TSTF-23-08, TSTF-592, Revision 2, Revise Automatic Depressurization System (ADS) Instrumentation Requirements Correction
| ML23283A002 | |
| Person / Time | |
|---|---|
| Site: | 99902042, Technical Specifications Task Force |
| Issue date: | 10/10/2023 |
| From: | Lashley P, Lueshen K, Richards A, Sparkman W, Vaughan J BWR Owners Group, Babcock & Wilcox Co, PWR Owners Group, Technical Specifications Task Force, Westinghouse |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| TSTF-23-08 | |
| Download: ML23283A002 (1) | |
Text
11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 804-339-7034 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF October 10, 2023 TSTF-23-08 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
TSTF-592, Revision 2, "Revise Automatic Depressurization System (ADS)
Instrumentation Requirements" Correction On September 13, 2023, the TSTF submitted traveler TSTF-592, Revision 2, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements," (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23256A352).
The TSTF has discovered an error in the submitted traveler. In both NUREG-1433 and NUREG-1434, Technical Specification 3.3.5.1, "ECCS Instrumentation," Required Action H.2, has two Completion Times. The second Completion Time states, "8 days [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channels in one trip system." The phrase "in one trip system" is unnecessary and potentially confusing. Required Action H.2, Note 2, states, "Only applicable when one ADS trip system is inoperable,"
making the phrase redundant. The phrase "in one trip system" was deleted from the first Completion Time of Required Action H.2 in Revision 2 of the traveler, but the same phrase in the second Completion Time was inadvertently retained. This letter corrects the traveler by removing the phrase from the second Completion Time.
Removal of the phrase "in one trip system" from the Required Action H.2 second Completion Time does not affect the Technical Specifications Bases and only affects the justification within two quotes. Enclosed are three pages to replace the corresponding pages in TSTF-592, Revision
- 2.
Should you have any questions, please do not hesitate to contact us.
Andrew M. Richards, Jr. (PWROG/W)
Phil H. Lashley (BWROG)
Kevin Lueshen (PWROG/CE)
Jordan L. Vaughan (PWROG/B&W)
Wesley A. Sparkman (PWROG/AP1000)
TSTF 21-08 October 10, 2023 Page 2 Enclosure cc:
Michelle Honcharik, Technical Specifications Branch Shivani Mehta, Technical Specifications Branch
Enclosure Replacement Pages for TSTF-592, Revision 2, "Revise Automatic Depressurization System (ADS) Instrumentation Requirements"
TSTF-592, Rev. 2 Page 5
- High channels inoperable." The Completion Time is "1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems."
Required Action H.2 states, "Restore affected channels to Operable status. It is modified by two Notes. The first Note limits the Required Action applicability to Functions 4.e, 4.f, 5.e, and 5.f. The second Note limits the Required Action applicability to when one ADS Trip System is inoperable due to Core Spray/LPCI Pump Discharge Pressure - High channels inoperable. The Completion Time is 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of inoperable channels concurrent with HPCI or RCIC inoperable and 8 days from discovery of inoperable channels. The option of including a Risk Informed Completion Time (RICT) alternative is included. If the licensee currently has an NRC-approved RICT for the existing Required Action G.2, then a RICT may be retained for the revised Required Action G.2, and for the new Required Action H.2. For plants that have not been approved for a RICT for Required Action G.2, it is outside the scope of this traveler to add it.
Required Action H.3 states, "Restore channel to OPERABLE status," with a Completion Time of "30 days."
Current Action H is renamed Action I, and is modified to include the revised Condition H.
NUREG-1434:
Table 3.3.5.1-1 is revised to reference Action H instead of Action G for Functions 4.e, 4.f, 4.h, 5.e, and 5.g.
TS 3.3.5.1, Required Action G.1, is revised to delete the Note.
TS 3.3.5.1 is revised to add a new Condition H.
The Condition states, "As required by Required Action A.1 and referenced in Table 3.3.5.1-1."
Required Action H.1states, "Declare ADS valves inoperable, and is modified by two Notes. The first Note limits the Required Action applicability to Functions 4.e, 4.f, and 5.e. The second Note limits the Required Action applicability to when both ADS Trip Systems are inoperable due to LPCS/LPCI Pump Discharge Pressure -
High channels inoperable." The Completion Time is "1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of loss of ADS initiation capability in both trip systems."
Required Action H.2 states, "Restore affected channels to OPERABLE status." It is modified by two Notes. The first Note limits the Required Action applicability to Functions 4.e, 4.f, and 5.e. The second Note limits the Required Action applicability to when one ADS Trip System is inoperable due to LPCS/LPCI Pump Discharge Pressure - High channels inoperable. The Completion Time is 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> from discovery of inoperable channels concurrent with HPCS or RCIC inoperable and 8 days from discovery of inoperable channels. The option of including an RICT alternative is included. If the licensee currently has an NRC-approved RICT for the existing Required Action G.2, then a RICT may be retained for the revised Required Action G.2, and for the new Required Action H.2. For plants that have not been approved for a RICT for Required Action G.2, it is outside the scope of this traveler to add it.
Required Action H.3 states, "Restore channel to OPERABLE status," with a Completion Time of "30 days."
ECCS Instrumentation 3.3.5.1 General Electric BWR/4 STS 3.3.5.1-7 Rev. 5.0 AND H.2
NOTE--------------
- 1. Only applicable for Functions 4.e, 4.f, 5.e, and 5.f.
- 2. Only applicable when one ADS trip system is inoperable due to Core Spray/LPCI Pump Discharge Pressure -
High channels inoperable.
Restore affected channels to OPERABLE status.
AND H.3 Restore channel to OPERABLE status.
capability in both trip systems 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channels concurrent with HPCI or RCIC inoperable AND 8 days [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channels 30 days TSTF-592, Rev. 2
ECCS Instrumentation 3.3.5.1 General Electric BWR/6 STS 3.3.5.1-7 Rev. 5.0 H.2
NOTE--------------
- 1. Only applicable for Functions 4.e, 4.f, and 5.e.
- 2. Only applicable when one ADS trip system is inoperable due to LPCS/LPCI Pump Discharge Pressure -
High channels inoperable.
Restore affected channels to OPERABLE status.
AND H.3 Restore channel to OPERABLE status.
96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channels concurrent with HPCS or RCIC inoperable AND 8 days [or in accordance with the Risk Informed Completion Time Program] from discovery of inoperable channels 30 days IH. Required Action and associated Completion Time of Condition B, C, D, E, F, G or GH not met.
IH.1 Declare associated supported feature(s) inoperable.
Immediately TSTF-592, Rev. 2