ML25241A166
| ML25241A166 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 09/08/2025 |
| From: | Michelle Honcharik Office of Nuclear Reactor Regulation |
| To: | Technical Specifications Task Force |
| References | |
| EPID L-2024-PMP-0005 | |
| Download: ML25241A166 (4) | |
Text
September 8, 2025 Technical Specifications Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RE: TRAVELER TSTF 604, REVISION 0, REVISE VENTILATION SYSTEM ACTIONS (EPID: L-2024-PMP-0005)
Dear Members of the Technical Specifications Task Force:
By letter dated March 4, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25063A075), you submitted a request to the U.S. Nuclear Regulatory Commission (NRC) to incorporate Traveler TSTF 604, Revision 0, Revise Ventilation System Actions, into the standard technical specifications.
Upon review of the information provided, the NRC staff has determined that additional information is needed to complete the review. Mr. Brian Mann, Vice President of Licensing, EXCEL Services Corporation, agreed that the NRC staff will receive your response to the enclosed request for additional information questions within 90 calendar days of the date of this letter.
The review schedule that was provided in the acceptance letter dated April 29, 2025 (ADAMS ML25104A287), has not changed.
MILESTONE SCHEDULE DATE Issue Draft Safety Evaluation April 28, 2026 Issue Final Safety Evaluation August 26, 2026 If you have any questions, please contact me at (301) 415-1774 or via email to Michelle.Honcharik@nrc.gov.
Sincerely,
/RA/
Michelle C. Honcharik, Senior Project Manager Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation Project No. 753
Enclosure:
Request for Additional Information 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 Wadsworth, TX 77483 Email: amrichards@stpegs.com Rebecca L. Steinman Constellation Energy Generation 4300 Winfield Road Warrenville IL 60555 Email: Rebecca.Steinman@constellation.com Jordan L. Vaughan Duke Energy EC07C / P.O. Box 1006 Charlotte, NC 28202 Email: jordan.vaughan@duke-energy.com Shane Jurek 2818 Provin Oaks Ct NE Grand Rapids, MI 49525 Email: Shane.Jurek@pseg.com
- via email NRR-106 OFFICE NRR/DRA/ARCB/BC* NRR/DSS/SCPB/BC* NRR/DSS/STSB/BC* NRR/DSS/STSB/PM*
NAME KHsueh MValentin SMehta MHoncharik DATE n/a 9/3/2025 9/8/2025 9/8/2025
REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATIONS TASK FORCE TSTF-604, REVISION 0, REVISE VENTILATION SYSTEM ACTIONS (EPID: L-2024-PMP-0005)
INTRODUCTION By letter dated March 4, 2025 (Agencywide Documents Access and Management System Accession No. ML25063A075), the Technical Specifications Task Force (TSTF) submitted Traveler TSTF-604, Revision 0, Revise Ventilation System Actions, to the U.S. Nuclear Regulatory Commission (NRC).
The U.S. Nuclear Regulatory Commission (NRC) staff requires the following additional information complete our review of the traveler.
REQUESTS FOR ADDITIONAL INFORMATION
- 1. Using the CLIIP for adoption of TSTF-604 would require that a licensee previously adopted TSTF-287 and TSTF-448 (or have made the same changes to their TS). Please clarify in TSTF-604 this requirement, so it is clear to the licensees.
- 2. Please provide additional justification for why the boundary inoperability is an equivalent safety significance as two mechanical systems being inoperable.
- 3. For clarity and consistency purposes, revise the STS Bases markup for two control room ventilation subsystems inoperable to better align with the inoperable boundary bases writeup. Additionally, the word temperature is listed twice in the control room ventilation bases markups. Therefore, immediate action must be initiated to implement mitigating actions to lessen the effect on the CRE occupants from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature, relative humidity, and temperature
- 4. Section 3.1 of TSTF-604 states in part If both control room ventilation trains or subsystems are inoperable, it's also possible that the control room occupants are not protected, but there are a number of ways that the ventilation trains or subsystems may be inoperable while still providing protection to the control room occupants Please provide more details and/or examples of how the control room occupants would be protected while ventilation trains or subsystems are inoperable.
- 5. TSTF-604 does not provide reasonable assurance that adequate protection will be maintained without the ventilation systems and without the use of compensatory measures. Because the compensatory measures are relied upon to provide reasonable assurance that adequate protection will be maintained, and they are considered part of the fundamental technical basis for the approval of TSTF-604, the NRC staff consider them to be a requirement. Either provide additional justification for not including TS requirements to implement mitigating actions for all proposed TS ventilation systems or include the compensatory measures as a TS requirement.
- 6. (TSTF-604 PDF page 56 of 89) B.3.7.12 - ECCS PREACS Action A.1 (1431) The Bases states in part: Concurrent failure of two ECCS PREACS trains would result in the loss of functional capability; therefore, LCO 3.0.3 must be entered immediately. Provide additional information about this apparent inconsistency or revise the bases.