TSTF-05-08, Submittal and Request for Fee Waiver for Review of TSTF-485, Revision 0, Correct Example 1.4-1.

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Submittal and Request for Fee Waiver for Review of TSTF-485, Revision 0, Correct Example 1.4-1.
ML051570066
Person / Time
Issue date: 05/31/2005
From: Crowthers M, Infanger P, Sparkman W, Woods B
B & W Owners Group, BWR Owners Group, Combustion Engineering Owners Group, Technical Specifications Task Force, Westinghouse Owners Group
To: Funches J
Document Control Desk, NRC/OCFO
References
TSTF-05-08
Download: ML051570066 (12)
v • d • e


Text

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l _ TECHNICAII SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY May 31, 2005 TSTF-05-08 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Mr. Jesse L. Funches Chief Financial Officer U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Submittal and Request for Fee Waiver for Review of TSTF-485, Revision 0, "Correct Example 1.4-1"

Dear Sir or Madam:

Enclosed for NRC review is TSTF-485, Revision 0, "Correct Example 1.4-1." TSTF-485 is a proposed change to the Standard Technical Specifications (STS) NUREG- 1430 through NUREG-1434, and a candidate for adoption by licensees under the Consolidated Line Item Improvement Process (CLIIP).

TSTF-359, "Increase Flexibility in MODE Restraints," was approved by the NRC on May 12, 2003. TSTF-359 was a risk-informed change to STS LCO 3.0.4 and SR 3.0.4 and was granted a fee waiver. Subsequent to the approval of TSTF-359, it was determined that the changes to LCO 3.0.4 and SR 3.0.4 required a corresponding change to STS Section 1.4, Example 1.4-1. Without this change, Example 1.4-1 is incorrect. TSTF-485 corrects Example 1.4-1 and resolves this inconsistency in the ISTS.

We request that NRC review of TSTF-485 be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. The changes in this Traveler should have been included in TSTF-359 - a fee exempt change. As such, this Traveler meets the same exemption requirement in 10 CFR 170.1 1(a)(1)(iii) as TSTF-359, in that it is "a means of exchanging information between industry organizations and the NRC for the specific purpose of supporting the NRC's generic regulatory improvements or efforts." In this case, the generic regulatory improvement is risk-informed technical specifications.

The Owners Groups have not allocated funding for NRC review of this Traveler. If this change is not granted a fee waiver, please inform us so we may consider whether we wish to pursue or withdraw this change. Hi I 11921 Rockville Pike, Suite 100, Rockville, MD 20852

  • 0 Phone: 301-984-4400, Fax: 301-984-7600 e&w 0 ALe OWNERS'GROUP Email: tsff@excelservices.com Owners Groupl \i v Administered by EXCEL Services Corporation

TSTF 05-08 May 31, 2005 Page 2 Should you have any questions, please do not hesitate to contact us.

Michael Crowthers (BWROG)

Brian Woods (WOG/CE) Paul Infang BWOG)

Enclosure cc: Thomas H. Boyce, Technical Specifications Section, NRC

WOG-177, Rev. 0 TSTF-485, Rev. 0 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Correct Example 1.4-1 NUREGs Affected: v 1430 Vi 1431 v' 1432 Se 1433 v 1434 Classification: 3) Editorial Change Recommended for CLIIP?: Yes Correction or Improvement: Correction NRC Fee Status: Exemption Requested Benefit: Increases Operator Understanding Industry

Contact:

Wes Sparkman, (205) 992-5061, wasparkmgsouthernco.com 1.0 Description Section 1.4, Frequency, Example 1.4-1, is revised to be consistent with the requirements of SR 3.0.4. SR 3.0.4 was revised by TSTF-359, Revision 9, and the current example is not consistent with the Technical Specification requirements.

2.0 Proposed Change The second paragraph of Example 1.4-1 is revised. The paragraph states:

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition. Failure to do so would result in a violation of SR 3.0.4.

It is being revised to state:

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable. The Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition or the LCO is considered not met (in accordance with SR 3.0.1) and LCO 3.0.4 becomes applicable.

3.0 Background

TSTF-359, Revision 9, "Increase Flexibility in MODE Restraints," revised LCO 3.0.4 and SR 3.0.4. The changes made in TSTF-359 to SR 3.0.4 have made certain statements in Example 1.4-1 incorrect.

31-May-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-177, Rev. 0 TSTF-485, Rev. 0 4.0 Technical Analysis Example 1.4-1 states that if the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the MODE or other specified condition. Failure to do so would result in a violation of SR 3.0.4.

SR 3.0.4 states that entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency. TSTF-359 modified SR 3.0.4 to state that when an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4. TSTF-359 modified LCO 3.0.4 to provide conditions under which it is acceptable to enter the Applicability of the LCO with the LCO not met. Therefore, it possible to enter the MODE or other specified condition in the Applicability of an LCO with a Surveillance not performed within the Frequency requirements of SR 3.0.2 and this does not result in a violation of SR 3.0.4.

The Example 1.4-1, second paragraph discussion is modified to parallel the discussion in the previous paragraph. The previous paragraph discusses Surveillances that exceed the interval without being performed while in the Applicability. The second paragraph is modified to make a similar statement regarding Surveillances that exceed the interval while not being in the Applicability.

The second sentence of the second paragraph is modified to reference the provisions of SR 3.0.3. This is necessary as TSTF-359 modified SR 3.0.4 to recognize that performance of a missed Surveillance may have been extended and prior to performance of the missed Surveillance, but within the time permitted under SR 3.0.3, a MODE change occurs.

The statement that failure to perform a Surveillance prior to entering the Applicability would constitute a violation of SR 3.0.4 is deleted and a statement is inserted to state the LCO would not be met and LCO 3.0.4 becomes applicable . This is consistent with the revised SR 3.0.4.

31-May-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-177, Rev. 0 TSTF-485, Rev. 0 5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

I . Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises Section 1.4, Frequency, Example 1.4-1, to be consistent with Surveillance Requirement (SR) 3.0.4 and Limiting Condition for Operation (LCO) 3.0.4. This change is considered administrative in that it modifies the example to demonstrate the proper application of SR 3.0.4 and LCO 3.0.4. The requirements of SR 3.0.4 and LCO 3.0.4 are clear and are clearly explained in the associated Bases. As a result, modifying the example will not result in a change in usage of the Technical Specifications (TS). The proposed change does not adversely affect accident initiators or precursors, the ability of structures, systems, and components (SSCs) to perform their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated.

Therefore, this change is considered administrative and will have no effect on the probability or consequences of any accident previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

No new or different accidents result from utilizing the proposed change. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the change does not impose any new or different requirements or eliminate any existing requirements. The change does not alter assumptions made in the safety analysis. The proposed change is consistent with the safety analysis assumptions and current plant operating practice.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change is administrative and will have no effect on the application of the Technical Specification requirements. Therefore, the margin of safety provided by the Technical Specification requirements is unchanged.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

31-May-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-177, Rev. 0 TSTF-485, Rev. 0 Based on the above, the TSTF concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of"no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria This change is adminstrative and will have no effect on any regulatory requirements or criteria.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

6.0 Environmental Consideration A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

7.0 References None.

Revision History OG Revision 0 Revision Status: Active Revision Proposed by: Braidwood Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 08-Dec-04 Owners Group Comments:

(No Comments)

Owners Group Resolution: Approved Date: 08-Dec-04 TSTF Review Information TSTF Received Date: 07-Feb-05 Date Distributed for Review: 07-Feb-05 31-May-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-177, Rev. 0 TSTF-485, Rev. 0 OG Revision 0 Revision Status: Active OG Review Completed: at BWOG v WOG v CEOG ] BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 17-May-05 NRC Review Information NRC Received Date: 31-May-05 Affected Technical Specifications 1.4 Frequency Change

Description:

Example 1.4-1 31-May-05 Traveler Rev. 3. Copyright (C) 2005, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-485, Rev. 0 Frequency 1.4 1.4 Frequency EXAMPLES (continued)

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the stated Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Example 1.4-3), then SR 3.0.3 becomes applicable.

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable. T-the Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition. Failure to de so aa ould result in violation of SR 3.0.1. or the LCO is considered not met (in accordance with SR 3,0,1) and LCO 3.0.4 becomes applicable.

1.4-3 Rev. 3.0, 03/31/04 STS BWOG STS 1 .4-3 Rev. 3.0, 03/31/04

TSTF-485, Rev. 0 Frequency 1.4 1.4 Frequency EXAMPLES (continued)

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the stated Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Example 1.4-3), then SR 3.0.3 becomes applicable.

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable. Tthe Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified bv SR 3.0.3, prior to entry into the MODE or other specified condition. Fail to do o urlt violation-of-SR--3-,.O4 or the LCO is considered not met (in accordance with SR 3.0.1) and LCO 3.0.4 becomes applicable.

WOG STS 1.4-3 Rev. 3.0, 03/31/04

TSTF-485, Rev. 0 Frequency 1.4 1.4 Frequency EXAMPLES (continued)

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the stated Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Example 1.4-3), then SR 3.0.3 becomes applicable.

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes aDDlicable. Tthe Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3. prior to entry into the MODE or other specified conditionFaketo deso -weuld-e#4P-a violation 3.104 of SR or the LCO is considered not met (in accordance with SR 3.0.1) and LCO 3.0.4 becomes applicable.

1.4-3 Rev. 3.0, 03/31/04 STS CEOG STS 1.4-3 Rev. 3.0, 03/31/04

TSTF-485, Rev. 0 Frequency 1.4 1.4 Frequency EXAMPLES (continued)

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable. Tthe Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition.alu-w-4--4e-s*-w-uld--resu4t-iR-a violation of SR 3,0A, or the LCO is considered not met (in accordance with SR 3.0.1) and LCO 3.0.4 becomes applicable.

EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after

> 25% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time reactor power is increased from a power level

< 25% RTP to 2 25% RTP, the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND").

This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2. "Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If reactor power decreases to

< 25% RTP, the measurement of both intervals stops. New intervals start upon reactor power reaching 25% RTP.

1.4-3 Rev. 3.0, 03/31/04 STS BWR/4 STS 1 .4-3 Rev. 3,0, 03/31/04

TSTF-485, Rev. 0 Frequency 1.4 1.4 Frequency EXAMPLES (continued)

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.0.4 becomes applicable. Tthe Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition.--eao-so-wo-4*4--r-esuft--i4-a ilatin of . or the LCO is considered not met (in accordance with SR 3.0.1) and LCO 3.0.4 becomes applicable.

EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after 2 25% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time reactor power is increased from a power level

< 25% RTP to 2 25% RTP, the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND").

This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2. "Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If reactor power decreases to

< 25% RTP, the measurement of both intervals stops. New intervals start upon reactor power reaching 25% RTP.

1.4-3 Rev. 3.0, 03/31/04 BWR/6 STS BWR/6 STS 1.4-3 Rev. 3.0, 03/31/04

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