ML21126A071

5/6/2021 Meeting Handout - Interaction of Technical Specification Surveillances and 10 CFR 50.69

ML21126A071
Person / Time
Site:	Technical Specifications Task Force
Issue date:	05/06/2021
From:	Technical Specifications Task Force
To:
Honcharik M
Shared Package
ML21126A068	List: ML21126A071 ML21126A072 ML21126A073 ML21127A275
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Download: ML21126A071 (6)

Text

Technical Specifications Task Force TSTF A Joint Owners Group Activity Interaction of Technical Specification Surveillances and 10 CFR 50.69 1

Technical Specifications Task Force TSTF A Joint Owners Group Activity Issue Statement

• There are many TS SRs which reference the Inservice Testing Program (IST) in the frequency or in the surveillance.

- ~11 PWR STS and 7 BWR STS

• It was unclear what actions are required by a licensee if a system tested by one of those SRs is no longer required to meet requirements of 10 CFR 50.55a(f) due to categorization under 10 CFR 50.69.

• Making a change to the TS SR prior to removing the component from the IST is undesirable because it requires NRC approval of a change that should be able to be performed under the approval to use 50.69.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Issue Scope

• The industry identified systems that could potentially no longer be required to meet the requirements of 10 CFR 50.55a(f) and have SRs that reference the IST program.

• PWR Systems

- ECCS pump developed head

- CIV Isolation Time

- Containment Spray pump developed head

- MSIV isolation time

- MFSV, MFCV, SFCV, MFIV, and MFRV isolation time

- EFW/AFW pump developed head

• BWR Systems

- Standby Liquid Control pump developed head

- PCIV and SCIV Isolation Time 3

Technical Specifications Task Force TSTF A Joint Owners Group Activity Industry Position

• 78% of plants have adopted TSTF-545, TS Inservice Testing Program Removal &

Clarify SR Usage Rule Application to Section 5.5 Testing, which introduced a TS definition that states, "The INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 10 CFR 50.55a(f)."

• After reviewing the various combinations of Improved TS requirements, non-ITS requirements, and adoption of TSTF-545, the industry developed the following position:

- For the plants that have adopted TSTF-545, a change to the TS is not required to apply 10 CFR 50.69 special treatment provisions to frequencies that reference the Inservice Testing Program if the licensee's program that fulfills the requirements of 10 CFR 50.55a(f) contains a provision for testing components that are subject to alternate treatment under 10 CFR 50.69.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Industry Position

• For the operating plants with TS based on the STS that have not adopted TSTF-545, the TS Section 5.5, "Inservice Testing Program," does not contain any specific requirement regarding performance of testing in accordance with 10 CFR 50.55a(f) and no change to the TS is required.

• However, if the plant TS is not based on the STS and Surveillance Requirement 4.0.5 contains a reference to "specific written relief has been granted by the Commission," regarding testing frequencies, a change to the TS to permit exceptions from 10 CFR 50.55a(f) under 10 CFR 50.69 would be required to change the frequency of IST testing under 10 CFR 50.69.

• A licensee may choose to revise the applicable TS to explicitly address alternative testing requirements under 10 CFR 50.69 for clarity even if it is not required.

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Technical Specifications Task Force TSTF A Joint Owners Group Activity Discussion 6