ML20245E807

Summary of 890406 Meeting W/Westinghouse Owners Group Re Proposed New STS & Planned Review Process.List of Attendees & Handout Slides Encl

ML20245E807
Person / Time
Issue date:	04/25/1989
From:	Fischer D Office of Nuclear Reactor Regulation
To:	Butcher E Office of Nuclear Reactor Regulation
References
NUDOCS 8905020151
Download: ML20245E807 (53)

Text

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,, ' April 25,1989 .

l MEMORANDUM FOR: Edward J. Butcher, Chief l Techaical Specifications Branch Division of Operational Events Assessment, NRR FROM: David C. Fischer Section Chief  :

Special Projects Section j Technical Specifications Branch Division of Operational Events Assessment, NRR

SUBJECT:

MINUTES OF MEETING WITH WESTINGHOUSE OWNER'S GROUP (WOG)

ON THEIR NEW STANDARD TECHNICAL SPECIFICATIONS (STS)

On April 6, 1989 the NRC staff met with.the Westinghouse Owners Group (WOG) to hear their presentation of their proposed new Standard Technical. Specifications (STS), and to present an overview of the planned review process. The WOG presentation was divided into a short executive briefing and a longer meeting for the staff reviewers in which the format and organization of the submittal were discussed. The review of the WOG new STS commences on April 7, 1989 per

.the schedule and milestone chart provided.

Fridhilign#d B7 Mark Reinhart for j David.C. Fischer, Section Chief Special Projects Section Technical Specifications Branch q Division of Operational Events Assessment, NRR-  !

Enclosures:

List of attendees O WOG slides (bandout)

Milestones for the Westinghouse new STS and lead plant DISTRIBUTION:

Please see attached j

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es2!;d' TEMurley JHConran JHSniezek CHEerlinger OTSB Members FJMiraglia' WDLanning 0TSB R/F DMCrutchfield JLieberman DOEA R/F-SAVarga LCShao PDR BKGrines JWRoe GClainas ELJordan FJCongel CIGrimes FGillespie EJButcher Regional Administrators-

. GMilolahan MGMalsch NRC Participants BDLiaw CERossi OTSB S/F - Meeting Notice WDKennedy y

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MEETING ON WESTINGHOUSE NEW STS April 6, 1989 I

ATTENDEES j Name ORGANIZATION 1

Bob Tjader OTSB/NRR l I

Car 1 Schulten OTSB/NRR.

John Monninger PDIV/DRSP/NRR Larry Kopp SRXB/NRR John Tsao DEST /NRR J Ernie Rossi DOEA/NRR (

David Fischer OTSB/NRR 1 Millard Wohl OTS8/NRR I David Notley DEST /ECEB Howard Richings SRXB/NRR David Fieno SRXB/NRR Robert J. Giardina OTSB/NRR James Wing DEST /ECEB Sai P. Chan DEST /ESGB Tom Dunning OTSB/NRR Scott Newberry DEST /SICB Iqbal Ahmed DEST /SICB l Jose A. Calvo DRSP/PD4 Mark Reinhart OTSB/NRR Jim Richardson EAD/NRR Richard Correta LHFB/NRR Nanette Gilles Region III/NRC Chris L. Hoxie OTSB/NRR Bill Le Fave DEST /SPLB Ken Dempsey EMEB/NRR Jim Miller OTSB/NRR i Calvin W. Moon OTSB/NRR ,

Frank J. Witt DEST /ECEB  !

Jim Lazevnick SELB/NRR Bob White LLNL Jacquie Hinds Pacific Gas & Electric Roger Newton Wisconsin Electric Power Joe George TV Electric Aileen Wooley Spec. Services Warren J. Hall NUMARC

WESTINGHOUSE OWNERS GROUP MERITS PROGRAM 1

ROCKVILLE, MARYLAND APRIL 6, 1989 1

e s PRESENTATION OUTLINE OVERVIEW MEETING OBJECTIVES MERITS PROGRAM INDUSTRY COOPERATION INDUSTRY PROCESS METHODOLOGY PHILOSOPHY OF MERITS TS I

EXAMPLES OF MERITS TS ENHANCEMENTS PHILOSOPHY OF MERITS BASES MERITS PROGRAM STRUCTURE MERITS TS AND BASES REPORT ORGANIZATION MERITS TS FEATURES CORE OPERATING LIMITS REPORT MERITS. BASES

--____a

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MEETING OBJECTIVES I

FAMILIARIZE NRC MANAGEMENT AND STAFF  !

REVIEWERS WITH THE MERITS PROGRAM AND PHASE II REPORT i l

DISCUSS MERITS TECHNICAL SPECIFICATIONS AND BASES REVIEW PLAN WITH NRC OTSB l

u_________

l MERITS PROGRAM PURPOSE AND OBJECTIVES PURPOSE ENHANCE CONTROL ROOM OPERATOR'S USE OF TECHNICAL SPECIFICATIONS (TS) i OBJECTIVES LIMIT TS REQUIREMENTS TO ISSUES OF l IMMEDIATE CONCERN TO THE HEALTH AND SAFETY OF THE PUBLIC DEVELOP HUMAN FACTORED ORGANIZATION AND FORMAT IMPROVE TECHNICAL CONTENT AND UTILIZE TECHNICAL WRITING SKILLS DEVELOP EXPANDED BASES DEVELOP TS WRITERS GUIDE

't 4 6 .

MERITS PROGRAM PROGRAM PLAN PHASE I -

TEST ALL ASPECTS OF THE PROGRAM GAIN NRC ENDORSEMENT

. PHASE II -

APPLY AIF/NRC SCREENING CRITERIA WRITE MERITS TS AND BASES PHASE III -

OBTAIN NRC SAFETY EVALUATION REPORT PHASE IV -

ASSIST PLANT SPECIFIC IMPLEMENTATION 1

LEAD PLANT -

NORTH ANNA UNITS 1 AND 2

MERITS PROGRAM j MILESTONES I MAY 1986 MERITS PROGRAM INITIATION I

MARCH 1987 WOG SUBMITS PHASE-I REPORT T0 NRC MAY 1987 NRC PROVIDES ASSESSMENT OF PHASE I REPORT NOVEMBER 1987 W0G SUBMITS PHASE II CRITERIA APPLICATION REPORT TO NRC MAY 1988 NRC PROVIDES REVIEW 0F CRITERIA APPLICATION REPORT MARCH 1989 WOG SUBMITS MERITS TS AND BASES TO NRC APRIL 1989 NRC INITIATES REVIEW OF MERITS TS AND BASES

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MERITS PROGRAM j

RESOURCES I l

WOG-MERITS WORKING GROUP j WESTINGHOUSE SERVICES WESTINGHOUSE FUNCTIONAL GROUPS WOG-TECH SPEC SUBCOMMITTEE VIRGINIA POWER STAFF COOPERATIVE EFFORT WITH OTHER NSSS VENDOR OWNERS GROUPS AND NUMARC WOG-MERITS PROGRAM EXPENDITURES THROUGH MARCH 24, 1989 - $3.9 M l

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. =.

RESOURCES (continued)

WESTncHoUSE OW?ERS GROUP UTTTM REPRESDUATIVES Rich Belanger New Ha:pshire Yankee Sherry Bernhoft Wisconsin Public Service Corporation Harold Chen eff Wolf Creek Nuclear Operating Corporation )

Tcxn Grosan Florida Power & Light 0:xopany Vice-Chairman, WCG 7bchnical Specification Sub:xt:nittee Jacquie Hinds Pacific Cas & Electric Ccxnpany )

Chairran, W3G Technical  !

Specification StL W ittee l Bt.eaIti Iozito Virginia Power Ctmpany l Chairran, WJG MERITS l Working Group j Rcger Ouellette Duke Power Otmpany Dave Shafer Union Electric Otmpany Grecs Sin $ers Carolina Power & Light Cbqpany 1

Jack Strirgfellcv Georgia Power Otmpany 1

Russell Thcepson h = Valley Authority WESTDGOUSE TECHUCAL SPrx1r1CATICE PRCGRAM SUNICES DcINEERS R. R. Auerswald K. D. Daschke G. P. Richard T. W. Ball F. P. Ferri S. J. Sarver R. L. Bencini M. C. Gross J. D. Simpson D. E. Bottnan J. G. Lahti G. G. Smith C. S. Brockhoff C. E. IbrtJan C. L. Mc:mn R. F. Dockley T. L. Morriscn C. W. Suggs J. W. Buforti J. R. Reagan A. A. Wallens

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1 INDUSTRY COOPERATION )

1 DEVELOP.TS WRITERS GUIDE l I

SHARE DRAFTS OF TS AND BASES i

COMMON REVIEW 0F DRAFTS SHARE SOLUTION OPTIONS i

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INDUSTRY CHAPTER LEADERS USE AND APPLICATION WOG LC0 & SURVEILLANCE WOG ,

REQUIREMENT APPLICABILITY.

REACTOR B&WOG INSTRUMENTATION WOG REACTOR C0OLANT SYSTEM B&WOG ECCS CEOG CONTAINMENT SYSTEMS B&WOG PLANT SYSTEMS CE0G ELECTRICAL POWER SYSTEMS BWR0G REFUELING WOG

INDUSTRY PROCESS METHODOLOGY P

CHAPTER DRAFT  !

1 V

CTG REVIEW CHAPTER TASK GROUP J

INDUSTRY y COORDINATION ICWG REVIEW WORKING GROUP WOG-TSSC W FUNCTIONAL GROUPS CONSISTENCY REVIEW i

l ISSUE

o O d a PHILOSOPHY OF MERITS TS l

CONFORM TO NRC REVIEW OF MERITS CRITERIA APPLICATION OPERATOR ORIENTATION MAKE TS TECHNICALLY CORRECT AND COMPLETE STATE REQUIREMENTS CLEARLY.AND CONCISELY ADD REQUIREMENTS WHERE NEEDED PROPOSE SELECTED IMPROVEMENTS REMOVE DUPLICATION GROUP RELATED REQUIREMENTS TOGETHER HAVE MERITS TS GENERALLY APPLICABLE TO WOG PLANTS

___ __ _ _ _ _a

EXAMPLES OF MERITS TS ENHANCEMENTS .

FORMAT NRC APPROVED RX TRIP SYSTEM AND ESFAS -

PRA BASED IMPROVEMENTS G.L. 88-16 CYCLE SPECIFIC VARIABLES G.L. 89-01 RETS j REPORTING REQUIREMENTS MOVED TO )

ADMINISTRATIVE CONTROLS l CROSS REFERENCES ADDITION OF MAIN FEEDWATER ISOLATION TS GROUP CONTAINMENT INTEGRITY REQUIREMENTS INTO A SINGLE LCO

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I REACTOR COOLANT SYSTEM 3/4.4.8 SPECIFIC ACTIVITY .

LIMITING CONDITION FOR OPERATION 3.4.8 The specific activity of the primary coolant shall be limited to:

a. Less than or equal to 1.0 microcurie per gram DOSE EQUIVALENT I-131, and

b. Less than or equal to 100/E microcuries per gram.

APPLICABILITY: MODES 1, 2, 3, 4, and 5.

ACTION:

H0 DES 1, 2 and 3*:

a. With the specific activity of the primary coolant greater than 1.0 microcurie per gram DOSE EQUIVALENT I-131 but within the allowable l limit (below and to the lef t of the line) shown on Figure 3.4-1, '

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operation may continue for to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided that the cumula-tive operating time under - te circumstances does not exceed 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in any consecuti, 12-month period. With the total cumulative operating time at a primary :colant specific activity greater than 1.0 microcurie per gram DOSE EQUIVALENT I-131 exceeding 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in any consecutive 6-month period, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days indicating the number of hours above this limit. The provisions of Specification 3.0.4 are not applicable.

b. With the specific activity of the primary coolant greater than 1.0 microcurie per gram DOSE EQUIVALENT I-131 for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during one continuous time interval or exceeding the limit line shown on Figure 3.4-1, be in at least HOT STANDBY with T less than 500*F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. avg

c. With the specific activity of the primary coolant greater than 100/I microcuries per gram, be in at least HOT STANDBY with T less than 500'F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, avg I

• With T,yg greater than or equal to 500*F.

W-STS

~ 3/4 4-27 H:Y : 1081

I REACTOR COOLANT SYSTEM ACTION: (Continued)

MODES 1, 2, 3, 4, and 5: '

a. With the specific activity of the primary coolant greater than ,

1.0 microcarie per gram DOSE EQUIVALENT I-131 or greater than 100/E microcuries per gram, perform the sampling and analysis requirements of item 4a of Table 4.4-4 until the specific activity of the primary .

coolant is restored to within its limits. A REPORTA8LE OCCURRENCE shall be prepared and submitted to the Commission pursuant to Speciff-cation 6.9.1. This report shall contain the results of the specific activity analyses together with the following information:

1. Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded, ,

2. Fuel burnup by core region,

3. Clean-up flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded.

4. History of de gassing operations, if any, starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in .vhich the limit was exceeded, and 1

5. The time duration when the specific activity of the primary i coolant exceeded 1.0 microcurie per gram DOSE EQUIVALENT l-131. )

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SURVEILLANCE REQUIREMENTS 1

4.4.8 The specific activity of the primary coolant shall be determined to be within the limits by performance of the sampling and analysis program of Table 4.4-4.

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i 20 30 40 50 80 70 80 90 100 PERCENT OF RATED THERMAL POWER FIGURE 3.41 DOSE EQUIVALENT l-131 Primary Coolant Specific Activity Limit Versus Porcent of RATED THERMAL POWER with the Primary Coolant Specific Activity >1.0pCl/ gram Dose Equivalent 1131

.- a M-STS 3/4 4 20 tiOV 2 1981

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RCS Specific Activity 3.3.17 3.3 REACTOR COOLANT SYSTEM (RCS) 3.3.17 RCS Specific Activity LC0 3.3.17 Reactor coolant specific activity shall be limited to:

a. A gross specific activity of 100/E yC1/g,

b. A DOSE EQUIVALENT I-131 specific activity as provided in Figure 3.3.17-1, and

c. A DOSE EQUIVALENT I-131 specific activity of 1.0 yCi/g.

APPLICABILITY: MODES 1 and 2, MODE 3 with RCS average. temperature 1 500*F.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Reactor coolant gross A.1 Be in MODE 3 with RCS 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> l specific activity average temperature outside limit. < 500*F. {

1 AND l A.2 Perform SR 3.3.17.1. Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> until reactor toolant gross specific l

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activity restored to within limit j (continued)  ;

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Unit Name 3.3-43 Amendment 60G-CE M @. fht /L_---

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'RCS Specific Activity  ;

3.3.17  ;

ACTIONS (continued) h CONDITION REQUIRED ACTION COMPLETION TIME ] i l

B. Reactor coolant DOSE B.1 Verify, by performing Once per EQUIVALENT I-131 SR_3.3.17.4, reactor -4 hours i specific activity coolant DOSE EQUIVALENT  !

> 1.0 pCi/g. 1-131 specific activity is s the limit provided j-in Figure 3.3.17-1.

08 >

B.2 Verify, by performing 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> I SR 3.3.17.4, reactor- I I

coolant DOSE EQUIVALENT-I-131 specific activity l 1s s 1.0 #Ci/g. I C. Reactor coolant DOSE C.1 Be in MODE 3 with RCS 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> EQUIVALENT l-131 average temperature specific activity > the < 500*F.

limit provided in figure 3.3.17-1. q 1

.03 Required Actions of Condition B not met I 1

within required i Completion Times.  !

1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY  !

l SR 3.3.17.1 Verify reactor coolant gross specific 72. hours s activity within limit. 1 (con,tinued) . .  ;

1 Unit Name 3.3 Amendment WOG-MERITS Cb% A ._ .

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RCS Specific Activity 3.3.17 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE- FREQUENCY

..... NOTE-----

Only required in MODE 1 SR 3.3.17.2 Verify reactor coolant DOSE EQUIVALENT 14 days I-131 specific activity within limits by performing a full isotopic analysis, including I-131, I-132, 1-133, I-134, and I-135..

SR 3.3.17.3 -----.-------------NOTE------------------- -----NOTE-----

Sample after a minimum of 2 EFPD or Only required 20 days of MODE I operation have elapsed in MODE 1 -

since the reactor was last subcritical -------------

for 1 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Determine i by radiochemical analysis. 6 months SR 3.3.17.4 Verify reactor coolant DOSE EQUIVALENT From 2 to 6 I-131 specific activity within limits by hours after performing a short isotopic analysis using a THERMAL I-131, 1-133, and I-135. POWER change of 115% RATED

. THERMAL POWER within a 1-hour period e

CROSS REFERENCES - None.

Unit Name 3.3-45 Amendment WOG-MERITS Ra A

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RCS Specific Activity 3.3.17 300 ,  ;  ;

THIS FIGURE FOR ILLUSTRATION ONLY.

DO NOT USE FOR OPERATION.

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20 30 40 50 60 70 80 90 100 l Percent of RATED THERMAL POWER Figure 3.3.17-1 (Page 1 of 1)

Reactor Coolant DOSE EQUIVALENT I-131 Specific Activity Limit Versus Percent of RATED THERMAL POWER Unit Name 3.3-46 Amendment WOG-MERITS Rem A

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RHILOSOPHY OF MERITS BASES j l

EXPAND CONTENT l

LINK TS REQUIREMENTS TO THE SAFETY ANALYSES 1

LINK TS REQUIREMENTS TO APPROPRIATE ,

SCREENING CRITERION I DESCRIBE WHY EACH TS REQUIREMENT IS 1 NEEDED l

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I MERITS TS AND BASES REPORT ORGANIZATION INITIAL REPORT FIVE '/0LUMES ORGANIZED FOR REVIEW TABLE OF CONTENTS IN.EACH l VOLUME INTRODUCTION IN EACH VOLUME l

l TS, BASES, AND JUSTIFICATIONS ARE TOGETHER FOR EACH LC0 FINAL REPORT ORGANIZED FOR USE l

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TS IN ONE VOLUME BASES IN SEVERAL VOLUMES JUSTIFICATIONS IN ONE VOLUME

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MERII5_ PROGRAM STRUCTURE l

INDUSTRY COORDINATION NSSS VENDOR OWNERS GROUPS NUMARC WOG-MERITS MERITS WORKING GROUP WOG - TS SUBCOMMITTEE WESTINGHOUSE TS SERVICES WESTINGHOUSE FUNCTIONAL GROUPS UTILITY - WESTINGHOUSE CHAPTER LEADERS 1

MERITS TS AND BASES REPORT ORGANIZATION FIVE VOLUMES REPORT FRONT MATTER TABLE OF CONTENTS, INTRODUCTION IN EACH VOLUME TS FRONT MATTER PREFACE TS TABLE OF CONTENTS LIST OF ACRONYMS 4

1

.o MERITS TS AND BASES REPORT ORGANIZATION (CONTINUED) l FIVE TS DIVISIONS DIVISION 1 - USE AND APPLICATION DEFINITIONS LOGICAL CONNECTORS COMPLETION TIMES LEGAL CONSIDERATIONS DIVISION 2 - SAFETY LIMITS i

1 MERITS TS AND BASES REPORT ORGANIZATION (CONTINUED) ,

1 DIVISION 3 - LC0 l

3.0 APPLICABILITY 3.1 REACTOR 3.2 INSTRUMENTATION 3.3 RCS l l

3.4 ECCS l

3.5 CONTAINMENT 3.6 PLANT SYSTEMS i

3.7 ELECTRICAL SYSTEMS l

1 3.8 REFUELING OPERATIONS

i

.. l MERITS TS AND BASES REPORT ORGANIZATION (CONTINUED)

DIVISION 4 - DESIGN FEATURES DESCRIBES TEXT CHANGES NEEDED TO BE MADE 1 BY LICENSEES FOR MERITS IMPLEMENTATION I

DIVISION 5 - ADMINISTRATIVE CONTROLS l I

DESCRIBES TEXT CHANGES NEEDED TO BE MADE BY LICENSEES FOR MERITS IMPLEMENTATION MERITS BASES EXPANDED BASES FOR EACH TS REQUIREMENT JUSTIFICATIONS IDENTIFY AND EXPLAIN EACH CHANGE RELATIVE TO STS OR OTHER REFERENCE TS

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-4 48 MERITS TS FEATURES J

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CONTROL ROOM OPERATOR ORIENTED HUMAN FACTORED FORMAT CLEAR AND CONCISE STATEMENT OF REQUIREMENTS CONSISTENT PRESENTATION STYLE

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- i GROUP RELATED REQUIREMENTS TOGETHER CLEAR IDENTIFICATION OF REQUIRED  !

SHUTDOWN ACTIONS l i

OPTIONAL USE OF CROSS-REFERENCES l GENERALLY APPLICABLE TO WOG PLANTS MERITS TS CHANGES D0 HDI REQUIRE NEW ANALYSES l

.. j l

CORE OPERATING LIMITS REPORT (COLR) J MERITS TS PROVIDES EXAMPLES l

MERITS TS EXAMPLES COMPLY WITH G.L. 88-16 i

ADDITIONAL-INFORMATION CAN BE PROVIDED TO  !

SUPPORT MERITS TS EXAMPLES I J

LICENSEES WILL DEFEND COLR USE WOG CONSIDERING LEAD-PLANT APPROACH l

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. 1 Coments on the-Reactor Chanter Draft I ine HERITS Technical Specification Program will be complete in the near future. The first chapter to reach the Draft Stage for inclusion in the topical report is the Reactor Chapter which is attached for your ,

information. In looking through this chapter, a number of changes can be i noted which distinguish these specifications from the existing i specifications in the Desk Reference STS or an existing plant specification used as a model.

One difference to note is the use of the CORE OPERATING LIMITS REPORT (COLR) as the means of providing the limiting values for Moderator Temperature Coefficient, rod insertion limits, core maaking factors, and axial power distribution. One other difference is tse relocation of reporting requirements to the Administrative Controls section. . There are other differences between MERITS and the Desk Reference STS that may be considered to fall into the categories of Relaxations or Added Requirements. Some of these are noted below:

Relaxations Specifications related to Control or Shutdown Rod Irisertion Limits have been rewritten as specifications for Control or Shutdown Bank Insertion-Limits. The specification for rod group alignment addresses the issue of individual rod positions compared to group or demand positions. l The required Completion Time for restoring one or more Shutdown Banks to within their insertion limits has been increased from I hour to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.-

This is consistent with the currently licensed time for Control Banks below insertion limits. The issues of concern'are the same in either case: core peaking factors and LHUTDOWN MARGIN in the applicable PDES.

The specification on Moderator Temperature Coefficient (MTC) includes a feature that allows the End Of Cycle surveillance to be discontinued provided the value of MTC measured at 60 ppm is within the limiting value at 60 ppm provided in the COLR.

The AXIAL FLUX DIFFERENCE (AFD) specification for Constant Axial Offset Control (CAOC) no longer requires AFD to be within the Target Band below 50%. Prior to increasing power above 50%, it requires that the accumulated penalty minutes be fewer than 60 within the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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Added Requirements 'I The specification on QUADRANT POWER TILT RATIO (QPTR), modeled after the Seabrook technical specifications, now contains Required Actions calling for the reevaluation of specific safety analyses.

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Overlap and sequence requirements have been added to the specification on .

Control Bank Insertion Limits. These limits will appear in the COLR.

An additional surveillance has been added to the Fg specification which provides for a direct check on the value of Fg in addition to the checks on a potential violation of limits ( using the F xy type specification or the F g(Z) surveillance type specification which employs a W(Z) factor).

The specification for MODE 1 Physics Tests Exceptions now contains as a requirement the standard practice of setting the Power Range Neutron Flux, tiigh Trip Set >oints to 510% of Rated Thermal Power (RTP) above the power .

level at whici the tests are being performed with a maximum setting of 90%  ;

of RTP.  !

These items listed are not intended to be comprehensive listing of all the changes, but do point out some of the mors significant ones, i

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CommentsontheInstrumentation'ChanterDraft 1he MERITS Technical Specification Program will be complete-in the near-future. One'of the first chapters to reach the draft stage for inclusion j

into the topical report is the Instrumentation Chapter which is attached-for your information. . In looking through this chapter, a number of changes can be noted which distinguish theseLspecifications from the existing D i

specifications in the.Deak Reference STS or an existing plant specification used as a model.

Reactor Trip System Instrumentation, LCO 3.2.1-l Added Requirements ]

A requirement to have NIS Source Range channels OPERABLE in MODES 3,.4,'and' 5 with the reactor trip breakers open has been:added.to the specification.

Numerous reactor trip functions have been added to the-specification to make it applicable to as many Westinghouse plants as reasonably possible, including 2, 3, and 4 loop plants.with varying numb::rs of channels.

Conditions and associated actions now address one or two inoperable NIS- 1 Intermediate Range channels or Source Range channels. l Performance of an ANALOG CHANNEL OPERATIONAL TEST on the.NIS Power Range Low Setpoint reactor trip function prior to reactor.startup hasLbeen added.

The action for an inoperable' P-10 channel above P-10 now have the operator verify the interlock is in the correct state for existing plant' conditions;

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within 15 minutes after going below P-10.

The actions for an inoperaule manual reactor trip function now also open. '

the reator trip breakers within'I hour.

Relaxations The format for the trip functions now has all of the requirements for each particular function contained in a single table. This also includes'the Limiting Safety System Settings from Section 2. of the STS.

The performance of Equation 2.2-1.has.been deleted from the specification because it does not reflect current industry practice.

The Response Time Tables have been removed from the Technical Specifications and will be relocated to another controlled document.- The performance of Response Time Testing is maintained in the LC0 but the  ;

actual tables have been relocated.

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. . j Comments on the Instrumentation Chaoter Draft (continued)

The note allowing bvp8 sing of the NIS Power Range reactor trip during surveillance testfrs us been expanded to allow bypassing while resetting  !

the Trip Setpoint.

Surveillance used to determine NIS response to core burnup have been l changed from a daily frequency to a frequency of effective full power days. j l

The improvements from WCAP-10271 have been incorporated into the MERITS 1 specifications. I l

The performance of a plateau curve for the NIS Power Range detectors has j been deleted since they have a fixed voltage power supply. j Other The conditions now clearly allow being in more than one condition at a (

time. This is a clarification of the STS. l The reactor trips on low flow, RCP Undervoltage, RCP Underfrequency, and RCP Breaker position are now only applicable when above P-8 (Single Loop) ,

I or above P-7 and below P-8 (Two Loops).

The reactor trips on turbine trip are now only applicable above the [P-9) setpoint.

The reactor trip breaker undervoltage coil and shunt trip coil are now a_

separate line item and are no longer included with.the reactor trip breaker line item.

The MERITS technical specifications no longer address (n-1) loop operation.  ;

1 The f(AI) function has been separated fro'a the NIS Power Range High  !

Setpoint reactor trip function and is a separate line item in the table. '

The surveillance associated with the f(AI) function are with this function and no longer with the NIS Power Range High Setpoint reactor trip function.

The MERITS position regarding the reactor trip bypass breakers is that they must meet the same Surveillance Requirements as the reactor trip breakers if they (the bypass breakers) are going to be placed in service.

The MERITS format has deleted the use of Total Number of Channels and Minimum Channels Operable. The_new format uses the column heading Minimum -

Channels Operable but is really the same as the old Total Number of Channels. The STS actions have been reworded to address this change.

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Comments on the Instrumentation Chapter Draft .) 1 j

(continued) k Engineered Safety Features Actuation System Instrumentation, LC0 3.2.2 f Added Requirements Numerous ESFAS functions have been added to the specification to make it i applicable to as many Westinghouse plants as reasonably possible, including 2, 3, and 4 loop plants with varying numbers of channels.

A completion time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> was added to the Containment Purge Isolation function for closure of the associated valves.

The required actions for an inoperable P-12 or P-14 interlock have been clarified to state that additional actions from the respective functional section aust also be performed, in addition to verifying the status of the interlock.

Relaxations The format for the trip functions now has all of the requirements for each j particular function contained in a single table.

The performance of Equation 2.2-1 has been deleted from the specification j!

because it does not reflect current industry practice.

The Response Time Tables have been removed from the Technical Specifications and will be' relocated to another controlled document. The performance of Response Time Testing is maintained in the LCO but the i actual tables have been relocated.

The improvements from WCAP-10271 have been incorporated into the MERITS specifications.

01hfLt The conditions now clearly allow being in more than one condition at a time. This is a clarification of the STS.

The MERITS technical specifications no longer address (n-1) loop operation.

The requirement to have the individual Main Steam Line Isolation Valve switches as part of the ESFAS functions has been deleted. This is a manual actuation and the Safety Analyses do not model manual actuation for these l

valves. This function is covered in LCO 3.6.3, Main Steam Isolation Valves.

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i Comments on the Instrumentation Chapter Draft j i

(continued) 4 i

The requirement to have the individual Auxiliary Feedwater Pump switches as 4 part of the ESFAS functions has been deleted. This is a manual actuation l and the Safety Analyses do not model manual. actuation of Auxiliary l Feedwater. This function is covered in LCO 3.6.5, Auxiliary feedwater System.

The Safeguards 4 kV Bus Undervoltage and Degraded Voltage functions only .

start the emergency diesel generators. These functions have been relocated ]I to LCD 3.7.1, AC Sources Operating. <

l The MERITS format tas deleted the use of Total Number of' Channels and Minimum Channels operable. , The new lormat uses the column heading Minimun Cbsnnels Operable but is really.the same as the old Total Number of Channels. The STS actions have been reworded to address this change.

Accident Monitoring. Instrumentation, LCO 3.2.3 )

t Added Requirements

. Conditions now address plants that.have more than 2 channels per function.

These actions 'are based on the Vogtle Technical Specifications.

Relaxations The reporting requirements have been moved to the Administration.section of i technical specifications.

The table has been shortened to show only examples of variables that utilize the prescribed required actions. Plant specific lists are. in the i plant specific FSAR and plant specific Technical Specifications. l The STS allowed outage times have been increased, consistent with otiier J licensed technical specifications. .

Other The conditions now clearly allow being in more than one condition at a time. . This is a clarification of the STS.

The completion times for functions that are on a "per unit" basis are now .;

clearly identified.

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Comments on the Instrumentation Chapter Draft. j s

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(continued). i J

Remote Shutdown System- ,

.1 Relaxations .

The reporting requirements have been moved to the Administration.section of technical specifications. < u The table has been shortened to show only examples of variables that utilize the prescribed required actions. Plant specific. lists are in the plant specific FSAR and plant specific Technical Specifications.

The STS allowed outage times have been increased, consistent with other licensed technical specifications.

Other j l

The conditions now clearly allow being in more than one condition at a i time. This is a clarification of the STS. 4 The completion times for functions that'are on a "per unit" basis are now clearly identified. j l

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• 1 REACTOR COOLANT SYSTEM

SUMMARY

OF ADDED REQUIREMENTS AND RELAXATIONS The MERITS Technical Specification Program is comple'te through Revision A of the Topical Report. In looking through the RCS Chapter, a number of changes can be noted which distinguish the specifications of Revision A from the Desk Reference STS or other existing specifications used as models.

One difference to note is the use of the CORE OPERATING LIMITS REPORT l (COLR) as the means of providing the limiting values of the j Pressure / Temperature Curves and the Heatup and Cooldown Limits. Another '

difference, is the relocation of reporting requirements to the Administrative Controls section. Other differences between the MERITS ,

specifications and the model specifications are listed below in categories '

of either relaxations or added requirements. .)

Rel axat ions Specifications relocated outside of technical specifications.  ;

The DNB specification was modified to include RCS flow. Although the inclusion of RCS flow is not a specific relaxation, the surveillance '

i requirements for verifying RCS flow were relaxed. The requirment for i verifying RCS flow prior to exceeding 75% has been deleted since the flow j instruments and temperature instruments are calibrated prior to startup and their-indications provide adequate indication of flow degradation.

The pressurizer safety valve specification was modified to permit in situ setting of the valves provided a cold setting is done prior to. entering the applicable modes of the LCO.

In the operational leakage specification a number of changes were made.

These changes include deleting surveillance for monitoring the RCS leakage detection instrumentation and the Reactor Vessel Head Flange Leakoff system, making a separate LCO for PIV leakage, and removing controlled leakage. The controlled leakage was relocated to a new LCO more appropriately identified as Seal Injection Flow. In addition, surveillance related to post maintenance activities have been deleted from individual specifications.

The RCS leakage detection instrumentation specification has been revised to allow continued operation for up to 30 days with all sump monitors inoperable.

The APPLICABILITY for RCS specific activity has been changed to MODES 1, 2, l and_3 with RCS average temperature < 500 degrees F. Also, the definition of E was removed from the specification since the definition already exists in the definition section of technical specifications.

The Cold Overpressure Prevention specification has been modified to permit

! use of the RHR suction relief valves provided the. unit adequately verifies the acceptability of the valves for this function.

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Added Requirements There are no specific a'dded requirements to the RCS Chapter. However, relocation of existing requirements-in other chapters to the RCS Chapter-may be considered as added requirements, and therefore, are listed below.

The new Pressure Isolation Valve Leakage specification contains surveillance for verifying RHR Auto-Closure interlocks. These  !

requirements existed in the ECCS Chapter.

The Cold Overpressure Prevention specification contains requirements'for l lockout of high pressure injection pumps. These requirements existed .in the ECCS Chapter.

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! I Summary of ECCS Chapter Changes Thc following summarizes the major changes made to the Westinghouse'STS as a result of the current MERITS program. Each change is briefly summarized below. The complete justification for the change can be found in the j justifications supplied with each spec. (j o

LCO 3.4.1 Accumulators The Required Action time for opening the isolation valve of "immediately" was changed to I hour in order to quantify the term "immediately".

The Completion Time for restoring boron concentration was changed from I hour to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> based on the South Texas Project Technical Specifications.

The surveillance activities which required verifying that the isolation i valves would open automatically was eliminated since this LCO _ requires that the isolation valves are open and the power to the valves is removed.

The phrases "by the absence of alarms" was eliminated from the surveillance on pressure and volume since this is sper.ifying method of determining accumulator pressure and volume.

The ANALOG CHANNEL OPERATIONAL TEST was eliminated since this test requiras the lifting of leads or draining down the reference leg. In addition the ANALOG CHANNEL OPERATIONAL TEST and the CHANNEL CALIBRATION surveillance were both eliminated.

The boron concentration limits were relocated to the CORE OPERATING LIMITS REPORT.

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. i LCO 3.4.2 ECCS Trains - Tavg 2 350*F 1

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Condition B was added to allow operability when 100% of required flow is )

available with inoperabic components in separate trains. l The phrase "during shutdown" was deleted so as to not require a. shutdown to -i perform the flow balance test surveillance.  ;

Surveillance Requirement 3.4.2.4 provides verification that the pump's developed head is greater than or equal to the required developed head at one point on the pump's required head curve. This is an alternative to the STS, Rev. 5 which required that the pumps be tested at the recirculation flow point. However, the same information is obtained by testing at any  !

point along the pump's required head curve. This developed head technique is proposed to allow more flexibility in testing. An example of this would be testing in a normal operational alignment, rather than a recirculation alignment. Neither the intent nor the meaning of the existing specification is changed. - Testing at any one flow point is sufficient to warn of abnormal sump performance. Under ASME requirements, a pump head curve is establis ted and any change in this established ownp head curve is ,

monitored by periodic ASME Section XI pump testing. Aliowable pump  !

degradation is limited by the ASME Section XI requirements or the pump I operating performance assumptions used in the accident analyses, whichever is greater.

LC0 3.4.3 ECCS Trains - Tava < 350*F The note regarding the centrifugal charging pump operability was relocated to the COMS spec, LC0 3.3.18, Overpressure Protection.

LCO 3.4.4 Seal Injection Flow This LC0 was created when the definition for CONTROLLED LEAKAGE was deleted from the Use & Application section.

LC0 3.4.5 Refuelina Water Storace Tank I l

The boron concentration limits were relocated to the CORE .0PERATING LIMITS REPORT.

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COMMENTS ON THE CONTAINMENT CHAPTER 1

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1. The Containment Chapter table of contents combines all 4 containment types into one chapter. Previously the Westinghouse Owners Group (WOG) " Standard Technical Specifications (STS) Containment Chapter M consisted of 4 repetitive chapters.  !

2. Consistent' with the practice' of' identifying requirements for a system 3 or component in only one LCO, the WOG MERITS Containment Integrity j Specification has been revised to include the requirements of the f following STS specifications: ~ 3.6.1.1, 3.6.1.2, -3.6.1.3, 3.6.1.4, .

3.6.1.8, and 3.6.4.

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3. The Atmospheric and Dual Containment Sprs/ and Cooling-System Specifications were combined into one new MERITS specification.~ 'The Ice Containment Specifications.do not' include a. Cooling System and a separate Containment Spray Specification was provided in MERITS for I Ice Containments.

4. The STS Containment Internal Pressure Specification has been split into two specifications. One MERITS specification for Atmospheric ,

Dual and Ice Containments and a separate MERITS. specification for-Subatmospheric Containments.

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5. The STS Containment Air' Temperature Specification has been split into three MERITS' specifications. One for Ice Containments. One for Subatmospheric Containments and one specification for Atmospheric and- i Dual Containments. )

6. The STS Electric Hydrogen Recombiner Specification ha's been split into two MERITS specifications. One specification for Ir,ternal and one for External Hydrogen Recombiners.

7. The two STS Ice Containment Specifications Divider Barrier Personnel Access Doors and Equipment Hatches and Divider Barrier Seal were combined into one MERITS Specification Divider Barrier Integrity.

8. Two additional STS Ice Containment Specifications Floor Drains.and i Refueling Canal Drains were combined into one MERITS Specification Containment Recirculation Drains. ,

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9. The STS Shield Building Integrity Specification has been' incorporated  ;

into the MERITS Specification Shield Building Air Cleanup' System. '

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10. The Hydrogen Monitor and'Recombiner specifications were revised to- l accommodate more relaxed Conditions and Completion Times in accordance with NUREG 0737. l j

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Comments on the Electrical Systems Chaoter Draf t j The MERITS Technical Specification Program will be complete in the near future. Among the first Chapter to reach the Draft Stage for inclusion in the l topical report is the Electrical Systems Chapter which is attached for your information. In looking through this chapter, a number of changes can be noted which distinguish these specifications from the existing specifications in the q i

Desk Reference STS.

One difference to note is the relocation of the diesel generator fuel oil properties to the Bases. Because of the unit to unit differences in the Standards or proceduras used to identify and scrify fuel oil properties the specific details are better addressed by unit administratively controlled procedures and discussed in the Bases. The Surveillance Requirements for fuel oil properties have been retained. One other difference is the relocation of the special reporting requirements for diesel generator failures to the Administrative Controls section. There are differences between MERITS and the Desk Reference STS that may be considered to' fall into the categories of Relaxations or Added Requirements. Some of these are noted below:

Relaxations Requirements for diesel generator lubricating oil storage and transfer to the 3 diesel generator have been deleted. These items are related to refilling the i diesel generator lubricating oil, are part of the maintenance procedures, and are diesel generator OPERABILITY considerations if the lubricating oil is low and cannot be replenished.

The diesel generator test schedule was changed in the " Number of failures in tast 100 Hours" column from 5 4 and 2 5 to s 5 and 2 6 consistent with approved licensing amendments for the Diablo Canyon units.

In the DC Sources - Operating specification the requirement frequency for verification of the battery Category B limits after an over charge or terminal ,

voltage below a specified value has been changed from 7 days to 31 days  !

consistent with the IEEE Battery Working Group recommendations for ]

modifications to Standard Technical Specifications. -

The required action Completion time for one inverter inoperable in the Distribution Systems Operating specification has been changed to " initiate action to restore in 15 minutes" and " continue actions to restore until completed" from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The reason for this change is that during this period the bus supplied from the inverter is powered by the constant voltage source powered form the 480 VAC emergency bus as is the battery charger which supplies power to the inverter. Also, the safety functions are maintained and in the event of loss of AC power, which would require loss of both offsite  :

power and onsite diesel generator power, these safety functions are covered by the other complete train with two inverters and the remaining inverter-in the i train with the inoperable inverter. >

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• -- (continued)

Adde'd Requirements The ESFAS functions for the loss of' voltage (under voltage) trip device; grid degraded voltage trip device,--and the load shedding and. sequencing ~ timer in..the-Electrical Systems Chapter. These functions were relocated to this section from the ESFAS section of the Instrumentation Chapter.

Action has been added to address the condition where one diesel generator and one offsite circuit are inoperable at the same time.

A surveillance has been included to verify the proper pressure in the diesel generator air start receivers.

A sentence has been added to the Diesel Generator Test Schedule notes to clearly indicate the surveillance in AC Sources - Operating that do noti constitute a valid failure of the diesel 92nerator, such_ as .the ESFAS.

functions, fuel oil verifications, or other auxiliary equipment which should be addressed independently from the diesel generator testing frequencies.

The APPLICABILITY of the AC Sources - Shutdown, DC Sources - Shutdown, and Distribution Systems - Shutdown specifications has been extended to cover when-handling irradiated fuel and operations ~over irradiated. fuel assemblies. In these same specifications, a requirement has been added to within 15 minutes to suspend any operation which may result in draining the reactor vessel.

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Plant Systems Chapter Comments The Plant Systems Chapter as issued in the MERITS format contains various changes that are apparent when compaired to the Desk Reference Standard <

Technical Specifications. Some of these changes, which include both additions l to and relaxations from the Standard Technical Specifications, are noted below. ..

1. The Main Steam Safety Valve specification has been rewritten as two specifications which differ in response according to the RTP of the unit.

A relaxation has been provided that enables the unit to remain at < 10% RTP ,

by closing the inoperative Main Steam Safety Valve. 1 1

An additional relaxation of four hours has been provided in the Completion  !

Time allotted to reset the Power Range Neutron Flux --High trip setpoint.

Due to the complexity of both reducing the RTP and resetting the four 1 channels of the trip setpoint, a total of eight hours is now allotted as I the Completion Time. t In response to a previously unaddressed condition, an additional. i Surveillance Requirement has been identified. During reduction of the l Power Range Neutron Flux--High trip setpoint, the new Surveillance spt:ifies the reduced trip setpoint as the correct value rather than the l value specified in the. Instrumentation Chapter l l

Among items deleted from the Standard Specification are the references to )

N-1 loop operation and the Orifice Size required in the lift setting table. l

2. The Main Steam Isolation Valve specification now provides a relaxation in MODES 2 and 3 whereby one or more inoperative valves may be closed rather than place the unit in MODE 4 operation.

A Note has been added to allow for post repair OPERABILITY demonstration.

This allows the repaired valve to be cycled in MODES 2 or 3 rather than place the unit in MODE 4 operation.

3. In response to a previr,usly unaddressed condition, a new specification has been written concerning the safety isolation of the Main Feedwater System.

As this system varies in design from unit to unit, the specification has been written to address both the Main Feedwater Isolation Valves and the Main Feedwater Regulation Valves. It is the unit's option to specify the i idenity of the Main Feedwater System safety isolation valve and thus which specification shall be included in the unit's technical specifications.

The Callaway Main Feedwater specification is the bases for these two alternative specifications.

Page 1 of 2  :

i 4 The Auxiliary Feedwater System Surveillance of both the motor-driven and  ;

the turbine-driven pumps have been changed from a frequency of once every 31 days on a staggered test basis to a frequency based upon ANSI Section XI-pump test requirements. The pump's operational requirements have also been changed from a specified flow rate at a specified pressure to the testing of any point along the pump's required head curve in accordance with ANSI '

Section XI pump test requirements. This revised technique will allow greater testing -flexibility without. changing either the intent or the meaning of the existing specification. j In response to a previously unaddressed condition, the Action Statement now I addresses the situation when three Auxiliary Feedwater pumps are inoperable. In this condition,any MODE. changes will be suspended until at least one pump is restored to service  ;

5. An additional Action Statement has been added to both the Component Cooling i System and the Service Water System specifications. These statements address the situation when all trains of the system are inoperable.

6. The Control Room Air Cleanup System, the ECCS Pump Room Emergency Air Cleanup System, and the Fuel Building Air Cleanup System specifications ~ )

have been enlarged to include the applicable Action Statements and Surveillance Requirements that were formerly located in the Instrumentation Chapter.

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Commen,ts on MERITS Refuelino Chapter

1. The boron concentration value is being relocated to the Core Operating Limits Report.  ;

2. An LC0 requirement, LCO 3.8.2, was added which requires that the valves used to isolate unborated water sources are maintained secured in the closed position, for the plants which require this LCO, the requirement had been a surveillance requirement in the Boron Concentration technical  ;

specification. I

3. The requirements of 3 technical specifications, Containment Building Penetrations, Containment Purge and Exhaust Isolation System, and the i appropriate MODE 6 requirements frorn Radiation Monitoring Instrumentation have been combined into one MODE 6 technical specification.  ;

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4. For the Containment Building Penetrations technical specification, methods of isolation equivalent to a valve or blind flange are now permitted.

Possible methods could include a closed system in containment or a foam sealant.

5. In the RHR - Low Water Level technical specification, a surveillance requirement was added to verify a second OPERABLE RHR loop. The surveillance requirements were also made consistent to the RHR MODE 5 - ,

Loops Not filled technical specification.

6. The Reactor Vessel Water Level technical specification was split into 2 technical specifications, one for high water level and one for low water level. The low water level technical specification will permit small amounts of RCCA movement'within the reactor vessel with the equivalent of 23' of water above the fuel, as opposed to 23' of water above the reactor vessel flange. ,

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-l HERITS BASES -

BACKGROUND  !

i APPLICABLE SAFETY ANALYSES 'I LCOS APPLICABILITY ACTIONS j l 4 SURVEILLANCE REQUIREMENTS  ;

REFERENCES i

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SUMMARY

MERITS TS AND BASES-FOCUS ON OPERATOR USE I

NUMARC PRIORITY ISSUE  !

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a STRONG NRC COMMISSIONER SUPPORT FOR TS IMPROVEMENTS I

LARGE C00PERAT1VE INDUSTRY PROGRAM l

SUBSTANTIAL WOG COMMITMENT AND INVESTMENT 1

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