TSTF-08-10, Transmittal of TSTF-507, Revision 0, CLIIP Traveler to Increase Standardization
| ML081900429 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 07/03/2008 |
| From: | David Bice, Gambrell R, Joseph Messina, Yates B Technical Specifications Task Force |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML081900424 | List: |
| References | |
| TSTF-08-10, TSTF-507, Rev 0 | |
| Download: ML081900429 (62) | |
Text
TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY July 3, 2008 TSTF-08-10 PROJ0753 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
TSTF-507, Revision 0, "CLIIP Traveler to Increase Standardization"
Dear Sir or Madam:
Enclosed for NRC review is Revision 0 of TSTF-507, "CLIIP Traveler to Increase Standardization." The purpose of TSTF-507 is to provide an efficient means for plants to adopt previously NRC-approved Travelers that primarily affect the Improved Technical Specifications use and application; thus increasing standardization across the industry.
Any NRC review fees associated with the review of TSTF-507 should be billed to the Pressurized Water Reactors Owners Group.
The TSTF requests that the Traveler be made available under the Consolidated Line Item Improvement Process.
Should you have any questions, please do not hesitate to contact us.
Bert Yates (PWROG/W) John Messina (BWROG)
David Bice (PWROG/CE) Reene' Gambrell (PWROG/B&W)
Enclosure cc: Robert Elliott, Technical Specifications Branch, NRC Matthew Hamm, Technical Specifications Branch, NRC 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
WOG-190, Rev. 0 TSTF-507, Rev. 0 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler CLIIP Traveler to Increase Standardization NUREGs Affected: 1430 1431 1432 1433 1434 Classification 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement: Improvement NRC Fee Status: Not Exempt Benefit: Increase Consistency with Standard or Writer's Industry
Contact:
Bert Yates, (314) 554-3573, gyates@ameren.com See attached justification.
Revision History OG Revision 0 Revision Status: Active Revision Proposed by:
Revision
Description:
Original Issue Owners Group Review Information Date Originated by OG: 14-Apr-08 Owners Group Comments (No Comments)
Owners Group Resolution: Approved Date: 05-Jun-08 TSTF Review Information TSTF Received Date: 05-Jun-08 Date Distributed for Review 05-Jun-08 OG Review Completed: BWOG WOG CEOG BWROG TSTF Comments:
(No Comments)
TSTF Resolution: Approved Date: 19-Jun-08 NRC Review Information NRC Received Date: 03-Jul-08 Affected Technical Specifications 1.1 Definitions 03-Jul-08 Traveler Rev. 3. Copyright (C) 2006, 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-190, Rev. 0 TSTF-507, Rev. 0 Change
Description:
The individual changes for this Traveler are not entered as they are already recorded in the previously approved Travelers.
03-Jul-08 Traveler Rev. 3. Copyright (C) 2006, 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-507, Rev. 0 1.0 Description During the development of the Improved Standard Technical Specifications (ISTS), the NRC has approved and incorporated into the next revision of the ISTS a number of Travelers that affect the format and usage rules and the administrative controls. These Travelers improve consistency within the ISTS and with other regulatory requirements, clarify requirements, and in general advance the NRC and industry goal of standardization in Technical Specifications.
These Travelers are approved by the NRC and incorporated into the next revision of the ISTS. They are adopted by plants converting to the ISTS. However, it is frequently not cost-beneficial for a licensee to adopt an individual Traveler via license amendment request when the only benefit is standardization or clarification of requirements unless it is adopted during an ISTS conversion or requested as part of a larger amendment.
Therefore, many plant's Technical Specifications do not include these improvements.
It is to the advantage of the NRC and the nuclear industry for plant-specific Technical Specifications to follow the ISTS and use consistent terminology, definitions, format and usage rules, and administrative programs. Therefore, the TSTF proposes this Traveler for the purpose of encouraging standardization with the ISTS by combining Travelers that have been previously approved by the NRC into a single Traveler that can be offered for adoption using the Consolidated Line Item Improvement Process (CLIIP). By combining these changes and offering them via the efficient CLIIP process, the TSTF hopes to encourage licensees to adopt these consistency and standardization Travelers.
2.0 Proposed Change The TSTF proposes to included the following NRC-approved Travelers as a single item for adoption under CLIIP. The TSTF recommends that the model Safety Evaluation and model Application for this change be written to allow licensees to include those Travelers that are applicable to their plant and that have not been adopted. This approach will maximize the benefit of this change.
This Traveler includes Travelers that meet the following criteria:
- The Traveler was previously approved by the NRC as indicated by a letter or incorporation into the next version of the ISTS NUREGs. In one case (TSTF-475-A), NRC approval was by incorporation into a larger change that was approved under the CLIIP. In the majority of cases, the NRC has also approved the change on a plant-specific basis.
- The change principally affects Chapter 1, Section 3.0, or Chapter 5 of the ISTS.
In some cases, there are related changes to other Specifications. Some Travelers also affect the Technical Specification Bases.
TSTF-507, Rev. 0
- The change is not technical. In other words, there is no need to review or adopt a topical report or other engineering justification or make changes to the Technical Specifications that could affect the protection of the accident analysis assumptions.
Each NRC approved Traveler is summarized below. The approved Traveler is included as an attachment to this Traveler. The following information is provided in the summary for each Traveler:
Affected ISTS NUREGs - This topic lists the plant types (by corresponding ISTS NUREG) affected by this change.
ISTS Version Revised by the Traveler - This topic lists the version of the ISTS that was used when creating mark-ups for the Traveler.
ISTS Version in Which the Traveler is Incorporated - This topic lists the version of the ISTS in which the approved Traveler was incorporated.
Description of the Traveler - This topic describes the effect of adopting the subject Traveler on the plant's Technical Specifications.
Summary of the Approved Traveler Justification - This topic summarizes the justification utilized by the NRC when approving the Traveler.
NRC Approval - This topic references the NRC letter, if any, approving the Traveler. For early Travelers, the NRC sometimes verbally stated the Traveler was approved in a meeting with the TSTF and then demonstrated its approval by incorporating it into the next revision of the ISTS NUREGs. This section also provides example NRC approvals of plant-specific requests to adopt the Traveler. The NRC ADAMS system accession number (ACN) is given.
List of Affected Specifications - This topic lists the specifications affected by the adoption of this Traveler. It also lists the Bases affected by Traveler.
Because the Travelers were marked on various versions of the ISTS, the approved Travelers, including the ISTS markups, are attached.
The incorporated Travelers are:
- 2. TSTF-19-A, Revision 1, "Relocate the details of RTD and thermocouple calibration from the Channel Calibration definition"
- 3. TSTF-40-A, Revision 0, " Exempt RCP seal water injection or leakoff from the definition of Unidentified Leakage"
TSTF-507, Rev. 0
- 5. TSTF-47-A, Revision 0, "Eliminate 'manipulation' from the definition of Core Alteration"
- 6. TSTF-65-A, Revision 1, "Use of Generic Titles for Utility Positions"
- 7. TSTF-104-A, Revision 0, "Relocates discussion of exceptions from LCO 3.0.4 to the Bases"
- 8. TSTF-106-A, Revision 1, "Change to Diesel Fuel Oil Testing Program"
- 9. TSTF-118-A, Revision 0, "Administrative Controls Program Exceptions"
- 10. TSTF-124-A, Revision 0, "Delete Specific Reference to Bypasses in CFT and Calibration Definitions"
- 11. TSTF-125-A, Revision 1, "Delete EFPD Definition"
- 12. TSTF-152-A, Revision 0, "Revise Reporting Requirements to be Consistent with 10 CFR 20"
- 13. TSTF-166-A, Revision 0, "Correct Inconsistency Between LCO 3.0.6 and the SFDP Regarding Performance of an Evaluation"
- 14. TSTF-205-A, Revision 3, "Revision of Channel Calibration, Channel Functional Test, and Related Definitions"
- 15. TSTF-248-A, Revision 0, "Revise Shutdown Margin Definition for Stuck Rod Exception"
- 16. TSTF-258-A, Revision 4, "Changes to Section 5.0, Administrative Controls"
- 17. TSTF-273-A, Revision 2, "SFDP Clarifications"
- 18. TSTF-279-A, Revision 0, "Remove 'applicable supports' from Inservice Testing Program"
- 19. TSTF-284-A, Revision 3, "Add 'Met vs. Perform' to Specification 1.4, Frequency"
- 20. TSTF-299-A, Revision 3, "Administrative Controls Program 5.5.2.b Test Interval and Exception"
- 21. TSTF-308-A, Revision 1, "Determination of Cumulative and Projected Dose Contributions in RECP"
- 22. TSTF-343-A, Revision 1, "Containment Structural Integrity"
- 23. TSTF-348-A, Revision 1, "Cancellation of NRC Environmental Monitoring Program with States"
TSTF-507, Rev. 0
- 24. TSTF-362-A, Revision 0, " Change to the VFTP in ITS Section 5.0 in accordance with GL 99-02"
- 25. TSTF-363-A, Revision 0, "Revise Topical Report references in ITS 5.6.5, COLR"
- 26. TSTF-364-A, Revision 0, "Revision to TS Bases Control Program to Incorporate Changes to 10 CFR 50.59"
- 27. TSTF-419-A, Revision 0, "Revise PTLR Definition and References in ISTS 5.6.6, RCS PTLR"
- 28. TSTF-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO"
- 29. TSTF-471-A, Revision 1, "Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes"
- 30. TSTF-475-A, Revision 1, "Control Rod Notch Testing Frequency and SRM Insert Control Rod Action"
- 31. TSTF-479-A, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a"
- 32. TSTF-497-A, Revision 0, " Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less"
- 33. TSTF-485-A, Revision 0, "Correct Example 1.4-1"
3.0 Background
Most of the listed Travelers were developed and approved by the NRC before the CLIIP process was established. NRC approval for those Travelers was documented by letters to the TSTF or statements in meetings, followed by incorporation of the Travelers in the next revision of the ISTS. The level of detail in the justification and NRC approval has increased over time, with the early Travelers containing little detail and later Travelers providing justification similar to a plant-specific license amendment.
4.0 Technical Analysis The analysis of each Traveler is summarized below and included in the enclosed Traveler.
5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
TSTF-507, Rev. 0 The Travelers included in the proposed change increase standardization and consistency in the definitions, format and usage rules, and administrative requirements. The proposed changes do not affect any initiators in any accidents previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The proposed changes do not reduce the ability of systems to mitigate the consequences of an accident. As a result, the consequence of any accident previously evaluated is not significantly increased.
Therefore, the proposed changes do 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.
The Travelers included in the proposed change increase standardization and consistency in the definitions, format and usage rules, and administrative requirements. No new or different accidents result from utilizing the proposed change. The changes do not involve the installation of any new or different type of equipment or a change in the methods governing normal plant operation. The changes to the Technical Specifications are consistent with the safety analysis assumptions.
Therefore, the proposed changes do 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 Travelers included in the proposed change increase standardization and consistency in the definitions, format and usage rules, and administrative requirements. The proposed change does not result in a significant change in the control or operation of equipment important to plant safety.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
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 The proposed changes revise the ISTS to be consistent with the Improved Standard Technical Specifications contained in NUREG-1430, -1431, -1432, -1433, and -1434.
TSTF-507, Rev. 0 The ISTS and the proposed changes are consistent with the requirements for Technical Specifications in 10 CFR 50.36.
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 Commissions 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 effluent 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.
TSTF-507, Rev. 0 Attachment Discussion of Each Previously NRC Approved Traveler
TSTF-507, Rev. 0 Traveler: TSTF-6-A, Revision 1, "Add Exception for LCO 3.0.7 to LCO 3.0.1" Affected ISTS NUREGs: 1430 (B&W), 1431 (W)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description An exception is added to LCO 3.0.1 for LCO 3.0.7.
Summary of the Approved Traveler Justification This change completes ISTS Revision 0 change NRC-03, C.5 which added LCO 3.0.7 to address test exception LCOs. This exception was omitted in the original change for the B&W and Westinghouse ISTS NUREGs. The CEOG, BWR/4 and BWR/6 ITS already contain this change.
NRC Approval TSTF-6-A was approved by the NRC in a letter dated September 27, 1996 and it was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-6-A has been adopted by many plants as part of complete conversion to the ISTS.
List of Affected Specifications NUREG-1430, -1431 LCO 3.0.1, LCO Applicability
TSTF-507, Rev. 0 Traveler: TSTF-19-A, Revision 1, "Relocate the details of RTD and thermocouple calibration from the Channel Calibration definition" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description Relocate the details of RTD and thermocouple calibration from the Channel Calibration definition to the Bases associated with calibration of these components.
Summary of the Approved Traveler Justification The details associated with defining acceptable means by which a channel calibration can be accomplished for RTDs and thermocouples is proposed to be relocated to the Bases associated with the calibration of these components. The information contained in the definition is prescriptive in nature, better suited as Bases information consistent with other material relocated to the Bases.
NRC Approval TSTF-19-A was approved by the NRC on April 7, 1997. The NRC did not issue a letter approving TSTF-19-A, however it was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-19-A has been adopted by many plants as part of complete conversion to the ISTS.
List of Affected Specifications NUREG-1430, -1431, -1432 Section 1.1, Definition of "Channel Calibration."
The following Bases are revised to reflect the revised definition:
NUREG-1430 SR 3.3.1.6 Bases RPS Instrumentation SR 3.3.17.2 Bases PAM Instrumentation SR 3.3.18.3 Bases Remote Shutdown System NUREG-1431 SR 3.3.1.12 Bases RTS Instrumentation SR 3.3.3.2 Bases PAM Instrumentation SR 3.3.4.3 Bases Remote Shutdown System NUREG-1432 SR 3.3.11.2 Bases PAM Instrumentation (Analog)
SR 3.3.11.2 Bases PAM Instrumentation (Digital)
SR 3.3.12.3 Bases Remote Shutdown System (Analog)
SR 3.3.12.3 Bases Remote Shutdown System (Digital)
TSTF-507, Rev. 0 Traveler: TSTF-40-A, Revision 0, " Exempt RCP seal water injection or leakoff from the definition of Unidentified Leakage" Affected ISTS NUREGs: 1430 (B&W), 1432 (CE)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description Revise the definition of Unidentified Leakage from "All Leakage that is not identified leakage or controlled leakage" to "All leakage (except RCP seal water injection or leakoff) that is not identified leakage."
Summary of the Approved Traveler Justification The exception for controlled leakage from NUREG-0123 was revised in the definition of identified leakage to an exception for "RCP seal water injection or leakoff." However, the term was retained in the definition of Unidentified Leakage. This term, Controlled Leakage, should therefore be similarly revised and included as an exception in the definition of Unidentified Leakage since it is not considered to be Leakage, and the undefined term "Controlled Leakage" should not be used. This change is consistent with NUREG-1431.
NRC Approval TSTF-40-A was approved by the NRC on March 13, 1997. The NRC did not issue a letter approving TSTF-40-A, however it was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-40-A has been adopted by many plants as part of complete conversion to the ISTS.
List of Affected Specifications NUREG-1430, -1432 Section 1.1, Definition of "Leakage"
TSTF-507, Rev. 0 Traveler: TSTF-42-A, Revision 0, "Revise the wording of SR 3.0.2 to be consistent with the other NUREGs" Affected ISTS NUREGs: 1430 (B&W)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description Delete the phrase "Required Action requires performance of a surveillance or its" so that SR 3.0.2 would read: "If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance."
Summary of the Approved Traveler Justification The deleted phrase is unnecessary and potentially confusing. It is unnecessary since all "Once per..." basis requirements for Required Actions are in the Completion Time column. The deleted phrase is potentially confusing since it could be read to imply that the extension could only be applied if the periodic Required Action is a Surveillance. The proposed wording provides all the information that is necessary to correctly apply the extension. The proposed wording is consistent with NUREGs 1431, 1432, 1433, and 1434.
NRC Approval TSTF-42-A was approved by the NRC in a letter dated September 27, 1996 and it was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-42-A has been adopted by many plants as part of complete conversion to the ISTS.
List of Affected Specifications NUREG-1430, -1431 SR 3.0.1, SR Applicability
TSTF-507, Rev. 0 Traveler: TSTF-47-A, Revision 0, "Eliminate 'manipulation' from the definition of Core Alteration" Affected ISTS NUREGs: 1432 (CE)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description The words, "or manipulation" were deleted from the definition of Core Alteration.
Summary of the Approved Traveler Justification When considering components in the Reactor Vessel such as Fuel , CEAs, or sources, it is improbable (by definition of manipulation) that fuel, CEAs or Sources could be manipulated without moving these components. Also this change would make the CE NUREG consistent with NUREG-1430 and NUREG-1431.
NRC Approval TSTF-47-A was approved by the NRC in a letter dated September 27, 1996. TSTF-47-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-47-A was approved in a plant-specific license amendment for Millstone Unit 2 on January 11, 2002 (ADAMS Accession Number ML013440338.)
List of Affected Specifications NUREG-1432 Section 1.1, Definition of "Core Alterations"
TSTF-507, Rev. 0 Traveler: TSTF-65-A, Revision 1, "Use of Generic Titles for Utility Positions" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description Chapter 5, "Administrative Controls," is revised to eliminate utility-specific personnel titles and to substitute generic descriptions for those positions in order to increase standardization and consistency.
TSTF-65-A also affects Section 2 of the Technical Specification by revising the title of the utility position that must be notified when a Safety Limit is violated. This requirement was eliminated from the ISTS by TSTF-5-A, "Delete safety limit violation notification requirements."
Summary of the Approved Traveler Justification This change does not eliminate any of the qualifications, responsibilities or requirements for these positions, since the plant-specific personnel titles are currently identified in licensee controlled documents, such as the Final Safety Analysis Report or Quality Assurance (QA) Plan.
In addition, the improved STS require that these positions meet the qualifications of Regulatory Guide (RG) 1.8 or an ANSI Standard acceptable to the NRC staff. The relationship between the titles in the ANSI standard and the titles used by the licensee should be described in Section 17 of the FSAR or the QA Plan as appropriate. Changes to titles in the FSAR/QA Plan shou1d be handled using normal FSAR/QA Plan change procedures (10 CFR 50.54(a)).
NRC Approval TSTF-65-A was approved by the NRC in a letter dated September 22, 1997. TSTF-65-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-65-A has also been approved in at least 16 license amendments; for example Callaway on June 3, 2003 (ADAMS Accession Number ML031560842), Cooper on June 15, 2003 (ADAMS Accession Number ML032040006), and Peach Bottom on May 10, 2006 (ADAMS Accession Number ML061070292).
List of Affected Specifications All NUREGs 2.2 Safety Limits 5.1.1 Administrative Controls - Responsibility 5.2.1 Administrative Controls - Onsite and Offsite Organizations 5.2.2 Administrative Controls - Unit Staff 5.5.1 Administrative Controls - Programs and Manuals 5.7.1 Administrative Controls - High Radiation Area The following Bases are revised:
2.2 Bases Safety Limits
TSTF-507, Rev. 0 Traveler: TSTF-104-A, Revision 0, "Relocates discussion of exceptions from LCO 3.0.4 to the Bases" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description This change removes the additional discussion provided in LCO 3.0.4 with respect to the use of exceptions and provides the necessary discussion in the Bases.
Summary of the Approved Traveler Justification This change provides consistency with LCO 3.0.3 by moving the discussion of exceptions from the LCO to the Bases. In addition, this change reduces the potential for confusion by revising the discussion to eliminate the repeated use of the phrase "Modes or other specified conditions in the Applicability" to increase clarity.
NRC Approval TSTF-104-A was approved by the NRC on March 14, 1997 and it was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-104-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-104-A has also been approved in at least one license amendment; for example Perry on May 15, 2001 (ADAMS Accession Number ML011370360).
List of Affected Specifications All ISTS NUREGs LCO 3.0.4, LCO Applicability The following Bases are revised:
LCO 3.0.4 Bases, LCO Applicability
TSTF-507, Rev. 0 Traveler: TSTF-106-A, Revision 1, "Change to Diesel Fuel Oil Testing Program" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description The proposed change clarifies the requirements of the Diesel Fuel Oil Testing Program.
Summary of the Approved Traveler Justification TSTF-106 clarifies that the TS requirement for the Diesel Oil Testing Program is only applicable to new fuel, must be done within 31 days following addition of new fuel oil to the storage tanks, and is only required to be done one time. The current TS can be, and has been, misinterpreted.
TS 5.5.9.b is proposed to be revised from "Other properties for ASTM [American Society for Testing and Materials] 2D fuel oil are within limits within 31 days following sampling and addition to storage tanks; and" to "Within 31 days following addition of the new fuel oil to storage tanks, verify that the properties of the new fuel oil, other than those addressed in a.,
above, are within limits for ASTM 2D fuel oil; and".
NRC Approval TSTF-106-A was approved by the NRC in a letter dated September 27, 1996. TSTF-106-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-106-A has also been approved in at least two license amendments; for example Perry on May 15, 2001 (ADAMS Accession Number ML0113703600) and Peach Bottom on May 10, 2006 (ADAMS Accession Number ML061070292).
List of Affected Specifications NUREG-1430, -1431, -1432 5.1.13 Administrative Controls - Diesel Fuel Oil Testing Program NUREG-1433, -1434 5.1.10 Administrative Controls - Diesel Fuel Oil Testing Program
TSTF-507, Rev. 0 Traveler: TSTF-118-A, Revision 0, "Administrative Controls Program Exceptions" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description The proposed change clarifies revises Administrative Controls 5.5.9 to add the following sentence, "The provisions of SR 3.0.2 are applicable to the Steam Generator Tube Surveillance Program test frequencies," and revise 5.5.13 to add the following sentence, "The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program testing frequencies."
Summary of the Approved Traveler Justification These sentences provide consistency with the current application of these requirements as provided in 5.5.6, "Pre-Stressed Concrete Containment Tendon Surveillance Program," and in 5.5.11, "Ventilation Filter Testing program." SR 3.0.2 and SR 3.0.3 are already applicable to the surveillances which reference these programs, and, therefore, the lack of an applicability statement in the Programs introduces confusion. Further, the applicability of SR 3.0.2 and SR 3.0.3 to the program surveillances is consistent with current licensing basis and the old STS. SR 3.0.3 is not addressed for the SGTSP since these tests cannot be performed during operation.
NRC Approval TSTF-118-A was approved by the NRC on March 13, 1997. The NRC did not issue a letter approving TSTF-118-A, however it was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-118-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-118-A has also been approved in at least two license amendments; for example Perry on May 15, 2001 (ADAMS Accession Number ML0113703600) and Peach Bottom on May 10, 2006 (ADAMS Accession Number ML061070292).
List of Affected Specifications All NUREGs 5.5 Administrative Controls - Programs and Manuals
TSTF-507, Rev. 0 Traveler: TSTF-124-A, Revision 0, "Delete Specific Reference to Bypasses in CFT and Calibration Definitions" Affected ISTS NUREGs: 1430 (B&W)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description The proposed change revises the definition of CHANNEL CALIBRATION to delete the following sentence: "The CHANNEL CALIBRATION shall also include testing of safety related Reactor Protection System (RPS), Engineered Safety Feature Actuation System (ESFAS), and Emergency Feed water Initiation and Control (EFIC) bypass functions for each channel affected by the bypass operation," and revise the definition of CHANNEL FUNCTIONAL TEST to delete the last sentence, "The ESFAS CHANNEL FUNCTIONAL TEST shall also include testing of ESFAS safety related bypass functions for each channel affected by bypass operation."
Summary of the Approved Traveler Justification Separate delineation of the inclusion of bypasses in the CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION definitions are not necessary. The current industry standards clearly indicate the operating bypasses are a part of the system function (IEEE-603, which replaced IEEE-279, and is endorsed by RG 1.153) and that the CHANNEL FUNCTIONAL TEST should include the testing of such bypasses (IEEE 338, Section 6.3.2). Further , the revised definitions are consistent with the definitions provided in the ISTS NUREGs for all other vendors.
NRC Approval TSTF-124-A was approved by the NRC on October 1, 1997. The NRC did not issue a letter approving TSTF-124-A, however it was incorporated by the NRC into Revision 2 of the ISTS NUREGs.
List of Affected Specifications NUREG-1430 Section 1.1, Definitions
TSTF-507, Rev. 0 Traveler: TSTF-125-A, Revision 1, "Delete EFPD Definition" Affected ISTS NUREGs: 1430 (B&W)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description The proposed change deletes the definition of EFFECTIVE FULL POWER DAYS.
Summary of the Approved Traveler Justification This definition is unnecessary, and inconsistent with the other ISTS NUREGs. EFPD is a very well understood, common term which does not require definition. This term is consistently used throughout the nuclear industry, and has been consistently applied for many years without a TS definition. Additionally, the term is not used as a defined term in the Bases.
A search of the ISTS NUREGs reveals that the term "EFPD" is used in 37 Specifications or Bases in the PWR NUREGs. It is only defined in one occurrence (NUREG-1430, LCO 3.2.2 Bases). EFPD is not a defined term in the other ISTS NUREGs. Therefore, eliminating the defined term from NUREG-1430 and eliminating the one occurrence of its definition from the NUREG-1430 Bases makes NUREG-1430 internally consistent in its usage and with the other NUREGs (both definitions, Specifications, and Bases).
NRC Approval TSTF-125-A was approved by the NRC on April 17, 1997. The NRC did not issue a letter approving TSTF-125-A, however it was incorporated by the NRC into Revision 2 of the ISTS NUREGs.
List of Affected Specifications NUREG-1430 Section 1.1, Definitions The following Bases are revised:
LCO 3.3.2 Bases, APSR Insertion Limits
TSTF-507, Rev. 0 Traveler: TSTF-152-A, Revision 0, "Revise Reporting Requirements to be Consistent with 10 CFR 20" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433(BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description This change revises 5.6.1, Occupational Radiation Exposure Report, and 5.6.3, Radioactive Effluent Release Report, to be consistent with NRC letter dated 7/28/95 by C. I. Grimes on changes to Technical Specifications resulting from 10 CFR 20 and 50.36a changes.
Summary of the Approved Traveler Justification NRC provided guidance on how to change the ITS in a proposed Generic Letter that was never issued. These changes reflect the rule changes.
NRC Approval TSTF-152-A was approved by the NRC on March 13, 1997. The NRC did not issue a letter approving TSTF-152-A, however it was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-152-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-152-A has also been approved in at least five license amendments; for example Perry on May 15, 2001 (ADAMS Accession Number ML0113703600) and Peach Bottom on May 10, 2006 (ADAMS Accession Number ML061070292).
List of Affected Specifications All NUREGs 5.6.1 Occupational Radiation Exposure Report 5.6.3 Radioactive Effluent Release Report
TSTF-507, Rev. 0 Traveler: TSTF-166-A, Revision 0, "Correct Inconsistency Between LCO 3.0.6 and the SFDP Regarding Performance of an Evaluation" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description Revise LCO 3.0.6 to explicitly require an evaluation per the Safety Function Determination Program. Delete statement "additional . . . limitations may be required" from LCO 3.0.6.
Summary of the Approved Traveler Justification This change corrects an inconsistency between LCO 3.0.6, the Safety Function Determination Program (SFDP), and the LCO 3.0.6 Bases. As currently written, LCO 3.0.6 does not explicitly require an evaluation in accordance with the SFDP; rather it states that additional evaluations may be required. Both the SFDP and the LCO 3.0.6 Bases state that upon entry into LCO 3.0.6, an evaluation shall be made to determine if a loss of safety function exists. In addition, because LCO 3.0.6 states that the evaluation be done in accordance with the SFDP and the SFDP states that other appropriate actions may be taken, there is no need for the statement "additional . . .
limitations may be required" in LCO 3.0.6.
NRC Approval TSTF-166-A was approved by the NRC on May 2, 1997. The NRC did not issue a letter approving TSTF-166-A, however it was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-166-A has also been approved in at least one license amendment, ; for example Perry on May 15, 2001 (ADAMS Accession Number ML0113703600).
List of Affected Specifications All ISTS NUREGs LCO 3.0.6, LCO Applicability
TSTF-507, Rev. 0 Traveler: TSTF-205-A, Revision 3, "Revision of Channel Calibration, Channel Functional Test, and Related Definitions" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433(BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description In April, 1997, the NRC described problems that had been found with the ISTS definitions of Channel Calibration, Channel Functional Test, and related definitions. The NRC proposed revised definitions for these terms. Based on the NRC's suggestions, revised definitions of these terms were developed.
Summary of the Approved Traveler Justification The revised definitions eliminate a current ambiguity and possible misinterpretation of Channel Calibration, Channel Functional Test, Actuation Logic Test, Channel Operational Test, Trip Actuating Device Operational Test, and Logic System Functional Test. The current definitions use phrases similar to "required sensor, alarm, interlock, display and trip functions," and "required relays and contacts, trip units, solid state logic elements, etc." There is ambiguity in the application of the word "required" and whether the list is inclusive or representative.
Therefore, this list has been replaced with phrases similar to, "all devices in the channel required for channel OPERABILITY." This clarifies the use of the word "required" and makes clear that the components that are required to be tested or calibrated are only those that are necessary for the channel to perform its safety function. The list of components is eliminated from the definition. These changes will clarify the requirements and allow for consistent application of the definitions, tests, and calibrations.
In addition, the clarified the allowance to have the test "... performed by means of any series of sequential, overlapping or total channel steps. " The Bases of applicable Surveillances are modified to include this clarification of the acceptable methods of testing. This clarification is applied to all Channel Functional Tests, Channel Operational Tests, and TADOTs. In the Bases of the SRs a statement is added to indicate that, "A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable [CHANNEL FUNCTIONAL TEST / CHANNEL OPERATIONAL TEST / TADOT] of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests."
Other changes are made for consistency of the definitions between the ISTS NUREGs.
The changes proposed increase the consistency of the five NUREGs and are not intended to change the meaning or intent of the affected definitions.
NRC Approval TSTF-205-A was approved by the NRC in a letter dated January 13, 1999. It was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-205-A has been adopted by many
TSTF-507, Rev. 0 plants as part of complete conversion to the ISTS. TSTF-205-A has also been approved in at least one plant-specific license amendments; for example Cooper on March 10, 2006 (ADAMS Accession Number ML060460135).
List of Affected Specifications NUREG-1430 1.1, Definitions - Channel Calibration 1.1, Definitions - Channel Functional Test NUREG-1431 1.1, Definitions - Actuation Logic Test 1.1, Definitions - Channel Calibration 1.1, Definitions - Channel Operational Test 1.1, Definitions - Master Relay Test 1.1, Definitions - Slave Relay Test 1.1, Definitions - Trip Actuating Device Operational Test NUREG-1432 1.1, Definitions - Channel Calibration 1.1, Definitions - Channel Functional Test NUREG-1433 1.1, Definitions - Channel Calibration 1.1, Definitions - Channel Functional Test 1.1, Definitions - Logic System Functional Test NUREG-1434 1.1, Definitions - Channel Calibration 1.1, Definitions - Channel Functional Test 1.1, Definitions - Logic System Functional Test The following Bases are revised:
NUREG-1430 SR 3.3.1.4 Bases Reactor Protection System (RPS) Instrumentation SR 3.3.2.1 Bases Reactor Protection System (RPS) Manual Reactor Trip SR 3.3.3.1 Bases Reactor Protection System (RPS)Reactor Trip Module (RTM)
SR 3.3.4.1 Bases CONTROL ROD Drive (CRD) Trip Devices SR 3.3.5.2 Bases Engineered Safety Feature Actuation System (ESFAS)
Instrumentation SR 3.3.6.1 Bases Engineered Safety Feature Actuation System (ESFAS) Manual Initiation SR 3.3.7.1 Bases Engineered Safety Feature Actuation System (ESFAS)
Automatic Actuation Logic SR 3.3.8.2 Bases Emergency Diesel Generator (EDG) Loss of Power Start (LOPS)
SR 3.3.11.2 Bases Emergency Feedwater Initiation and Control (EFIC) System Instrumentation
TSTF-507, Rev. 0 SR 3.3.12.1 Bases Emergency Feedwater Initiation and Control (EFIC) Manual Initiation SR 3.3.13.1 Bases Emergency Feedwater Initiation and Control (EFIC) Logic SR 3.3.14.1 Bases Emergency Feedwater Initiation and Control (EFIC)-Emergency Feedwater (EFW)Vector Valve Logic SR 3.3.15.2 Bases Reactor Building (RB) Purge IsolationHigh Radiation SR 3.3.16.2 Bases Control Room IsolationHigh Radiation SR 3.4.12.7 Bases Low Temperature Overpressure Protection (LTOP) System SR 3.4.15.2 Bases RCS Leakage Detection Instrumentation SR 3.7.5.6 Bases Emergency Feedwater (EFW) System NUREG-1431 SR 3.3.1.4 Bases Reactor Trip System (RTS) Instrumentation SR 3.3.1.7 Bases Reactor Trip System (RTS) Instrumentation SR 3.3.1.8 Bases Reactor Trip System (RTS) Instrumentation SR 3.3.1.9 Bases Reactor Trip System (RTS) Instrumentation SR 3.3.1.13 Bases Reactor Trip System (RTS) Instrumentation SR 3.3.1.14 Bases Reactor Trip System (RTS) Instrumentation SR 3.3.1.15 Bases Reactor Trip System (RTS) Instrumentation SR 3.3.2.5 Bases Engineered Safety Feature Actuation System (ESFAS)
Instrumentation SR 3.3.2.7 Bases Engineered Safety Feature Actuation System (ESFAS)
Instrumentation SR 3.3.2.8 Bases Engineered Safety Feature Actuation System (ESFAS)
Instrumentation SR 3.3.2.11 Bases Engineered Safety Feature Actuation System (ESFAS)
Instrumentation SR 3.3.4.4 Bases Remote Shutdown System SR 3.3.5.2 Bases Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation SR 3.3.6.4 Bases Containment Purge and Exhaust Isolation Instrumentation SR 3.3.6.6 Bases Containment Purge and Exhaust Isolation Instrumentation SR 3.3.7.2 Bases Control Room Emergency Filtration System (CREFS) Actuation Instrumentation SR 3.3.7.6 Bases Control Room Emergency Filtration System (CREFS) Actuation Instrumentation SR 3.3.8.2 Bases Fuel Building Air Cleanup System (FBACS) Actuation Instrumentation SR 3.3.8.4 Bases Fuel Building Air Cleanup System (FBACS) Actuation SR 3.3.9.1 Bases Boron Dilution Protection System (BDPS)
SR 3.4.12.8 Bases Low Temperature Overpressure Protection (LTOP) System SR 3.4.15.2 Bases RCS Leakage Detection Instrumentation SR 3.4.19.2 Bases RCS Loops-Test Exceptions NUREG-1432 SR 3.1.5.4 Bases Control Element Assembly (CEA) Alignment (Digital)
TSTF-507, Rev. 0 SR 3.1.5.6 Bases Control Element Assembly (CEA) Alignment (Analog)
SR 3.3.1.4 Bases Reactor Protective System (RPS) Instrumentation-Operating (Analog)
SR 3.3.1.6 Bases Reactor Protective System (RPS) Instrumentation-Operating (Analog)
SR 3.3.1.7 Bases Reactor Protective System (RPS) Instrumentation-Operating (Analog)
SR 3.3.1.7 Bases Reactor Protective System (RPS) Instrumentation-Operating (Digital)
SR 3.3.1.9 Bases Reactor Protective System (RPS) Instrumentation-Operating (Digital)
SR 3.3.1.11 Bases Reactor Protective System (RPS) Instrumentation-Operating (Digital)
SR 3.3.1.13 Bases Reactor Protective System (RPS) Instrumentation-Operating (Digital)
SR 3.3.2.2 Bases Reactor Protective System (RPS) Instrumentation-Shutdown (Analog)
SR 3.3.2.2 Bases Reactor Protective System (RPS) Instrumentation-Shutdown (Digital)
SR 3.3.2.3 Bases Reactor Protective System (RPS) Instrumentation-Shutdown (Analog)
SR 3.3.2.3 Bases Reactor Protective System (RPS) Instrumentation-Shutdown (Digital)
SR 3.3.3.1 Bases Reactor Protective System (RPS) Logic and Trip Initiation (Analog)
SR 3.3.3.2 Bases Reactor Protective System (RPS) Logic and Trip Initiation (Analog)
SR 3.3.3.3 Bases Control Element Assembly Calculators (CEACs) (Digital)
SR 3.3.3.3 Bases Reactor Protective System (RPS) Logic and Trip Initiation (Analog)
SR 3.3.3.5 Bases Control Element Assembly Calculators (CEACs) (Digital)
SR 3.3.4.1 Bases Reactor Protective System (RPS) Logic and Trip Initiation (Digital)
SR 3.3.4.2 Bases Engineered Safety Features Actuation System (ESFAS)
Instrumentation (Analog)
SR 3.3.4.2 Bases Reactor Protective System (RPS) Logic and Trip Initiation (Digital)
SR 3.3.4.3 Bases Engineered Safety Features Actuation System (ESFAS)
Instrumentation (Analog)
SR 3.3.4.3 Bases Reactor Protective System (RPS) Logic and Trip Initiation (Digital)
SR 3.3.5.1 Bases Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip (Analog)
SR 3.3.5.2 Bases Engineered Safety Features Actuation System (ESFAS)
Instrumentation (Digital)
SR 3.3.5.2 Bases Engineered Safety Features Actuation System (ESFAS) Logic
TSTF-507, Rev. 0 and Manual Trip (Analog)
SR 3.3.5.5 Bases Engineered Safety Features Actuation System (ESFAS)
Instrumentation (Digital)
SR 3.3.6.1 Bases Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip (Digital)
SR 3.3.6.2 Bases Diesel Generator (DG)-Loss of Voltage Start (LOVS) (Analog)
SR 3.3.6.3 Bases Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip (Digital)
SR 3.3.7.2 Bases Containment Purge Isolation Signal (CPIS) (Analog)
SR 3.3.7.2 Bases Diesel Generator (DG)-Loss of Voltage Start (LOVS) (Digital)
SR 3.3.7.3 Bases Containment Purge Isolation Signal (CPIS) (Analog)
SR 3.3.7.5 Bases Containment Purge Isolation Signal (CPIS) (Analog)
SR 3.3.8.2 Bases Control Room Isolation Signal (CRIS) (Analog)
SR 3.3.8.3 Bases Containment Purge Isolation Signal (CPIS) (Digital)
SR 3.3.8.3 Bases Control Room Isolation Signal (CRIS) (Analog)
SR 3.3.8.4 Bases Containment Purge Isolation Signal (CPIS) (Digital)
SR 3.3.8.5 Bases Containment Purge Isolation Signal (CPIS) (Digital)
SR 3.3.8.5 Bases Control Room Isolation Signal (CRIS) (Analog)
SR 3.3.8.8 Bases Containment Purge Isolation Signal (CPIS) (Digital)
SR 3.3.9.2 Bases Chemical and Volume Control System (CVCS) Isolation Signal (Analog)
SR 3.3.9.2 Bases Control Room Isolation Signal (CRIS) (Digital)
SR 3.3.9.3 Bases Control Room Isolation Signal (CRIS) (Digital)
SR 3.3.9.5 Bases Control Room Isolation Signal (CRIS) (Digital)
SR 3.3.10.1 Bases Shield Building Filtration Actuation Signal (SBFAS) (Analog)
SR 3.3.10.2 Bases Fuel Handling Isolation Signal (FHIS) (Digital)
SR 3.3.10.2 Bases Shield Building Filtration Actuation Signal (SBFAS) (Analog)
SR 3.3.10.3 Bases Fuel Handling Isolation Signal (FHIS) (Digital)
SR 3.3.10.4 Bases Fuel Handling Isolation Signal (FHIS) (Digital)
SR 3.3.12.4 Bases Remote Shutdown System (Analog)
SR 3.3.12.4 Bases Remote Shutdown System (Digital)
SR 3.3.13.2 Bases [Logarithmic] Power Monitoring Channels (Analog)
SR 3.3.13.2 Bases [Logarithmic] Power Monitoring Channels (Digital)
SR 3.4.12.6 Bases Low Temperature Overpressure Protection (LTOP) System SR 3.4.15.2 Bases RCS Leakage Detection Instrumentation SR 3.4.17.2 Bases Special Test Exceptions (STE) RCS Loops NUREG-1433 SR 3.3.1.1.4 Bases Reactor Protection System (RPS) Instrumentation SR 3.3.1.1.5 Bases Reactor Protection System (RPS) Instrumentation SR 3.3.1.1.9 Bases Reactor Protection System (RPS) Instrumentation SR 3.3.1.1.12 Bases Reactor Protection System (RPS) Instrumentation SR 3.3.1.2.5 Bases Source Range Monitor (SRM) Instrumentation SR 3.3.1.2.6 Bases Source Range Monitor (SRM) Instrumentation SR 3.3.2.1.1 Bases Control Rod Block Instrumentation SR 3.3.2.1.2 Bases Control Rod Block Instrumentation
TSTF-507, Rev. 0 SR 3.3.2.1.3 Bases Control Rod Block Instrumentation SR 3.3.2.1.6 Bases Control Rod Block Instrumentation SR 3.3.2.2.2 Bases Feedwater and Main Turbine High Water Level Trip Instrumentation SR 3.3.4.1.1 Bases End of Cycle Recirculation Pump Trip (EOC-RPT)
Instrumentation SR 3.3.4.2.2 Bases Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation SR 3.3.5.1.2 Bases Emergency Core Cooling System (ECCS) Instrumentation SR 3.3.5.2.2 Bases Reactor Core Isolation Cooling (RCIC) System Instrumentation SR 3.3.6.1.2 Bases Primary Containment Isolation Instrumentation SR 3.3.6.1.5 Bases Primary Containment Isolation Instrumentation SR 3.3.6.2.2 Bases Secondary Containment Isolation Instrumentation SR 3.3.6.3.2 Bases Low-Low Set (LLS) Instrumentation SR 3.3.6.3.3 Bases Low-Low Set (LLS) Instrumentation SR 3.3.6.3.4 Bases Low-Low Set (LLS) Instrumentation SR 3.3.7.1.2 Bases [Main Control Room Environmental Control (MCREC)] System Instrumentation SR 3.3.8.1.2 Bases Loss of Power (LOP) Instrumentation SR 3.3.8.2.1 Bases Reactor Protection System (RPS) Electric Power Monitoring SR 3.4.6.2 Bases RCS Leakage Detection Instrumentation SR 3.9.2.2 Bases Refuel Position One-Rod-Out Interlock NUREG-1434 SR 3.3.1.1.4 Bases Reactor Protection System (RPS) Instrumentation SR 3.3.1.1.5 Bases Reactor Protection System (RPS) Instrumentation SR 3.3.1.1.9 Bases Reactor Protection System (RPS) Instrumentation SR 3.3.1.1.12 Bases Reactor Protection System (RPS) Instrumentation SR 3.3.1.2.5 Bases Source Range Monitor (SRM) Instrumentation SR 3.3.1.2.6 Bases Source Range Monitor (SRM) Instrumentation SR 3.3.2.1.1 Bases Control Rod Block Instrumentation SR 3.3.2.1.2 Bases Control Rod Block Instrumentation SR 3.3.2.1.3 Bases Control Rod Block Instrumentation SR 3.3.2.1.4 Bases Control Rod Block Instrumentation SR 3.3.2.1.8 Bases Control Rod Block Instrumentation SR 3.3.4.1.1 Bases End of Cycle Recirculation Pump Trip (EOC-RPT)
Instrumentation SR 3.3.4.2.2 Bases Anticipated Transient Without Scram Recirculation Pump Trip (ATWS-RPT) Instrumentation SR 3.3.5.1.2 Bases Emergency Core Cooling System (ECCS) Instrumentation SR 3.3.5.2.2 Bases Reactor Core Isolation Cooling (RCIC) System Instrumentation SR 3.3.6.1.2 Bases Primary Containment Isolation Instrumentation SR 3.3.6.2.2 Bases Secondary Containment Isolation Instrumentation SR 3.3.6.3.2 Bases Residual Heat Removal (RHR) Containment Spray System Instrumentation SR 3.3.6.4.2 Bases Suppression Pool Makeup (SPMU) System Instrumentation
TSTF-507, Rev. 0 SR 3.3.6.5.1 Bases Relief and Low-Low Set (LLS) Instrumentation SR 3.3.7.1.2 Bases [Control Room Fresh Air (CRFA)] System Instrumentation SR 3.3.8.1.2 Bases Loss of Power (LOP) Instrumentation SR 3.3.8.2.1 Bases Reactor Protection System (RPS) Electric Power Monitoring SR 3.4.7.2 Bases RCS Leakage Detection Instrumentation SR 3.9.1.1 Bases Refueling Equipment Interlocks SR 3.9.2.2 Bases Refuel Position One-Rod-Out Interlock
TSTF-507, Rev. 0 Traveler: TSTF-248-A, Revision 0, "Revise Shutdown Margin Definition for Stuck Rod Exception" Affected ISTS NUREGs: 1430 (B&W), 1431 (W)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description The definition of SHUTDOWN MARGIN (SDM), item a, is revised to include the following as a new sentence: "However, with all CONTROL RODS verified as fully inserted by two independent means, it is not necessary to account for a stuck CONTROL ROD in the SDM calculation."
Summary of the Approved Traveler Justification The consideration of a stuck rod is provided only to allow for a single failure of one rod to not insert when a scram is initiated. However, with positive indication that all rods are already fully inserted, such a provision is overly conservative. This change is consistent with the definition of SDM provided in NUREG-1432 for CE plants.
NRC Approval TSTF-248-A was approved by the NRC in a letter dated October 31, 2000. It was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-248-A has been adopted by many plants as part of complete conversion to the ISTS.
List of Affected Specifications All NUREGs 1.1, Definitions - Shutdown Margin
TSTF-507, Rev. 0 Traveler: TSTF-258-A, Revision 4, "Changes to Section 5.0, Administrative Controls" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description This traveler is based on the recommendations in the April 9, 1997 letter from C. Grimes (NRC) to J. Davis (NEI). This traveler proposes the following changes:
- 1) Revise Administrative Control 5.2.2, Unit Staff, to delete item b, revises item e eliminating specific details for working hour limits, and revises item g to clarify the requirements for the Shift Technical Advisor function,
- 2) Inserts brackets around entire second sentence in 5.3.1 and adds 5.3.2, Unit Staff Qualifications to retain elements required in TS by regulations,
- 3) Revises Section 5.5.4 to be consistent with the intent of 10 CFR 20
- 4) Revises Section 5.6.4 to be consistent with Generic Letter 97-04, and
- 5) Revises Section 5.7 in accordance with 10 CFR 20.1601(c)
Summary of the Approved Traveler Justification Changes to Section 5.2, Organization: The requirements of 10 CFR 50.54(m)(2)(iii) and 50.54(k) adequately provide for shift manning and the detail in the Technical Specifications is not required. Wording is added to be compliant with 10 CFR 50.54(m). The change to Section 5.2.2.e. to eliminate specific working hour limits and to require administrative procedures to control working hours will provide reasonable assurance that impaired performance caused by excessive working hours will not jeopardize safe plant operation. Section 5.2.2.g is revised so that it does not imply that the STA and the Shift Supervisor must be different individuals and is consistent with 10 CFR 50.54(m)(2)(i).
Changes to 5.3, Unit Staff Qualifications: In Section 5.3.1, part a, the second sentence is bracketed in its entirety. There may be cases were the entire unit staff are covered by the standard specified in the first sentence or there may be specific exceptions for specific positions that could then be specified by bracketing the entire sentence. Adding Paragraph 5.3.2, part b, ensures that there is no misunderstanding when complying with 10 CFR 55.4 requirements.
Adding Paragraph 5.3.2, part c, is consistent with the staffing requirements in Generic Letter 87-16.
Changes to 5.5.4, Radioactive Effluent Controls Program: The NRC issued a draft Generic Letter, 93-XX, on proposed changes to STS NUREGS based on the revised 10 CFR 20. The Traveler changes are consistent with the draft generic letter and the April 9, 1997 letter from C.
Grimes to J. Davis with some exceptions. The proposed changes maintain the same overall level of effluent control while retaining the operational flexibility that exists with current TS under the previous 10 CFR 20.
Changes to 5.6.4, Monthly Operating Reports. The requirements are modified to eliminate the need to report challenges to the pressurizer safety and relief valves. Note that all licensees have eliminated the requirement to submit the monthly operating report under TSTF-369.
TSTF-507, Rev. 0 Changes to 5.7, High Radiation Area: Section 5.7 is revised in accordance with 10 CFR 20.1601(c) and updates the acceptable alternate controls to those given in 10 CFR 20.1601.
NRC Approval TSTF-258-A was approved by the NRC in a letter dated June 29, 1999. It was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-258-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-258-A has also been approved in at least twenty five license amendments; for example Perry on May 15, 2001 (ADAMS Accession Number ML0113703600) and Peach Bottom on August 30, 2001 (ADAMS Accession Number ML012140530).
List of Affected Specifications All NUREGs 5.2.2 Administrative Controls, Unit Staff 5.3.1 Administrative Controls, Unit Staff Qualifications 5.5.4 Administrative Controls, Radioactive Effluent Controls Program 5.6.4 Administrative Controls, Monthly Operating Reports 5.7 Administrative Controls, High Radiation Area
TSTF-507, Rev. 0 Traveler: TSTF-273-A, Revision 2, "SFDP Clarifications" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description Add to the LCO 3.0.6 Bases a clarification of "appropriate LCO for loss of function" and clarify in the requirements for the SFDP that consideration does not have to be made for a loss of power in determining loss of function.
Summary of the Approved Traveler Justification The NUREGs were developed such that the Actions for a single support system inoperability would be addressed by that support system's Actions - without cascading to the supported system; even if both trains of the support system were inoperable resulting from a loss of function. This intent is clarified in the LCO 3.0.6 Bases. Without this clarification, supported systems with a single support system (such as both Containment Spray and ECCS trains supported by the Refueling Water Tank) would be declared inoperable when the support system is inoperable under the provisions of LCO 3.0.6 even though the support system Actions were designed to provide the appropriate response.
Also the NUREGs were developed with the appropriate "loss of function" (i.e., cross-train) check for electrical power inoperability contained within the LCO 3.8.1 Actions, without reliance on the SFDP. The NUREG Bases for LCO 3.8.1, Required Actions A.2 and B.2 (last paragraph in each) were added during development to attempt to clarify this issue. However, the actual requirements for the SFDP in Chapter 5.0 are sufficiently ambiguous to have resulted in misinterpretation. Therefore, clarification is added to the requirements for the SFDP, consistent with the intent of the NUREGs NRC Approval TSTF-273-A was approved by the NRC in a letter dated January 13, 1999. It was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-273-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-273-A has also been approved in at least three license amendments; for example Susquehanna on February 25, 2003 (ADAMS Accession Number ML030560811) and Palo Verde on October 15, 2001 (ADAMS Accession Number ML012880473).
List of Affected Specifications NUREG-1430, -1431, and -1431 5.5.15 Administrative Controls, Safety Function Determination Program NUREG-1433, and -1434 5.5.12 Administrative Controls, Safety Function Determination Program The following Bases are revised:
LCO 3.0.6 Bases, LCO Applicability
TSTF-507, Rev. 0 Traveler: TSTF-279-A, Revision 0, "Remove 'applicable supports' from Inservice Testing Program" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description The reference to the "applicable supports" was deleted from the description of the "Inservice Testing Program" contained in Section 5.5.
Summary of the Approved Traveler Justification The Inservice Testing Program (IST) provides controls for testing Code Class 1, 2 and 3 components. The discussion of the IST Program in Section 5.5 of the STS was revised by the NRC to include the "applicable supports" in February 1992 due to concerns related to the relocation of the snubber LCO from the ITS NUREGs. However, this is inappropriate; supports are addressed under the Inservice Inspection Program not the IST Program. Thus, the reference to the applicable supports in the IST Program description in Section 5.5 was deleted. ASME has developed OM-5 and other guidance to provide appropriate testing requirements for supports and snubbers.
NRC Approval TSTF-279-A was approved by the NRC in a letter dated July 16, 1998. It was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-279-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-279-A has also been approved in at least six license amendments; for example Watts Bar on December 18, 2006 (ADAMS Accession Number ML063190441) and Susquehanna on February 25, 2003 (ADAMS Accession Number ML030560811).
List of Affected Specifications NUREG-1430, -1431, and -1431 5.5.8 Administrative Controls, Inservice Testing Program NUREG-1433, and -1434 5.5.7 Administrative Controls, Inservice Testing Program
TSTF-507, Rev. 0 Traveler: TSTF-284-A, Revision 3, "Add 'Met vs. Perform' to Specification 1.4, Frequency" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description This Traveler inserts into Specification 1.4 a discussion paragraph and new example to facilitate the use and application of SR Notes that utilize "met" and "perform". Surveillances are revised as necessary to appropriately use "met" and "perform" exceptions.
Summary of the Approved Traveler Justification NUREG-1433 and 1434 contained a discussion in Specification 1.4 regarding the use of "met" and "performed" in SR Notes. Similarly, the Writer's Guide provides a distinction between these phrases. NUREG-1430, -1431, and -1432 did not contain this detail; however, various locations throughout these NUREGs provide Notes with "met" and "performed" distinctions. Inserting this Section 1.4 material will provide for better use, application, and understanding of these Notes. Furthermore, this change will establish consistency between the NUREGs. With this clarification, several exceptions that are unclear or have incorrect usage of "met" and "perform" are also corrected.
Examples of Surveillance Notes are added. The examples parallel the existing example 1.4-3 of Notes that allow for the SR to "Not required to be performed . . .". The examples will alleviate misunderstanding and provide explicit direction for these types of SR Notes.
NRC Approval TSTF-284-A was approved by the NRC on February 3, 1999. The NRC did not issue a letter approving TSTF-284-A, however it was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-284-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-284-A has also been approved in at least five license amendments; for example Duane Arnold Energy Center on May 12, 2005 (ADAMS Accession Number ML051320211) and Columbia on December 13, 2007 (ADAMS Accession Number ML073120268).
List of Affected Specifications NUREG-1430 1.4 Frequency SR 3.1.3.2 MTC SR 3.4.12.6 LTOP System SR 3.7.5.3 EFW System SR 3.7.5.4 EFW System SR 3.9.3.2 Containment Penetrations NUREG-1431 1.4 Frequency SR 3.1.11.1 SDM Test Exceptions SR 3.1.11.2 SDM Test Exceptions
TSTF-507, Rev. 0 SR 3.4.11.1 Pressurizer PORVs SR 3.4.11.2 Pressurizer PORVs SR 3.9.4.2 Containment Penetrations NUREG-1432 1.4 Frequency SR 3.1.4.1 MTC (Analog)
SR 3.1.4.1 MTC (Digital)
SR 3.1.4.2 MTC (Analog)
SR 3.1.4.2 MTC (Digital)
SR 3.1.7.1 Regulating CEA Insertion Limits (Analog)
SR 3.9.3.2 Containment Penetrations SR 3.1.7.1 Regulating CEA Insertion Limits (Digital)
SR 3.2.1.1 LHR (Analog)
SR 3.2.1.1 LHR (Digital)
SR 3.2.1.2 LHR (Analog)
SR 3.2.1.3 LHR (Analog)
SR 3.2.3.1 Tq (Digital)
SR 3.2.4.1 DNBR (Digital)
SR 3.2.4.2 DNBR (Digital)
SR 3.3.8.3 CPIS (Digital)
SR 3.3.8.4 CPIS (Digital)
SR 3.4.11.1 Pressurizer PORVs SR 3.4.11.2 Pressurizer PORVs SR 3.7.5.3 AFW System SR 3.7.5.3 AFW System SR 3.7.5.4 AFW System The following Bases are revised:
NUREG-1430 SR 3.1.3.2 Bases MTC SR 3.4.12.6 Bases LTOP System SR 3.7.5.3 Bases EFW System SR 3.7.5.4 Bases EFW System SR 3.9.4.2 Bases Containment Penetrations NUREG-1431 SR 3.1.11.2 Bases SDM Test Exceptions Action 3.4.11 Bases Pressurizer PORVs Ref. 3.4.11 Bases Pressurizer PORVs SR 3.4.11.1 Bases Pressurizer PORVs SR 3.4.11.2 Bases Pressurizer PORVs SR 3.9.4.2 Bases Containment Penetrations NUREG-1432 SR 3.1.4.1 Bases MTC (Analog)
TSTF-507, Rev. 0 SR 3.1.4.1 Bases MTC (Digital)
SR 3.1.4.2 Bases MTC (Analog)
SR 3.1.4.2 Bases MTC (Digital)
SR 3.9.4.2 Bases Containment Penetrations SR 3.1.7.1 Bases Regulating CEA Insertion Limits (Analog)
SR 3.1.7.1 Bases Regulating CEA Insertion Limits (Digital)
SR 3.2.1.1 Bases LHR (Analog)
SR 3.2.1.1 Bases LHR (Digital)
SR 3.2.1.2 Bases LHR (Analog)
SR 3.2.4.1 Bases DNBR (Digital)
SR 3.3.8.3 Bases CPIS (Digital)
SR 3.3.8.4 Bases CPIS (Digital)
Ref. 3.4.11 Bases Pressurizer PORVs SR 3.4.11.1 Bases Pressurizer PORVs SR 3.4.11.2 Bases Pressurizer PORVs SR 3.7.5.4 Bases AFW System NUREG-1433 & -1434 1.4 Frequency
TSTF-507, Rev. 0 Traveler: TSTF-299-A, Revision 3, "Administrative Controls Program 5.5.2.b Test Interval and Exception" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description Program 5.5.2, "Primary Coolant Sources Outside Containment," is revised to clarify the intent of refueling cycle intervals with respect to the system integrated leak test requirements (i.e., [18]
month intervals) and to add the following sentence, "The provisions of SR 3.0.2 are applicable."
Summary of the Approved Traveler Justification ISTS 5.5.2.b provides integrated leak test requirements for each system at refueling cycle intervals or less. ISTS 5.5.5.2.b is revised to require integrated leak test requirements for each system at [18] month intervals or less. ISTS 5.5.2.b is essentially a Surveillance Requirement.
Since normal "refueling cycle intervals" are 18 months, presenting the requirement in this manner achieves consistency with similar requirements in the ISTS. The ISTS Surveillance Requirements specify "[18] months" and not refueling cycle intervals for Surveillance performed at refueling intervals. This change also allows approved changes to ISTS 5.5.2.b associated with implementation of 24 month refueling cycles to be explicitly documented. As a result of explicitly stating the interval for the test, it will no longer be possible to account for shutdowns or power reductions that may occur during the cycle in order to satisfy the interval requirements for the tests required by ISTS 5.5.2 b, i.e., a refueling cycle may be longer than [18] months in order to achieve the required fuel burnup, but the testing of ISTS 5.5.2.b would be required to be performed once per [18] months. For consistency with normal Surveillance Requirements in the ISTS LCO Sections that allow a 25% extension of the Frequency in accordance with ISTS SR 3 0.2, ISTS 5.5.2.b is considered a Surveillance Requirement. ISTS 5.5.2 is revised to allow the provisions of ISTS SR 3 0 2 to be applicable to ISTS 5.5.2 b. The applicability of ISTS SR 3.0.2 must be explicitly stated in ISTS 5.5.2 since ISTS SR 3.0.2 only applies to the ISTS LCO Sections (i.e., ISTS LCO Sections 3.1 through 3.9 or 3.10).
NRC Approval TSTF-299-A was approved by the NRC in a letter dated October 31, 2000. It was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-299-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-299-A has also been approved in at least nine license amendments; for example Watts Bar on November 13, 2003 (ADAMS Accession Number ML033210231) and Susquehanna on February 25, 2003 (ADAMS Accession Number ML030560811).
List of Affected Specifications All NUREGs 5.5.2 Administrative Controls, Primary Coolant Sources Outside of Containment
TSTF-507, Rev. 0 Traveler: TSTF-308-A, Revision 1, "Determination of Cumulative and Projected Dose Contributions in RECP" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description Specification 5.5.4, "Radioactive Effluent Controls Program," paragraph e, is revised to clarify the intent of the dose projections. The proposed words are the same as the pre-Generic Letter 89-01 implementation.
Summary of the Approved Traveler Justification The NRC Staff's draft STS for 4-loop Westinghouse plants (8/14/87 letter to Texas Utilities) included Radioactive Effluent Technical Specifications. SR 4.11.1.2 for DOSE states, "Cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year shall be determined in accordance with the methodology and parameters in the ODCM at least once per 31 days." SR 4.11.1.3.1 for LIQUID RADWASTE TREATMENT SYSTEM states, "Doses due to liquid releases from each unit to UNRESTRICTED AREAS shall be projected at least once per 31 days in accordance with the methodology and parameters in the ODCM when Liquid Radwaste Treatment Systems are not being fully utilized."
Generic Letter 89-01 appears to have combined these two Surveillance Requirements for cumulative and projected doses. In combining these requirements in Generic Letter 89-01, the new program element can be interpreted to require determining projected dose contribution for the current calendar quarter and current calendar year every 31 days. Therefore, the proposed change clarifies the wording in 5.5.4.e to not require dose projections for a calendar quarter and a calendar year every 31 days.
NRC Approval TSTF-308-A was approved by the NRC on July 6, 2000. The NRC did not issue a letter approving TSTF-308-A, however it was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-308-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-308-A has also been approved in at least nine license amendments; for example Watts Bar on November 13, 2003 (ADAMS Accession Number ML033210231) and Susquehanna on February 25, 2003 (ADAMS Accession Number ML030560811).
List of Affected Specifications All NUREGs 5.5.4 Administrative Controls, Radioactive Effluent Controls Program
TSTF-507, Rev. 0 Traveler: TSTF-343-A, Revision 1, "Containment Structural Integrity" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 3 ISTS Version in Which the Traveler was Incorporated: 3.1 Description The proposed Traveler revises the "Pre-Stressed Containment Tendon Surveillance Program,"
the NUREG-1430, NUREG-1431, and NUREG-1432 "Containment Leakage Rate Testing Program," and the NUREG-1433 and NUREG-1434 "Primary Containment Leakage Rate Testing Program," for consistency with the requirements of 10 CFR 50.55a(g)(4) for components classified as Code Class CC. This regulation requires licensees to update their containment inservice inspection requirements in accordance with Subsections IWE and IWL of Section XI, Division I of the ASME Boiler and Pressure Vessel Code as limited by 10 CFR 50.55a(b)(2)(vi) and modified by 10 CFR 50.55a(b)(2)(viii) and 10 CFR50.55a(b)(2)(ix).
Summary of the Approved Traveler Justification Technical Specification 5.5.6, "Pre-Stressed Concrete Containment Tendon Surveillance Program," states in part, "The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with [Regulatory Guide 1.35, Revision 3, 1990]." As identified above, 10 CFR 50.55a(g)(4) requires licensees to update their containment inservice inspection requirements in accordance with Subsections IWE and IWL of Section XI, Division I of the ASME Boiler and Pressure Vessel Code as limited by 10 CFR 50.55a(b)(2)(vi) and modified by 10 CFR 50.55a(b)(2)(viii) and 10 CFR 50.55a(b)(2)(ix). The requirements in 10 CFR 50.55a(g)(4) and ASME Code Section XI, Subsection IWL, do not reference Regulatory Guide 1.35, Revision 3. As such, the ISTS are inconsistent with the requirements of 10 CFR 50.55a.
NRC Approval TSTF-308-A was approved by the NRC in a letter dated December 6, 2005. It was incorporated by the NRC into Revision 3.1 of the ISTS NUREGs. TSTF-308-A has been adopted by plants as part of complete conversion to the ISTS. TSTF-308-A has also been approved in at least nine license amendments; for example Diablo Canyon on June 26, 2007 (ADAMS Accession Number ML071370728) and Susquehanna on March 19, 2007 (ADAMS Accession Number ML070710224).
List of Affected Specifications NUREG-1430, 1431, 1432 5.5.6 Administrative Controls, Pre-Stressed Concrete Containment Tendon Surveillance Program 5.5.16, Containment Leakage Rate Testing Program NUREG-1433, 1434 5.5.6 Administrative Controls, Pre-Stressed Concrete Containment Tendon Surveillance Program
TSTF-507, Rev. 0 5.5.13, Primary Containment Leakage Rate Testing Program The following Bases are revised:
NUREG-1430, -1431, -1432 SR 3.6.1.1 Bases Containment SR 3.6.1.2 Bases Containment Ref. 3.6.1 Bases Containment NUREG-1433 SR 3.6.1.1.1 Bases Primary Containment NUREG-1434 SR 3.6.1.1.1 Bases Primary Containment Ref. 3.6.1.1 Bases Primary Containment SR 3.6.1.1.2 Bases Primary Containment
TSTF-507, Rev. 0 Traveler: TSTF-348-A, Revision 1, "Cancellation of NRC Environmental Monitoring Program with States" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description In press release no. 98-08, dated January 13, 1998, the NRC announced that it ended its contract with 34 states to perform radiation monitoring around certain facilities at the end of 1997. In section 5.6.2 of the NUREG, there is a statement in the Annual Radiological Environmental Operating Report that the TLD results that represent collocated dosimeters in relation to the NRC TLD Program and the exposure period associated with each result be included in the report. The TLD Program that the NUREG references is the same program that the NRC cancelled at the end of 1997.
Summary of the Approved Traveler Justification In press release no. 98-08, dated January 13, 1998, the NRC announced that it ended its contract with 34 states to perform radiation monitoring around certain facilities at the end of 1997. There is no longer a need to reference this program.
NRC Approval TSTF-348-A was approved by the NRC in a letter dated November 1, 1999. It was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-348-A has been adopted by many plants as part of complete conversion to the ISTS. TSTF-348-A has also been approved in at least two license amendments; for example Calvert Cliffs on July 16, 2003 (ADAMS Accession Number ML031330142) and Susquehanna on February 25, 2003 (ADAMS Accession Number ML030560811).
List of Affected Specifications All NUREGs 5.6.2 Administrative Controls, Annual Radiological Environmental Operating Report
TSTF-507, Rev. 0 Traveler: TSTF-362-A, Revision 0, "Change to the VFTP in ITS Section 5.0 in accordance with GL 99-02" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description Generic Letter 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, was issued on June 3, 1999. A primary change identified in GL 99-02 was the specification of ASTM D3803-1989 for charcoal filter laboratory testing. The ISTS NUREGs already identified this particular ASTM standard, however, the GL also allows the use of a different safety factor than that currently in the ISTS. The allowed safety factor is identified in the existing Reviewers Note of ITS 5.511 which is being replaced with the Reviewers Note contained in GL 99-02, attachment
- 2. The change in safety factor results in a change to the penetration values specified in TS 5.5.11.
The Bases of various Specifications are revised to eliminate statements that the filter testing is performed in accordance with Regulatory Guide 1.52. Under this change, filter testing is performed in accordance with the ATSM standard. When necessary, references are renumbered to accommodate this change. In addition, references to Regulatory Guide 1.52 are revised to be consistent.
Summary of the Approved Traveler Justification The Traveler reflects the changes identified in GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, issued on June 3, 1999. In previous testing standards, it was erroneously assumed that the high temperature/high relative humidity provided the most severe test conditions. Later with more testing experience, it was determined that the most conservative testing of charcoal is at low temperature/high humidity. The NRC position in GL 99-02 is that testing to a standard other than ASTM D3803-1989 may result in an overestimation of the capability of the charcoal to adsorb radiation due to a lack of proper control of testing conditions (humidity and temperature). Since testing charcoal per ASTM D3803-1989 will yield more accurate results that better characterize the carbons ability to absorb radioactive gases, the use of a lower safety factor is allowed.
NRC Approval TSTF-362-A was approved by the NRC in a letter dated October 31, 2000. It was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-362-A has been adopted by plants as part of complete conversion to the ISTS.
List of Affected Specifications All NUREGs 5.6.11 Administrative Controls, Ventilation Filter Testing Program The following Bases are revised:
NUREG-1430 SR 3.7.10.2 Bases CREVS
TSTF-507, Rev. 0 Ref. 3.7.12 Bases EVS SR 3.7.12.2 Bases EVS Ref. 3.7.13 Bases FSPVS SR 3.7.13.2 Bases FSPVS NUREG-1431 SR 3.6.11.2 Bases ICS (Atmospheric and Subatmospheric)
SR 3.6.13.2 Bases SBACS (Dual and Ice Condenser)
SR 3.7.10.2 Bases CREFS SR 3.7.12.2 Bases ECCS PREACS SR 3.7.13.2 Bases FBACS SR 3.7.14.2 Bases PREACS NUREG-1432 Ref. 3.6.10 Bases ICS (Atmospheric and Dual)
SR 3.6.10.2 Bases ICS (Atmospherics and Dual)
Ref. 3.6.11 Bases Shield Building (Dual)
Ref. 3.6.13 Bases SBEACS (Dual)
SR 3.6.13.2 Bases SBEACS (Dual)
SR 3.7.11.2 Bases CREACS SR 3.7.13.2 Bases ECCS PREACS Ref. 3.7.14 Bases FBACS SR 3.7.14.2 Bases FBACS Ref. 3.7.15 Bases PREACS NUREG-1433 Ref. 3.6.4.3 Bases SGT System SR 3.6.4.3.s Bases SGT System SR 3.7.4.2 Bases [MCREC] System NUREG-1433 SR 3.6.4 Bases SGT System SR 3.6.4.2 Bases SGT System Ref. 3.7.3 Bases [CRFA] System SR 3.7.3.2 Bases [CRFA] System
TSTF-507, Rev. 0 Traveler: TSTF-363-A, Revision 0, "Revise Topical Report references in ITS 5.6.5, COLR" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description The requirement in ITS 5.6.5, Core Operating Limits Report (COLR), to identify the Topical Report(s) by number, title, date, and NRC staff approval document is revised to allow the Topical Reports to be identified by number and title. A requirement is added to specify the complete citation in the COLR, including the Topical Report number, title, revision, date, and any supplements.
Summary of the Approved Traveler Justification In a letter from Mr. Stuart A. Richards (NRC) to Mr. James F. Mallay (Siemens Power Corporation) dated December 15, 1999, entitled "Acceptance for Siemens References to Approved Topical Reports in Technical Specifications," the NRC stated that it is acceptable for the references to Topical Reports in ITS Section 5.6.5, COLR, to give the Topical Report title and number as long as the complete citation is given in the COLR.
As stated in the letter, this method of referencing topical reports would allow licensees to use current topical reports to support limits in the COLR without having to submit an amendment to the facility operating license every time the topical report is revised. The COLR would provide specific information identifying the particular approved topical reports used to determine the core limits for the particular cycle in the COLR report. This would eliminate unnecessary expenditure of NRC and licensee resources, and would ease the burden of TS submittal and approval needed to license reload fuel.
NRC Approval TSTF-363-A was approved by the NRC on April 13, 2000. It was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-363-A has been adopted by plants as part of complete conversion to the ISTS. TSTF-363-A has also been approved in at least twenty eight license amendments; for example Columbia Generating Station on May 12, 2003 (ADAMS Accession Number ML031350003) and Callaway on April 2, 2007 (ADAMS Accession Number ML070600786).
List of Affected Specifications NUREG-1430, -1431, -1432, -1433, -1434 5.6.5 Administrative Controls, Core Operating Limits Report (COLR)
TSTF-507, Rev. 0 Traveler: TSTF-364-A, Revision 0, "Revision to TS Bases Control Program to Incorporate Changes to 10 CFR 50.59" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 1 ISTS Version in Which the Traveler was Incorporated: 2 Description The Technical Specifications (TS) Bases Control Program requires a program for processing changes to the Bases of the Technical Specifications. Paragraph b. states, "Licensees may make changes to the Bases without prior NRC approval provided the changes do not involve either of the following: 1. a change in the TS incorporated in the license; or 2. a change to the updated FSAR or Bases that involves an unreviewed safety question as defined in 10 CFR 50.59."
Paragraph b.2 is revised to state: "a change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59."
Summary of the Approved Traveler Justification The NRC amended its regulations concerning the authority for licensees of production or utilization facilities, such as nuclear reactors, and independent spent fuel storage facilities, and for certificate holders for spent fuel storage casks, to make changes to the facility or procedures, or to conduct tests or experiments, without prior NRC approval. The final rule clarifies the specific types of changes, tests, and experiments conducted at a licensed facility or by a certificate holder that require evaluation, and revises the criteria that licensees and certificate holders must use to determine when NRC approval is needed before such changes, tests, or experiments can be implemented. The final rule also adds definitions for terms that have been subject to differing interpretations , and reorganizes the rule language for clarity.
As indicated above, the Technical Specification Bases Control Program allows licensees to make changes to the Bases without NRC approval provided the change does not involve a change to the updated FSAR or Bases that involves an unreviewed safety question as defined in 10 CFR 50.59. With the revisions to 10 CFR 50.59, the definition of unreviewed safety question was eliminated. Therefore, the TS should be revised consistent with the revision to 10 CFR 50.59.
NRC Approval TSTF-364-A was approved by the NRC on June 16, 2000 and subsequently approved an editorial change, indicated as WOG-ED-24. It was incorporated by the NRC into Revision 2 of the ISTS NUREGs. TSTF-364-A has been adopted by plants as part of complete conversion to the ISTS. TSTF-364-A has also been approved in at least twenty three license amendments; for example Watts Bar on June 15, 2001 (ADAMS Accession Number ML011630323) and Perry on February 21, 2002 (ADAMS Accession Number ML020100004).
List of Affected Specifications NUREG-1430, -1431, -1432 5.6.14 Administrative Controls, Technical Specifications (TS) Bases Control Program
TSTF-507, Rev. 0 NUREG-1433, -1434 5.6.11 Administrative Controls, Technical Specifications (TS) Bases Control Program
TSTF-507, Rev. 0 Traveler: TSTF-419-A, Revision 0, "Revise PTLR Definition and References in ISTS 5.6.6, RCS PTLR" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 2 ISTS Version in Which the Traveler was Incorporated: 3 Description The definition of PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) is revised to delete the reference to the Specifications containing the limits specified in the PTLR.
The requirement in ITS 5.6.6, "Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)," to identify the NRC staff approval document by date is revised to allow the Topical Report(s) to be identified by number and title. A requirement is added to the Reviewers Note to specify the complete citation in the PTLR for each Topical Report, including the report number, title, revision, date, and any supplement.
Similar changes to NUREG-1432 are addressed in TSTF-408.
Summary of the Approved Traveler Justification NRC Generic Letter 96-06, "Relocation of the Pressure Temperature Limit Curves and Low Temperature Overpressure Protection System Limits," dated January 31, 1996, allows licensees to relocate the pressure temperature (P/T) limit curves from their plant technical specifications (TS) to a pressure temperature limits report (PTLR) or a similar document. The Low Temperature Overpressure Protection (LTOP) System limits were also allowed to be relocated to the same document. The methodology used to determine the P/T and LTOP System limit parameters must comply with the specific requirements of Appendices G and H to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR), be documented in an NRC approved topical report or in a plant-specific submittal, and be incorporated by reference into the TS. Subsequent changes in the methodology must be approved by a license amendment.
The definition of PTLR identifies the specifications in which the pressure and temperature limits are addressed. Specification 5.6.6a. requires that the individual specifications that address RCS pressure and temperature limits be referenced. The proposed changes to the definition eliminate duplication between the definition of PTLR and Section 5.6.6.
The revision to ITS 5.6.6 to allow the Topical Reports to be identified by number and title would allow licensees to use current Topical Reports to support limits in the PTLR without having to submit an amendment to facility operating license every time the Topical Report is revised. The PTLR would provide specific information identifying the particular approved Topical Reports used to determine the P/T limits or LTOP System limits. This still provides the assurance that only the approved versions of the referenced Topical Reports will be used for the determination of the P/T limits or LTOP System limits since the complete citation will be provided in the PTLR. This proposed change is consistent with TSTF-363, "Revise Topical Report references in ITS 5.6.5,
TSTF-507, Rev. 0 COLR," which was approved by the NRC on April 13, 2000.
NRC Approval TSTF-419-A was approved by the NRC in a letter dated March 21, 2002, which included a generic Safety Evaluation, and was incorporated by the NRC into Revision 3 of the ISTS NUREGs. TSTF-419-A has been adopted by plants as part of complete conversion to the ISTS. TSTF-419-A has also been approved in at least nine license amendments; for example Comanche Peak on February 22, 2007 (ADAMS Accession Number ML070320823) and Byron on November 27, 2006 (ADAMS Accession Number ML062610512).
List of Affected Specifications NUREG-1430, -1431, -1433, -1434 1.0, Definitions, Pressure and Temperature Limits Report (PTLR) 5.6.6 Administrative Controls, Pressure and Temperature Limits report (PTLR)
TSTF-507, Rev. 0 Traveler: TSTF-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 3 ISTS Version in Which the Traveler was Incorporated: 3.1 Description In the Improved Standard Technical Specifications (NUREGs 1430 through 1434) (ISTS) a second Completion Time was included for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that result in a single continuous failure to meet the LCO. These Completion Times (henceforth referred to as "second Completion Times") are joined by an "AND" logical connector to the Condition-specific Completion Time and state "X days from discovery of failure to meet the LCO" (where "X" varies by specification). The intent of the second Completion Time was to preclude entry into and out of the ACTIONS for an indefinite period of time without meeting the LCO by providing a limit on the amount of time that the LCO could not be met for various combinations of Conditions.
The proposed Traveler deletes these second Completion Times from the affected Required Actions. It also revises ISTS Example 1.3-3 to remove the second Completion Times and to revise the discussion in that Example to state that alternating between Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCO is inconsistent with the basis of the Completion Times and is inappropriate. Therefore, the licensee shall have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO is not inappropriately extended.
Summary of the Approved Traveler Justification The adoption of a second Completion Time was based on an NRC concern that a plant could continue to operate indefinitely with an LCO governing safety significant systems never being met by alternately meeting the requirements of separate Conditions. In 1991, the NRC could not identify any regulatory requirement or program which could prevent this misuse of the Technical Specifications. However, that is no longer the case. There are now two programs which would provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent, the Maintenance Rule (10 CFR 50.65 (a)(1)), and the Reactor Oversight Process.
NRC Approval TSTF-439-A was approved by the NRC on January 11, 2006. It was incorporated by the NRC into Revision 3.1 of the ISTS NUREGs. TSTF-439-A has been adopted by plants as part of complete conversion to the ISTS. TSTF-439-A has also been approved in at least four license
TSTF-507, Rev. 0 amendments; for example Crystal River on October 21, 2004 (ADAMS Accession Number ML042880048) and Fermi on August 1, 2007 (ADAMS Accession Number ML071830114).
List of Affected Specifications All NUREGs 1.3, Completion Times Action 3.8.1.A AC Sources - Operating Action 3.8.1.B AC Sources - Operating Action 3.8.9.A Distribution Systems - Operating Action 3.8.9.B Distribution Systems - Operating Action 3.8.9.C Distribution Systems - Operating NUREG-1430 Action 3.6.6.A Containment Spray and Cooling Systems Action 3.6.6.C Containment Spray and Cooling Systems Action 3.7.5.A EFW System Action 3.7.5.B EFW System Action 3.6.6.A Bases Containment Spray and Cooling Systems Action 3.6.6.C Bases Containment Spray and Cooling Systems Action 3.7.5.A Bases EFW System Action 3.7.5.B Bases EFW System NUREG-1431, -1432 Action 3.6.6B.A Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.6.6A.A Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.6.6B.B Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.6.6A.C Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.7.5.A AFW System Action 3.7.5.B AFW System Action 3.6.6A.A Bases Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.6.6B.A Bases Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.6.6B.B Bases Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.6.6A.C Bases Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.7.5.A Bases AFW System Action 3.7.5.B Bases AFW System NUREG(s)- 1431 1432 NUREG-1433, -1434 Action 3.1.7.A SLC System Action 3.1.7.B SLC System
TSTF-507, Rev. 0 Action 3.1.7.A Bases SLC System Action 3.1.7.B Bases SLC System The following Bases are revised:
All NUREGs Action 3.8.1.A Bases AC Sources - Operating Action 3.8.1.B Bases AC Sources - Operating Action 3.8.9.A Bases Distribution Systems - Operating Action 3.8.9.B Bases Distribution Systems - Operating Action 3.8.9.C Bases Distribution Systems - Operating NUREG-1430 Action 3.6.6.A Bases Containment Spray and Cooling Systems Action 3.6.6.C Bases Containment Spray and Cooling Systems Action 3.7.5.A Bases EFW System Action 3.7.5.B Bases EFW System NUREG-1431, -1432 Action 3.6.6A.A Bases Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.6.6B.A Bases Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.6.6B.B Bases Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.6.6A.C Bases Containment Spray and Cooling Systems (Atmospheric and Dual)
Action 3.7.5.A Bases AFW System Action 3.7.5.B Bases AFW System NUREG(s)- 1431 1432 NUREG-1433, -1434 Action 3.1.7.A Bases SLC System Action 3.1.7.B Bases SLC System
TSTF-507, Rev. 0 Traveler: TSTF-471-A, Revision 1, "Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE)
ISTS Version Revised by the Traveler: 3 ISTS Version in Which the Traveler was Incorporated: Not Yet Incorporated Description In the PWR ITS NUREGs (NUREG-1430-1432), the defined term CORE ALTERATIONS appears in the Required Actions and Surveillance Notes of less than 10 specifications. It is not used in any Applicability statements. Suspending CORE ALTERATIONS or exempting testing except during CORE ALTERATIONS has no effect on the initial conditions or mitigation of any Design Basis Accident (DBA) or transient, and these requirements apply an operational burden with no corresponding safety benefit. Therefore, the uses of the defined term CORE ALTERATIONS are removed from the Technical Specifications.
Summary of the Approved Traveler Justification The term "core alteration" does not appear in the Standard Review Plan or in Title 10 of the Code of Federal Regulations. Since CORE ALTERATIONS only occur when the reactor vessel head is removed, it only applies in MODE 6. There are only two accidents considered during MODE 6 for PWRs: a fuel handling accident and a boron dilution accident. According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of a [recently] irradiated fuel assembly, either in the containment or in the fuel building. There are no mitigation actions, except some plants credit ventilation systems to reduce the dose consequences. Suspension of CORE ALTERATIONS, except for suspension of movement of [recently] irradiated fuel, will not prevent or impair the mitigation of a fuel handling accident.
The second analyzed event is a boron dilution accident. A boron dilution accident is initiated by a dilution source which results in the boron concentration dropping below that required to maintain the SHUTDOWN MARGIN. As described in the Bases of Specification 3.9.1, "Boron Concentration,"
(which applies in MODE 6), "The refueling boron concentration limit is specified in the COLR. Unit procedures ensure the specified boron concentration in order to maintain an overall core reactivity of keff 0.95 during fuel handling, with control element assemblies (CEAs) and fuel assemblies assumed to be in the most adverse configuration (least negative reactivity) allowed by unit procedures." The accident is mitigated by stopping the dilution. Suspension of CORE ALTERATIONS has no effect on the mitigation of a boron dilution accident. Movement of control rods or fuel do not affect the initial conditions of a boron dilution accident as it is assumed that the control rods and fuel are in the most adverse conditions with a large safety margin (keff 0.95). To address the possibility of a misloaded fuel assembly in Technical Specification 3.9.2, a Required Action is added that suspends positive reactivity additions if nuclear instrumentation is not available.
This precludes movement of fuel assemblies which could add reactivity to the core.
In summary, with the exception of suspending movement of [recently] irradiated fuel assemblies, there are no design basis accidents or transients that are initiated by, or mitigation affected by, suspension of CORE ALTERATIONS. Therefore, if all Required Actions that require suspension of
TSTF-507, Rev. 0 CORE ALTERATIONS also require suspension of movement of [recently] irradiated fuel, suspension of CORE ALTERATIONS provides no safety benefit.
NRC Approval TSTF-471-A was approved by the NRC in a letter dated December 7, 2006, which included a generic Safety Evaluation. TSTF-471-A has been approved in at least two license amendments; for example Calvert Cliffs on September 21, 2006 (ADAMS Accession Number ML062350447) and Point Beach on February 15, 2007 (ADAMS Accession Number ML063450067).
List of Affected Specifications NUREG-1430, 1431, and 1432 3.8.2, A.C. Sources - Shutdown 3.8.5, D.C. Sources - Shutdown 3.8.8, Inverters - Shutdown 3.8.10, Distribution Systems - Shutdown 3.9.1, Boron Concentration 3.9.2 or 3.9.3, Nuclear Instrumentation NUREG-1431 3.9.2, Unborated Water Source Isolation Valves NUREG-1432 SR 3.3.8.4, CPIS (Digital)NUREG-1430, -1431, -1432, -1433, -1434
TSTF-507, Rev. 0 Traveler: TSTF-475-A, Revision 1, "Control Rod Notch Testing Frequency and SRM Insert Control Rod Action" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 3 ISTS Version in Which the Traveler was Incorporated: Not yet incorporated Description TSTF-475-A contains a BWR-specific change to control rod notch testing frequency and an SRM inert control rod action. TSTF-475-A also included a change applicable to all ISTS NUREGs. Example 1.4-3 in Section 1.4 "Frequency", is revised to make it clear that the 25%
extension allowed by SR 3.0.2 may be applied to the 31 day period in the SR 3.1.3.2 NOTE in the "SURVEILLANCE" column, just like it is applied to the 31 day period in the SR 3.1.3.2 "FREQUENCY" column. Discussions with the NRC in 1997 clarified that the above is true, and led to the cancellation of BWROG-36, since the BWROG-36 changes were determined to not be necessary. This change to Example 1.4-3 documents the results of those discussions.
The proposed change for this Traveler only includes the change to Example 1.4-3 and not the BWR technical changes in TSTF-475-A.
Summary of the Approved Traveler Justification The change to Example 1.4-3 in Section 1.4 "Frequency", makes it clear that the 1.25 provision in SR 3.0.2 is equally applicable to time periods specified in the "FREQUENCY" column and in NOTEs in the "SURVEILLANCE" column. This change to Example 1.4-3 is linked to TSTF-475 since the newly re-numbered SR 3.1.3.2 contains a 31 day time period in both the "SURVEILLANCE" column and in the "FREQUENCY" column - and the revised Example makes it clear that the 1.25 provision is equally applicable to both of these 31 day periods in SR 3.1.3.2. This is a "consistency" change, being made to be consistent with the definition of "specified Frequency" provided in the second paragraph of Section 1.4. This paragraph states:
"The 'specified Frequency' is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Surveillance column that modify performance requirements."
As made clear in the second sentence above, the "specified Frequency" includes time periods discussed in Notes in the "Surveillance" column, in addition to time periods listed in the "Frequency" column. Therefore, the provisions of SR 3.0.2 (which permit a 25% grace period to facilitate surveillance scheduling and avoid plant operating conditions that may not be suitable for conducting the test) also apply to the time periods listed in Notes in the "SURVEILLANCE" column. This is because SR 3.0.2 states that "The specified Frequency (emphasis added) for each SR is met if the Surveillance is performed within 1.25 times the interval specified".
Therefore, Example 1.4-3 is revised to be consistent with the above statements. The Example currently explicitly recognizes that the 25% extension allowed by SR 3.0.2 is applicable to the time period listed in the "FREQUENCY" column, but it does not explicitly recognize that the SR
TSTF-507, Rev. 0 3.0.2 extension is applicable to the time period listed in the NOTE in the "SURVEILLANCE" column. The change to the Example provides this explicit recognition by copying the phrase
"(plus the extension allowed by SR 3.0.2)" in two additional portions of the discussion for this Example.
NRC Approval The TSTF-475-A Notice for Comment was published by the NRC in the Federal Register on November 13, 2007.
List of Affected Specifications All NUREGs 1.4, Frequency
TSTF-507, Rev. 0 Traveler: TSTF-479-A, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a" and TSTF-497-A, Revision 0, " Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: TSTF-479-A modified Revision 3 TSTF-497-A modified Revision 3.1 ISTS Version in Which the Traveler was Incorporated: TSTF-479-A was incorporated into Revision 3 TSTF-497-A has not yet been incorporated Description TSTF-479-A revises the improved Standard Technical Specification (ISTS) Administrative Controls, "Inservice Testing Program," for consistency with the requirements of 10 CFR 50.55a(f)(4) for pumps and valves which are classified as American Society of Mechanical Engineers (ASME) Code Class 1, Class 2 and Class 3.
TSTF-497-A is an administrative change to the ISTS NUREGs to revise paragraph b of the Inservice Testing Program in the ISTS to state, "The provisions of SR 3.0.2 are applicable to the above required Frequencies and to other normal and accelerated Frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities."
Summary of the Approved Traveler Justification The purposes of the Inservice Testing Programs are to assess the operational readiness of pumps and valves, to detect degradation that might affect component OPERABILITY, and to maintain safety margins with provisions for increased surveillance and corrective action. NRC regulation, 10 CFR 50.55a, defines the requirements for applying industry codes to each licensed nuclear powered facility. Licensees are required by 10 CFR 50.55a(f)(4)(i) to initially prepare programs to perform inservice testing of certain ASME Section III, Code Class 1, 2, and 3 pumps and valves during the initial 120-month interval. The regulations require that programs be developed utilizing the latest edition and addenda incorporated into paragraph (b) of 10 CFR 50.55a on the date 12 months prior to the date of issuance of the operating license subject to the limitations and modification identified in paragraph (b).
NRC regulations also require that the Inservice Testing Programs be revised during successive 120-month intervals to comply with the latest edition and addenda of the Code incorporated by reference in paragraph (b) 12 months prior to the start of the interval.
Section XI of the ASME Codes has been revised on a continuing basis over the years to provide updated requirements for the inservice inspection and inservice testing of components. Until 1990, the ASME Code requirements addressing the IST of pumps and valves were contained in Section XI, Subsections IWP (pumps) and IWV (valves). In 1990, the ASME published the initial edition of the OM Code that provides the rules for the inservice testing of pumps and valves. Since the establishment of the 1990 Edition of the OM Code, the rules for the inservice
TSTF-507, Rev. 0 testing of pumps are no longer being updated in Section XI. As identified in NRC SECY-99-017 dated January 13, 1999, the NRC has generally considered the evolution of the ASME Code to result in a net improvement in the measures for inspecting piping and components and testing pumps and valves.
The Technical Specification Inservice Testing Program is revised to indicate that the provisions of SR 3.0.2 are applicable to other IST Frequencies that are not specified in the Program. The Inservice Test Program may have Frequencies for testing that are based on risk and do not conform to the standard testing Frequencies specified in the Technical Specifications. For example, an Inservice Testing Program may use ASME Code Case OMN-1, "Alternative Rules for Preservice and Inservice Testing of Certain Electric Motor-Operated Valve Assemblies in Light-Water Reactor Plants," in lieu of stroke time testing. The Frequency of the Surveillance may be determined through a mix of risk informed and performance based means in accordance with the Inservice Testing Program. This is consistent with the guidance in NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants," which indicates that the 25%
extension of the interval specified in the Frequency would apply to increased frequencies the same what that it applies to regular frequencies. If a test interval is specified in 10 CFR 50.55a, the TS SR 3.0.2 Bases indicates that the requirements of the regulation take precedence over the TS.
At the February 23, 2006 meeting between the NRC and the TSTF, members of the Component Branch of the NRC stated that TSTF-479 did not provide an adequate justification for applying SR 3.0.2 to Frequencies specified in the Inservice Testing Program as greater than 2 years and the NRC would not approve plant-specific amendments based on TSTF-479 incorporating this change without further justification. After consideration, the TSTF declined to develop a technical justification for applying SR 3.0.2 to IST Frequencies specified as greater than 2 years at this time due to inadequate cost benefit. Therefore, TSTF-497-A is an administrative change to the ISTS NUREGs which modifies the Inservice Testing Program, paragraph b, to remove the provisions that were not deemed by the NRC to be adequately justified in TSTF-479.
NRC Approval TSTF-479-A was approved by the NRC in a letter dated December 6, 2005. TSTF-497-A was approved by the NRC in a letter dated on October 4, 2006. TSTF-479-A has also been approved in at least ten license amendments; for example Columbia on December 13, 2007 (ADAMS Accession Number ML073120268) and Wolf Creek on November 15, 2006 (ADAMS Accession Number ML062980230). TSTF-497-A has been approved in at least four license amendments; for example Columbia on December 13, 2007 (ADAMS Accession Number ML073120268) and Comanche Peak on December 4, 2007 (ADAMS Accession Number ML073110162).
List of Affected Specifications NUREG-1430, -1431, -1432 5.5.8, Administrative Controls, Inservice Testing Program NUREG-1433, -1434 5.5.7, Administrative Controls, Inservice Testing Program
TSTF-507, Rev. 0 Traveler: TSTF-485-A, Revision 0, "Correct Example 1.4-1" Affected ISTS NUREGs: 1430 (B&W), 1431 (W), 1432 (CE), 1433 (BWR/4), 1434 (BWR/6)
ISTS Version Revised by the Traveler: 3 ISTS Version in Which the Traveler was Incorporated: Not yet incorporated 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. 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.
Summary of the Approved Traveler Justification 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.
TSTF-507, Rev. 0 NRC Approval TSTF-485-A was approved by the NRC on December 5, 2005. TSTF-439-A has been adopted by plants as part of complete conversion to the ISTS. TSTF-485-A has also been approved in at least six license amendments; for example River Bend on December 6, 2007 (ADAMS Accession Number ML072490028) and Palo Verde on February 21, 2007 (ADAMS Accession Number ML070350039).
List of Affected Specifications All NUREGs 1.4, Frequency
TSTF-507, Rev. 0 Enclosure Incorporated Previously NRC-Approved Travelers