ML993190284
| ML993190284 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 11/01/1999 |
| From: | Beckner W Technical Specifications Branch |
| To: | Jennifer Davis Nuclear Energy Institute |
| References | |
| Download: ML993190284 (9) | |
Text
November 1, 1999 Mr. James Davis, Director Operations Department Nuclear Energy Institute 1776 I Street, N. W.
Suite 400 Washington, DC 20006-3708
Dear Mr. Davis:
This is to inform you of our decisions on changes to the Standard Technical Specification (STS) NUREGs proposed by the NEI Technical Specification Task Force (TSTF). Those travelers Approved are TSTFs -017, R.2; 036, R.4; 037, R.2; 051, R.2; 348; 350; and -351.
Those travelers Modified are TSTFs -284, R.2; 322; and -340. Our comments on those travelers Modified or Rejected are enclosed.
For your information, the following travelers are pending evaluation by a technical branch:
TSTFs -052, R.2 (SPLB); -207, R.3 (SPLB); -226 (SRXB); -264 (SRXB); -295 (EICB); -296 (SRXB); -297 (SPLB); -306 (EICB); -313 (MCEB); -332 (EICB); -334 (SPLB & SPSB); -335 (SPLB); -336 (SPLB); -337 (SRXB); -343 (EMEB); -344 (SRXB); -345 (SRXB); and -352 (SRXB)
Please contact me at (301) 415-1161 or e-mail wdb@nrc.gov, if you have any questions or need further information.
Sincerely, Original Signed By William D. Beckner, Chief Technical Specifications Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 689
Enclosures:
As stated
""DISTRIBUTION:
cc: N. Clarkson, BWOG F CENTER TSB RJF H. Pontious, BWROG PUBLIC TSB Staff T. Weber, CEOG DMatthews/SNewbe .. ,,
D. Buschbaum, WOG WDBeckner S: .....
D. Hoffman, EXCEL RLDennig .
DOCUMENT NAME: G\RTSB\JOHNSON\Owners Group Correspondence\I 199DIS.WPD
- see previous concurrences OFFICE RTSB/DRIP:NRR .. NRR/Proj. 689 SC:RTý;J;NRR C:RTSB/DRIP:NRR NAME DLJohnson* . JBirmingham* RLDe4r4*-" .WDBeckner &V31 DATE 10/26/99 10/29/99 11/ 1/99 11 :/ /99 OFFICIAL RECORD COPY * ,'.
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.4 UNITED STATES 0NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 1, 1999 Mr. James Davis, Director Operations Department Nuclear Energy Institute 1776 1Street, N. W.
Suite 400 Washington, DC 20006-3708
Dear Mr. Davis:
This is to inform you of our decisions on changes to the Standard Technical Specification (STS) NUREGs proposed by the NEI Technical Specification Task Force (TSTF). Those travelers Approved are TSTFs -017, R.2; 036, R.4; 037, R.2; 051, R.2; 348; 350; and -351.
Those travelers Modified are TSTFs -284, R.2; 322; and -340. Our comments on those travelers Modified or Rejected are enclosed.
For your information, the following travelers are pending evaluation by a technical branch:
TSTFs -052, R.2 (SPLB); -207, R.3 (SPLB); -226 (SRXB); -264 (SRXB); -295 (EICB); -296 (SRXB); -297 (SPLB); -306 (EICB); -313 (MCEB); -332 (EICB); -334 (SPLB & SPSB); -335 (SPLB); -336 (SPLB); -337 (SRXB); -343 (EMER); -344 (SRXB); -345 (SRXB); and -352 (SRXB).
Please contact me at (301) 415-1161 or e-mail wdb@nrc.gov, if you have any questions or need further information.
Sincerely, William D. Beckner, Chief Technical Specifications Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 689
Enclosures:
As stated cc: N. Clarkson, BWOG H. Pontious, BWROG T. Weber, CEOG D. Buschbaum, WOG D. Hoffman, EXCEL
Nuclear Energy Institute Project No. 689 cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy Institute Suite 400 Suite 400 1776 I Street, NW 1776 1Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineering, Inc.
Suite 400 12300 Twinbrook Parkway, Suite 330 1776 1Street, NW Rockville, Maryland 20852 Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Licensing Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708 Mr. Hank Sepp, Manager Regulatory and Licensing Engineering Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 1776 1Street, NW Washington, DC 20006-3708
DISPOSITION
SUMMARY
TSTF-284, R.2: Modify Based on discussion with TSTF Owners Group representatives during a TSTF/RTSB meeting on 10114/99, the staff agreed with the met/performed convention concept as proposed.
However, the staff did decide to recommend modification of TSTF-284, R.2. Specifically, the staff agreed to suggest clarifications to language in insert 1 to the TSTF markup of NUREGs 1430,1431, and 1432, to ensure NUREG Section 1.4 adequately explains the distinction between requiring a SR to be met and requiring a SR to be performed. (Note that such clarifications would also apply to NUREGs 1433 and 1434, which already contain the language of insert 1.) In addition, the staff may also propose clarifications to the language in one or more of the proposed examples 1.4-4, 1.4-5, and 1.4-6. Any suggested language changes will be forwarded with the letter requesting modification of TSTF-284, R.2. The staff also proposed that the TSTF prepare a complete list of all SRs in each NUREG (Revision 1) that have notes which modify the SR's applicability, frequency, or both. For each SR note, the list should explain why the note needs changing or does not need changing to conform to one of the met/performed frequency examples (Examples 1.4-3 through 1.4-6). Any other changes to such notes since issuance of Revision I of the NUREGs (i.e., changed by other approved TSTF generic changes) should also be described. The staff asked for this list because TSTF-284, R.2, appeared to omit a few notes contained in the NUREGs that may be relevant to the "met" versus "performed" issue. Such a list will reduce the chance of missing a note that needs changing, facilitate staff review, and ensure the consistent use of met and performed SR notes in all five NUREGs.
TSTF-322, R.7: Modify During the Owners Group meeting (10/13-14/99), the staff discussed and provided marked up copies of TSTF-322, R.A Inserts for WOG, CEOG, BWR!4 and BWRI6 (see attached).
TSTF-340: Modify The description of this change reflects the proposal contained in TSB-015, to permit 7 days to restore the turbine-driven AFW/EFW pump to operability if the pump is found to be inoperable in Mode 3 prior to entering Mode 2 following a refueling outage (i.e., minimal decay heat).
Note that the Plant Systems Branch proposed TSB-015 to address a specific concern highlighted by a Beaver Valley Technical Specification change request. Beaver Valley needed more time (more than 3 days) to repair a turbine driven pump if found inoperable following the kind of routine maintenance which is typically performed during a refueling outage. The actual change proposed by TSTF-340, however, goes further. It proposes to permit 7 days to restore the turbine-driven AFW/EFW pump to operability regardless of which Mode the inoperability occurs. The justification for this relaxation appears insufficient. The proposal also creates an ambiguity regarding the actions required should one of the turbine steam supplies become inoperable (the NUREGs presently require restoration in 7 days). Recommend modification of this proposal limiting it to the problem that TSB-01 5 was attempting to address. Relaxations beyond that will require stronger justification, removal of the noted ambiguity, and Plant Systems Branch approval.
TECHNICAL BRANCH NAMES AND ACRONYMS Division of Engineering (DE)
Materials and Chemical Engineering Branch (EMCB)
Mechanical and Civil Engineering Branch (MCEB)
Electrical and Instrumentation Controls Branch (EICB)
Division of Systems Safety and Analysis (DSSA)
Plant Systems Branch (SPLB)
Reactor Systems Branch (SRXB)
Probabilistic Safety Assessment Branch (SPSB)
S74f Co TSTF-322, Rev. I
- WOG INSERT The Shield Building Air Cleanup System produces a negative pressure to prevent leakage from the "building. SR 3.6.19.4 verifies that the shield building can be rapidly drawn down to [-0.5] inch water gauge in the annulus. This test is used to ensure shield building boundary integrity.
Establishment of this pressure is confirmed by SR 3.6.19.4, Which demonstrates that the shield building down to < [-0.5] inches of vacuum water gauge in the annulus S [22] seconds using onecan be drawn Shield Building Air Cleanup System train. The time limit ensures that'no significant quantity material leaks from the shield building prior todeveloping the negative pressure.. of radioactive Since this SR is a shield building boundary integritytest, it does not need to be performed with each Shield Building Air Cleanup System train. The Shield Building Air Cleanup System train Used for this Surveillance is staggered to ensure that in addition to the requirements of LCO 3.6.19.4, either train will perform this test. The primary Purpose ofi RxK Isto ensure shield buildingintegrity. The secondary purpose of!eSFRX is to ensure tha tShield Building Air cleanup System being tested functions as designed. Th operability of the Shield Building Air Cleanup System train does not constitute a failure of this le The 18 month Frequency is based on the need to perform is
'Surveillance un itsthat apply during a plant outage.
te's4'.
A 0
S 'TSTF-322, Rev. I CEOG INSERT The SBEACS produces a negative pressure to prevent leakage from the building. SR 3.6.11.4 verifies that the shield building can be rapidly drawn down to > [0.25] inch water. This test is used to ensure shield building boundary integrity. Establishment of this pressure is confirmed by SR 3.6.11.4.
which demonstrates that the shield building can be drawn down to > 10.251 inches of water < 1 minute using one SBEACS train. Thetime limit ensures that no significant quantity of radioactive material leaks from the shield building priorto developing the negative pressure.. Since this SR is a shield building boundary integrity test, it does not need to be performed with SBEACS train. The SBEACS train uised for this Surveillance is staggered tO ensure that in addition to the requirements of LCO.3.8.11.4, either train will perform this'uose The inar of *s SR* is to ensure shield building Integrity. The secondary purpose of(ýSRfs to ensure that the SEACS being tested functions as designed. The inoperability of the SB .EACStrain does no constitute a failure of this The 18 month Frequency is consistent with Regulatory iude 1.52 (Ref. 1) guidance fr unctional testing of the ability of the SBEACS.
S TSTF-322, Rev.I l
BWR/6 INSERT The SGT System exhausts the [secondaryl containment atmosphere appropriate treatment to the environment through equipment. Each SGT subsystem is designed to draw down (secondary] containment to > £0.25] inches of vacuum water pressure in the gauge in f [120] seconds and maintain pressure In the [secondary] containment at k 10.266] inches of vacuum water gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate s [4000] CFM. To ensure that all fission products released to are treated, SR 3.6.4.1.4 and SR 3.6.4.1.5 verifythat a pressure In the the [secondary] containment
[secondary] containment that islessthan the lowest postulated pressure external to te (secondary] containment boundary can rapidly be established and maintained. When the SGT system establishment and maintenance of [secondary] containmentpressure Is operating as designed, the cannot be accomplished ifthe
[secondary] containment boundary is not intact. Establishment of this 'pressure Is confirmed by SR 3.4.4.14, which demonstrates that the (secondary] containment can be drawn down to k [0.25] inches of vacuum water gauge In s [1201 seconds using one SGT subsystem. SR 3.6.4.1.5 demonstrates that the pressure in the [secondary) containment can be maintained > [0.266] inches of vacuum water "gaugefor I hour using one SGT subsystem at aflow rate
- s. [4000] cfm. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> test period allows
[secondary) containment to be in thermal equilibrium at steady state conditions. The primary purpose of these SRs is to ensure [secondaiy] containment boundary integrity.
The secondary purpose of these SRs is to'ensure that the SGT subsystem being tested functions as designed. There is a separate LCO with Surveillance Requirements which serves the primary purpose of ensuring OPERABILITY of the SGT System. These SRs need not be performed with each SGT subsystem.
The SGT subsystem used for these Survellarnces Is staggered requirements of LCO 3.6.4.3, either SGT subspstem will erformto ensure that In addition to the this test. The Inoperability of the
-SGTSystem does noticonstitute a failure offhese Surveia
(
( e [secondary] containment boundarYIusually passes thes Operating experience has shown eillances when performed at the 18] moonh F-requency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint_
COVsf- TSTF-322, Rev. A BWR/4 INSERT The SGT System exhausts the [secondary] containment atmosphere to the environment through appropriate treatment equipment Each SGT subsystem is designed to draw down pressure in
[secondary] containment to 2 [0.251 inches of vacuum water gauge in s [120] seconds and maintain the pressure in the [secondary] containment at k [0.266] inches of vacuum water gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a flow rate k [4000] CFM. To ensure that all fission products released tothe [secondary) contanment are treated, SR 3.6.4.4.4 and SR 3.6.4.1.5 verify that a pressure in the [secondary] containment is less than the lfwest postulated pressure externalto te [secondary] containment boundary canthat rapidly be established and maintainmed. When the SGT System Is operating as designed, the establishment and maintenance of [secondary] containment pressure cannot be accomplished
[secondary] containment boundary Is not intact. Establishment of this pressure is confirmed by if the SR
.6.4.1.4, wýhich demronstrates that the [secondary] containment can be drawn down to ; [0.25] inches of vacuum water gauge in P [120] seconds using one SGT subsystem. SR 3.6.4.1.5 demonstrates that the pressure in the [secondary] containment can be maintained a [0.2661 inches of vacuum gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> using one SGT subsystem at a flow rate s [4000] cfm. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> test period water allows
[secondary] containment to be in thermal equilibrium at steady state conditions. The primary purpose of these SRs is to ensure [secondary] containment boundary integrity. The secondary purpose
-these SRs Is to ensure that the SGT subsystem beingtested functions as designed. There of separate LCO with Surveillance Requirements Which serves the primary purpose of ensuring is a OPERABILITY of the SGT System. These SRs need not be performed with each SGT subsystem.
The SGT subsystem used for these Surveillances is staggered to ensure that in addition to the requirements of LCO S.6.4.3, either SGT subsystem will Perform this test The Inoperability of the r - SGT System does not'aconstitue failure o r-yeit/azcs-, Operating experience has shown
-Ne secondary containment boun ary usually passes these Surveillances when performed at the (18] month Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability