NRC Generic Letter 1991-08

NRC Generic Letter 1991-008: Removal of Component Lists from Technical Specifications

ML031140516
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Washington Public Power Supply System, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Clinch River
Issue date:	05/06/1991
From:	Partlow J Office of Nuclear Reactor Regulation
To:
References
GL-91-008, NUDOCS 9105020075, NUDOCS 9105230015
Download: ML031140516 (18)

. .. I

• - -'°U Enclosure 1 UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20556 May 6, 1991 TO: ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION

NUCLEAR POWER REACTORS PERMITS FOR

SUBJECT: REMOVAL OF COMPONENT LISTS FROM TECHNICAL SPECIFICATIONS

(GENERIC LETTER 91-08)

This generic letter provides guidance for preparing amendment to remove component lists from technical a request for a license This guidance provides an acceptable alternative specifications (TS).

component by its plant identification number to identifying every the tables of TS components. The removal as it is currently listed in because it does not alter existing TS requirementsof component lists is acceptable they apply. The nuclear industry and the or those components to which (NRC) identified this line-item TS improvement U.S. Nuclear Regulatory Commission problems. Previous guidance was provided by during investigations of TS

Generic Letter 84-13 on removing the list of snubbers from TS.

This guidance includes the incorporation of are subject to the change control provisions lists into plant procedures that Administrative Controls Section of the TS. for plant procedures in the TS permits administrative control of changes The removal of component lists from a license amendment, as is required to update to these lists without processing to component lists contained in plant procedures TS component lists. Any change specified in the Administrative Controls Section is subject to the requirements procedures. Therefore, the change control of the TS on changes to plant provisions of the TS provide an adequate means to control changes to these incorporated into plant procedures, without component lists, when they have been including them in TS.

Licensees and applicants that plan to adopt encouraged to propose TS changes that are consistent this line-item TS improvement are in Enclosures 1 and 2. Enclosure 1 provides with the guidance provided specific lists of components. Enclosure 2 guidance on the TS changes for the current standard technical specification provides the applicable sections of changes to allow the removal of component lists. (STS) requirements with the TS

the facility will review conforming amendment The NRC project manager for that deviate from this guidance will lengthen requests. Proposed amendments review. Please contact the project manager the time required to complete the you have questions on this matter. or the contact identified below if This letter does not require any licensee procedures or propose changes to their plant to implement changes to their plant TS. Action taken in response to Contact: Tom Dunning, NRR/OTSB

(301) 492-1189

9105020075

9105230015 910501 PDR ORO NRRBPDR

C'Mnghr4^ I -++aw nl An as,, L-Ct'r 7L-U0 - z - .May 6, 1991 the guidance provided ir this generic letter is voluntary under 10 CFR 50.109. Therefore, Office of Manaqement and and is not a backfit Budget clearance is not required.

However, the NRC staff recommends that licensees who previously change to remove the list of containment isolation valves requested a from their plant TS

may wish to review the impact that this change can have on discussed in Enclosure 1. In some cases, previous TS changes TS requirements as TS provisions that were identified only as part of the list may have removed was removed from the TS. If such provisions are not retainedof components that noted in Enclosures 1 and 2, they will no longer apply. in the TS, as licensees may have TS that inappropriately reference other Likewise, some the updated safety analysis report, for a list of those documents, such as to which the TS limiting conditions for operation apply. individual components Enclosure 1, these references do not accomplish the intent As noted in remove a list of components from TS. Therefore, licensees of the TS change to that find either of these conditions may wish to submit a license amendment request TS provision that was inadvertently removed from the TS or to restore an.v inappropriate reference in the TS that would not accomplish to remove an the intent of removing the list from the TS.

Sincerely, Ines G. Partlow Asociate Director for Projects Office of Nuclear Reactor Regulation Enclosures:

As stated

Generic Letter 91-08 Enclosure 1 REMOVAL OF COMPONENT LISTS FROM TECHNICAL SPECIFICATIONS

(TS)

Background Generic Letter (GL) 64-13 provided guidance on removing the list of snubbers from technical specifications (TS). After GL 84-13 submitted proposals on a pldnt-specific basis to was issued, many licensees from TS. The nuclear industry has also recommended remove other component lists lists from TS as a TS improvement. This guidance the removal of component request to remove component lists from TS is based for a license amendment the NRC and the industry. on the experience of both The NRC staff noted that many license amendments add, delete, or modify the list of snubbers. The had been required in order to of snubbers was not necessary, provided the TS staff concluded that the list were modified to specify those snubbers that are required to be operable. Also, changes in the quantities, types, or locations the staff noted that any of snubbers would constitute a change to the facility and thus would be subject

50.59 of Title 10 of the Code of Federal Regulationsto the provisions of Section was modified to state that the only snubbers excluded (10 CFR). The snubber TS

were those installed on nonsafety-related systems, from the TS requirements ure or the failure of the system on which they and then only if their fail- adverse effect on any safety-related system. were Installed would have no The table with the list of snubbers and the associated references were removed for operation (LCO) and the associated surveillance from the limiting condition requirements.

Therefore, specifications may be stated in general types of components to which the requirements apply.terms that describe the able alternative to identifying components by their This provides an accept- plant as they are currently listed in tables of TS components. identification number ponent lists is acceptable because it does not The removal of com- or those components to which they apply. alter existing TS requirements Guidance on the Removal of Component Lists From TS

The approach taken In GL 84-13 to remove a list be used to remove other component lists from TS. of components from TS may also the TS should be revised to incorporate an explicitTo implement this approach, ponents for which the TS requirements apply. A description of those com- be included in a plant procedure that is subject list of those components must sions for plant procedures in the Administrative to the change control provi- This can be accomplished by incorporating in such Controls Section of the TS.

identifies all the components for which the TS a procedure the list that firming that an existing procedure includes this requirements apply or by con- specification is revised such that the scope of list of components. If a applies is increased, the additional components those components to which it shall when it is Incorporated in a plant procedure. Likewise, be added to the TS list ents in existing procedures shall also be updated. any list of TS compon- included in plant procedures, the identification When component lists are to which the TS requirements apply will be a simple of the individual components task.

Although some components may be listed in the updated report (FSAR), the FSAR should not be the sole final safety analysis means to identify these

Generic Letter 91-08 - 2 - Enclosure 1 components. Licensees are only required to update the FSAR annually, and they are only required to reflect changes made 6 months before the date of filing.

Thus, the FSAR may be out of date by as much as 18 months. However, to high- light the change controls of 10 CFR 50.59 or to clarify other issues related to these components, licensees may wish to include these component lists in the next update of the FSAR. The Bases Section of the TS may reference the plant procedures where these lists are located; however, component lists should not be included in the Bases Section because the Bases Section lacks an appropriate regulatory process for change control. Finally, it would be inappropriate for a limiting condition for operation of the TS to reference the FSAR or any other document to specify those individual components to which the TS requirements apply. If such references were used, a change in those references could constitute a change to a TS requirement and such changes should only be made via the license amendment process. This would negate the intent of removing the list from the TS which is to allow subsequent changes to the list without having to process a license amendment.

The stdff provides the following guidance for changing individual TS sections.

This guidance addresses considerations that are unique to specific types of component lists.

1. Containment Isolation Valves The specification for containment isolation valves applies to those valves that are listed in the table referenced in the TS. The alternative to listing these valves in a TS table is the revision of the LCO to state "Each contain- ment isolation valve shall be OPERABLE." The reference to valves 'specified in Table 3.6-2" should also be deleted from the action statement. Similarly, the surveillance requirements for (1) post-maintenance testing, (2) demonstrating automatic closure on isolation signals, and (3) confirming the isolation time of power-operdted or automatic valves, should be revised to remove the refer- ence to the TS table and revised to state "Each containment isolation valve shall . . .' or ". . . each power-operated or automatic containment isolation valve shall .

The list of containment isolation valves in the TS may not include all valves that are classified as containment isolation valves by the plant licensing basis. Generally, the FSAR Identifies those valves that are classified as con- tainment isolation valves. With this TS change, the LCO, remedial actions, and surveillance requirements will apply for all valves that are classified as con- tainment isolation valves by the plant licensing basis.

The list of containment isolation valves typically includes footnotes that modify the TS requirements for these valves. Such notes must be incorporated into the associated LCO so that they will remain in effect when the table containing these footnotes is removed from the TS. One of these footnotes involves valves that are exempt from the requirements of TS 3.0.4. TS 3.0.4 precludes entry into an operational mode or condition when an LCO would not be met without reliance on the provisions of the action requirements. The action requirements for containment isolation valves permit continued operation with an inoperable valve when the associated penetration is isolated. Therefore, an exception to the limitation of TS 3.0.4 on changes in operational modes or conditions is acceptable for this specification, and a statement may be added

Generic Letter 91- 08 - 3 - Enclosure I

to the LCO under the action requirements to state "The provisions of Specifica- tion 3.0.4 do not apply." This exception will apply to all containment isold- tion valves. The increase in the scope of this exception is acceptable because it is consistent with the guidance provided in Generic Letter 87-09. However, this statement is not necessary if TS 3.0.4 has been revised as allowed by Generic Letter 87-09.

The list of containment isolation valves may also include a footnote that addresses an operational consideration for specific valves that may be opened on an intermittent basis under administrative control. This provision applies to valves that are locked or sealed closed consistent with the design require- ments of General Design Criteria (GDC) 55, 56, and 57 of Appendix A to 10 CFR Part 50. The design of these valves includes positive control features to ensure that they are maintained closed. Therefore, in the absence of this provision, the opening of these locked or sealed closed valves would be contrary to the operability requirements for these valves that are currently listed in the TS table of containment isolation valves. With the removal of the TS list of valves, the operability requirements will apply to all contain- ment isolation valves that have the locked or sealed closed feature as required by these GDC.

The staff concludes that an acceptable alternative to identifying specific valves that may be opened under administrative control would be the addition of a footnote to the LCO to state "Locked or sealed closed valves may be opened on an intermittent basis under administrative control." With this change, the definition of Containment Integrity and the surveillance requirements for demonstrating containment integrity in Specification 4.6.1.1 should be revised to remove the reference to the table of containment isolation valves. These sections of the TS should be revised to state 0. . . , except for valves that are open under administrative control as permitted by Specification 3.6.4."

The footnote on opening valves under administrative control also may have been used in some plant TS for remote-manual valves associated with closed systems.

A remote-manudl valve is an acceptable alternative to a locked or sealed closed valve for closed systems as stated in GDC 57 in Appendix A to 10 CFR Part 50.

Therefore, this footnote need not remain in the TS to allow operators to open any remote-manual containment isolation valve associated with closed systems because such action is not contrary to the operability requirements for these valves.

However, the NRC staff wishes to restate its position on considerations that constitute an acceptable administrative control for opening locked or sealed closed containment isolation valves. Furthermore, these considerations should be stated in the Bases Section for this specification as the following and an updated copy of this section should be provided with the license amendment request.

The opening of locked or sealed closed containment isolation valves on an intermittent basis under administrative control includes the following considerations: (1) stationing an operator, who is in constant communication with control room, at the valve controls, (2) instructing this operator to close these valves in an accident situation, and (3) assuring that

Generic Letter 91- 08 - 4 - Enclosure I

environmental conditions will not preclude access to close the valves and that this action will prevent the release of radio- activity outside the containment.

Some plant TS may not have included provisions for opening locked or sealed closed valves on an intermittent basis under administrative control. In this case, these containment isolation valves probably were not listed in the table being removed from the TS. However as noted above, the removal of the list of valves from the TS results in the LCO operability requirements being applicable to all containment isolation valves. This extends the operability requirements to those valves that utilize locked or sealed closed features to comply with the requirements of the GDC. Therefore, if any of these valves are opened during the operational modes for which the LCO applies, the license amendment request should include the above footnote allowing these valves to be opened on an intermittent basis under administrative control as a proposed TS change.

Also, the Bases Section should be updated to include the clarification of what constitutes appropriate administrative control for opening these valves.

Another clarifying note used in the list of containment isolation valves iden- tifies those valves that are not subject to Type C leak testing requirements of Appendix J to 10 CFR Part 50. In this case, this notation does not alter the requirements of Appendix J but rather only clarifies where the NRC has granted exemptions to Type C leak testing or where Appendix J does not require this testing. Therefore, the TS need not address this clarification, but it may be included with a list of these valves in the FSAR if it is desired to clarify the applicability of Appendix J requirements. However, placing the current TS

list of containment isolation valves in the FSAR would not restrict the appli- cability of the TS requirements to only the valves on that list. As previously noted, the TS requirements would apply to all valves that have been defined as containment isolation valves in the pldnt licensing basis.

Finally, some TS have included valve closure times in the list of containment isolation valves. The inservice testing (IST) requirements referenced by Spec- ification 4.0.5 include the verification of valve stroke times for a broader class of valves than those containment isolation valves that have been listed in the TS. The removal of valve closure times that are included in some plant TS would not alter the TS requirements to verify that valve stroke times are within their limits. Therefore, removal of these closure times is acceptable.

Because plant-specific considerations may have required that these tables include other notes modifying the TS requirements for specific valves, any such exceptions should be stated in terms that identify the valves by function rather than by component number, if practical. This guidance also applies to any other component list removed from TS that includes notes that alter the TS requirements. If notes in these tables are only included for information and do not alter any TS requirement, the removal of these notes with the list of components would not affect the applicability of the TS requirements.

2. Reactor Coolant System Pressure Isolation Valves Guidance on removing from the TS the list of reactor coolant system pressure isolation valves is pending the NRC staff's resolution of generic concerns with

Generic Letter 91-08 - 5 - Enclosure 1 existing lists for these valves. In the interim, licensees should not submit proposals to remove this list from the TS.

3. Secondary Containment Bypass Leakage Paths The TS on containment leakage includes a list of secondary containment bypass leakage paths. The list identifies these leakage paths by penetration number for dual containment plants. The combined leakage rate for all penetrations identified as secondary containment bypass leakage paths is specified.

As part of the plant licensing basis, the FSAR defines the penetrations that are secondary containment bypass leakage paths. This definition of "secondary containment bypass leakage paths" is adequate such that the TS requirements do not require further clarification upon the removal of this list from the TS.

Therefore, the TS requirements may be stated in terms of secondary containment bypass leakage paths without further clarification. For example, the limita- tion of TS 3.6.1.2.c on containment leakage rates should be revised to state the following:

A combined leakage rate of less than or equal to rO.10 La for all penetrations that are secondary containment bypass leakage oaths when pressurized to Paa T. Containment Penetration Conductor Overcurrent Protective Devices The list of containment penetration conductor overcurrent protective devices includes those primary and backup fuses and breakers that preclude faults of a magnitude and duration that could compromise the integrity of electrical penetrations. Because the number of overcurrent protective devices associated with electrical circuits penetrating containment may exceed the basic reauire- ments for primary and backup protection, the description of these components should be stated to clarify those components to which the TS requirements apply. Also, these requirements exclude circuits for which credible fault currents would not exceed the electrical penetration design rating. For example, these requirements exclude thermocouple and other low-power-level signal circuits. An alternative to listing these components in a TS table is the following LCO statement:

Primary and backup containment penetration conductor overcurrent protective devices associated with each containment electrical penetration circuit shall be OPERABLE. The scope of these protective devices excludes those circuits for which credible fault currents would not exceed the electrical penetration design rating.

In addition, the surveillance requirements should state "The above noted pri- mary and backup containment penetration conductor overcurrent protective devices . . ." rather than referring to those components listed in Table F.3-1.

Generic Letter 91-08 -6 - Enclosure I

5. Motor-Operated Valves Thermal Overload Protection The TS contain a list of valves that have thermal overload protection and bypass devices integral with the motor starter. The table in the TS lists the valves by number, the bypass device, and the system affected. With the removal of this list of valves from the TS, the LCO should state 'The thermal overload protection and bypassed devices, integral with the motor starter, of each valve used in sdfety systems shall be OPERABLE." This statement for the LCO

adequately defines the scope of the valves that include these features to which the TS requirements apply.

6. Other Component Lists Component lists other than those previously described herein may be candidates for removal from TS on a plant-specific basis. A proposal to remove any other TS component list should be based on this guidance and any considerations that may be unique to a particular list.

Summary A request to remove component lists from TS should address the following issues:

1. Each TS should include an appropriate description of the scope of the components to which the TS requirements apply. Components that are defined by regulatory requirements or guidance need not be clarified further. However, the Bases Section of the TS should reference the applicable requirements or guidance.

2. If the removal of a component list results in the loss of notes that modify or provide an exception to the TS requirements, the specification should be revised to incorporate that modification or exception. The modification or exception should be stated in terms that identify any group of components by function rather than by plant identification number, if practical.

3. Licensees should confirm that the lists of components removed from the TS

are located in appropriately controlled plant procedures. The list of com- ponents may be included in the next update of the FSAR. The Bases Section of individual specifications also may reference the plant procedures or other documents that identify each component list. The Bases Section for the containment isolation valve TS should be updated to describe the intent of opening valves under administrative control.

This guidance is not to be used to remove from TS any table that addresses information or requirements other than a list of components to which a specifi- cation applies. Enclosure 2 provides the applicable sections of the current STS requirements and the associated TS changes that are necessary to allow the removal of the components lists.

Generic Letter 91-08 - I - Enclosure 2 EXISTING STS REQUIREMENTS AND CHANGES TO ALLOW

THE EMOVAL OF COMPONENT LISTS

3/4.6.4 CONTAINMENT ISOLATION VALVES (Existing)

3.6.4 The containment isolation valves specified in Table 3.6-2 shall be OPERABLE with isolation times as shown in Table 3.6-2.

ACTION:

With one or more of the isolation valve(s) specified in Table 3.6-2 inoper- able, maintain at least one isolation valve OPERABLE in each affected penetra- tion that is open and:

a. . . . .

ALTERNATIVE: (Changes high-lighted by underline or shown with (_)for deletions.)

3.6.4 Each containment isolation valve shall be OPERABLE.

ACTION:

With one or more of of the isolation valves(s) ( ) inoperable, maintain dt least one isolation valve OPERABLE in each affected penetration that is open and:

a. ....

(New statement under ACTION requirements.)

The provisions of Specification 3.0.4 do not apply.

(New footnote for TS 3.6.4.)

• Locked or sealed closed valves may be oened on an intermittent basis under administrat ve control.

SURVEILLANCE REQUIREMENTS (Existing)

4.6.4.1 The isolation valves specified in Table 3.6-2 shall be demonstrated OPERABLE prior to returning the valve to service after maintenance, repair, or replacement work is performed on the valve or its associated actuator, control, or power circuit by performance of a cycling test and verification of isolation time.

4.6.4.2 Each isolation valve specified in Table 3.6-2 shall be demonstrated OPERABLE during the COLD SHUTDOWN or REFUELING MODE at least once per 18 months by:

a. . . . e

4.6.4.3 The isolation time of each power-operated or automatic valve of Table 3.6-2 shall be determined to be within its limit when tested pursuant to Specification 4.0.5.

Generic Letter 91-08 - 2 - Enclosure 2 ALTERNATIVE:

4.6.4.1 Each containment isolation valve () shall be demonstrated OPERABLE

prior to returning the valve to service after maintenance, repair, or replace- ment work is performed on the valve or its associated actuator, control, or power circuit by performance of a cycling test and verification of isolation time.

4.6.4.2 Each containment isolation valve ( ) shall be demonstrated OPERABLE

during the COLD SHUTDOWN or REFUELING MODE it least once per 18 months by:

a. . . . .

4.6.4.3 The isolation time of each power-operated or automatic containment isolation valve ( ) shall be determined to be within its limit w -iiTeTiEF

pursuant to SpeciTication 4.0.5.

DEFINITIONS

CONTAINMENT INTEGRITY (Existing)

1.7 CONTAINMENT INTEGRITY shall exist when:

a. All penetrations required to be closed during accident conditions are either:

1) Capable of being closed by an OPERABLE containment automatic isolation valve system, or

2) Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except as provided in Table 3.6-2 of Specification 3.6.4.

b. . . .

ALTERNATIVE

1.7 CONTAINMENT INTEGRITY shall exist when:

a. All penetrations required to be closed during accident conditions are either:

1) Capable of being closed by an OPERABLE containment automatic isolation vdlve system, or

2) Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves that are o en under administrative control as Permitted by Specification 3.6.4.

b. . . . .

Generic Letter 91-08 - 3 - Enclosure 2

3/4.6.1 PRIMARY CONTAINMENT (Existing)

4.6.1.1 Primary Containment Integrity shall be demonstrated:

a. At least once per 31 days by verifying that all penetrations* not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except as provided in Table 3.6-2 of Specification 3.6.4.

b. . . ..

ALTERNATIVE:

4.6.1.1 Primary Containment Integrity shall be demonstrated:

a. At least once per 31 days by verifying that all penetrations* not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except for valves that are open under administrative control as permitted E--ecica-tion 364 b. . . . .

CONTAINMENT LEAKAGE (Existing)

3.6.1.2 Containment leakage rates shall be limited to:

a. . .

b. ..

c. A combined leakage rate of less than or equal to (0.10) La for all penetrations identified in Table 3.6-1 as secondary containment bypass leakage paths when pressurized to Pa ALTERNATIVE:

3.6.1.2 Containment leakage rates shall be limited to:

a. . . . .

b. . . . .

t c. A combined leakage rate of less than or equal to [0.10) a for all penetrations that are secondary containment bypass leakage paths when prsssurii-te- T-a.

Generic Letter 91-08 -4 - Enclosure 2 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES (Existing)

3.8.4.2 All containment penetration conductor overcurrent protective devices given in Table 3.8-1 shall be OPERABLE.

ACTION:

With one or more of the containment penetration conductor overcurrent protective device(s) given in Table 3.8-1 inoperable:

a. . . . .

ALTERNATIVE:

3.8.4.2 Primar and backup containment penetration conductor overcurrent protective devices associated with each containment electrical penetration circuit shall be OPERABLE. The scope of these protective devices excludes those circuits for which cred e au currents wou no excee e electrical penetration design rating.

ACTION:

With one or more of the containment penetration conductor overcurrent protective device(s) (_) inoperable:

a. . . a .

SURVEILLANCE REQUIREMENTS (Existing)

4.8.4.2 All containment penetration conductor overcurrent protective devices given in Table 3.8-1 shall be demonstrated OPERABLE:

a. . a . .

ALTERNATIVE

4.8.4.2 All containment penetration conductor overcurrent protective devices

() shall be demonstrated OPERABLE:

a. . . a .

MOTOR-OPERATED VALVES THERMAL OVERLOAD PROTECTION AND BYPASS DEVICES (Existing)

3.8.4.3 The thermal overload protection and bypass devices, integral with the motor starter, of each valve listed in Table 3.8-2 shall be OPERABLE.

ALTERNATIVE:

3.8.4.3 The thermal overload protection and bypass devices, integral with the motor starter, of each valve used in safety systems shall be OPERABLE.

- 5 - Enclosure 2 Generic Letter 91-08 from the TS.

With the above changes, the associated tables are to be removed its contents. The This should be done by removing the table title, name, and as "Not used" and can be accom- associated pages of the TS should be noted no longer used.

plished using a single page that notes those pages that are with a refer- It would not be appropriate to retain the table name aid number of components to which the associated ence to a document that contains a list incorporated into the TS applies. If such references are desired, they can be the TS index Bases Section of the associated TS. As a house-keeping measure, of component should be likewise updated to remove all references to tables lists that have been removed from the TS.

Enclosure 2 MODEL SAFETY EVALUATION REPORT

Underscored blank spaces are to be filled in with the applicable informa- tion. The information identified in brackets should be used as applicable on a plant-specific basis. (Note to PMs: A copy of this document may SER.)

be obtained from P. Coates, X-21161, by requesting 5520 document LIST

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

RELATED TO AMENDMENT NO. TO FACILITY OPERATING LICENSE NO.

[UTILITY NAME]

[PLANT NAME]

DOCKET NO. SO-

1.0 INTRODUCTION

, 1991, [utility name] (the licensee) requested an By letter dated proposed Ti erating License No.

amendment to FacTTlty for [plant name]. The amendment would remove the technical specification (TS) tables that include the lists of components referenced in individual specifications. In addition, tables TS requirements have been modified such that all references to these have been removed. Finally, the TS have been modified to state requirements.

from in general terms that include the components listed in the tables removed Letter the TS. Guidance on the proposed TS changes was provided by Generic

91- _, dated March _, 1991.

2.0 EVALUATION

The licensee has proposed the removal of Table 3.6-1, 'Secondary Containment of Bypass Leakage Paths," that is referenced in TS 3.6.1.2. With the removal for this table, the licensee has proposed to modify the limiting condition by operation (LCO) on containment leakage rates to state the limit specified TS 3.6.1.2.c as the following:

A combined leakage rate of less than or equal to [0.10] La for all penetrations that are secondary containment bypass leakage paths when pressurized to Pa.

Isolation The licensee has proposed the removal of Table 3.6-[2], HContainmentthis table, the Valves," that is referenced in TS 3/4.6.4. With the removal of TS

under licensee has proposed to include the following statement of the LCO 3.6.4:

Each containment isolation valve shall be OPERABLE.

In addition the licensee has revised [the definition of Containment throughIntegrity, TS 4.6.1.1,1 the action requirements under TS 3.6.4, and TS 4.6.4.1

4.6.4.3 to remove all references to Table 6.3-[21. [The definition of Contain- now ment Integrity and TS 4.6.1.1 refer to TS 3.6.4 for an exception that is the TS.

covered by a footnote to the LCO rather than by the table removed from

- 2 -

With the removal of the reference to Table 6.3-[21, the licensee has proposed to state this exception as:

, exceot for valves that are open under administrative control as permitted by Specification 3.6.4.]

The surveillance requirements of TS 4.6.4.1 through 4.6.4.3 have been revised to state "Each containment isolation shall. . .'"or ". . . each power-operated or automatic containment isolation valve shall . . ." rather than stating the requirements in relation to the valves specified in Table 3.6-[2]. not [Because Table 3.6-[2] notes that the provisions of Specification 3.0.4 are applic- able to specific valves, the following statement has been added to the LCO for TS 3.6.4:

The provisions of Specification 3.0.4 do not apply.

to This is a charge in the application of this exception, from specific valves all containment isolation valves, and is acceptable because it is consistent with the guidance provided in Generic Letter 87-09 and as noted in Generic Letter 91-__.]

rThe table of containment isolation valves identified specific manually- operated locked or sealed closed valves with a footnote stating that these valves may be opened on an intermittent basis under administrative control.] oper- OR [With the removal of the table of containment isolation valves, the con-

7aility requirements have been stated in general terms that apply to all tainment isolation valves including those that are locked or sealed closed.]

These valves are locked or sealed closed consistent with the regulatory requirements for manually-operated valves that are used as containment isola- tion valves. Because opening these valves would be contrary to the operability requirements of these valves, the following footnote to the LCO has been proposed:

Locked or sealed closed valves may be opened on an intermittent basis under administrative control.

This change is consistent with the guidance in Generic Letter 91- and is, therefore, acceptable.

The licensee has proposed the removal of Table 3.8-1, Containment Penetration Conductor Overcurrent Protective Devices" that is referenced in TS 3/4.8.4.2.

With the removal of this table, the licensee has proposed to include the following statement for the LCO under TS 4.8.3.2:

Primary and backup containment penetration conductor overcurrent protective devices associated with each containment electrical penetration circuit shall be OPERABLE. The scope of these protec- tive devices excludes those for which credible fault currents would not exceed the electrical penetration design rating.

In addition, the licensee has proposed to revise TS 4.8.3.2 to remove the state ref- erence to Table 8.3-1. The surveillance requirement has been revised to the following:

-3 -

The above noted primary and backup containment penetration conductor overcurrent protective devices shall be demonstrated OPERABLE:

The licensee has proposed the removal of Table 3.8-2, Motor-Operated Valves Thermal Overload Protection,' that provides a list of valves with bypass devi- ces that is referenced in TS 3.8.4.3. With the removal of this table, the licensee has proposed to include the following statement of the LCO under TS 3.8.3.3:

The thermal overload protection and bypass devices, integral with the motor starter, of each valve used in safety systems shall be OPERABLE.

The licensee has proposed changes to the above TS that are consistent with the guidance provided in Generic Letter 91- . In addition, the licensee has pro- vided an updated copy of Bases Section of TS 3.6.4 that addresses appropriate considerations for opening locked or sealed closed valves on an intermittent basis. Finally, the licensee has confirmed that component lists removed from the TS have been updated to identify all components for which the TS reauire- ments apply and are located in controlled plant procedures. [These lists of components will also be included in the next revision of the updated safety analysis report.] (NOTE to PMs: The inclusion of this list in the next FSAR

update is not a requirement, but-the SER should reflect any commitment by the licensee to do so.)

On the basis of its review of this matter, the staff finds that the proposed changes to the TS for [plant name] Units 1 and 2 are primarily an administra- tive change that does not alter the requirements set forth in the existing TS.

However, the applicability of the operability requirements will extend to all containment isolation valves as noted in this evaluation. Overall, these changes will allow licensees to make corrections and updates to the list of components for which these TS requirements apply, under the provisions that control changes to plant procedures as specified in the Administrative Controls Section of the TS. Therefore, the staff finds that the proposed TS changes are acceptable.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the (name of State) State official was notified of the proposed issuance of the amendment. The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in

10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on

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such finding (56 FR ) Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assess- ment need be prepared in connection with the issuance of the amendment.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Thomas G. Dunning, OTSB

, PD-_

Date:

Enclosure 3 LIST OF RECENTLY ISSUED GENERIC LETTERS

Getteri c Date of Letter No. Subject Issuance Issued To

91-05 LICENSEE COMMERCIAL-GRADE 04/09/91 ALL HOLDERS OF OLs PROCUREMENT AND DEDICATION AND CPs FOR NUCLEAR

PROGRAMS POWER REACTORS

91-04 CHANGES IN TECHNICAL SPECIFI- 04/02/91 ALL HOLDERS OF OLs CATION SURVEILLANCE INTERVALS OR CPs FOR NUCLEAR

TO ACCOMMODATE A 24-MONTH FUEL POWER REACTORS

CYCLE

91-03 REPORTING OF SAFEGUARDS 03/06/91 ALL HOLDERS OF OLs EVENTS OR CPs FOR NUCLEAR

POWER REACTORS AND

ALL OTHER LICENSED

ACTIVITIES INVOLVING

A FORMULA QUANTITY

OF SPECIAL NUCLEAR

MATERIAL (SNM)

91-02 REPORTING MISHAPS INVOLVING 12/28/90 ALL OPERATORS OF

LLW FORMS PREPARED FOR LOW-LEVEL RADIO-

DISPOSAL ACTIVE WASTE (LLW)

DISPOSAL SITES,

WASTE PROCESSORS,

& ALL HOLDERS OF

LICENSES FOR NUCLEAR

FUELS, NUCLEAR

MATERIALS & NUCLEAR

POWER REACTORS

91-01 REMOVAL OF THE SCHEDULE FOR 01/04/91 ALL HOLDERS OF OLs THE WITHDRAWAL OF REACTOR OR CPs FOR NUCLEAR

VESSEL MATERIAL SPECIMENS POWER PLANTS

FROM TECHNICAL SPECIFICATIONS

90-09 ALTERNATIVE REQUIREMENTS FOR 12/11/90 ALL LIGHT-WATER

SNUBBER VISUAL INSPECTION REACTOR LICENSEES

INTERVALS AND CORRECTIVE AND APPLICANTS

ACTIONS

89-10 CONSIDERATION OF THE RESULTS 10/25/90 ALL LICENSEES OF

SUPP. 3 OF NRC-SPONSORED TESTS OF OPERATING NUCLEAR

MOTOR-OPERATED VALVES POWER PLANTS AND

HOLDERS OF CONSTRUC-

TION PERMITS FOR

NUCLEAR POWER PLANTS

90-08 SIMULATION FACILITY 08/10/90 ALL HOLDERS OF

EXEMPTIONS OPERATING LICENSES

OR CONSTRUCTION

PERMITS FOR NUCLEAR

POWER REACTORS