TSTF-12-10, Comment (1) of the Technical Specifications Task Force on the Federal Register Notice Regarding TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month
| ML12115A305 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 04/23/2012 |
| From: | Browning R, Croft W, Steelman W, Stringfellow N Technical Specifications Task Force |
| To: | Cindy Bladey Rulemaking, Directives, and Editing Branch |
| References | |
| 77FR16869 00001, NRC-2012-0071, TSTF-12-10, TSTF-522, Rev 0 | |
| Download: ML12115A305 (5) | |
Text
TECHNICAL SPECIFICATIONS T-ASK FORCE TSTF A JONVT 0"W'VERS GR OUP A. CT! VITY April 23, 2012 3/c 4_/ .) TSTF-12-10 PROJ0753 0/
Cindy Bladey °...*
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Chief, Rules, Announcements, and Directives Branch (RADB) ] -j I-*-
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Office of Administration Mail Stop: TWB-05-BOIM U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
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SUBJECT:
Technical Specification Task Force (TSTF) Response to the Marchi-2, 2012 CIO Federal Register Notice, "Proposed Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-522, Revision 0, 'Revise Ventilation System Surveillance Requirements To Operate for 10 Hours per Month',"
Docket ID NRC-2012-0071 Enclosed for NRC consideration are comments prepared by the Technical Specification Task Force (TSTF) on the subject Federal Register Notice regarding TSTF-522, Revision 0, "'Revise Ventilation System Surveillance Requirements To Operate for 10 Hours per Month."
Should you have any questions, please do not hesitate to contact us.
J. Stringfellowv(PWROG/W) Roy A. Browning (BWROG)
Wl J. t a WE William J. Steelman (PWROG/CE) Wendy E. (PWROG/B&W)
Enclosure cc: Robert Elliott, Technical Specifications Branch, NRC Michelle Honcharik, Licensing Processes Branch, NRC 11921 Rockville Pike, Suite 100, Rockville, MD 2085: PWROG BW Phone: 301-984-4400, Fax: 301-984-7600 .~OWNERS-GROUP Administration by EXCEL Services Corporation
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Technical Specification Task Force (TSTF) Response to the March 22, 2012 Federal Register Notice, "Proposed Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-522, Revision 0, 'Revise Ventilation System Surveillance Requirements To Operate for 10 Hours per Month'," Docket ID NRC-2012-0071
- 1. In Section 1.0, "Introduction," Section 2.0, "Regulatory Evaluation," and Section 3.0, "Technical Evaluation," the model Safety Evaluation refers to performing the subject Surveillance Requirement every 31 days. Note that the proposed change does not alter the frequency of performance, only the testing required to be performed at that frequency.
On July 6, 2009, the NRC approved TSTF-425, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b." This Traveler relocated periodic Surveillance Frequencies to licensee control, including the 31 day Frequency of the subject Surveillance Requirements. Nearly half of licensees have adopted this change.
We recommend that the model safety evaluation be revised to refer to "[every 31 days] / [at a frequency controlled in accordance with the Surveillance Frequency Control Program]" in all locations, as illustrated in the markups in Comment 2 below. The NRC reviewer may select the phrase which describes the plant Technical Specification requirements.
- 2. The proposed change in TSTF-522 revises the subject Surveillance Requirements to state, "Operate each [train or subsystem] > 15 minutes [with heaters operating.]" The brackets around the phrase "with heaters operating" indicates that it is plant-specific.
As discussed in Section 4.0, "Technical Analysis," of the justification for TSTF-522, the bracketing of the phrase "with heaters operating" reflects Regulatory Position 4.9 of Regulatory Guide 1.52, Revision 3, "Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants." This regulatory position states that licensees may either install electric heaters and test representative samples of activated carbon at a relative humidity of 70%, or they may test representative samples of activated carbon at a relative humidity of 95% and not install or credit electric heaters.
As stated in the justification, "Plants which test ventilation system adsorption at a relative humidity of 95% do not require heaters for the ventilation system to perform its specified safety function consistent with Regulatory Position 4.9, given above. These plants may eliminate the reference to heaters in the
Technical Specification Task Force (TSTF) Response to the March 22, 2012 Federal Register Notice, "Proposed Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-522, Revision 0, 'Revise Ventilation System Surveillance Requirements To Operate for 10 Hours per Month'," Docket ID NRC-2012-0071 Surveillance Requirements and Bases. These plants may also subsequently pursue elimination of the heaters from the plant design under 10 CFR 50.59."
The relative humidity at which representative samples of activated carbon are tested is described in Paragraph c of the Ventilation Filter Testing Program in Section 5.5 of the Technical Specifications. Therefore, some Surveillances may contain the phrase "with heaters operating" and some may not, depending on the relative humidity, specified in the Ventilation Filter Testing Program, used during the activated carbon testing.
In addition, in many locations the model Safety Evaluation misstates the requirement to operate the system as a requirement to operate the heaters.
We recommend the following changes to the model Safety Evaluation.
Additions are in italics; deletions are struck through.
" Section 1.0, "Introduction," second paragraph:
The proposed change would revise Surveillance Requirements (SRs) which currently require operating the heaters-i ventilation systems for at least [10 continuous hours] with the heaters operatingevei.-y31.-day[every 31 days] /
[at afrequency controlledin accordancewith the Surveillance Frequency Control Program]. The SRs would be changed to require at least 15 continuous minutes of ventilation system heater operation [with the heaters operating]evei:y-3 -days [every 31 days] /[at afr-equency controlledin accordancewith the Surveillance Frequency Control Program].
" Section 1.0, "Introduction," fourth through seventh paragraphs:
In particular SRs [varies by paragraph] , which currently require operating the heaterin t respective systems for at least 10 continuous hours with heaters operatingevei=y 34ay-s [every 31 days] /[at afrequency controlled in accordancewith the Surveillance Frequency ControlProgram],would be changed to require at least 15 continuous minutes of ventilation system heater operation [with heaters operating]every d [every 31 days] / [at afrequency controlledin accordancewith the Surveillance Frequency Control Program].
Technical Specification Task Force (TSTF) Response to the March 22, 2012 Federal Register Notice, "Proposed Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-522, Revision 0, 'Revise Ventilation System Surveillance Requirements To Operate for 10 Hours per Month'," Docket ID NRC-2012-0071
" Section 2.0, "Regulatory Evaluation," second paragraph:
Current testing requirements for the air filtration and adsorption systems state that heaters-i the systems should be operated for at least 10 continuous hours with heaters operatingeeiy--34-days [every 31 days] /[at afrequency controlledin accordancewith the Surveillance Frequency Control Program]. These requirements are based on outdated NRC staff guidance for testing air filtration and adsorption systems. New NRC staff guidance states at least 15 continuous minutes of ventilation system heate operation with heaters operatinge.eiz-31-.days is acceptable for those plants that test ventilation system adsorption at a relative humidity of less than 95% Plants that test ventilation system adsorption at a relative humidity of 95% do not require heaters for the ventilation system to perform its specified safety function and the bracketedphrase "with heaters operating"is not included in the Surveillance Requirements.
" Section 3.0, "Technical Evaluation," third paragraph:
RG 1.52, Revision 3, Regulatory Position 6.1 states, "Each ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with the heaters on (if so equipped), to justify the operability of the system and all its components." The licensee stated that operating the train heati*ige*1e.e.. for 15 minutes is sufficient to demonstrate the operability of the train heaters. Operating the train heaters for longer than 15 minutes provides no more assurance than a 15 minute period.
" Section 3.0, "Technical Evaluation," fourth paragraph:
One of the reasons for the previous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> requirement for ventilation system heate operation with heaters operatingwas to minimize the effects of moisture on the adsorber's ability to capture gaseous activity. However, these effects are already accounted for in the Ventilation and Filter Testing Programs by performing testing at a relative humidity of 95%. The
[PLANT] TS [5.5.11] Ventilation Filter Testing Program requires testing charcoal adsorbers in a manner to account for the effects of moisture on the adsorber's ability to capture gaseous activity. Therefore, the licensee proposed to remove the requirement to operate heaters misture elimination purpose from SRs {for B&W Plants}[3.7.10.1, 3.7.12.1 and 3.7.13.1] {for
Technical Specification Task Force (TSTF) Response to the March 22, 2012 Federal Register Notice, "Proposed Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-522, Revision 0, 'Revise Ventilation System Surveillance Requirements To Operate for 10 Hours per Month'," Docket ID NRC-2012-0071 Westinghouse Plants}[3.6.11.1 3.6.13.1, 3.7.10.1, 3.7.12.1, 3.7.13.1, and 3.7.14.1 ] {for Combustion Engineering Plants } [3.6.8.1, 3.6.10.1, 3.7.11.1, 3.7.13.1, 3.7.14.1 and 3.7.15.1] {for General Electric Plants}[3.6.4.3.1 and 3.7.4.1].