ML23059A334
| ML23059A334 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 02/28/2023 |
| From: | Victor Cusumano NRC/NRR/DSS/STSB |
| To: | Technical Specifications Task Force |
| References | |
| EPID L-2019-PMP-0207 | |
| Download: ML23059A334 (1) | |
Text
February 28, 2023 Technical Specifications Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852
SUBJECT:
OPEN ISSUES RE: TRAVELER TSTF-576, "REVISE SAFETY/RELIEF VALVE REQUIREMENTS (EPID L-2019-PMP-0207)
Dear Members of the Technical Specifications Task Force (TSTF):
By letter dated December 13, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19347A726), you submitted to the U.S. Nuclear Regulatory Commission (NRC) for review Traveler TSTF-576, "Revised Safety/Relief Valve [SRV]
Requirements.
On February 9, 2023, NRC staff and the TSTF conducted a public meeting (ML23033A538) to discuss open issues relating to the draft Revision 2 of TSTF-576 (ML23019A253). During that meeting the TSTF clarified several issues for the NRC staff and provided verbal answers to some of our questions. In addition, there was an outstanding issue about the relationship between the technical specifications (TS), the core operating limits report (COLR), and the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code and in-service inspection program.
Following that meeting, the NRC distilled the significant open issues to two main outstanding questions to help us understand how the proposed system-level acceptance criteria in the COLR would be developed and implemented as allowed by this traveler. These may need to be addressed in the traveler and/or model application. The NRC staff requires clarification in writing to allow us to rely on the process outlined in the traveler. These issues supersede the substantive comments provided in September 2022 (ML22258A177) and the comments handed out at the February 2023 meeting (ML23033A384).
As noted in the traveler, the COLR Specification, paragraph c, states that all applicable limits of the safety analysis are met, and the traveler references several impacts beyond the reactor pressure vessel overpressure analyses. The method(s) for determining this are unclear, especially since they may be plant-specific. Also, the proposed COLR limits as discussed in the traveler are characterized as system-level limits which are based on overall performance of the SRVs rather than valve-specific limits. The NRC staff is aware of cases where the most limiting safety analysis may be a valve-specific analysis, such as the SRV piping structural integrity analysis based on dynamic loading during valve actuation.
Finally, the NRC staff seeks clarity on how the new COLR limits would be implemented when performing the proposed surveillance requirements (SRs) (i.e., TS SR 3.4.3.2 for BWR/4 and TS SR 3.4.4.3 for BWR/6), which require evaluating as-found valve test results from the prior cycle against the values in the COLR. To address these concerns, the NRC staff has the following questions:
Technical Specifications Task Force Project 753
- 1.
How will licensees determine that the limits relocated to and/or changed in the COLR ensure that the secondary requirements other than the overpressure limits are protected? How will this determination consider valve-specific limitations due to dynamic loading on the associated SRV piping (e.g., could individual valves require valve-specific setpoint criteria)?
- 2.
Could the COLR limits be changed while verifying that as-found setpoints are within the limits specified in the COLR under the proposed SRs, or do the SRs require the evaluation be done against the COLR limits in place for the prior cycle?
We look forward to discussing these with you after you have reviewed them, to ensure we have a common understanding so we can make an informed decision on any path forward. The review schedule in the acceptance letter dated February 13, 2020 (ML20037A129), is no longer valid. An updated review schedule will be developed once a path forwarded is decided.
If you have any questions, please contact Michelle Honcharik at (301) 415-1774 or via e-mail to Michelle.Honcharik@nrc.gov.
Sincerely, Victor G.
Cusumano Digitally signed by Victor G. Cusumano Date: 2023.02.28 16:21:29 -05'00' Victor G. Cusumano, Chief Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation Project No. 753 cc: See next page
cc:
Technical Specifications Task Force c/o EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Attention: Brian D. Mann email: brian.mann@excelservices.com Drew Richards STP Nuclear Operating Company 12090 FM 521 Mail Code: N5016 email: amrichards@stpegs.com Phil H. Lashley Energy Harbor 168 E. Market St.
Akron, OH 44308 email: phlashley@energyharbor.com Kevin Lueshen Constellation Energy Generation 4300 Winfield Road Warrenville IL 60555 email: kevin.lueshen@constellation.com Jordan L. Vaughan Duke Energy EC07C / P.O. Box 1006 Charlotte, NC 28202 email: jordan.vaughan@duke-energy.com Wesley Sparkman Southern Nuclear Operating Company 3535 Colonnade Parkway / Bin N-226-EC Birmingham, AL 35242 email: wasparkm@southernco.com
ML23059A334 *concurred via e-mail NRR-106 OFFICE NRR/DSS/STSB/PM*
NRR/DSS/STSB/BC*
NAME MHoncharik VCusumano DATE 2/28/2023 2/28/2023