ML17208A158: Difference between revisions

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| issue date = 07/24/2017
| issue date = 07/24/2017
| title = Discussion of I&C Related Issues Regarding TSTF-505 for July 25 and Augsut 1, 2017 Teleconferences
| title = Discussion of I&C Related Issues Regarding TSTF-505 for July 25 and Augsut 1, 2017 Teleconferences
| author name = Mann B D
| author name = Mann B
| author affiliation = Excel Services Corp
| author affiliation = Excel Services Corp
| addressee name = Honcharik M
| addressee name = Honcharik M
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| docket = PROJ0753
| docket = PROJ0753
| license number =  
| license number =  
| contact person = Honcharik M C
| contact person = Honcharik M
| case reference number = TSTF-505
| case reference number = TSTF-505
| document type = E-Mail
| document type = E-Mail
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=Text=
=Text=
{{#Wiki_filter:From: Brian Mann <Brian.Mann@excelservices.com> Sent: Monday, July 24, 2017 2:38 PM To: Honcharik, Michelle Cc: ANDERSON, Victoria; Tjader, Theodore; kjse@pge.com; Myung.Kang@duke-energy.com  
{{#Wiki_filter:From:                   Brian Mann <Brian.Mann@excelservices.com>
Sent:                   Monday, July 24, 2017 2:38 PM To:                     Honcharik, Michelle Cc:                     ANDERSON, Victoria; Tjader, Theodore; kjse@pge.com; Myung.Kang@duke-energy.com


==Subject:==
==Subject:==
[External_Sender] Discussion of I&C Related Issues regarding TSTF-505 Michelle, The industry would like to discuss three issues related to instrumentation and control (I&C) systems modified by TSTF-505. These issues were raised by the NRC the May 4, 2017 document.
[External_Sender] Discussion of I&C Related Issues regarding TSTF-505
Issue 1: Many of the Conditions in the NRC's table are for conditions similar to "One or more channels-inoperable" or "two or more channels-inoperable." While the safety function may be performed with some number of channels inoperable, it may not be possible to perform the function for all circumstances in which the phrase "or more" would be applicable.
: Michelle, The industry would like to discuss three issues related to instrumentation and control (I&C) systems modified by TSTF-505. These issues were raised by the NRC the May 4, 2017 document.
Issue 1: Many of the Conditions in the NRC's table are for conditions similar to "One or more channelsinoperable" or "two or more channelsinoperable." While the safety function may be performed with some number of channels inoperable, it may not be possible to perform the function for all circumstances in which the phrase "or more" would be applicable.
Industry Suggested Resolution: An alternative to the presentation in TSTF-505 would be to limit the TS Condition to when the minimum number of channels needed to perform the function are operable (assuming no additional failures). The Required Actions and Completion Times would be the same and would provide the option to calculate a RICT. Either a new condition would be created that applies when less than the minimum number of channels are operable or, depending on the construction of the TS, LCO 3.0.3 would apply. The licensee would need to justify that the function can still be performed in the revised Action.
Issue 2: The NRC table included the following for NUREG-1431, Westinghouse plants:
NUREG-        LCO and Condition Text/Description                        Comments/ Notes 1431 LCO Condition 3.3.1.F        LCO: The RTS instrumentation for each Function in          Treat as LOF Table 3.3.1-1 shall be OPERABLE.
Condition: One Power Range Neutron Flux - High channel inoperable.
Industry Question: Please explain why one Power Range Neutron Flux - High channel inoperable is treated as a loss of the ability to perform the safety function.
Issue 3: The NRC table included the following for NUREG-1431, Westinghouse plants:
NUREG-        LCO and Condition Text/Description                        Comments/ Notes 1431 LCO Condition


Industry Suggested Resolution:  An alternative to the presentation in TSTF-505 would be to limit the TS Condition to when the minimum number of channels needed to perform the function are operable (assuming no additional failures). The Required Actions and Completion Times would be the same and would provide the option to calculate a RICT. Either a new condition would be created that applies when less than the minimum number of channels are operable or, depending on the construction of the TS, LCO 3.0.3 would apply. The licensee would need to justify that the function can still be performed in the revised Action.
NUREG-       LCO and Condition Text/Description               Comments/ Notes 1431 LCO Condition 3.3.1.DD      LCO: The RTS instrumentation for each Function in Treat as LOF.
 
Table 3.3.1-1 shall be OPERABLE.
Issue 2:  The NRC table included the following for NUREG-1431, Westinghouse plants:  NUREG-1431 LCO Condition  LCO and Condition Text/Description Comments/ Notes 3.3.1.F LCO: The RTS instrumentation for each Function in Table 3.3.1-1 shall be OPERABLE.
Condition: One RTB train inoperable.
Condition:  One Power Range Neutron Flux - High channel inoperable. Treat as LOF Industry Question:  Please explain why one Power Range Neutron Flux - High channel inoperable is treated as a loss of the ability to perform the safety function.
Industry Question: As the Reactor Trip Breaker trains are independent and redundant, plese explain why one inoperable RTB train would prevent the performance of the safety function.
Issue 3:  The NRC table included the following for NUREG-1431, Westinghouse plants:  NUREG-1431 LCO Condition  LCO and Condition Text/Description Comments/ Notes NUREG-1431 LCO Condition  LCO and Condition Text/Description Comments/ Notes 3.3.1.DD LCO:  The RTS instrumentation for each Function in Table 3.3.1-1 shall be OPERABLE. Condition: One RTB train inoperable. Treat as LOF. Industry Question: As the Reactor Trip Breaker trains are independent and redundant, plese explain why one inoperable RTB train would prevent the performance of the safety function.
We look forward to discussing these issues with the NRC staff.
We look forward to discussing these issues with the NRC staff.  
Brian Brian D. Mann Vice President of Industry Programs and Services EXCEL Services Corporation Mobile (804) 339-7034 Main (301) 984-4400 E-mail: brian.mann@excelservices.com Web: www.excelservices.com Web: www.nukapedia.com}}
 
Brian  
 
Brian D. Mann Vice President of Industry Programs and Services EXCEL Services Corporation Mobile (804) 339-7034 Main   (301) 984-4400 E-mail: brian.mann@excelservices.com Web: www.excelservices.com Web: www.nukapedia.com}}

Latest revision as of 00:27, 30 October 2019

Discussion of I&C Related Issues Regarding TSTF-505 for July 25 and Augsut 1, 2017 Teleconferences
ML17208A158
Person / Time
Site: Technical Specifications Task Force
Issue date: 07/24/2017
From: Mann B
Excel Services Corp
To: Michelle Honcharik
NRC/NRR/DSS/STSB
Honcharik M
References
TSTF-505
Download: ML17208A158 (2)


Text

From: Brian Mann <Brian.Mann@excelservices.com>

Sent: Monday, July 24, 2017 2:38 PM To: Honcharik, Michelle Cc: ANDERSON, Victoria; Tjader, Theodore; kjse@pge.com; Myung.Kang@duke-energy.com

Subject:

[External_Sender] Discussion of I&C Related Issues regarding TSTF-505

Michelle, The industry would like to discuss three issues related to instrumentation and control (I&C) systems modified by TSTF-505. These issues were raised by the NRC the May 4, 2017 document.

Issue 1: Many of the Conditions in the NRC's table are for conditions similar to "One or more channelsinoperable" or "two or more channelsinoperable." While the safety function may be performed with some number of channels inoperable, it may not be possible to perform the function for all circumstances in which the phrase "or more" would be applicable.

Industry Suggested Resolution: An alternative to the presentation in TSTF-505 would be to limit the TS Condition to when the minimum number of channels needed to perform the function are operable (assuming no additional failures). The Required Actions and Completion Times would be the same and would provide the option to calculate a RICT. Either a new condition would be created that applies when less than the minimum number of channels are operable or, depending on the construction of the TS, LCO 3.0.3 would apply. The licensee would need to justify that the function can still be performed in the revised Action.

Issue 2: The NRC table included the following for NUREG-1431, Westinghouse plants:

NUREG- LCO and Condition Text/Description Comments/ Notes 1431 LCO Condition 3.3.1.F LCO: The RTS instrumentation for each Function in Treat as LOF Table 3.3.1-1 shall be OPERABLE.

Condition: One Power Range Neutron Flux - High channel inoperable.

Industry Question: Please explain why one Power Range Neutron Flux - High channel inoperable is treated as a loss of the ability to perform the safety function.

Issue 3: The NRC table included the following for NUREG-1431, Westinghouse plants:

NUREG- LCO and Condition Text/Description Comments/ Notes 1431 LCO Condition

NUREG- LCO and Condition Text/Description Comments/ Notes 1431 LCO Condition 3.3.1.DD LCO: The RTS instrumentation for each Function in Treat as LOF.

Table 3.3.1-1 shall be OPERABLE.

Condition: One RTB train inoperable.

Industry Question: As the Reactor Trip Breaker trains are independent and redundant, plese explain why one inoperable RTB train would prevent the performance of the safety function.

We look forward to discussing these issues with the NRC staff.

Brian Brian D. Mann Vice President of Industry Programs and Services EXCEL Services Corporation Mobile (804) 339-7034 Main (301) 984-4400 E-mail: brian.mann@excelservices.com Web: www.excelservices.com Web: www.nukapedia.com