Response to NRC Request for Additional Information Regarding TSTF-431, Revision 1, Change in Technical Specifications End States (BAW-2441), Dated May 3, 2007ML071910061 |
Person / Time |
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Site: |
Technical Specifications Task Force |
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Issue date: |
07/09/2007 |
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From: |
Gambrell R, Joseph Messina, Millar D, Yates B Babcock & Wilcox, BWR Owners Group, Combustion Engineering, PWR Owners Group, Technical Specifications Task Force |
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To: |
Document Control Desk, Office of Nuclear Reactor Regulation |
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References |
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BAW-2441, TSTF-07-21 |
Download: ML071910061 (6) |
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Category:Letter type:TSTF
MONTHYEARTSTF-22-07, Transmittal of TSTF-592, Revision 0, Revise Automatic Depressurization System (ADS) Instrumentation Requirements2022-07-19019 July 2022 Transmittal of TSTF-592, Revision 0, Revise Automatic Depressurization System (ADS) Instrumentation Requirements TSTF-22-06, Technical Specifications Task Force - Request for a Workshop to Discuss the Interaction of Natural Phenomena Protection Design Features and Operability2022-07-0808 July 2022 Technical Specifications Task Force - Request for a Workshop to Discuss the Interaction of Natural Phenomena Protection Design Features and Operability TSTF-22-04, Technical Specifications Task Force - Transmittal of TSTF-591, Revision 0, Revise Risk Informed Completion Time (RICT) Program2022-03-22022 March 2022 Technical Specifications Task Force - Transmittal of TSTF-591, Revision 0, Revise Risk Informed Completion Time (RICT) Program TSTF-21-03, TSTF Response to NRC Questions on TSTF-576, Revision 0, Revise Safety/Relief Valve Requirements and Submittal of Revision 12021-06-23023 June 2021 TSTF Response to NRC Questions on TSTF-576, Revision 0, Revise Safety/Relief Valve Requirements and Submittal of Revision 1 TSTF-21-01, Transmittal of TSTF-580, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2021-01-26026 January 2021 Transmittal of TSTF-580, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling TSTF-20-04, Technical Specifications Task Force - Transmittal of TSTF-577, Revision 0, Revised Frequencies for Steam Generator Tube Inspections2020-06-0808 June 2020 Technical Specifications Task Force - Transmittal of TSTF-577, Revision 0, Revised Frequencies for Steam Generator Tube Inspections TSTF-20-01, Transmittal of TSTF-IG-20-02, Guidance on Evaluating One-Time Surveillance Frequency Changes Under the Surveillance Frequency Control Program (TSTF-425M SFCP)2020-04-0909 April 2020 Transmittal of TSTF-IG-20-02, Guidance on Evaluating One-Time Surveillance Frequency Changes Under the Surveillance Frequency Control Program (TSTF-425M SFCP) TSTF-19-14, Technical Specifications Task Force - TSTF Response to NRC Questions on TSTF-582, RPV WIC Enhancements2020-02-12012 February 2020 Technical Specifications Task Force - TSTF Response to NRC Questions on TSTF-582, RPV WIC Enhancements TSTF-19-11, TSTF Response to NRC Questions on TSTF-554, Revise Reactor Coolant Leakage Requirements2020-01-16016 January 2020 TSTF Response to NRC Questions on TSTF-554, Revise Reactor Coolant Leakage Requirements TSTF-19-09, Technical Specifications Task Force - Transmittal of TSTF-576, Revision 0, Revise Safety/Relief Valve Requirements2019-12-13013 December 2019 Technical Specifications Task Force - Transmittal of TSTF-576, Revision 0, Revise Safety/Relief Valve Requirements TSTF-19-13, Technical Specifications Task Force - Updated TSTF Membership and Distribution2019-12-0303 December 2019 Technical Specifications Task Force - Updated TSTF Membership and Distribution TSTF-19-12, TSTF Comments on Draft Safety Evaluations for Traveler TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position.2019-11-0505 November 2019 TSTF Comments on Draft Safety Evaluations for Traveler TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position. 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TSTF-18-06, TSTF Response to NRC Questions on TSTF-569, Revise Response Time Testing Definition2018-10-31031 October 2018 TSTF Response to NRC Questions on TSTF-569, Revise Response Time Testing Definition TSTF-18-12, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-564, Revision 1, Safety Limit MCPR2018-10-24024 October 2018 TSTF Comments on Draft Safety Evaluation for Traveler TSTF-564, Revision 1, Safety Limit MCPR TSTF-18-11, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-563, Revision 0, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program.2018-10-12012 October 2018 TSTF Comments on Draft Safety Evaluation for Traveler TSTF-563, Revision 0, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program. TSTF-18-08, Updated TSTF Membership and Distribution2018-07-17017 July 2018 Updated TSTF Membership and Distribution TSTF-18-07, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-505, Provide Risk-Informed Extended Completion Times and Submittal of TSTF-505, Revision 22018-07-0202 July 2018 TSTF Comments on Draft Safety Evaluation for Traveler TSTF-505, Provide Risk-Informed Extended Completion Times and Submittal of TSTF-505, Revision 2 TSTF-18-05, TSTF Response to NRC Questions on TSTF-564, Safety Limit (Minimum Critical Power Ratio) MCPR2018-05-29029 May 2018 TSTF Response to NRC Questions on TSTF-564, Safety Limit (Minimum Critical Power Ratio) MCPR TSTF-17-19, TSTF Response to NRC Questions on TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program2018-04-27027 April 2018 TSTF Response to NRC Questions on TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program TSTF-18-04, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-567, Revision 1, Add Containment Sump TS to Address GSI-191 Issues.2018-04-16016 April 2018 TSTF Comments on Draft Safety Evaluation for Traveler TSTF-567, Revision 1, Add Containment Sump TS to Address GSI-191 Issues. TSTF-18-03, Transmittal of TSTF-565, Revision 1, Revise the LCO 3.0.2 and LCO 3.0.3 Bases2018-03-30030 March 2018 Transmittal of TSTF-565, Revision 1, Revise the LCO 3.0.2 and LCO 3.0.3 Bases TSTF-18-02, Technical Specifications Task Force - Transmittal of TSTF-569, Revision 0, Revise Response Time Testing Definition.2018-02-0808 February 2018 Technical Specifications Task Force - Transmittal of TSTF-569, Revision 0, Revise Response Time Testing Definition. TSTF-17-18, Transmittal of TSTF-566, Revision 0, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems.2018-01-19019 January 2018 Transmittal of TSTF-566, Revision 0, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems. 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TSTF-17-08, Change in TSTF Traveler Invoicing2017-07-0505 July 2017 Change in TSTF Traveler Invoicing TSTF-17-07, Transmittal of TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program2017-05-10010 May 2017 Transmittal of TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program TSTF-17-06, Request to Incorporate TSTF-565, Clarify the Term Operational Convenience in the LCO 3.0.2 Bases, Into the Standard Technical Specifications2017-05-0909 May 2017 Request to Incorporate TSTF-565, Clarify the Term Operational Convenience in the LCO 3.0.2 Bases, Into the Standard Technical Specifications TSTF-17-03, Technical Specifications Task Force - Request for Fee Exemption for TSTF-567, Add Containment Sump TS to Address GSI-191 Issues.2017-03-30030 March 2017 Technical Specifications Task Force - Request for Fee Exemption for TSTF-567, Add Containment Sump TS to Address GSI-191 Issues. 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TSTF-17-02, Technical Specifications Task Force - Request for NRC to Withdraw November 7, 2013 Letter to TSTF Concerning TSTF-51, TSTF-286, and TSTF-4712017-02-0202 February 2017 Technical Specifications Task Force - Request for NRC to Withdraw November 7, 2013 Letter to TSTF Concerning TSTF-51, TSTF-286, and TSTF-471 TSTF-17-01, TSTF Draft Response to NRC Questions on TSTF-505, Provide Risk-Informed Extended Completion Times for 02/16/2017 Public Meeting2017-01-31031 January 2017 TSTF Draft Response to NRC Questions on TSTF-505, Provide Risk-Informed Extended Completion Times for 02/16/2017 Public Meeting TSTF-16-12, Technical Specifications Task Force - Updated TSTF Membership and Distribution2016-11-18018 November 2016 Technical Specifications Task Force - Updated TSTF Membership and Distribution TSTF-16-10, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control, and Transmittal of Editorial Corrections to TSTF-542, Revision 22016-11-0202 November 2016 TSTF Comments on Draft Safety Evaluation for Traveler TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control, and Transmittal of Editorial Corrections to TSTF-542, Revision 2 TSTF-16-08, Withdrawal of TSTF-553, Revision 0, Add Action for Two Inoperable Creatcs Trains.2016-10-13013 October 2016 Withdrawal of TSTF-553, Revision 0, Add Action for Two Inoperable Creatcs Trains. 2022-07-08
[Table view] Category:Technical Specifications
MONTHYEARML24016A2702023-12-12012 December 2023 TSTF-585, Draft Revision 3, Revise LCO 3.0.3 to Require Managing Risk ML22320A5942022-10-24024 October 2022 Draft TSTF-596, Rev. 0, Expand the Applicability of the Surveillance Frequency Frequency Control Panel (Sfcp), Improved Standard Technical Specifications Change Traveler ML22244A2192022-07-0707 July 2022 Revised Draft TSTF-588, Revise List of COLR Methods (July 2022) ML21316A2362021-10-26026 October 2021 Draft TSTF-589,Eliminate Automatic Diesel Generator Start During Shutdown ML21316A2352021-09-24024 September 2021 Draft TSTF-584, Eliminate Automatic RWCU System Isolation on SLC Initiation ML21109A2952021-04-22022 April 2021 Draft Traveler TSTF-585, Revise LCO 3.0.3 ML21117A3522021-02-0101 February 2021 TSTF-576, Rev 1, Revise Safety/Relief Valve Requirements Draft ML20181A2212020-06-29029 June 2020 Draft TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling ML19323C9002019-11-19019 November 2019 Comparison of the Original Draft Justification and the Revised Draft Justification of TSTF-576, Revise Safety/Relief Valve Requirements TSTF-17-16, Technical Specifications Task Force - Transmittal of TSTF-568, Clarify Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.22017-12-19019 December 2017 Technical Specifications Task Force - Transmittal of TSTF-568, Clarify Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2 TSTF-17-17, Transmittal of TSTF-557, Revision 1, Spent Fuel Storage Rack Neutron Absorber Monitoring Program2017-12-19019 December 2017 Transmittal of TSTF-557, Revision 1, Spent Fuel Storage Rack Neutron Absorber Monitoring Program ML17023A0082017-01-23023 January 2017 Draft of TSTF-567, Add Containment Sump TS to Address GSI-191 Issues. TSTF-16-09, Technical Specifications Task Force - Revision 3 of TSTF-551, Revise Secondary Containment Surveillance Requirements.2016-10-0303 October 2016 Technical Specifications Task Force - Revision 3 of TSTF-551, Revise Secondary Containment Surveillance Requirements. TSTF-15-08, Technical Specifications Task Force - Transmittal of TSTF-529, Revision 3, Clarify Use and Application Rules.2015-09-14014 September 2015 Technical Specifications Task Force - Transmittal of TSTF-529, Revision 3, Clarify Use and Application Rules. TSTF-15-05, Withdrawal of TSTF-531, Revision 1, Revision of Specification 3.8.1, Required Actions B.3.1 and B.3.2.2015-04-15015 April 2015 Withdrawal of TSTF-531, Revision 1, Revision of Specification 3.8.1, Required Actions B.3.1 and B.3.2. ML15028A1282015-01-28028 January 2015 TSTF-14-13 TSTF Concerns with Proposed RIS on Pressure Boundary Leakage TSTF-13-09, Transmittal of TSTF-545, Revision 0, TS Inservice Testing (IST) Program Removal.2013-11-0404 November 2013 Transmittal of TSTF-545, Revision 0, TS Inservice Testing (IST) Program Removal. TSTF-13-12, Transmittal of TSTF-541, Revision 0, Add Exceptions to Surveillance Requirements When the Safety Function Is Being Performed2013-09-10010 September 2013 Transmittal of TSTF-541, Revision 0, Add Exceptions to Surveillance Requirements When the Safety Function Is Being Performed TSTF-12-04, Transmittal of TSTF-537, Revision 0, Increase CIV Completion Time; Update of TSTF-3732012-03-27027 March 2012 Transmittal of TSTF-537, Revision 0, Increase CIV Completion Time; Update of TSTF-373 TSTF-12-01, Transmittal of TSTF-454, Revision 2, Extend PCIV Completion Times (NEDC-33046).2012-02-22022 February 2012 Transmittal of TSTF-454, Revision 2, Extend PCIV Completion Times (NEDC-33046). TSTF-11-17, Proposed Revision to the Model Application for TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b.2011-10-12012 October 2011 Proposed Revision to the Model Application for TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b. ML17339A1682011-06-14014 June 2011 Draft Table 2 of TSTF-505, Revision 2, Conditions Requiring Plant-Specific Technical Justification ML17290A0822011-06-14014 June 2011 Draft Traveler TSTF 505, Revision 2, Provide Risk Informed Extended Completion Times - RITSTF Initiative 4B. ML17290A0972011-06-14014 June 2011 Draft Table 1 of TSTF-505, Revision 2, Affected Technical Specifications ML18115A4822011-06-14014 June 2011 NRC Revised TSTF-505, Revision 2, Draft Model Application TSTF-11-02, Correction to TSTF-510, Revision 2, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection2011-03-0101 March 2011 Correction to TSTF-510, Revision 2, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection ML1104205302011-02-0909 February 2011 ITSB Resolution of Excel Services Corporation Proposed TSTF-426 Wording ML1027306882011-02-0202 February 2011 Model Application and Model SE of TSTF-423, Revision 1, Technical Specification End States, NEDC-32988-A ML1027804862010-09-28028 September 2010 Response to Nrc'S Request for Additional Information Regarding TSTF-432, Revision 0, Change in Technical Specifications End States, (WCAP-16294) TSTF-09-24, Technical Specification Task Force Recommended Changes to Be Incorporated in Revision 4 of the Standard Technical Specifications, NUREG-1430 Through 14342009-11-30030 November 2009 Technical Specification Task Force Recommended Changes to Be Incorporated in Revision 4 of the Standard Technical Specifications, NUREG-1430 Through 1434 TSTF-09-15, Transmittal of TSTF-517, Revision 0, Allowance for Non-TS Cooling / Ventilation Systems Degradation on Support System Operability and Associated Implementation Guidance2009-10-28028 October 2009 Transmittal of TSTF-517, Revision 0, Allowance for Non-TS Cooling / Ventilation Systems Degradation on Support System Operability and Associated Implementation Guidance TSTF-09-10, Transmittal of TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b, Sections 3.1.1 - 3.7.52009-03-18018 March 2009 Transmittal of TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b, Sections 3.1.1 - 3.7.5 TSTF-08-21, Transmittal of TSTF-513, Revision 0, Revise Operability Requirements and Actions for RCS Leakage Instrumentation.2008-11-14014 November 2008 Transmittal of TSTF-513, Revision 0, Revise Operability Requirements and Actions for RCS Leakage Instrumentation. 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TSTF-08-13, TSTF-426, Revision 1, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiatives 6b & 6c2008-08-0505 August 2008 TSTF-426, Revision 1, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiatives 6b & 6c TSTF-08-08, TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation.2008-07-0303 July 2008 TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation. TSTF-08-07, Proposed Model Application for TSTF-500, Revision 0, DC Electrical Rewrite - Update to TSTF-360.2008-03-11011 March 2008 Proposed Model Application for TSTF-500, Revision 0, DC Electrical Rewrite - Update to TSTF-360. TSTF-08-04, TSTF-446, Revision 3, Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP-15791).2008-02-19019 February 2008 TSTF-446, Revision 3, Risk Informed Evaluation of Extensions to Containment Isolation Valve Completion Times (WCAP-15791). TSTF-08-01, Response to NRC June 25, 2007 Request for Additional Information Regarding TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions.2008-01-18018 January 2008 Response to NRC June 25, 2007 Request for Additional Information Regarding TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions. ML0721201452007-07-25025 July 2007 NRC Response to 4/16/2007 Submittal of TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions, Enclosure 5a - CEOG_3.3.01a_B for TSTF-493R2eITSB ML0720702512007-07-25025 July 2007 NRC Response to 4/16/2007 Submittal of TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions, Enclosure 2 - 493 R2 pp-1_12 Markup Rev. B ML0720702602007-07-25025 July 2007 NRC Response to 4/16/2007 Submittal of TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions, Enclosure 3a - Bwog - 3.3.01_ B for TSTF -493R23e ITSB ML0720702692007-07-25025 July 2007 NRC Response to 4/16/2007 Submittal of TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions, Enclosure 3b-BWOG - 3.3.05_B for TSTF-493R23e ITSB ML0720703552007-07-25025 July 2007 NRC Response to 4/16/2007 Submittal of TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions, Enclosure 4a - BWR4_3.03.1.01_B for TSTF-493R2eITSB ML0720703582007-07-25025 July 2007 NRC Response to 4/16/2007 Submittal of TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions, Enclosure 4b - BWR4_3.03.2.01_B for TSTF 493 R2eITSB ML0721200762007-07-25025 July 2007 NRC Response to 4/16/2007 Submittal of TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions, Enclosure 4d - BWR4_3.03.5.01_B for TSTF-493R2eITSB ML0721201192007-07-25025 July 2007 NRC Response to 4/16/2007 Submittal of TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions, Enclosure 4k - BWR6_3.03.6.05_B for TSTF-493R2eITSB ML0721201112007-07-25025 July 2007 NRC Response to 4/16/2007 Submittal of TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions, Enclosure 4j -BWR6_3.03.5.02_B for TSTF-493R2eITSB 2023-12-12
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TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY July 9, 2007 TSTF-07-21 PROJ0753 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Response to NRC Request for Additional Information Regarding TSTF-431, Revision 1, "Change in Technical Specifications End States (BAW-2441)," dated May 3, 2007.
REFERENCE:
Letter from Timothy Kobetz (NRC) to the Technical Specifications Task Force, "Request for Additional Information Regarding TSTF-431, Revision 1,
'Change in Technical Specifications End States (BAW-2441)'," dated May 3, 2007.
Dear Sir or Madam:
In the referenced letter, the NRC provided a Request for Additional Information (RAI) regarding TSTF-431, Revision 1, "Change in Technical Specifications End States (BAW-2441)." This letter responds to the NRC's referenced request.
The NRC granted a fee exemption for the review of TSTF-431 as documented in the letter from Timothy Kobetz (NRC) to the TSTF dated December 5, 2006.
The TSTF requests that the Traveler be made available under the Consolidated Line Item Improvement Process.
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
TSTF 07-21 July 9, 2007 Page 2 Should you have any questions, please do not hesitate to contact us.
Bert Yates (PWROG/W) John Messina (BWROG)
Dana Millar (PWROG/CE) Reene' Gambrell (PWROG/B&W)
Enclosure cc: Tim Kobetz, Technical Specifications Branch, NRC Ross Telson, Technical Specifications Branch, NRC Matthew Hamm, Technical Specifications Branch, NRC
Technical Specification Task Force (TSTF) Response to NRC Request for Additional Information Regarding TSTF-431, Revision 1, "Change in Technical Specifications End States (BAW-2441)," dated May 3, 2007 The following is the Technical Specification Task Force (TSTF) response to NRCs May 3, 2007, letter requesting the following information to complete the review of TSTF-431.
- 1. Question:
Discuss how TSTF-431 implements the condition of approved topical report for LCO 3.4.15 regarding the availability and use of alternative RCS leakage detection capabilities.
Background:
In Section 4.4.4 of the approved topical report BAW-2441-A Rev. 2, the basis for the proposed change affecting Technical Specification (TS) Limiting Condition of Operation (LCO) 3.4.15 Reactor Coolant System (RCS) Leakage Detection, identifies the availability of additional instruments to provide secondary indication of a loss of coolant accident. TSTF-431, Rev. 1 does not address this requirement. LCO 3.4.15 currently includes action requirements (A.1, B.1.1, and B.1.2) to use alternative leakage detection instrumentation and containment sampling until the LCO action is exited, either by restoration of the inoperable leakage detection instruments or by exiting the mode of applicability of the LCO. The proposed change in BAW-2441-A Rev. 2 to establish a Mode 4 endstate identified the availability of the alternative instrumentation as a basis for acceptability. This requirement of the topical report should be implemented in TSTF-431 by revising the TS actions to include a requirement to continue implementing alternative RCS leakage detection actions while the plant remains in Mode 4.
Response
TSTF-431, Rev. 1, modifies Condition C, which states "Required Action and associated Completion Time not met," to require the plant to be in Mode 4 instead of Mode 5. Condition C is only entered when the Required Actions and associated Completion Times of Conditions A or B are not met. As discussed in the "Background" section of the RAI, Required Actions A.1, B.1.1, and B.1.2 require the use of alternate leakage detection instrumentation and containment sampling as discussed in the Topical Report.
When Condition C is entered, the Required Actions of Condition A or B continue to be applicable and must be followed. As a result, the alternate leakage detection instrumentation and containment sampling required by Required Actions A.1, B.1.1, or B.1.2 must be continued while remaining in Mode 4 under the revised Required Action C.2. Therefore, the assumption in the Topical Report is implemented in TSTF-431, Rev. 1.
The Improved Standard Technical Specifications require multiple condition entry which means that all Conditions that apply are entered simultaneously. LCO 3.0.2 states, "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated." Note that the word "Conditions" is plural. All applicable Conditions are entered and may not be exited unless the LCO is met or is no longer applicable. As long as the plant is within the Applicability of the LCO (i.e., Modes 1 - 4), the Required Actions of all the applicable Conditions must be followed.
Technical Specification Task Force (TSTF) Response to NRC Request for Additional Information Regarding TSTF-431, Revision 1, "Change in Technical Specifications End States (BAW-2441)," dated May 3, 2007
- 2. Question:
Discuss how TSTF-431 implements the conditions of approved topical report for LCO 3.6.1 regarding the availability of the equipment hatch, air locks, and isolation capability.
Background:
In Section 4.4.6 of BAW-2441-A Rev. 2, for TS LCO 3.6.1 Containment, an "assumed limitation" is identified, which requires that the containment equipment hatch remains closed while remaining in Mode 4. TSTF-431 Rev. 1, does not include this restriction.
Further, in Section 4.4.6 of the topical report, part of the basis for the proposed change is the availability of isolation capability for each containment process line, including the containment air locks. The staff review of the LCO requirements for these components determined that the proposed changes of TSTF-431 do not assure availability of isolation capability for all process lines and the airlocks, while LCO 3.6.1 Action B.2 is in effect in Mode 4, which is inconsistent with the stated basis for the proposed change.
The staff notes that similar changes were proposed and approved in CE-NPSD-1186-A Rev. 0, applicable to Combustion Engineering designed nuclear steam supply systems. The implementation of these changes were per approved TSTF-422-A Rev. 1, which did not apply a Mode 4 end state to LCO 3.6.1. This implementation conservatively assured that the topical report assumptions regarding the equipment hatch, air locks, and isolation capability were met while operating in Mode 4. As noted in the TSTF, this implementation approach "retains the topical and safety evaluation restrictions on large leakage while providing the approved flexibility for smaller containment leaks." It is unclear to the staff why the same approach should not apply to TSTF-431.
Response
This RAI addresses three issues:
- Implementation of the assumed limitation on the containment equipment hatch,
- Availability of isolation for all process lines and airlocks, and
Implementation of the assumed limitation on containment equipment hatch BAW-2441, Section 4.4.6, the section entitled, "Current and Proposed End State," "Assumed Limitation," states that the proposed end state assumes the equipment hatch will remain closed while in Mode 4. This is a reasonable assumption because licensees would not remove the containment equipment hatch in Mode 4 while relying on the proposed action.
As stated in BAW-2441 and the NRC's Safety Evaluation for BAW-2441, "The primary purpose of entering the end state is to correct the initiating condition and return to power as soon as is practical," and "These assumptions are consistent with typical entries into Mode 4 for short duration repairs, which is the intended use of the TS end state changes." Removal of the Reactor Building equipment hatch is a convoluted, time-consuming process that would not be part of any anticipated short duration repairs necessary to repair the containment and return to power as soon as possible.
Technical Specification Task Force (TSTF) Response to NRC Request for Additional Information Regarding TSTF-431, Revision 1, "Change in Technical Specifications End States (BAW-2441)," dated May 3, 2007 The TSTF-431 Bases of Required Actions B.1 and B.2 state, "The release of stored energy to the Reactor Building in the event of an accident in MODE 4 is substantially less than the energy release assumed due to an accident at power. Therefore, the challenge to containment systems is substantially reduced. The analysis in Reference 4 assumed that the equipment hatch remains closed in MODE 4. Because of the reduction in RCS pressure and temperature in MODE 4, the likelihood of an event is also reduced." The inclusion of this information in the Bases will alert the operator to this assumption in the analysis. Note that these types of assumptions were included in the Bases in TSTF-422-A (See the TSTF-422-A Bases for Specifications 3.5.4 and 3.7.7).
Furthermore, all licensees are committed to implementing actions to reduce shutdown risk consistent with NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," which endorses the guidance of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Section 11, as revised in February 2000, as an acceptable approach to meet 10 CFR 50.65(a)(4). Section 11 of NUMARC 93-01 addresses assessing and managing risk in both the operating Modes and during shutdown conditions. The risk assessments described by NUMARC 93-01 for shutdown conditions reference the guidance in NUMARC 91-06, "Guidelines for Industry Actions to Assess Shutdown Management." Section 4.1.1 of NUMARC 91-06, item 3, states, " Containment hatches (equipment and personnel) and other penetrations that communicate with the containment atmosphere (primary or secondary, as appropriate) should either be closed or capable of being closed prior to core boiling following a loss of DHR and should be addressed in procedures." The time to boil in the subject condition (i.e., Mode 4 for short duration repairs) following a loss of DHR is too short to allow reinstallation of the equipment hatch. Therefore, the equipment hatch could not be removed in Mode 4.
Based on these considerations and the inclusion of the Topical Report assumption in the Bases, no changes to TSTF-431 are required.
Availability of isolation for all process lines and airlocks BAW-2441, Section 4.4.6, the section entitled "Basis for Proposed End State," states, "Relative to containment isolation, each process line has redundant isolation that can be implemented manually from the MCR." This assumption will be valid while in the proposed Mode 4 end state with no change to the existing Technical Specifications or to the changes proposed in TSTF-431.
Requirements on the containment penetrations (process lines) and the containment airlock are in Specification 3.6.3, "Containment Isolation Valves, " and Specification 3.6.2, "Containment Air Locks," respectively. If the containment is inoperable for reasons not associated with containment penetrations or the containment airlock, those systems will be Operable and capable of performing their containment isolation function as assumed in the Topical Report.
Technical Specification Task Force (TSTF) Response to NRC Request for Additional Information Regarding TSTF-431, Revision 1, "Change in Technical Specifications End States (BAW-2441)," dated May 3, 2007 If the containment is inoperable due to leakage through a containment airlock greater than La, Specification 3.6.2, Required Action C.2, requires a door to be closed in the affected airlock.
This provides the maximum available isolation capable with the degraded airlock as assumed in the Topical Report.
If the containment is inoperable due to leakage through a containment penetration greater than La, Specification 3.6.3, Required Actions B.1, C.1, and D.1, require the affected penetration flow path to be isolated by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange. This is consistent with the assumption in the Topical Report.
Therefore, the existing and proposed Technical Specifications will assure availability of isolation capability for all process lines and the airlocks, while LCO 3.6.1 Action B.2 is in effect in Mode 4.
Differences between TSTF-431 and TSTF-422-A BAW-2441, Section 4.4.6, the section entitled "Basis for Proposed End State," states, "Because the energy that can be released to the RB [Reactor Building] when operating in Mode 4 is only a fraction of that associated with a DBA, RB pressure will be only slightly higher should a LOCA occur when operating in Mode 4 as compared to when operating in Mode 5. Also, assuming a RB breach that would cause La at DBA conditions exists (triggering plant shutdown in accordance with this LCO), it would produce RB leakage flow rates considerably less than La when operating in Mode 4 with occurrence of a LOCA" (emphasis added). Note that the BAW-2441 justification explicitly assumes that the containment leakage was greater than La.
The Topical Report for Combustion Engineering plants, CE-NPSD-1186, utilized a different assumption. CE-NPSD-1186, in Sections 5.5.11 (Containment Air Locks) and 5.5.12 (Containment Isolation Valves), assumed that containment leakage was less than La. The NRC's Safety Evaluation for CE-NPSD-1186 stated "only small changes in containment integrity are considered." TSTF-422-A, Attachment 1, "Comparison of CEOG-152, CE-NSPD-1186, and the NRC's July 17, 2001 Safety Evaluation," stated, "These restrictions are inconsistent with LCO 3.6.1, which requires that leakage be less than 1.0 La. Therefore, if the ACTIONS of LCO 3.6.1 are entered, containment leakage must be large (e.g., > 1.0 La). In order to remain consistent with the current application of the specifications, the changes to LCO 3.6.1 are not adopted. If leakage is "large," MODE 5 must be entered in accordance with LCO 3.6.1." Therefore, CE-NPSD-1186 did not assume that containment leakage was greater than La.
Because of this difference in assumptions, it is consistent with the NRC's approval of BAW-2441 to implement the Mode 4 end state for Specification 3.6.1.