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| | issue date = 04/17/2009 | | | issue date = 04/17/2009 |
| | title = Request for Additional Information Regarding TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation | | | title = Request for Additional Information Regarding TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation |
| | author name = Williams J F | | | author name = Williams J |
| | author affiliation = NRC/NRR/DPR/PSPB | | | author affiliation = NRC/NRR/DPR/PSPB |
| | addressee name = | | | addressee name = |
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| | docket = PROJ0753 | | | docket = PROJ0753 |
| | license number = | | | license number = |
| | contact person = Williams J F, NRR/DPR, 415-1470 | | | contact person = Williams J, NRR/DPR, 415-1470 |
| | case reference number = TAC MD9433, TSTF-448, TSTF-508, Rev 0 | | | case reference number = TAC MD9433, TSTF-448, TSTF-508, Rev 0 |
| | document type = Letter, Request for Additional Information (RAI) | | | document type = Letter, Request for Additional Information (RAI) |
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| =Text= | | =Text= |
| {{#Wiki_filter:April 17, 2009 Technical Specification Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852 | | {{#Wiki_filter:April 17, 2009 Technical Specification Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| REQUEST FOR ADDITIONAL INFORMATION REGARDING TSTF-508, REVISION 0, "REVISE CONTROL ROOM HABITABILITY ACTIONS TO ADDRESS LESSONS LEARNED FROM TSTF-448 IMPLEMENTATION" (TAC NO. MD9433) | | REQUEST FOR ADDITIONAL INFORMATION REGARDING TSTF-508, REVISION 0, REVISE CONTROL ROOM HABITABILITY ACTIONS TO ADDRESS LESSONS LEARNED FROM TSTF-448 IMPLEMENTATION (TAC NO. MD9433) |
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| ==Dear Members of the TSTF,== | | ==Dear Members of the TSTF,== |
| By letter dated July 3, 2008, the Pressurized Water Reactors Owners Group (PWROG) submitted TSTF-508, Revision 0, "Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation." The staff has determined that additional information is needed to complete the review. Enclosure 1 is the NRC staff's request for additional information (RAI). Please contact me at (301)415-1470 or by electronic mail at joseph.williams@nrc.gov if you have any questions on this topic. | | |
| Sincerely, /RA/ | | By letter dated July 3, 2008, the Pressurized Water Reactors Owners Group (PWROG) submitted TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation. The staff has determined that additional information is needed to complete the review. Enclosure 1 is the NRC staffs request for additional information (RAI). Please contact me at (301)415-1470 or by electronic mail at joseph.williams@nrc.gov if you have any questions on this topic. |
| Joseph F. Williams, Senior Project Manager Special Projects Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation | | Sincerely, |
| | /RA/ |
| | Joseph F. Williams, Senior Project Manager Special Projects Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation |
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| ==Enclosure:== | | ==Enclosure:== |
| Request for Additional Information cc: See next page
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| ML090680813 NRR-106 OFFICE PSPB:PM PSPB: LA ITSB:DIRS SCVB:DSS AADB:DRA NAME JWilliams DBaxley (GLappert For) MHamm RDennig RTaylor DATE 04/15/09 04/16/09 03/10/09 03/10/09 03/12/09 OFFICE ITSB:DIRS BC PSPB:BC NAME RElliott SRosenberg DATE 03/24/09 04/17/09 Technical Specifications Task Force Mailing List cc: Technical Specifications Task Force 11921 Rockville Pike Suite 100 Rockville, MD 20852 Attention: Donald Hoffman Telephone: 301-984-4400 E-mail: donaldh@excelservices.com
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| Kenneth Schrader Diablo Canyon Power Plant Building 104/5/21A P.O. Box 56 Avila Beach, CA 93424 Telephone: 805-545-4328 E-mail: kjse@pge.com John Messina First Energy Nuclear Operating Company 76 South Main Street Mail Stop: Akron-GO-14 Akron, OH 44308 Telephone: 330-384-5878 E-mail: jmessina@firstenergycorp.com Thomas Raidy Southern California Edison Mail Stop D-3-E P.O. Box 128 San Clemente, CA 92672 Telephone: (949) 368-7582 E-mail: Tom.Raidy@sce.com Reene' V. Gambrell Duke Energy Mailcode: ON03RC 7800 Rochester Highway Seneca, SC 29672 Telephone: 864-885-3364 E-mail: RVGambrell@duke-energy.com Brian Mann EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Telephone: 301-984-4400 E-mail: brianm@excelservices.com ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATION TASK FORCE (TSTF) TRAVELER 508, REVISION 0 "REVISE CONTROL ROOM HABITABILITY ACTIONS TO ADDRESS LESSONS LEARNED FROM TSTF-448 IMPLEMENTATION" (TAC NO. MD9433)
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| By letter dated July 3, 2008, the Pressurized Water Reactors Owners Group (PWROG) submitted TSTF-508, Revision 0, "Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation." As discussed below, the NRC staff has determined that additional information is needed to complete the review.
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| The Standard Technical Specifications (STS), as amended by TSTF-448, require immediate suspension of movement of irradiated fuel and immediate suspension of Operations with a Potential for Draining the Reactor Vessel (OPDRVs) for boiling water reactors (BWRs) when one or more Control Room Emergency Ventilation System/Control Room Emergency Filtration System/Control Room Emergency Air Cleanup System/Main Control Room Environmental Control/Control Room Fresh Air [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable control room envelope (CRE) boundary.
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| TSTF-508 contains 3 basic changes to the STS, as amended by TSTF-448. The changes are described on page 2 of TSTF-508 (Agencywide Documents Access and Management System (ADAMS) accession number ML081850420). This request for additional information pertains to the change described in paragraph "a" on page 2 of TSTF-508. Among other things, those changes provide a relaxation of the restrictions on movement of irradiated fuel and OPDRVs when one or more [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable CRE boundary. The proposed changes allow operators to continue movement of irradiated fuel and continue OPDRVs for up to 90 days when one or more [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable CRE boundary.
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| The second paragraph on page 5 of TSTF-508 (Technical Analysis) provides justification for the relaxation of the restrictions on fuel movement and OPDRVs. The first justification states: "First, suspension of fuel movement is unnecessary if Required Action B.2 verifies that the required mitigating actions protect the CRE occupants, just as is required in the operating Modes." When one or more [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable CRE boundary, the proposed changes to the STS as written allow movement of irradiated fuel and OPDRVs to continue for up to 24 hours prior to completion of Required Action B.2. This appears to conflict with the justification given in the second paragraph on page 5 of TSTF-508, in that the justification seems to imply that fuel movement would be suspended until Required Action B.2 is complete. The NRC staff also believes that it is prudent to immediately suspend fuel handling operations or OPDRVs until after Required Action B.2 is complete. The characteristic risk of a Fuel Handling Accident (FHA), and the dynamic nature of plant maintenance, repair, testing, and other ongoing operations that could be taking place during Modes 5 and 6 is of primary concern.
| | Request for Additional Information cc: See next page |
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| In TSTF-448, rev. 3, Required Action B.2 is applicable to MODES 1 through [4](hot shutdown). "The 24-hour Completion Time of new Required Action B.2 is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions as directed by Required Action B.1." Generally, the plant would be expected to remain in a steady state condition during the 24-hour verification time. However, there is the possibility of a fuel handling accident each time a fuel assembly is moved. TSTF-508 would permit continued movement of fuel, and therefore, continued risk of a fuel handling accident, for up to 24-hours before completing the verification that mitigating actions protect CRE occupants from chemical and smoke hazards and that radiological limits will not be exceeded. The NRC staff believes TSTF-508 did not provide sufficient justification based on safety for continued movement of irradiated fuel assemblies or performing OPDRVS before completion of Required Action B.2.
| | ML090680813 NRR-106 OFFICE PSPB:PM PSPB: LA ITSB:DIRS SCVB:DSS AADB:DRA NAME JWilliams DBaxley MHamm RDennig RTaylor (GLappert For) |
| : 1. Explain how the proposed change in TSTF-508 will ensure CRE occupant radiological exposures will not exceed limits, and CRE occupants will be protected from chemical and smoke hazards during the period of time between the discovery of one or more [CREVS/CREFS/CREACS/MCREC/CRFA] | | DATE 04/15/09 04/16/09 03/10/09 03/10/09 03/12/09 OFFICE ITSB:DIRS BC PSPB:BC NAME RElliott SRosenberg DATE 03/24/09 04/17/09 Technical Specifications Task Force Mailing List cc: |
| subsystems inoperable due to an inoperable CRE and the completion of Required Action B.2 while moving irradiated fuel or performing OPDRVs.
| | Technical Specifications Task Force Brian Mann 11921 Rockville Pike EXCEL Services Corporation Suite 100 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Rockville, MD 20852 Attention: Donald Hoffman Telephone: 301-984-4400 Telephone: 301-984-4400 E-mail: brianm@excelservices.com E-mail: donaldh@excelservices.com Kenneth Schrader Diablo Canyon Power Plant Building 104/5/21A P.O. Box 56 Avila Beach, CA 93424 Telephone: 805-545-4328 E-mail: kjse@pge.com John Messina First Energy Nuclear Operating Company 76 South Main Street Mail Stop: Akron-GO-14 Akron, OH 44308 Telephone: 330-384-5878 E-mail: jmessina@firstenergycorp.com Thomas Raidy Southern California Edison Mail Stop D-3-E P.O. Box 128 San Clemente, CA 92672 Telephone: (949) 368-7582 E-mail: Tom.Raidy@sce.com Reene' V. Gambrell Duke Energy Mailcode: ON03RC 7800 Rochester Highway Seneca, SC 29672 Telephone: 864-885-3364 E-mail: RVGambrell@duke-energy.com |
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| On page 6 of TSTF-508, the response to the question "Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?" is No. Since the STS, as amended by TSTF-448, do not allow movement of irradiated fuel while a plant's CRE boundary is inoperable, the probability of a FHA when moving irradiated fuel while a plant's CRE boundary is inoperable is essentially zero. As stated above, TSTF-508 would allow irradiated fuel movement and OPDRVs to occur while a plant's CRE boundary is inoperable. This causes the probability of a FHA when moving irradiated fuel while a plant's CRE boundary is inoperable to be greater than zero.
| | REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATION TASK FORCE (TSTF) TRAVELER 508, REVISION 0 REVISE CONTROL ROOM HABITABILITY ACTIONS TO ADDRESS LESSONS LEARNED FROM TSTF-448 IMPLEMENTATION (TAC NO. MD9433) |
| Similarly, STS as amended by TSTF-448 cause the consequences of a FHA while a plant's CRE boundary is inoperable to be essentially zero. Using the STS proposed by TSTF-508 could cause the consequences of a FHA while a plant's CRE boundary is inoperable to be significantly greater than the consequences of a FHA when using the STS as amended by TSTF-448.
| | By letter dated July 3, 2008, the Pressurized Water Reactors Owners Group (PWROG) submitted TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation. As discussed below, the NRC staff has determined that additional information is needed to complete the review. |
| | The Standard Technical Specifications (STS), as amended by TSTF-448, require immediate suspension of movement of irradiated fuel and immediate suspension of Operations with a Potential for Draining the Reactor Vessel (OPDRVs) for boiling water reactors (BWRs) when one or more Control Room Emergency Ventilation System/Control Room Emergency Filtration System/Control Room Emergency Air Cleanup System/Main Control Room Environmental Control/Control Room Fresh Air [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable control room envelope (CRE) boundary. |
| | TSTF-508 contains 3 basic changes to the STS, as amended by TSTF-448. The changes are described on page 2 of TSTF-508 (Agencywide Documents Access and Management System (ADAMS) accession number ML081850420). This request for additional information pertains to the change described in paragraph a on page 2 of TSTF-508. Among other things, those changes provide a relaxation of the restrictions on movement of irradiated fuel and OPDRVs when one or more [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable CRE boundary. The proposed changes allow operators to continue movement of irradiated fuel and continue OPDRVs for up to 90 days when one or more |
| | [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable CRE boundary. |
| | The second paragraph on page 5 of TSTF-508 (Technical Analysis) provides justification for the relaxation of the restrictions on fuel movement and OPDRVs. The first justification states: First, suspension of fuel movement is unnecessary if Required Action B.2 verifies that the required mitigating actions protect the CRE occupants, just as is required in the operating Modes. When one or more [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable CRE boundary, the proposed changes to the STS as written allow movement of irradiated fuel and OPDRVs to continue for up to 24 hours prior to completion of Required Action B.2. This appears to conflict with the justification given in the second paragraph on page 5 of TSTF-508, in that the justification seems to imply that fuel movement would be suspended until Required Action B.2 is complete. The NRC staff also believes that it is prudent to immediately suspend fuel handling operations or OPDRVs until after Required Action B.2 is complete. The characteristic risk of a Fuel Handling Accident (FHA), and the dynamic nature of plant maintenance, repair, testing, and other ongoing operations that could be taking place during Modes 5 and 6 is of primary concern. |
| | ENCLOSURE |
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| Therefore, the staff does not agree with the justification or the response to the question "Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?" proposed in TSTF-508. | | In TSTF-448, rev. 3, Required Action B.2 is applicable to MODES 1 through [4](hot shutdown). |
| : 2. Explain or provide further justification for the response to the question "Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?"}} | | The 24-hour Completion Time of new Required Action B.2 is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions as directed by Required Action B.1. Generally, the plant would be expected to remain in a steady state condition during the 24-hour verification time. However, there is the possibility of a fuel handling accident each time a fuel assembly is moved. TSTF-508 would permit continued movement of fuel, and therefore, continued risk of a fuel handling accident, for up to 24-hours before completing the verification that mitigating actions protect CRE occupants from chemical and smoke hazards and that radiological limits will not be exceeded. The NRC staff believes TSTF-508 did not provide sufficient justification based on safety for continued movement of irradiated fuel assemblies or performing OPDRVS before completion of Required Action B.2. |
| | : 1. Explain how the proposed change in TSTF-508 will ensure CRE occupant radiological exposures will not exceed limits, and CRE occupants will be protected from chemical and smoke hazards during the period of time between the discovery of one or more [CREVS/CREFS/CREACS/MCREC/CRFA] |
| | subsystems inoperable due to an inoperable CRE and the completion of Required Action B.2 while moving irradiated fuel or performing OPDRVs. |
| | On page 6 of TSTF-508, the response to the question Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? is No. |
| | Since the STS, as amended by TSTF-448, do not allow movement of irradiated fuel while a plants CRE boundary is inoperable, the probability of a FHA when moving irradiated fuel while a plants CRE boundary is inoperable is essentially zero. As stated above, TSTF-508 would allow irradiated fuel movement and OPDRVs to occur while a plants CRE boundary is inoperable. This causes the probability of a FHA when moving irradiated fuel while a plants CRE boundary is inoperable to be greater than zero. |
| | Similarly, STS as amended by TSTF-448 cause the consequences of a FHA while a plants CRE boundary is inoperable to be essentially zero. Using the STS proposed by TSTF-508 could cause the consequences of a FHA while a plants CRE boundary is inoperable to be significantly greater than the consequences of a FHA when using the STS as amended by TSTF-448. |
| | Therefore, the staff does not agree with the justification or the response to the question Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? proposed in TSTF-508. |
| | : 2. Explain or provide further justification for the response to the question Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?}} |
Letter Sequence RAI |
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TAC:MD9433, Control Room Habitability, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation (Open) |
|
MONTHYEARML0827504932008-10-0707 October 2008
Acceptance for Review and Establishment of Milestone Schedule for TSTF Traveler 508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation
Project stage: Acceptance Review
ML0906808132009-04-17017 April 2009
Request for Additional Information Regarding TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation
Project stage: RAI
TSTF-10-18, Response to NRC Request for Additional Information on TSTF-508, Revision 1, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation2010-10-11011 October 2010
Response to NRC Request for Additional Information on TSTF-508, Revision 1, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation
Project stage: Response to RAI
ML1104205302011-02-0909 February 2011
ITSB Resolution of Excel Services Corporation Proposed TSTF-426 Wording
Project stage: Other
ML1105606302011-03-23023 March 2011
February 9, 2011, Summary of NRC Meeting with the Technical Specifications Task Force Discussed the Topics as Presented on the Agenda
Project stage: Request
ML1103803112011-03-23023 March 2011
2/9/11 Meeting Handout - NRC Staff'S Draft LCO 3.0.X
Project stage: Request
ML1108908172011-04-12012 April 2011
Request for Additional Information Regarding TSTF-508, Revision 1, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation
Project stage: RAI
2010-10-11
[Table View] |
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Category:Letter
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TSTF-19-08, Draft of Traveler TSTF-582, Revision 0, RPV WIC Enhancements.2019-07-0303 July 2019
Draft of Traveler TSTF-582, Revision 0, RPV WIC Enhancements.
TSTF-19-06, TSTF Comments on Draft Safety Evaluations for Traveler TSTF-569, Revision 1, Revise Response Time Testing Definition2019-06-25025 June 2019
TSTF Comments on Draft Safety Evaluations for Traveler TSTF-569, Revision 1, Revise Response Time Testing Definition
2024-09-06
[Table view]
Category:Request for Additional Information (RAI)
MONTHYEARML24264A0232024-09-20020 September 2024
RAI TSTF-600, Rev. 0, Revise the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) Leakage Testing Frequency
ML23222A2272023-08-10010 August 2023
Request for Additional Information Traveler TSTF-592, Revision 1, Revise Automatic Depressurization System (ADS) Instrumentation Requirements
ML23010A2592023-01-11011 January 2023
Request for Additional Information Traveler TSTF-592, Revision 0, Revise Automatic Depressurization System (ADS) Instrumentation Requirements
ML22272A5542022-10-0707 October 2022
Request for Additional Information Traveler TSTF-591, Revise Risk Informed Completion Time (RICT) Program
ML22235A7382022-08-19019 August 2022
NRR E-mail Capture - Draft RAIs for TSTF-591 (L-2022-PMP-0003)
ML22193A2372022-07-12012 July 2022
Request for Additional Information TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown
ML21109A1352021-04-12012 April 2021
TSTF-576 NRC Comments on Draft Rev 1 and Draft RAI Response
ML20308A6562020-11-0606 November 2020
Request for Additional Information Traveler TSTF-577, Revision 0, Revised Frequencies for Steam Generator Tube Inspections
ML20132A1832020-05-11011 May 2020
Request for Additional Information TSTF-576, Revision 0, Revised Safety/Relief Valve Requirement
ML20065J9902020-03-0505 March 2020
March 5 2020 TSTF Quarterly Meeting Handout, Agenda Item Iiib - Generic RAIs for LARs to Adopt TSTF-505 Rict
ML19323D5342019-11-19019 November 2019
Draft RAIs TSTF-554, Revise Reactor Coolant Leakage
ML18134A0752018-05-21021 May 2018
Request for Additional Information (RAI) Technical Specifications Task Force (TSTF) Traveler TSTF-569, Revise Response Time Testing Definition
ML18127A4052018-05-0707 May 2018
Draft RAI TSTF-569, Revise Response Time Testing Definition.
ML18122A1662018-04-27027 April 2018
Draft RAIs TSTF-568, Clarify Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.
ML18095A2292018-04-12012 April 2018
Request for Additional Information Traveler TSTF-564, Safety Limit MCPR
ML18085A0252018-03-20020 March 2018
Traveler TSTF-564, Safety Limit MCPR, Draft RAIs
ML18100A0942018-01-29029 January 2018
Draft RAIs from Apla TSTF-563, Revise Instrument Testing Definitions to Incorporate SFCP
ML16215A1252016-08-0202 August 2016
Request for Additional Information for Technical Specifications Task Force TSTF-553, Revision 0, Add Action for Two Inoperable Control Room Emergency Air Temperature Control System Trains, CAC No. MF7061
ML16028A4532016-02-23023 February 2016
Request for Additional Information TSTF-553, Add Action for Two Inoperable Creatcs (Control Room Emergency Air Temperature Control System) Trains.
ML15322A2842016-02-0404 February 2016
Request for Additional Information TSTF-537, Revision 0, Increase CIV Completion Time; Update of TSTF-373.
ML15322A2702016-01-12012 January 2016
Request for Additional Information Regarding Traveler TSTF-454, Revision 3, Extend PCIV Completion Times (NEDC-33046).
ML15293A1612015-12-0808 December 2015
Request for Additional Information (RAI) TSTF 542, Rev. 1, Reactor Pressure Vessel Water Inventory Control,
ML15281A2912015-11-18018 November 2015
Request for Additional Information Regarding TSTF-551, Revision 1, Revise Secondary Containment Surveillance Requirements.
ML15208A2872015-08-13013 August 2015
Request for Additional Information Traveler TSTF-541, Rev 0, Add Exceptions to Surveillance Requirements When the Safety Function Is Being Performed
ML15033A1082015-06-0202 June 2015
Draft Request for Additional Information Traveler TSTF-529, Revision 2, Clarify Use and Application Rules
TSTF-14-17, Technical Specification Task Force - Response to NRC Request for Additional Information Regarding TSTF-454, Revision, Extend PCIV Completion Times (NEDC-33046) and Submittal of TSTF-454, Revision 32015-03-31031 March 2015
Technical Specification Task Force - Response to NRC Request for Additional Information Regarding TSTF-454, Revision, Extend PCIV Completion Times (NEDC-33046) and Submittal of TSTF-454, Revision 3
ML15057A2482015-02-26026 February 2015
Notice of Forthcoming Public Meeting Between the U.S. Nuclear Regulatory Commission and the Technical Specifications Task Force TSTF-551
ML14310A3442014-11-0606 November 2014
Draft RAI from Srxb TSTF-547, Clarification of Rod Position Requirements.
ML14196A4142014-07-0707 July 2014
TSTF Handout from 7/10/14 Meeting TSTF Concerns with TSTF-505 RAIs
ML13045A8602013-03-0404 March 2013
Request for Additional Information Traveler TSTF-537, Revision 0, Increase CIV (Containment Isolation Valve) Completion Time; Update of TSTF-373
ML12279A2082012-10-19019 October 2012
TSTF-531 RAIs
ML12279A1342012-10-19019 October 2012
TSTF-454, Rev 2, RAIs
ML12158A5472012-06-13013 June 2012
TSTF-523 Acceptance Letter and RAIs
ML1108908172011-04-12012 April 2011
Request for Additional Information Regarding TSTF-508, Revision 1, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation
ML1020402322010-07-27027 July 2010
Request for Additional Information Regarding TSTF-505, Revision 0, on Risk-Informed Extended Completion Times - RITSTF Initiative 4b
ML1015304012010-07-0707 July 2010
Acceptance for Review and Request for Additional Information for TSTF-432, Revision 0, Change in Technical Specifications End States (WCAP-16294).
ML0914704322009-06-11011 June 2009
Request for Additional Information Regarding TSTF-514 on Reactor Coolant System Leakage Detection
ML0906808132009-04-17017 April 2009
Request for Additional Information Regarding TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation
ML0828004842008-11-0404 November 2008
Evaluation of TSTF Responses to NRC Staff Request for Additional Information (RAI) Regarding Traveler TSTF-493, Revision 2, Clarify Application of Setpoint Methodology for LSSS Functions.
ML0820406052008-08-13013 August 2008
RAI for Review of TSTF-506, Rev 0
ML0812101752008-06-0404 June 2008
Request for Additional Information Regarding TSTF-500, Rev. 0, DC Electrical Rewrite - Update to TSTF-360.
ML0810400032008-05-0505 May 2008
Request for Additional Information Regarding TSTF-501, Revision 0, Relocate Stored Fuel Oil and Lube Oil Values to Licensee Control
ML0721206302007-10-0202 October 2007
Request for Additional Information (RAI) Regarding TSTF Traveler 425, Revision 1, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5.
ML0627700892006-11-0909 November 2006
Request for Additional Information Regarding TSTF-478, Revision 0, BWR Technical Specification Changes That Implement the Revised Rule for Combustible Gas Control
2024-09-20
[Table view] |
Text
April 17, 2009 Technical Specification Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING TSTF-508, REVISION 0, REVISE CONTROL ROOM HABITABILITY ACTIONS TO ADDRESS LESSONS LEARNED FROM TSTF-448 IMPLEMENTATION (TAC NO. MD9433)
Dear Members of the TSTF,
By letter dated July 3, 2008, the Pressurized Water Reactors Owners Group (PWROG) submitted TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation. The staff has determined that additional information is needed to complete the review. Enclosure 1 is the NRC staffs request for additional information (RAI). Please contact me at (301)415-1470 or by electronic mail at joseph.williams@nrc.gov if you have any questions on this topic.
Sincerely,
/RA/
Joseph F. Williams, Senior Project Manager Special Projects Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Information cc: See next page
ML090680813 NRR-106 OFFICE PSPB:PM PSPB: LA ITSB:DIRS SCVB:DSS AADB:DRA NAME JWilliams DBaxley MHamm RDennig RTaylor (GLappert For)
DATE 04/15/09 04/16/09 03/10/09 03/10/09 03/12/09 OFFICE ITSB:DIRS BC PSPB:BC NAME RElliott SRosenberg DATE 03/24/09 04/17/09 Technical Specifications Task Force Mailing List cc:
Technical Specifications Task Force Brian Mann 11921 Rockville Pike EXCEL Services Corporation Suite 100 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Rockville, MD 20852 Attention: Donald Hoffman Telephone: 301-984-4400 Telephone: 301-984-4400 E-mail: brianm@excelservices.com E-mail: donaldh@excelservices.com Kenneth Schrader Diablo Canyon Power Plant Building 104/5/21A P.O. Box 56 Avila Beach, CA 93424 Telephone: 805-545-4328 E-mail: kjse@pge.com John Messina First Energy Nuclear Operating Company 76 South Main Street Mail Stop: Akron-GO-14 Akron, OH 44308 Telephone: 330-384-5878 E-mail: jmessina@firstenergycorp.com Thomas Raidy Southern California Edison Mail Stop D-3-E P.O. Box 128 San Clemente, CA 92672 Telephone: (949) 368-7582 E-mail: Tom.Raidy@sce.com Reene' V. Gambrell Duke Energy Mailcode: ON03RC 7800 Rochester Highway Seneca, SC 29672 Telephone: 864-885-3364 E-mail: RVGambrell@duke-energy.com
REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATION TASK FORCE (TSTF) TRAVELER 508, REVISION 0 REVISE CONTROL ROOM HABITABILITY ACTIONS TO ADDRESS LESSONS LEARNED FROM TSTF-448 IMPLEMENTATION (TAC NO. MD9433)
By letter dated July 3, 2008, the Pressurized Water Reactors Owners Group (PWROG) submitted TSTF-508, Revision 0, Revise Control Room Habitability Actions to Address Lessons Learned from TSTF-448 Implementation. As discussed below, the NRC staff has determined that additional information is needed to complete the review.
The Standard Technical Specifications (STS), as amended by TSTF-448, require immediate suspension of movement of irradiated fuel and immediate suspension of Operations with a Potential for Draining the Reactor Vessel (OPDRVs) for boiling water reactors (BWRs) when one or more Control Room Emergency Ventilation System/Control Room Emergency Filtration System/Control Room Emergency Air Cleanup System/Main Control Room Environmental Control/Control Room Fresh Air [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable control room envelope (CRE) boundary.
TSTF-508 contains 3 basic changes to the STS, as amended by TSTF-448. The changes are described on page 2 of TSTF-508 (Agencywide Documents Access and Management System (ADAMS) accession number ML081850420). This request for additional information pertains to the change described in paragraph a on page 2 of TSTF-508. Among other things, those changes provide a relaxation of the restrictions on movement of irradiated fuel and OPDRVs when one or more [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable CRE boundary. The proposed changes allow operators to continue movement of irradiated fuel and continue OPDRVs for up to 90 days when one or more
[CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable CRE boundary.
The second paragraph on page 5 of TSTF-508 (Technical Analysis) provides justification for the relaxation of the restrictions on fuel movement and OPDRVs. The first justification states: First, suspension of fuel movement is unnecessary if Required Action B.2 verifies that the required mitigating actions protect the CRE occupants, just as is required in the operating Modes. When one or more [CREVS/CREFS/CREACS/MCREC/CRFA] subsystems is inoperable due to an inoperable CRE boundary, the proposed changes to the STS as written allow movement of irradiated fuel and OPDRVs to continue for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to completion of Required Action B.2. This appears to conflict with the justification given in the second paragraph on page 5 of TSTF-508, in that the justification seems to imply that fuel movement would be suspended until Required Action B.2 is complete. The NRC staff also believes that it is prudent to immediately suspend fuel handling operations or OPDRVs until after Required Action B.2 is complete. The characteristic risk of a Fuel Handling Accident (FHA), and the dynamic nature of plant maintenance, repair, testing, and other ongoing operations that could be taking place during Modes 5 and 6 is of primary concern.
ENCLOSURE
In TSTF-448, rev. 3, Required Action B.2 is applicable to MODES 1 through [4](hot shutdown).
The 24-hour Completion Time of new Required Action B.2 is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions as directed by Required Action B.1. Generally, the plant would be expected to remain in a steady state condition during the 24-hour verification time. However, there is the possibility of a fuel handling accident each time a fuel assembly is moved. TSTF-508 would permit continued movement of fuel, and therefore, continued risk of a fuel handling accident, for up to 24-hours before completing the verification that mitigating actions protect CRE occupants from chemical and smoke hazards and that radiological limits will not be exceeded. The NRC staff believes TSTF-508 did not provide sufficient justification based on safety for continued movement of irradiated fuel assemblies or performing OPDRVS before completion of Required Action B.2.
- 1. Explain how the proposed change in TSTF-508 will ensure CRE occupant radiological exposures will not exceed limits, and CRE occupants will be protected from chemical and smoke hazards during the period of time between the discovery of one or more [CREVS/CREFS/CREACS/MCREC/CRFA]
subsystems inoperable due to an inoperable CRE and the completion of Required Action B.2 while moving irradiated fuel or performing OPDRVs.
On page 6 of TSTF-508, the response to the question Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? is No.
Since the STS, as amended by TSTF-448, do not allow movement of irradiated fuel while a plants CRE boundary is inoperable, the probability of a FHA when moving irradiated fuel while a plants CRE boundary is inoperable is essentially zero. As stated above, TSTF-508 would allow irradiated fuel movement and OPDRVs to occur while a plants CRE boundary is inoperable. This causes the probability of a FHA when moving irradiated fuel while a plants CRE boundary is inoperable to be greater than zero.
Similarly, STS as amended by TSTF-448 cause the consequences of a FHA while a plants CRE boundary is inoperable to be essentially zero. Using the STS proposed by TSTF-508 could cause the consequences of a FHA while a plants CRE boundary is inoperable to be significantly greater than the consequences of a FHA when using the STS as amended by TSTF-448.
Therefore, the staff does not agree with the justification or the response to the question Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? proposed in TSTF-508.
- 2. Explain or provide further justification for the response to the question Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?