TSTF-07-16, Comment (1) of Technical Specifications Task Force on Model Safety Evaluation & Model License Amendment Request on Technical Specification Improvement Re Relocation of Departure from Nucleate Boiling Parameters to the Core Operating Limit
| ML071030076 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 04/10/2007 |
| From: | Gambrell R, Joseph Messina, Millar D, Yates B BWR Owners Group, PWR Owners Group, Technical Specifications Task Force |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 72FR12223 00001, TSTF-07-16 | |
| Download: ML071030076 (3) | |
Text
TECHNICAL SPECIFICATIONS TASK FORCE A JOINVT 0 WN7ERS GR OUP A CTI VIT TSTF April 10, 2007 TSTF-07-16 9/6 -1P7 PROJ0753 Chief, Rulemaking, Directives, and Editing Branch Division of Administrative Services
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Office of Administration
ý71 Mail Stop: T-6 D59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Cm)
SUBJECT:
Technical Specification Task Force (TSTF) Response to the March 15, 2007to Federal Register Notice, "Notice of Opportunity To Comment on Model Safety Evaluation and Model License Amendment Request on Technical Specification Improvement Regarding Relocation of Departure From Nucleate Boiling Parameters to the Core Operating Limits Report for Combustion Engineering Pressurized Water Reactors Using the Consolidated Line Item Improvement Process" Enclosed for NRC consideration are comments prepared by the Technical Specification Task Force (TSTF) on the subject March 15, 2007 Federal Register Notice on TSTF-487, Revision 0, "Relocate DNB Parameters to the COLR."
Should you have any questions, please do not hesitate to contact us.
Bert Yates (POG/W) John Messina (BWROG)
Dana Millar (PWROG/CE) Re ?ne'Gambrell (PWROG/B&W)
Enclosure cc: Tim Kobetz, Technical Specifications Branch, NRC Ross Telson, Technical Specifications Branch, NRC eeý-7r-leT-ý) 5 :-ý ý9 bAW -e-0 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Email: tstf@excelservices.com Administered by EXCEL Services Corporation (e;
Technical Specification Task Force (TSTF) Response to the March 15, 2007 Federal Register Notice, "Notice of Opportunity To Comment on Model Safety Evaluation and Model License Amendment Request on Technical Specification Improvement Regarding Relocation of Departure From Nucleate Boiling Parameters to the Core Operating Limits Report for Combustion Engineering Pressurized Water Reactors Using the Consolidated Line Item Improvement Process"
- 1. Section 3.0, "Technical Evaluation," of the proposed Safety Evaluation, last paragraph, states, "For safety analyses of transients or accidents, various sections of Chapter 15 of the Standard Review Plan (Ref. 7.3) specify that the reactor is initially at the RTP plus uncertainty, and the RCS flow is at nominal design flow including the measurement uncertainty. If one or more DNB parameter limits change, and these changes do not support the RTP, a license amendment would be required to either reduce the RTP or limit the plant operation at a level below the RTP. 10 CFR 50 Appendix K requires that the loss of coolant accident analysis be performed at 102% of the RTP. Other plant-specific analyses can contain an initial condition to be performed at RTP. To insure a clear understanding of this requirement the following statement has been added to TS 5.6.3: 'The maximum thermal power from the COLR shall be equal to or greater than the RTP defined in TS 1.1.'"
The TSTF concurs with the description of the regulatory requirement. However, we do not agree that the proposed change to Technical Specification (TS) 5.6.3 is the suitable method to ensure a clear understanding of the requirement. Instead, we propose that a commitment be added to the model application contained in the Consolidated Line Item Improvement Program (CLIIP) Notice of Availability. The commitment would state, "[LICENSEE]
commits that the procedures for revising the Core Operating Limits Report (COLR) do not allow the cycle-specific limits in the COLR to be used to reduce the Rated Thermal Power level assumed in the safety analyses without prior NRC approval."
A survey of industry representatives determined that the proposed TS 5.6.3 wording was confusing and would likely lead to misinterpretation. Contrary to the proposed change, the maximum thermal power is not specified in the Core Operating Limits Report (COLR).
Also, the sentence appears to be addressing the maximum RTP value, not a reduced thermal power limit as discussed in the paragraph.
Restating the regulatory requirement in the Technical Specifications is inconsistent with the Improved Standard Technical Specifications (ISTS) content guidance provided by the NRC.
NRC guidance on the appropriate content of the Administrative Controls was provided in the October 25, 1993 letter from William T. Russell (NRC) to ISTS Lead Plant Group (now the Technical Specifications Task Force), titled, "Content of the Standard Technical Specifications, Section 5.0, Administrative Controls." It states, "In general, technical specifications should not duplicate other regulatory requirements." It provided the caveat that the Administrative Controls should contain "specific requirements that are broadly covered by regulations or other regulatory controls, for which details need to be specified in the technical specifications to ensure safe plant operation." As stated in the Request for Additional Information, 10 CFR 50, Appendix K is very specific regarding the power level at which loss of coolant accident safety analyses are to be performed. There is no need to clarify that regulatory requirement in the Technical Specifications.
The TSTF believes that a commitment is preferable to the proposed change to the Administrative Controls because the intent is clear, the information will be located in the
Technical Specification Task Force (TSTF) Response to the March 15, 2007 Federal Register Notice, "Notice of Opportunity To Comment on Model Safety Evaluation and Model License Amendment Request on Technical Specification Improvement Regarding Relocation of Departure From Nucleate Boiling Parameters to the Core Operating Limits Report for Combustion Engineering Pressurized Water Reactors Using the Consolidated Line Item Improvement Process" appropriate licensee procedures, and it does not repeat regulatory requirements unnecessarily in the Technical Specifications.
Incorporation of this comment will also necessitate other revisions to the Notice for Comment. Reference to TS 5.6.3 changes in TSTF-487 (i.e., the Notice Summary and Applicability) should be removed as TSTF-487 does not revise TS 5.6.3.
- 2. In the model application (the cover letter, list of enclosures, and Sections 1.0 and 2.0) remove references to the Bases. It is unnecessary for licensees to submit proposed Bases changes in their plant-specific amendment to adopt TSTF-487. The Bases changes are not material to the amendment and will be made by the licensee under the Technical Specification Bases Control Program. Furthermore, licensees are not required to submit final Bases changes to the NRC as the format and content of the Bases is under licensee control as described by the Technical Specification Bases Control Program.
- 3. The Model Application states, "I declare under penalty of perjury under the laws of the United States of America that I am authorized by [LICENSEE] to make this request and that the foregoing is true and correct." This statement is not consistent with the recommended statement given in RIS 2001-18, "Requirements for Oath or Affirmation." RIS 2001-18 recommends the statement, "I declare [or certify, verify, state] under penalty of perjury that the foregoing is true and correct." Note that RIS 2001-18 states that this statement must be used verbatim. We recommend that the Model Application be revised to be consistent with RIS 2001-18.
- 4. In the Notice under "Applicability," the last two sentences state, "Significant variations from the approach, or inclusion of additional changes to the license, will result in NRC staff rejection of the submittal. Instead, licensees desiring significant variations and/or additional changes should submit a LAR that does not claim to adopt TSTF-487." Should a licensee submit an application that requests adoption of TSTF-487 but includes significant variations or additional changes (for example, as part of a license amendment request to convert to the Standard Technical Specifications), it would facilitate the NRC's review for the licensee to acknowledge that the change is based on TSTF-487 so that the NRC may use the model Safety Evaluation to the extent possible. We recommend revising the sentence to state, "Instead, licensees desiring significant variations and/or additional changes should submit a LAR that does not request to adopt TSTF-487 under the Consolidated Line Item Improvement Process."