View source for TSTF-03-09, Traveler - November 10, 2003 - Transmits TSTF-430, R.1, AOT Extension to 7 Days for LPI and Containment Spray (BAW-2295-A, Rev. 1)

{{Adams
| number = ML033250219
| issue date = 11/10/2003
| title = Traveler - November 10, 2003 - Transmits TSTF-430, R.1, AOT Extension to 7 Days for LPI and Containment Spray (BAW-2295-A, Rev. 1)
| author name = Furio P, Infanger P, Silko T, Wideman S
| author affiliation = Technical Specifications Task Force
| addressee name = Beckner W
| addressee affiliation = NRC/NRR/DRIP
| docket = 
| license number = 
| contact person = 
| case reference number = BAW-2295-A, Rev 1, TSTF-03-09, TSTF-430, Rev 1
| document type = Letter type:TSTF
| page count = 21
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:TECHNICAL SPECIFICATIONS TASK FORCE TSTF                                              A JOINT OWNERS GROUP ACTIVITY November 10, 2003                                                                  TSTF-03-09 Dr. William D. Beckner, Director Operating Reactor Improvements Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==
TSTF-430, Revision 1, AOT Extension to 7 Days for LPI and Containment Spray (BAW-2295-A, Rev. 1)

==Dear Dr. Beckner:==

Enclosed for NRC review is Revision 1 to TSTF-430, AOT Extension to 7 Days for LPI and Containment Spray (BAW-2295-A, Rev. 1). This revision addresses the NRCs comments of September 10, 2002, regarding the discovery of failure to meet the LCO Completion Times.
The TSTF has held several meetings and conference calls with your staff to understand their concerns. Based on those discussions, we believe we have addressed the staffs concerns by modifying the justification to explain the changes to these Completion Times and to reference a precedent.
This Traveler will be incorporated into the proposed Revision 3 of the Improved Technical Specification NUREGs (e.g., NUREG-1430 through -1434).
Should you have any questions, please do not hesitate to contact us.
Steve Wideman (WOG)                                   Tom Silko (BWROG)
Patricia Furio (CEOG)                                 Paul Infanger (BWOG)
Enclosure cc: Drew Holland (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

Bcc: Steve Wideman (WOG)
Patricia Furio (CEOG)
Tom Silko (BWROG)
Paul Infanger (BWOG)
Donald Hoffman (EXCEL)
Brian Mann (EXCEL)
Ken Putnam (BWROG)
Ken Vavrek (WOG)

BWOG-104, Rev. 1                  TSTF-430, Rev. 1 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler AOT Extension to 7 Days for LPI and Containment Spray (BAW-2295-A, Rev. 1)
NUREGs Affected:               1430           1431            1432            1433        1434 Classification: 1) Technical Change                                                Recommended for CLIIP?: Yes Correction or Improvement:            Improvement Industry

==Contact:==
Paul Infanger, (352) 563-4796, paul.infanger@pgnmail.com 1.0 Description This change implements the changes described in Topical Report BAW-2295-A, Revision 1, "Justification For Extension Of Allowed Outage Time For Low Pressure Injection And Reactor Building Spray Systems."
BAW-2295 was approved by the NRC on July 15, 1999. The ITS 3.5.2 Completion Time for a single Low Pressure Injection (LPI) train inoperable is extended from 72 hours to [7] days. The ITS 3.6.6 Completion Time for a containment spray train inoperable is extended from 72 hours to [7] days. The maximum time that LCO 3.6.6 cannot be met in ACTIONS A and C is extended from 10 days to [14] days.
2.0 Proposed Change The proposed change extends the Completion Time for a single inoperable Low Pressure Injection (LPI) train from 72 hours to [7] days. The Completion Time for an inoperable containment spray train is extended from 72 hours to [7] days.
The "modified time zero" Completion Times in Specification 3.6.6, Conditions A and C are revised from 10 days to 14 days. The "discovery of failure to meet the LCO" Completion Times are an administrative limit intended to prevent plants from successively entering and exiting ACTIONS associated with different systems governed by one LCO without ever meeting the LCO (i.e., "flip flopping") . The "discovery of failure to meet the LCO" Completion Times are the sum of the Conditions which can be successively entered, in this case Specification 3.6.6, Conditions A and C.
These administrative limits are calculated without regard to the method used to determine the component Completion Times. Therefore, an extension of one of the component Completion Times will result in a corresponding extension of the "discovery of failure to meet the LCO" Completion Time. This portion of the change is consistent with the Staff's approval of Grand Gulf Nuclear Station, Unit 1, Amendment 151, dated July 16, 2002.
08-Nov-03 Traveler Rev. 3. Copyright (C) 2003, 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.

BWOG-104, Rev. 1                  TSTF-430, Rev. 1

===3.0 Background===
The LPI serves a dual function as a component of the decay heat removal (DHR) system, and as a component of the emergency core cooling system (ECCS) in the emergency operating mode. In the B&W plant design, the DHR system and LPI are combined and share most components, including pumps, valves, and piping. The function of LPI portion of the ECCS is to flood the core with borated water immediately following a large or intermediate loss-of-coolant accident (LOCA) to prevent a significant amount of cladding failure with subsequent release of fission products into the containment. The DHR system is a high-capacity, low-head system with separation and sufficient number of components to provide two-train redundancy for the safeguards mode of operation. It also removes heat from the core for extended periods of time following a LOCA, and in non-emergency conditions such as shutdown and refueling operations.
The containment spray system removes heat and fission products from the post-accident containment atmosphere by directing borated water spray into the containment following a LOCA. The system consists of two pumps, two spray headers, and necessary piping, valves, instrumentation, and controls.
The LPI and containment spray are related systems in that they both take suction from the borated water storage tank (BWST) and can also draw suction from the reactor building sump for coolant recirculation.
When the water in the BWST reaches a low level during the injection mode, the recirculation mode is initiated by realigning the LPI/containment spray pump suction from the BWST to the reactor building emergency sump. Each LPI train shares common suction piping with its corresponding containment spray train.
The TS that are affected by this proposed change are 3.5.2, "ECCS - Operating" and 3.6.6, "Containment Spray and Cooling Systems." Currently, 3.5.2 requires two trains of ECCS to be OPERABLE. With one train of ECCS inoperable, a Completion Time of 72 hours is allowed to restore the train or commence a shutdown. The proposed change provides an additional action which allows one train of LPI to be inoperable for [7] days. The high pressure injection (HPI) Completion Time is not being extended at this time. At times, one train of containment spray is affected by LPI train maintenance because of the common suction piping.
Therefore, the proposed change extends the Completion Time for one inoperable train of containment spray to
[7] days. Under the conventions in the Writer's Guide, the extension of the Completion Time for one train of containment spray from 72 hours to [7] days also requires an extension of the "modified time zero" portion of 3.6.6 from 10 days to [14] days.
08-Nov-03 Traveler Rev. 3. Copyright (C) 2003, 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.

BWOG-104, Rev. 1                  TSTF-430, Rev. 1 4.0 Technical Analysis The analysis for this change is presented in detail in BAW-2295-A, Revision 1, "Justification For Extension Of Allowed Outage Time For Low Pressure Injection And Reactor Building Spray Systems." BAW-2295 was approved by the NRC on July 15, 1999. The NRCs evaluation of BAW-2295 considered both deterministic and probabilistic analyses.
Effect on Safety Analyses The deterministic evaluation consisted of each utilitys review of the systems and safety functions that are affected by the entry into the LPI / containment spray train AOT. The licensee assured that all the affected DHR, LPI and RBS safety functions were identified and quantitatively and qualitatively assessed. The licensees determined that there are no systems, structures, or components that will change status due to the proposed changes (i.e., no additional systems, structures, or components will become significant to public health and safety due to the proposed change). The licensees determined that no new accidents or transients will be introduced by the proposed change.
Effect on Risk Informed Analysis BAW-2295, Revision 1 (October 1997) describes the risk informed evaluation that was performed to evaluate the extension of the Completion Time for LPI and containment spray to 7 days. The NRC found this evaluation acceptable, as detailed in their Safety Evaluation dated July 15, 1999.
Specific compensatory measures are required in an effort to reduce the risk impacts. The compensatory measures defined as part of the proposed LPI and containment spray Completion Time changes are:
  > Avoiding simultaneous outages of additional risk-significant components during the Completion Time of the LPI and containment spray system trains. These components whose simultaneous outages are identified to be avoided, in addition to the current TS requirements, are both trains of the emergency feedwater (EFW),
high pressure injection (HPI), reactor building cooling unit (RBCU), and their power supplies.
  > Defining specific criteria for scheduling only those preventive maintenances which can be completed within the Completion Time, such that the chance for needing a forced outage for failing to complete the maintenance is negligible.
  > Assuring that the frequency of entry into the Completion Time and consequently, the average maintenance duration per year remains within that assumed in the submittal. In some cases, a reduction of the number of entries in to the Completion Time was assumed.
  > Taking measures to assure that when maintaining the LPI and containment spray trains both are not made unavailable unless it is necessary. In many situations, maintenance in one of the trains can be conducted without affecting the other train.
The NRCs Safety Evaluation also requires the licensees implement a "Configuration Risk Management Program" which meets the criteria put forward in the Safety Evaluation. Mainteance Rule 10 CFR 50.65(a)(4) eliminates the need for a Configuration Risk Management Program to support this change as 10 CFR 50.65(a)
(4) mandates a similar program.
08-Nov-03 Traveler Rev. 3. Copyright (C) 2003, 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.

BWOG-104, Rev. 1                  TSTF-430, Rev. 1 5.0 Regulatory Analysis 5.1 No Significant Hazards Consideration The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change allows one inoperable Low Pressure Injection train and/or Containment Spray train for [7] days. The Low Pressure Injection system or Containment Spray system are not initiators for any accident previously evaluated. The consequences of an event during the extended Completion Time are no more severe than the consequences of the same event during the current Completion Time. Therefore, the consequences of an event previously analyzed are not increased. Therefore, the proposed change does 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 proposed change allows one inoperable Low Pressure Injection train and/or Containment Spray train for [7] days. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The proposed change allows one inoperable Low Pressure Injection train and/or Containment Spray train for [7] days. An evaluation presented in Topical Report BAW-2295 and accepted by the NRC concluded that the extended Completion Time did not result in a significant reduction in the margin of safety.
Therefore, the proposed change does 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.
08-Nov-03 Traveler Rev. 3. Copyright (C) 2003, 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.

BWOG-104, Rev. 1                  TSTF-430, Rev. 1 5.2 Applicable Regulatory Requirements The analysis in BAW-2295-A demonstrates that the proposed changes continue to meet the applicable regulatory requirements and 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 Impact 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 BAW-2295-A, Revision 1, Justification for Extension of Allowed Outage Time for Low Pressure Injection and Reactor Building Spray Systems.
Revision History OG Revision 0                                  Revision Status: Closed Revision Proposed by:        BWOG Revision

== Description:==

Original Issue Owners Group Review Information Date Originated by OG: 23-Mar-00 Owners Group Comments:
EXCEL to make indicated changes Owners Group Resolution:            Superceeded Date: 02-Aug-00 OG Revision 1                                  Revision Status: Closed Revision Proposed by:        BWOG Revision

== Description:==

Revised the description and justification to more closely match the NRC's Safety Evaluation for BAW-2295-A.
08-Nov-03 Traveler Rev. 3. Copyright (C) 2003, 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.

BWOG-104, Rev. 1                  TSTF-430, Rev. 1 OG Revision 1                                  Revision Status: Closed Owners Group Review Information Date Originated by OG: 07-Dec-00 Owners Group Comments:
(No Comments)
Owners Group Resolution:            Approved          Date: 07-Dec-00 TSTF Review Information TSTF Received Date:          12-Feb-01                  Date Distributed for Review: 12-Feb-01 OG Review Completed:              BWOG            WOG            CEOG           BWROG TSTF Comments:
2/14/2001 - discussed by TSTF. BWOG only. BWOG to revise to make consistent with similar CEOG change.
Bracket the 7 and 14 days. Put Reviewer's Note in the Bases to explain the adoption of the Topical. Leave in one TSTF since this is the way the Topical is written. Evaluate the need for a Condition when both Spray and Cooling is inoperable for 72 hours. WOG and CEOG want to hear the resolution of the need for the combination before approval of the Traveler.
3/6/2001 - Incorporate comments from BWOG meeting. BWOG would like this to be a high priority CLIIP item.
12/15/01 - Revised mark on Rev. 2 pages, revised description and justification to met new format, revised to number references in order of appearance.
TSTF Resolution:         Approved                                            Date: 23-Jan-02 NRC Review Information NRC Received Date:           01-Feb-02 NRC Comments:                                                                       Date of NRC Letter: 10-Sep-02 This is to inform you that disposition has been made on Technical Specification Task Force (TSTF)-439 containing proposed changes to the Standard Technical Specification (STS) NUREG-1430, Babmck and Wilcox Plants, made by the Nuclear Energy Institute (NEI) TSTF. The staff is prepared to approve TSTF-430 with respect to the proposed changes to Low Pressure Injection and Containment Spray completion time extensions. The staff is not prepared to approve the proposed completion time extensions to the modified time zero" completion times, since the resolution of TSTF-439 will apply to those completion times. The staff is closing out TSTF-430 with a recommendation to modify it and submit TSTF430 Revision 1 based upon the final results of approved TSTF-439.
Final Resolution:        Superceded by Revision                                     Final Resolution Date:          10-Sep-02 TSTF Revision 1                                Revision Status: Active Revision Proposed by:        BWOG Revision

== Description:==

In a letter dated September 10, 2002, the NRC stated, "The staff is prepared to approve TSTF-430 with respect to the proposed changes to Low Pressure Injection and Containment Spray completion time extensions. The staff is not prepared to approve the proposed completion time extensions to the 'modified time zero' completion times, since the resolution of TSTF-439 will apply to those completion times."
08-Nov-03 Traveler Rev. 3. Copyright (C) 2003, 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.

BWOG-104, Rev. 1                  TSTF-430, Rev. 1 TSTF Revision 1                                Revision Status: Active The TSTF and the NRC held several discussions on the history and purpose of the "modified time zero" or "discovery of failure to meet the LCO" Completion Times. The "discovery of failure to meet the LCO" Completion Times are an administrative limit intended to prevent plants from successively entering and exiting ACTIONS associated with different systems governed by one LCO without ever meeting the LCO (e.g., "flip flopping") . The "discovery of failure to meet the LCO" Completion Times are generally the sum of the longest and shortest Completion Times that could be successively entered (in this case, Specification 3.6.6 Conditions A and C). This administrative limit is calculated without regard to the method used to determine the component Completion Times. Therefore, an extension of one of the component Completion Times will result in a corresponding extension of the "discovery of failure to meet the LCO" Completion Time. The NRC determined that increasing the "discovery of failure to meet the LCO" Completion Times based on adding a risk-based and deterministic Completion Time was consistent with the Staff's approval of Grand Gulf Nuclear Station, Unit 1, Amendment 151, dated July 16, 2002.
This revision changes TSTF-430 by expanding the justification under the "Proposed Change" section to explain the purpose of the "discovery of failure to meet the LCO" Completion Times. No other changes are made to the Traveler.
TSTF Review Information TSTF Received Date:          15-Oct-03                  Date Distributed for Review: 26-Oct-03 OG Review Completed:              BWOG            WOG            CEOG           BWROG TSTF Comments:
(No Comments)
TSTF Resolution:         Approved                                            Date: 29-Oct-03 NRC Review Information NRC Received Date:           11-Nov-03 Affected Technical Specifications Ref. 3.5.2 Bases            ECCS - Operating Action 3.5.2.A              ECCS - Operating Change

== Description:==
Relabeled B Action 3.5.2.A              ECCS - Operating Change

== Description:==
New Action 3.5.2.A Bases        ECCS - Operating Change

== Description:==
New Action 3.5.2.A Bases        ECCS - Operating Change

== Description:==
Relabeled B 08-Nov-03 Traveler Rev. 3. Copyright (C) 2003, 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.

BWOG-104, Rev. 1                  TSTF-430, Rev. 1 Action 3.5.2.B              ECCS - Operating Change

== Description:==
Relabeled C Action 3.5.2.B Bases        ECCS - Operating Change

== Description:==
Relabeled C Action 3.5.2.C              ECCS - Operating Change

== Description:==
Relabeled D Action 3.5.2.C Bases        ECCS - Operating Change

== Description:==
Relabeled D SR 3.5.2.1 Bases            ECCS - Operating SR 3.5.2.4 Bases            ECCS - Operating Ref. 3.6.6 Bases            Containment Spray and Cooling Systems Action 3.6.6.A              Containment Spray and Cooling Systems Action 3.6.6.A Bases        Containment Spray and Cooling Systems Action 3.6.6.C              Containment Spray and Cooling Systems Action 3.6.6.C Bases        Containment Spray and Cooling Systems SR 3.6.6.4 Bases            Containment Spray and Cooling Systems 08-Nov-03 Traveler Rev. 3. Copyright (C) 2003, 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-430, Rev. 1 TSTF-430, Rev. 1 TSTF-430, Rev. 1 TSTF-430, Rev. 1 TSTF-430, Rev. 1 TSTF-430, Rev. 1 TSTF-430, Rev. 1 TSTF-430, Rev. 1 TSTF-430, Rev. 1 TSTF-430, Rev. 1 TSTF-430, Rev. 1}}