in general.
In performing our review we did not attempt to evaluate the detailed plant specific technical merits of the applicant's proposals. Our focus was instead on whether the proposals were consistent with the overall objectives and current direction of the NRC's Technical Specification Improvement Program.
The results of our review are provided in Enclosures which are organized to correspond to your categorization of the applicant's proposals.
ORIGINAL SIGNED BY DENNIS L. ZIEMANN FOR William T. Russell, Director Division of Human Factors Technology Office of Nuclear Reactor Regulation
Enclosures:
- 1. Changes which Transfer Control of Requirements
- 2. PRA-Based Changes
- 3. 03/21/86 Memo from Kulin D. Desai to Edward J. Butcher:
"AIF/TSIP Criteria Trial Application - Wolf Creek / Limerick TS Split"
- 4. 03/25/86 memo from Edward J. Butcher to George Rivenbark:
" Proposed Technical Specification Changes - Hatch Unit 1."
cc w/entis:
H. Thompson T. Novak V. Benaroya r N S. Israel CC60 o [ Cf g Y C. Moon TSCB Members
( -
CONTACT: David Langford, NRR (49-24906)
Distribution:
TSCB Reading File
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(TSCBI - memo to rossi from russell) (
TSCB:DHFT:NRR C: DHFT:NRR DD:DHFT :DHFT A
DLangford: dim E er DLZiemann , WTRussell -
04/ 7 /86 04/ /86 04/[( /86 04/ll/86 -
/ 'o UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION
$ . ,i wAsecTow, o. c.rosss
+ April 11, 1986 1
l PEPORANDUM FOR: Charles E. Rossi, Assistant Director ]
for PWR-A I Division of PWR Licensing-A, NRR l l
FROM: William T. Russell, Director Division of Human factors Technology 1
SUBJECT:
SEABROOK TECHNICAL SPECIFICATIONS By remoranda dated February 28, 1986, and March 6,1986, you requested that the TSCB review a number of deviations from the STS proposed by Public Service of New Hampshire for the Seabrook Station Technical Specifications.
It is our understanding that the staff had agreed to consider any such proposals that the applicant wished to make on a plant specific basis as part of our effort to explore ways to improve Technical Specifications in general.
In performing our review we did not attempt to evaluate the detailed plant specific technical merits of the applicant's proposals. Our focus was instead on whether the proposals were consistent with the overall objectives and current direction of the NRC's Technical Specification Improvement Program.
The results of our review are provided in Enclosures which are organized to correspond to your categorization of the applicant's proposals.
s M3 William T. Russel Director Division of Human Factors Technology Office of Nuclear Reactor Regulation
Enclosures:
- 1. Changes which Transfer Control of Requirements
- 2. PRA-Based Changes
- 3. 03/21/86 Memo from Kulin D. Desai to Edward J. Butcher:
"AIF/TSIP Criteria Trial Application - Wolf Creek / Limerick TS Split"
- 4. 03/25/86 memo from Edward J. Butcher to George Rivenbark:
" Proposed Technical Specification Changes - Hatch Unit 1."
cc w/encls:
H. Thompson T. Novak V. Benaroya S. Israel C. Moon TSCB Members CONTACT: David Langford, NRR (49-24906)
Enclosure 1 CHANGES WHICH TRANSFER CONTROL OF REQUIREMENTS
- A. Deletion of Technical Specifications
- 1. TS 3/4.3.3.8 LOOSE PART DETECTION INSTRUMENTATION Seabrook Proposal The applicant wants to delete the above TS and include the reporting requirements in a licensee maintained and controlled document.
FOB Position ,
"The [F0B] position is that Technical Specification 3/4.3.3.8 be deleted, I if the applicant's subsequent inclusion of the same requirements in the FSAR are acceptable. This position is based on the observation that the ACTION is a reporting requirement after 30 days of inoperability, and that, therefore, the Limiting Condition for Operation does not directly limit operations."
TSCB Connents The TSCB finds that deletion of TS 3/4.3.3.8 for the 1150 Mwe Seabrook PWR is consistent with the result obtained in a trial split of the TS for the 1150 Mwe Wolf Creek PWR, as documented in Enclosure 3.
- 2. TS 3/4.4.5 STEAM GENERATORS Seabrook Proposal The applicant wants to delete the above TS, include its surveillance requirements in the ISI/IST program, and ignore its action statements on the basis that they are covered by other TS.
F0B Position "The [F0B] position is that Technical Specification 3/4.4.5 STEAM GENERATORS be retained in the Seabrook Technical Specifications. The 1 primary reason is that the applicant proposes to rely on the ISI/IST program which we understand is not scheduled for submittal and staff review until after issuance of an operating license. In addition, we {
conclude that changes to Technical Specification 3/4.4.1 would be j necessary to permit the conclusion proposed by the applicant that the Action Statement of 3.4.5 is covered by the Action Statements in 3.4.1.1. , 3.4.1. 2, and 3.4.1. 3. "
TSCB Comments I The TSCB finds that retention of TS 3/4.4.5 is consistent with the result obtained in Enclosure 3.
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- Asterisks identify cases where the TSCB does not agree with the F0B position.
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1 B. Deletion of Limiting Conditions for Operation '
- 3. TS 3.4.6.2(e) "52 gpm CONTROLLED LEAKAGE at a Reactor Coolant System pressure of 2235 +20 psig."
Seabrook Proposal l The applicant wants to delete the above TS on the grounds that almost all of the " leakage" is into the reactor coolant system.
F0B Position i "The [F0B] position is that the deletion of LC0 3.4.6.2(e) should not be made unless a more complete justification is provided. The applicant states that controlled leakage is not real leakage but is the flow into the RCP seals and that almost all of this flow is recovered back into the reactor coolant system. The bases for this specification, which the applicant proposed to delete, states that this leakage limitation ensures that in the event of a LOCA, the safety injection flow will not be less than assumed in the accident analysis."
TSCB Comments The TSCB finds that retention of TS 3.4.6.2(e) is consistent with the result obtained in Enclosure 3.
- 4. TS 3.3.1 As a minimum, the reactor trip system instrumentation, channels and interlocks of Table 3.3-1 shall be OPERABLE [with RESPONSE TIMES as shown in Table 3.3-2].
- 5. TS 3.3.2 The Engineered Safety Features Actuation System (ESFAS) instrumentation chanr.als and interlocks shown in Table 3.3-3 shall be OPERABLE with their Trip Setpoints set consistent with the values shown in the Trip Setpoint Column of Table 3.3-4 [and with RESPONSE TIMESasshowninTable3.3-5).
Seabrook Proposal The applicant wants to delete those parts of the above TS in square brackets and place then in a licensee maintained and controlled document, but the surveillance requirements would remain in TS.
FOB Position "The [F0B] position is that the elimination of RESPONSE TIMES from the LC0's of 3.3.1 and 3.3.2 is acceptable as a technical specification simplification. Because the definition of OPERABLE includes response time there is no relaxation of requirements by this change." j TSCB Comments j The TSCB agrees with the F0B statement that "there is no relaxation of !
requirements by this change. l j
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C. Deletion of Surveillance Requirements
- 6. TS 4.4.1.1 "The above required reactor coolant loops shall be verified to be in operation and circulating reactor coolant at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."
Seabrook Proposal The applicant wants to eliminate the above Surveillance TS as being an )
unnecessary diversion of the operators which provides only additional )
paperwork. )
F0B Position "The applicant argues that Surveillance 4.4.1.1 is unnecessary because the operator is constantly observing his control boards which contain i alarms, indications, and graphs. The [F0B] position is that flow rate is I a fundamental parameter important to assuring that operation is within safety limits, and hence the cost of recording the verification once each 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is small compared to the value of assuring operation within safety limits."
TSCB Comments The TSCB finds that retention of TS 4.4.1.1 is consistent with the l result obtained in Enclosure 3.
- 7. TS 4.4.9.1.2 "The reactor vessel material irradiation surveillance specimens shall be removed and examined, to determine changes in material properties, as required by 10 CFR 50, Appendix H in l accordance with the schedule in Table 4.4-5. The results of these examinations shall be used to update Figures 3.4-2 and 3.4-3."
Seabrook Proposal The applicant wants to delete the above Surveillance TS and include it in the ISI/IST program under the scope of a licensee maintained and controlled document.
FOB Position
" Surveillance 4.4.9.1.2 does not include any requirements not already incorporated in 10 CFR 50, Appendix H. Therefore, the [F0B) position is that Surveillance 4.4.9.1.2 can be deleted."
TSCB Coments The TSCB agrees with the FOB position.
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The applicant wants to delete the above Surveillance TS and include the !
requirements in a licensee maintained and controlled document.
l FOB Position "The Bases state 'All snubbers are required to be OPERABLE to insure that the structural integrity of the Reactor Coolant System and all other safety-related systems is maintained during and following a seismic or other event initiating dynamic loads.' Clearly, snubbers are active devices that may have to function upon demand to avoid an immediate degradation of capability required for mitigating the consequences of design basis events. Therefore, the [F0B] position is that the Surveillance Requirement should be retained within the Seabrook Technical Specifications, but that prescription for conducting the surveillance can be transferred to the FSAR."
TSCB Comnents The TSCB finds that the F08 position is not consistent with the result obtained in Enclosure 3. And in particular, the TSCB finds that TS 4.7.7 (and TS 3.7.7) would have to be deleted entirely to be fully consistent with Enclosure 3 Wolf Creek trial split, TS 3.7.8.
D. Deletion of Tables
- 9. TS Table 3.2-1 DNB Parameters,
- 10. TS Table 4.3-5 Meteorological Monitoring Instrumentation Surveillance Requirements, i 11. TS Table 4.3-6 Remote Shutdown Monitoring Instrumentation l Surveillance Requirements,
- 12. TS Table 4.3-7 Accident Monitoring Instrumentation <
Surveillance Requirements, and
- 13. TS Table 4.4-3 Reactor Coolant System Chemistry Limits l Surveillance Requirements.
l Seabrook Proposal l The applicant wants to delete the above Tables and put any deleted requirements back into the TS in text form in appropriate places.
I F0B Position "These tables will be deleted in the [03/13/86] Proof & Review version of the Technical Specifications. With few exceptions the deleted material is a repetition of material in other tables. For the l exceptions, sirsple text additions can be used in lieu of the tables.
Thus, these omissions are in the nature of editorial simplifications."
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- The TSCB does not agree with the F0B position. ;
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TSCB Comments The five changes proposed above are not intended to change the substance of the TS so Enclosure 3 does not apply here; each change must be reviewed on an individual basis. Such reviews are normally plant specific and hence outside the scope of TSCB comments. However, there appears to be a problem with the implementation of one change, as discussed with C. Moon of F0B on 4/7/86 and as documented in the next paragraph.
Deletion of TS Table 3.2-1 would require compensatory changes in TS 4.2.5.1 [as shown in the marked-up TS attachments to the 2/28/86 meno, page 3/4 2-16 (or 2-15) and page 3/4 2-9]. The changes proposed for TS 4.2.5.1 would introduce a requirement for reactor coolant system (RCS) flow limit verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. That requirement is not now in !
TS Table 3.2-1. Moreover, that requirement appears to be inconsistent with TS 4.2.5.2 which requires only that the RCS total flow rate shall be measured every 18 months. The apparent inconsistency should be resolved.
- 14. TS Table 3.7-4 Fire Hose Stations, and
- 15. TS Table 3.7-5 Yard Fire Hyrants and Hydrant Hose Houses.
Seabrook Proposal The applicant wants to dele?e the above Tables from TS and include them in a licensee maintained and controlled document.
F0B Position "These tables will be deleted in the [03/13/86] Proof & Review version of the Technical Specifications. The associated ACTIONS do not directly limit operation of the facility. Therefore, maintenance of the tabulations in the FSAR instead of in the Technical Specifications is appropffate."
TSCB Comments The TSCB recommends that the applicant be given the option to follow the example set by the March 1986 TS for Perry, e.g., change the Seabrook TS '
so as to incorporate .the entire fire protection program into the Seabrook FSAR.
- 16. TS Table 3.6-2 Containment Isolation Valves.
- 17. TS Table 3.8-1 Containment Penetration Conductor Overcurrent Protective Devices, and
- 18. TS Table 3.8-2 Motor Operated Valves Thermal Overload Protection Devices.
- The TSCB does not agree with the F0B position. '
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Seabrook Proposal The applicant wants to delete the above tables fror TS and include them ,
in a licensee maintained and controlled document.
F0B Position j "These tables will not be deleted in the Proof & Review version of the '
Technical Specifications [for the following reasons]."
Concerning TS Table 3.6-2: "The containment isolation system is described in Section 6.2.4 of the SER as a system provided to ensure that no single active failure will result in the loss of containment integrity." ,
Concerning TS Table 3.8-1: "The maintenance of containment integrity is dependent upon successful operation of containment penetration conduction overcurrent protective devices."
Concerning TS Table 3.8-2: "As stated in SER Section 8.3.3-1.3, Thermal-Overload Protection, R.G.1.106 ' Thermal-Overload Protection for Electric Motors on Motor-Operated Valves' (November 1975) recommends bypassing during accident conditions or properly selecting the setpoints for the themal overloads supplemented with periodic testing of these devices, as acceptable methods to be implemented in the design of motor-operated valves. The SER then states that the applicant, by letter dated March 12, 1982, has indicated that thermal overloads are not bypassed and that the selection of trip setpoints, limiting conditions for operation, and surveillance requirements will be reviewed with and included in the Technic'11 Specifications."
' l TSCB Comments j Concerning TS Table 3.6.2: The TSCB would allow deletion of this table subject to conditions of the type in Enclosure 4 in which we recommended a similar deletion for the Hatch plant. This is contrary to the F0B ,
position.
Concerning TS Table 3.8-1: The TSCB finds this TS table could be !
deleted per Enclosure 3, contrary to the F0B position. I Concerning TS Table 3.8-2: The TSCB generic position is that a plant specific argument (such as that used by the F0B) takes precedence over generic arguments. Therefore the TSCB agrees that TS Table 3.8-2 should be retained.
- 19. TS Table 4.11-1 Radioactive Liquid Waste Sampling and Analysis Program.
- 20. TS Table 4.11-2 Radioactive Gaseous Waste Sampling and Analysis Program,
- The TSCB does not agree with the F0B position.
- 21. TS Table 3.12-1 Radiological Environmental Monitoring Program,
- 22. TS Table 3.12-2 Reporting Levels for Radioactivity Concentrations in Environmental Samples, and
- 23. TS Table 4.12-1 Detection Capabilities for Environmental Sample Analysis.
Seabrook Proposal The applicant wants to delete information from the above Tables and place it in a licensee maintained and controlled document.
F0B Position -
"These tables will be deleted in the Proof & Review version of the Technical Specifications. It is obvious that these Tables are not required to be in the Technical Specifications by the criteria of ALAB 531. However,10 CFR 50.36a does require that operating procedures for control of effluents be established and followed. This requirement of 10 CFR 50.36a will be satisfied by inclusion of such a requirement in the Section 6 of the Technical Specifications."
TSCB Coments The FOB position appears to be based on an application of the findings in ALAB-531. These findings are not directly applicable to Radiological Effluent Technical Specializations (RETS). The applicable regulation is, as was noted by the F0B, 10 CFR 50.36a. This regulation does not provide guidance on the specific content of RETS. Such guidance is, however, provided in NUREG-0472, Revision 3, " Draft Radiological i Technical Specifications for PWRs," March 1979. This guidance is that the information in the Tables stated above should be included in individual plant RETS.
1 The TSCB will, as a part of the Technical Specification Improvement Program, develop a position on whether all or part of the current RETS requirements can be transfered to the FSAR or to a licensee maintained and controlled document or can be removed completely. This could result in some of the RETS requirements being placed more under the control of the licensee and allow changes without prior NRC approval as the I Seabrook licensee has proposed. Dropping the requirement for RETS completely would require an amendment to the regulations.
Pending completion of this work TSCB recomends that the current guidance be followed by retaining the Tables in the Seabrook RETS. It is our understanding, however, that in the case of the recently issued Millstone TS a plant specific decision was made to place this type of information in another controlled document which could not be changed without prior NRC approval. In the interim while TSCB develops a position on the RETS issue, the F0B may wish to consider a similar plant specific approach for Seabrook.
- The TSCB does not agree with the F0B position.
l E. Other
- 24. TS 6.3 Station Staff Qualifications Seabrook Proposal The applicant wants to move this TS to Chapter 13 of the FSAR.
FOB Position
" Specification 6.3 ... will be deleted in the Proof & Review version because these qualifications do not have an immediate relationship to ,
the evaluations and analyses of Chapters 6 and 15 of the FSAR.
Therefore, control of changes in these qualification by changes in the FSAR is sufficient."
TSCB Comments The F0B position seems to be based on an application of the ALAB-531 i findings or the criteria for selecting TS proposed in the TSIP report.
These criteria are not directly applicable to section 6.0 of the TS.
The development of improvements to this section of the TS has been designated as a separate line item in the Technical Specification i Improvement Program Plan (Item 4.1). No final conclusions on the appropriate content of this section of the TS have been reached yet.
However, the cerrent DHFT generic position is that TS 6.3, Station Staff j Qualifications, should remain in the TS until the issue has been reviewed thoroughly and a decision reached as a part of the development :
of the new STS.
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- The TSCB does not agree with the F0B position.
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Enclosure 2 PRA-BASED CHANGES *
- 1. TS Item 2.1.1 Safety Limits-Reactor Core
- 2. TS Item 2.1.2 Safety Limits-RCS Pressure Seabrook Proposal The applicant requested a relaxation of the time limit (from one hour to two hours) to trip the reactor if a reactor core or RCS pressure safety limit is violated.
FOB Position The F0B position is that the request should "be denied because violation of a safety limit without an automatic plant trip indicates an unreviewed gap or failure in the plant protection system."
l TSCB Coments Tne TSCB agrees with the FOB position.
- 3. TS Item 3/4.3.4 Turbine Overspeed Protection System
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Seabrook Proposal The applicant requested that the turbine overspeed protection system be deleted from the technical specifications and the testing frequency for all turbine valves be relaxed from weekly to quarterly, Valve testing requirements would only appear in the Station Maintenance Procedures.
F0B Position The FOB position is that "the request to delete the turbine overspeed protection system from the technical specifications be denied because it could violate the staff's acceptance criterion (Seabrook SER)5that the total turbine missile generation probability be less'than 10 per reactor year."
FOB also recommended against " relaxation of valve testing frequency to !
quarterly yeause the potential turbine failure frequency could be as high as 10 per year when comon mode failures are considered."
TSCB Comments The TSCB finds that deletion of tha Turbine Overspeed Protection System from the TS for the 1150 Ne Seabrook PWR would be consistent with the result obtained in a trial split of the TS for the 1150 Ne Wolf Creek PWR, as documented in Enclosure 3. However, the TSCB generic position is that a plant-specific argument (such as that used by the F0B) takes precedence over generic arguments. Accordingly, the TSCB agrees with the FOB position for TS 3/4.3.4.
- Asterisks identify cases where the TSCB does not agree with the FOB position.
l 4. E tem 3.5.1.la Accumulators 4 Seabrook_ Proposal The applicant requested the relaxation of the allowed outage time (from one hour to eight hours) for the accumulators.
l l FOB Position
! The F05 position is that *the proposed relaxation be accepted because 1 than T /RY which is significantly smaller than the 10~g/RY numericalths es gate L objedtive cited in the staff Commission papers for ATWS and Station Blackout rulemaking."
TSCB Comments The accumulators are important, per Enclosure 3, Wolf Creek TS 3.5.1.
The F0B position is taken on a plant-specific PRA basis which does not conflict with Enclosure 3. Accordingly, the TSCB does not disagree with the F0B position.
- 5. TS Item 4.5.1.la Accumulators
- 6. TS Item 4.5.2a ECCS Subsystems Seabrook Proposal The applicant requested a relaxation of the accumulator and ECCS Subsystem valve surveillance interval from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The basis presented for th's request is that the likelihood of valves inadvertently .; losing is very small (10~6) in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval.
F0B Position The F0B position is that the requested relaxation should be accepted ution because F0Bofconcurs (to care melt) with "the an inadvertent applicant's valve closure is argumentvery small (that 10~the contrig/RY) compared to other failures in the systems."
TSCB Comments The accumulators and ECCS Subsystem are..important systems, per
! Enclosure 3. Wolf Creek TS 3.5.1, 3.5.2, and 3.5.3. The FOB position is I
taken on a plant-specific PPA basis which does not conflict with Enclosure 3. Accordingly, the TSCB does not disagree with the F0B position. ,
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- 7. TS Item 3.5.2 ECCS Subsystems Seabrook Proposal
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i The applicant requested a relaxation of the allowed outage time (from three days to seven days) for an ECCS Subsystem. The bases presented ,
for this request are that a change in A0T does not significantly affect I systems availability and that these changes would have a negligible effect on public risk. The applicant also presented a estimateofthechangeincoremeltfrequencyof6x10-gupperbound per year for an increase in A0T from three to seven days.
FOB Position The F0B position is that an increase in A0T from 3 days to 7 days should te of the core melt frequency for be accepted because an " upper estimg/RY) is just about at the numerical nce(2x10-
[the risk dominant]
objective sequg/RY) cited in prior staff actions on ATWS and threshold (10 Station Bla kout, and the estimated average over the plant lifetime is about3x10-g/RY."
TSCB Comments The ECCS subsystems are important systems, per Enclosure 3. Wolf Creek TS 3.5.2 and 3.5.3. The F0B position is taker, on a plant-specific PRA basis which does not conflict with Enclosure 3. Accordingly, the TSCB does not disagree with the FOB position.
- 8. TS Item 3.7.1.2 Emergency Feedwater System Seabrook Proposal The applicant requested a change in the corrective action time from "as soon as possible" to "within one hour" to restore at least one pump.
The applicant's basis for this request is that "immediately changing plant modes with no emergency feedwater pumps available is not the most appropriate action."
FOB Position The F0B position is that "the action time should be extended to one hour to allow the operating staff time to correct the problem or develop alternate means for decay heat removal."
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- The TSCB does not agree with the F0B position.
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TSCB Conments The TSCB disagrees with the applicants prcposal because the standard technical specifications (STS) do not call for a trip when there is no auxiliary feedwater available and the Seabrook proposal would call for such a trip. A private discussion with S. Israel of F0B on 3/19/86 i
indicated that the applicant also proposed to modify STS 3.7.1.2 to include use of only two auxiliary feedwater pumps instead of the three called for in the STS. The TSCB disagrees with this proposal also; the applicant should use STS 3.7.1.2.
i 9. TS Item 3.8.1.1 Electric Power Systems l
Seabrook Proposal The applicant requested relaxation of the A0T for one offsite circuit '
from three days to seven days.
I F0B Position The F0B position is that "the A0T for the offsite ac lines (3.8.1.1)
[should] be made tighter (one day instead of three days) because of the poor performance observed in the installed SF6 lines at the site."
TSCB Comments The electric power systems are important, per Enclosure 3. The F0B position is taken on a plant-specific PRA basis which does not conflict with Enclosure 3. Accordingly, the TSCB does not disagree with the F0B position.
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