ML20249A624
| ML20249A624 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/1998 |
| From: | Beckner W NRC (Affiliation Not Assigned) |
| To: | Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9806180008 | |
| Download: ML20249A624 (4) | |
Text
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3 June 11, 1998 Mr. James Davis Nuclear Energy Institute 1776 Eye Street, N. W.
Suite 300 Washington, DC 20006-2496
Dear Mr. Davis:
Disposition has been made on six proposed changes to the Standard Technical Specification (STS) NUREGs made by the NEl Technical Specification Task Force (TSTF). Disposition for TSTF-229 and -253 is Approve. Disposition for TSTF-171, -235, -240, and -258 is Modify; the disposition summaries for these TSTFs are enclosed.
The TSTF is reminced to exercise discipline in considering the threshold for proposed changes to the improved STS. Given the NRC as well as industry resource constraints and related discussions during meetings between the NRC and the TSTF, please refrain from proposing changes that are style only and have no effect on the STS requirements; e.g., TSTF-253.
Please contact me at (301) 415-1161 or e-mail wdb@nrc. gov if you have any questions or need further information on these dispositions.
Sincerely, Original Signed By William D. Beckner, Chief Technical Specifications Branch Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated cc: N. Clarkson, BWOG D. Wuokko, BWOG.
B. Ford, BWROG J. Volkoff, CEOG L. Bush, WOG D. Hoffman, EXCEL DISTRIBUTION:
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Mr. James Davis l Nuclear Energy Institute .
l 1776 Eye Street, N. W.
Suite 300 Washington, DC 20006-2496 I
Dear Mr. Davis:
1 l Disposition has been made on six proposed changes to the Standard Technical Specification i
(STS) NUREGs made by the NEl Technical Specification Task Force (TSTF). Disposition for l TSTF-229 and -253 is Approve. Disposition for TSTF-171, -235, -240, and -258 is Modify:
the disposition summaries for these TSTFs are enclosed. !
The TSTF is reminded to exercise discipline in considering the threshold for proposed l changes to the improved STS. Given the NRC as well as industry resource constraints and related discussions during meetings between the NRC and the TSTF, please refrain from )
proposing changes that are style only and have no effect on the STS requirements; e.g., J TSTF-253.
Please contact me at (301) 415-1161 or e-mail wdb@nsc. gov if you have any questions or need further information ore these dispositions.
Sincerely,
/4,/ ~ d. h&"
William D. Beckner, Chief Technical Specifications Branch -
Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated cc: N. Clarkson, BWOG D. Wuokko, BWOG B. Ford, BWROG J. Volkoff, CEOG -
L Bush, WOG D. Hoffman, EXCEL l
1' . .. . . _ . . . _ . _ _ _ . . . . _ . _ . _ . . . .
s DISPOSITION
SUMMARY
I TSTF-171: Modify l:
l The justification for the proposed change to SR 3.3.1.3 states that the change will ensure that
! the power range detectors are calibrated prior to reaching full power which could result in accidentally exceeding the allowed overpower limits. We agree that this justification provides an acceptable statement of the need for the proposed change. However, the TSTF markup l.
of SR 3.3.1.3 includes a provision to defer required testing only "after each fud loading prior to operation above 90% RTP." The TSTF justification should provide discussion for each change to the SR and to the proposed Bases.
TSTF-235: Modify This proposed change is consistent with 1) Westinghouse Nuclear Safety Advisory Letter, NSAL-94-OO1, " Operation at Reduced Power Levels with inoperable MSSVs," dated January 20,
! 1994, and NRC Information Notice 94-60, " Potential Overpressurization of the Main Steam
[ System," dated August 22,1994. .The proposed STS Section 3.7.1 is acceptable, except Action l_ ltem B which allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for reducing the power range neutron flux - high reactor trip l- setpoint in accordance with STS Table 3.7.1-1. We believe that the required completion time to j reset the power range neutron flux - high reactor trip should be consistent with the allowable l time for reducing thermal power in accordance with STS Table 3.7.1-1, which is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This j (s because the reactivity related transient initiated from a partial power level would require a reactor trip from the power range neutron flux - high setpoint to prevent overpressurization )
of the main steam system (this fact is stated in the proposed TS bases B 3.7.1). Therefore, the required Actions B.1 and B.2 should have the same safety significance with respect to overpressure protection.
TSTF-240: Modify The proposed changes to the LCOs are acceptable, and most of the Bases changes are acceptable.
However, the Bases for B 3.2.2, ACTIONS, A.1.1, (p. S 3.2-24) proposes to ;
l' delete the second and third paragraphs. These paragraphs provide the Bases for a note l which remains; therefore, these paragraphs should remain. (
TSTF-258: Modify 5.7.2d.2 and 5.7.2d.3(ii) l The proposed change is not acceptable for high radiation areas with dose rates in excess of 1 l R/hr. The STS provides several options for licensees to use and provides adequate flexibility L while still maintaining an adequate level of control over workers in high radiation areas. The
. proposed changes.will reduce the level of control maintained by the TS.
5.7.1e and 5.7.2e The proposed change to "...when the knowledge of the dose rates must be made to the worker." is not accepted. The STS provide appropriate controls to ensure workers are adequately controlled
o .% l i
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and protected while working in high radiation areas. The STS allows time for the RP technician )
to evaluate tne radiological hazard and brief the work 6rs about the radiological conditions in the work area prior to the workers entering the high radiation area. The control is required to ensure that workers do not focus solely on the work to be performed but remain informed about radiological conditions. However, there has been alternate wording to the STS proposed .l' by a licensee that was accepted by the staff in a licensee amendment. The approved alternate wording follows: "Except for individuals qualified in radiation protection procedures or ,
personnel continuously escorted by such individuals, entry into such areas shall be made only l after dose rates in the area have been determined and entry personnel are knowledgeable of them. These continuously escorted personnel will receive a pre-job briefing prior to entry into such areas. .This dose rate determination and knowledge does not require documentation prior to initial entry." This alternate wording may be proposed by licensees in lieu of the -
1 STS. However, the wording of the STS will remain as issued.
J 5.7.2a The preposed change-to substitute the word " inadvertent" for " unauthorized" is not accepted.
High radiation area controls are divided into distinct modes of control; areas below 1 R/hr where 9arricades are acceptable to prevent inadvertent entry and areas above 1 R/hr where the radiological is significantly greater and thus requires the use of locked doors which are not only in: ended to prevent inadvertent but to ensure that unauthorized entry is prevented. The use of the word " unauthorized" is expressly used to denote the extra controls that are required for high radiation areas greater than 1 R/hr. Regulatory Guide 8.38 does discuss the use of physical barriers to prevent unauthorized entry. The word " unauthorized" will continue to be used. .
5.7.2a.2 The comment is not accepted. The STS does not imply that an area would be locked so as to :
prevent personnel from exiting the area. The STS is designed to be very clear and literal. The l NRC and the licensee will recognize that a locked door will be " unlocked" when workers enter or exit the area, and this action would not result in a NOV. The standard TS wording will not be l
changed. I l
5.7.2f i
-The comment in not clear. The STS control is offered to licensees as a " relief" from 10 CFR j Part 20. If a licensee has a special need; a custom TS can be proposed and justified for the staff's consideration. The standard TS wording will ne be changed.
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