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MONTHYEARML23205A2142023-08-10010 August 2023
Acceptance for Review Regarding Traveler TSTF-596, Revision 0, Expand the Applicability of the Surveillance Frequency Control Program (SFCP)
Project stage: Acceptance Review
ML24262A1132024-09-18018 September 2024
TSTF-596 Rev 1 Expand the Applicability of the Surveillance Frequency Control Program (SFCP) Additional Corrections Needed
Project stage: Other
2023-08-10
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Category:- No Document Type Applies
MONTHYEARML24262A1132024-09-18018 September 2024
TSTF-596 Rev 1 Expand the Applicability of the Surveillance Frequency Control Program (SFCP) Additional Corrections Needed
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Text
COMMENTS ON TECHNICAL SPECIFICATIONS TASK FORCE TSTF-596, REVISION 1, EXPAND THE APPLICABILITY OF THE SURVEILLANCE FREQUENCY CONTROL PROGRAM (SFCP)
(EPID L-2023-PMP-0002)
On January 31, 2024, the Technical Specifications Task Force (TSTF) submitted TSTF-596, Revision 1, Expand the Applicability of the Su rveillance Frequency Control Program (SFCP),
(ADAMS Accession No. ML24031A319).
The TSTF states that TSTF-596 proposes to expand the applicability of the SFCP at nuclear power plants to include other periodic testing fr equencies in Technical Specifications (TS)
Section 5.5, Programs and Manuals. The TSTF indicates that the proposed change also revises the SFCP to encompass additional regulatory mechanisms that may be used to control surveillance frequencies, such as Title 10 of the Code of Federal Regulations (10 CFR),
Section 50.55a, Codes and standards, and 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and component s for nuclear power reactors. The proposed change revises Surveillance Requirements (SRs) that reference the Inservice Testing (IST)
Program to instead reference the SFCP. The proposed change affects the Standard Technical Specifications (STS) in NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, and NUREG-1434.
The STSB staff noted the following corrections/clarifications may be needed based on the changes made to TSTF-596, Revision 1, to ensure consistency throughout the STS:
NUREG-1430
- 1) The references in the STS Bases for 3.4.10, Pressurizer Safety Valves, need correction.
The Background Section refers to Reference 1 as being the ASME Boiler and Pressure Vessel Code,Section III. However, in NUREG-1430, Revision 5 (i.e., before TSTF-596), Ref 1 was the O&M Code. TSTF-596 changed the reference to 50.55a(f). Neither are correct for the Reference in the Background Section. Please add the BPV Code,Section III as a reference and revise the Background Section to refer to the BPV Reference (similar to NUREG-1431).
- 2) SR 3.4.11.1 (PORV Block Valves) should be marked up to reflect that the frequency is based on 50.55a(f) vice the ASME Code (Ref 3). In addition, the SFCP frequency statement should be marked up to reflect that it is controlled by the SFCP in accordance with 10CFR50.55a(f). Ref 3 needs to be revised to 50.55a(f).
- a. Same comment for SR 3.8.1.6 (fuel oil pump test).
NUREG-1431
- 1) SR 3.4.11.1 (PORVs) should be marked up to reflect that the frequency is based on 50.55a(f) vice the ASME Code (Ref 3). In addition, the SFCP frequency statement should be marked up to reflect that it is controlled by the SFCP in accordance with 10CFR50.55a(f). Ref 3 needs to be revised to 50.55a(f).
- a. Same comment for SR 3.8.1.6 (fuel oil pump test).
NUREG-1432
- 1) SR 3.4.11.1 (PORVs) should be marked up to reflect that the frequency is based on 50.55a(f) vice the ASME Code (Ref 4). In addition, the SFCP frequency statement should be marked up to reflect that it is controlled by the SFCP in accordance with 10CFR50.55a(f). Ref 4 needs to be revised to 50.55a(f).
- a. Same comment for SR 3.8.1.6 (fuel oil pump test).
NUREG-1433
- 1) SR 3.5.1.12 (ADS) is marked up to reflect that it is a 50.55a(f) required test. However, the SFCP frequency statement is not marked up to reflect that it is controlled by the SFCP in accordance with 10CFR50.55a(f).
- a. Same comment for SR 3.5.3.2 (RCIC).
- b. Same comment for SR 3.5.3.3(RCIC).
- 2) SR 3.4.3.2 (SR/Vs) is a 50.55a(f) test. While the Bases say the frequency is based on the S/RV test required by the Boiler and Pressure Vessel Code, the test itself is actually required by the O&M Code. Accordingly, the test should be marked up to reflect that it should be controlled in accordance with 10CFR50.55a(f) (similar to SR 3.4.4 in NUREG-1434).
- 3) SR 3.8.1.6 (EDG Fuel Oil Transfer Pump) is a 50.55a(f) test. It refers to the ASME Code as the basis for the frequency. It should be marked up to reflect the TSTF-596 changes.
NUREG-1434
- 1) The Background Section for the Bases to LCO 3.4.4 deletes the ASME BPV Code reference (Ref 1) but retains the discussion relative to the BPV requirements. The reference (in NUREG-1434, Revision 5) incorrectly cited the O&M Code. Please add the BPV code to the list of references and correct the Background Section to cite the BPV Code reference.
- 2) SR 3.4.4.2 is marked up to reflect that is it a 50.55a(f) required test. However, the SFCP frequency statement is not marked up to reflect that it is controlled by the SFCP in accordance with 10CFR50.55a(f).
- a. Same comment for SR 3.5.3.2.
- b. Same comment for SR 3.5.3.3.
- 3) SR 3.8.1.6 (EDG Fuel Oil Transfer Pump) is a 50.55a(f) test. It refers to the ASME Code as the basis for the frequency. It should be marked up to reflect the TSTF-596 changes.