ML090230254

Request for the Review of TSTF-512, Revision 0 Revise SR 3.0.3 to Address SRs That Cannot Be Performed or Are Not Met.

ML090230254
Person / Time
Site:	Technical Specifications Task Force
Issue date:	05/01/2009
From:	Boger B A Office of Nuclear Reactor Regulation, NRC/NRR/ADRO
To:	Technical Specifications Task Force
Bucholz, Kristy, NRR/DIRS 415-1295
References
Download: ML090230254 (3)

Text

May 1, 2009

Technical Specification Task Force (TSTF) 11921 Rockville Pike, Suite 100 Rockville, MD 20852

SUBJECT:

REQUEST FOR THE REVIEW OF TSTF-512, REVISION 0, "REVISE SR [SURVEILLANCE REQUIREMENT] 3.0.3 TO ADDRESS SRs THAT CANNOT BE PERFORMED OR ARE NOT MET" On October 14, 2008, the Technical Specifications Task Force (TSTF) submitted TSTF-512, Revision 0, "Revise SR 3.0.3 to Address SRs that Cannot be Performed or are Not Met," to the U.S. Nuclear Regulatory Commission (NRC) staff for review. We have conducted our review, included all supporting information provided with your application, to evaluate the new staff positions that would result from incorporating TSTF-512 changes in Standard Technical Specifications (STS) NUREG-1430 through NUREG-1434, Revision 3.0. As we notified you verbally on April 3, 2009, the NRC staff has concluded that TSTF-512 is not acceptable for review for the reasons discussed below.

Regarding SR 3.0.3(a), TSTF-512 states that proposed SR 3.0.3(a) retains the same SR 3.0.3 allowances as the NRC staff approved for use in TSTF-358-A. TSTF-358-A modified SR 3.0.3 to allow a delay period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the surveillance frequency interval, whichever is longer for surveillance intervals that are inadvertently exceeded. However, the NRC staff review determined that TSTF-512 incorporates industry TSTF-358-A SR 3.0.3 implementation guidance, through an addition to the SR 3.0.3(a) Bases, that has not been endorsed by the NRC and which would establish a new Office of Nuclear Reactor Regulation staff position. This new position would interpret surveillances described as never having been performed surveillances to be equivalent to surveillances whose test intervals are inadvertently exceeded. Analysis for this deviation from the current approved allowances of SR 3.0.3 for inadvertently exceeded surveillances was not provided for NRC staff review.

Secondly, the proposed TSTF-512 does not address technical adequacy, scope, or metrics required for the supporting risk evaluation identified in SR 3.0.3(a) and SR 3.0.3(b) which is inconsistent with Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk Informed Decisionmaking: Technical Specifications," and Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities." For the reasons stated above, the NRC staff concludes there is insufficient information in TSTF-512 to conduct a review. Therefore, your request for the review of TSTF-512 is denied.

TSTF Additionally, TSTF-512 SR 3.0.3(b) and SR 3.0.3(c) would add two new compliance exceptions to the requirements of SR 3.0.1 beyond the allowance that already exists for surveillance test intervals that are inadvertently exceeded. In consideration of these changes, the NRC staff has several concerns because SR 3.0.3(b) and SR 3.0.3(c) fundamentally alter the framework of STS Section 3.0, "Surveillance Requirement (SR) Applicability." SR 3.0.1 states that failure to meet a surveillance shall be failure to meet the LCO, it also states that failure to perform a surveillance within the specified frequency shall be failure to meet the LCO.

The SR 3.0.3(b) exception to SR 3.0.1 would apply when a licensee discovers it will not be possible to perform a surveillance within its specified frequency due to conditions that prohibit the performance of the surveillance but do not render the surveillance not met. Regarding this change, general surveillance requirement SR 3.0.2 already contains an allowance to consider an SR met if the Surveillance is performed within 1.25 times the interval specified in the surveillance Frequency.

The SR 3.0.3(c) exception to SR 3.0.1 would apply when a licensee discovers that a surveillance is not or will not be met and the licensee is able to document that the associated LCO will still be met. The condition described by this change contradicts general surveillance requirement SR 3.0.1. SR 3.0.1 requires that "failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performance of the Surveillance, shall be failure to meet the LCO."

The proposed compliance exceptions to the requirements of SR 3.0.1 would result in indeterminate and unenforceable allowances because the circumstance for which each change would apply as an exception to SR 3.0.1 cannot be readily ascertained. The improved STS are a highly structured, internally consistent set of requirements based on a set of conventions agreed upon by industry and the NRC staff through the use of formal definitions and usage rules that have been carefully crafted for over 20 years. TSTF-512 alters the general SR requirement conventions in such a manner as to call into question whether the necessary quality of components would be maintained, that facility operation would be within safety limits, and the limiting conditions for operation would be met in accordance with the requirements of 10 CFR 50.36(c)(3).

The NRC staff is willing to meet with the TSTF at some future date to respond to specific questions and provide clarification of the acceptance review findings.

Sincerely,

/RA/

Bruce A. Boger, Associate Director for Operating Reactor Oversight & Licensing Office of Nuclear Reactor Regulation

ML090230254 OFFICE ITSB:DIRS ITSB:DIRS APL:DRA ITSB:DIRS PSPB:DPR DPR DIRS:NRR ADRO:NRR NAME KBucholtz CSchulten AHowe RElliott DBaxley TBlount FBrown BABoger DATE 02/04/2009 02/04/2009 02/04/2009 02/05/2009 04/ 07/09 04/08/09 04/ 23/2009 05/1/2009