ML20246H635
| ML20246H635 | |
| Person / Time | |
|---|---|
| Issue date: | 07/03/1989 |
| From: | Rossi C Office of Nuclear Reactor Regulation |
| To: | Sterling E ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| References | |
| NUDOCS 8907170154 | |
| Download: ML20246H635 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION
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July 3,1989 I
Hr. Edward C. Sterling, III, P.E., Chairman l
Combustion Engineering Dwners Group c/o Arizona Nuclear Power Project 11226 N. 23rd Avenue Phoenix, Arizona 85029 Cear Mr. Sterling:
1 As you. know..the combustion Engineering Owners Group (CEOG) submitted proposed j
Restructured Standard Technical Specifications (RSTS) tu the NRC staff on June i
1 7, 198P. The NRC staff conducted an acceptance revicw of the submittal from June 7 througi, June 23. The results of this review were discussed with Richard Bernier on June 27, 1989.
The staff accepts the proposed RSTS and supporting material as sufficient to begin its. review. However, because of the number of proposed changes to i
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requirements that were to be retained in technical specifications and because of incomplete justifications for these changes, the staff is unable to assess j
at this time the impact on our resources and schedule. We understand that-substantially more material on proposed requirement changes will be forthcoming
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. from the CE0G in July,1989. The impact on the staff's review schedule will depend on the adequacy and. timeliness of the CE0G's response to the items i
listed below. Therefore, while we are beginning our review at this time, we will reassess our position in October 1989 to determine whether it is necessary to suspend the review or to extend the schedule due to a lack of the required information.-
REQUIRED It: FORMATION TO FULLY PROGRESS WITH THE REVIEW 0F THE CEOG'S PROPOSED
. HEW STS 1.
Please provide the staff with a comprehensive, marked up version of the current Combustion Engineering STS which identifies or includes the following:
a.
The complete Justification for not including, in the new STS, requirements that were to be retained. As an example, Table 3.3-10 in the current STS contains requirements for Feedwater Flow and Containment Water Level (Wide Range) instrumentation. The staff needs to.know where these requirements are to be relocated and the basis for such relocation, b.
The preferred location for requirements which have been authorized for relocation outside the RSTS, where adequate discussion is not present in the " Discussion" section of Volume 5 of the RSTS.
2.
Changes to requirements as a result of generic letters must be implemented exactly and completely as described in the generic letters. Since these details are mostly generic, they tnust be included in the standard. For example. Generic Letter 88-16. which allows for the use of a Ccre Operating 1imits Report (COLR), provides a very specific section to be added to the administrative control section of RSTS. The CEOG should submit an appropriate sub-section for Section 5.8 " Procedures and Programs."
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Mr. Edward C. Sterling, III 3.
Associated with the example used in item 2 above, Generic letter 88-16 is not intended to plece parameters which are not cycle specific in a COLR.
With respect to the CE0G's proposed RSTS, the following parameters do not appear to normally vary from cycle-to-cycle and therefore are not appropriate for inclusion in a COLR:
a.
Linear Heat Rate b.
DNBR Operating Limit based on Core Protection Calculator (CPC) monitoring.
The Moderator Temperature Coefficient (MTC) could be relocated to a COLR, but the positive and negative bounds should be retained in the RSTS.
For other parameters proposed to be included in a COLR, the new'STS must provide the specific references to NRC-approved methodologies used to develop the respective parameters and associated acceptance criteria.
Generic Letter 88-16 requires that the specific references " identify the Topical Report (s) by number, title, and date, or identify the staff's safety evaluation report for a plant-specific methodology by NRC letter and date."
Hawever, an NRC-approved, plant-specific methodology, by itself, does not constitute an NRC-approved, generic methodology. The new STS should also make it clear that individual plants have the option of retaining cycle specific parameters in their TS even if approvad methodologies for their plant exists.
For a satisfactory review of the parameters to be placed in a COLR, the staff needs a sample COLR which includes these parameters.
As an alternative, it may be more practical to retain all of the parameters in the body of the new STS and to identify the COLR option for plant specific submittals. With this alternative, submittal of the COLR and referenced NRC-approved methodologies could be deferred until the lead plant submittals.
The RCS Pressure and Temperature (P/T) Limits are not a COLR item and should not be placed in a COLR. However, the staff will consider a document similer to the COLR for P/T Limits, if submitted by the CEOG.
4 Surveillance Requirement 3.5.1.2 dealing with containment structural integrity should be expanded to clarify what surveillance are required.
Furthermore, the applicable acceptance criteria must be identified or referenced somewhere in the specifications.
5.
1he staff understands that the full text of the proposed new STS will be provided on electronic media in Word Perfect version 5.0 by July 26, 1969.
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July 3,,1989
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-Mr. Edward C. Sterling.'IIIl -
s As'~ discussed with Richard Bernier during a July 2,:1989 telephone conversation, your: complete response should be to the staff,by: July 20,.1989 in order to allow-the staff review team sufficient time to perform a meaningful review and return the marked up RSTS to the CEOG by August _23.-
Sincerely, ORIGINAL SIGNED BY JOSE A. CALVO..
/g Charles E. Rossi. Director.
Division of Operational Events' Assessment
. Office of Nuclear Reactor Regulation cc:. J. B. George M..R. Edelman T. E. Tipton
.A. Bivens:
W. J.. Hall' S. Webster-E. Lozito
.R. A. Bernier
'J. R. Hinds R. R. Sgarro J. Klapproth' C. W. Smyth' DISTRIBUTION:
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