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{{#Wiki_filter:11921 Rockville Pike, Suite 100, Rockville, MD  20852 Phone: 301-984-4400, Fax: 301-984-7600 Email: tstf@excelservices.com Administered by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVIT Y TSTF January 17, 2008 TSTF-07-34 PROJ0753  
{{#Wiki_filter:TECHNICAL SPECIFICATIONS TASK FORCE TSTF                                          A JOINT OWNERS GROUP ACTIVITY January 17, 2008                                                                     TSTF-07-34 PROJ0753 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
 
U. S. Nuclear Regulatory Commission Attn: Document Control Desk  
 
Washington, DC 20555-0001  


==SUBJECT:==
==SUBJECT:==
Response to N RC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surv eillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007  
Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007


==REFERENCE:==
==REFERENCE:==
Letter from Timothy Kobetz (NRC) to the Technical Specifications Task Force, "Request For Additional Information (RAI) Regarding TSTF Traveler 425, Revision 1, 'Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5'," dated October 2, 2007.  
Letter from Timothy Kobetz (NRC) to the Technical Specifications Task Force, "Request For Additional Information (RAI) Regarding TSTF Traveler 425, Revision 1, 'Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5'," dated October 2, 2007.


==Dear Sir or Madam:==
==Dear Sir or Madam:==


In the referenced letter, the NRC provided a Request for Additional Information (RAI) regarding TSTF-425, Revision 1, "Relocate Surveillance Fr equencies to Licensee Control - RITSTF Initiative 5b." This letter responds to the NRC's request.  
In the referenced letter, the NRC provided a Request for Additional Information (RAI) regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b." This letter responds to the NRC's request.
In responding to the RAI, the TSTF identified changes to TSTF-425. The changes are described in the enclosure. A complete revision of TSTF-425 is on the enclosed CD-ROM.
The NRC's review of TSTF-425 was granted a fee waiver in the NRC letter to A. R. Pietrangelo dated January 10, 2003. We request that the NRC review of the revision to TSTF-425 continue to be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. Specifically, the request is to support NRC generic regulatory improvements (risk management technical specifications),
in accordance with 10 CFR 170.11(a)(1)(iii).
The TSTF requests that the Traveler be made available under the Consolidated Line Item Improvement Process.
11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Email: tstf@excelservices.com Administered by EXCEL Services Corporation


In responding to the RAI, the TSTF identified changes to TSTF-425. The changes are described in the enclosure. A complete revision of TSTF-425 is on the enclosed CD-ROM.  
TSTF 07-34 January 17, 2008 Page 2 Contact Name:                Brian Mann Mailing Address:      EXCEL Services Corporation 11921 Rockville, Pike, Suite 100 Rockville, MD 20852 E-Mail Address:      brianm@excelservices.com Phone Number:        301-984-4400 Document Components:
One CD-ROM is included in this submission. The CD-ROM labeled "TSTF-425, Rev. 2" contains the following two (2) files:
TSTF-07-34 resp to RAI on TSTF-425R2.pdf, 202,288 bytes, publicly available TSTF-425,Rev2.pdf, 57,824,756 bytes, publicly available Should you have any questions, please do not hesitate to contact us.
Bert Yates (PWROG/W)                                John Messina (BWROG)
David Bice (PWROG/CE)                                Reene' Gambrell (PWROG/B&W)
Enclosure cc:    Gerald Waig, Technical Specifications Branch, NRC Matthew Hamm, Technical Specifications Branch, NRC


The NRC's review of TSTF-425 was granted a fee wa iver in the NRC letter to A. R. Pietrangelo dated January 10, 2003. We request that the NRC review of the re vision to TSTF-425 continue to be granted a fee waiver pursuant to the pr ovisions of 10 CFR 170.11. Sp ecifically, the request is to support NRC generic regulatory improvements (risk management technical specifications),
Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007 The following is the Technical Specification Task Force (TSTF) response to NRCs October 2, 2007, letter requesting additional information needed to complete the review of TSTF-425.
in accordance with 10 CFR 170.11(a)(1)(iii).  
: 1. Question:
Surveillance requirements (SR) with frequencies based on reactor core exposures (i.e.,
effective full power days, cumulative time operating in mode 1, or megawatt-days per ton) will be relocated by TSTF-425 to the Surveillance Frequency Control Program (SFCP).
However, the pilot application of NEI 04-10, Rev. 0, did not relocate these types of surveillance frequencies, and NEI 04-10 does not address evaluation of core exposure based tests. Provide a revision to TSTF-425 which retains these core exposure based SRs.
The scope of this comment is for the following SRs:
NUREG-1430:          SR 3.1.2.1 NUREG-1431:          SR 3.1.2.1      SR 3.2.1.1      SR 3.2.1.2    SR 3.2.2.1 SR 3.2.3.2      SR 3.2.3.3      SR 3.3.1.3    SR 3.3.1.6 NUREG-1432:          SR 3.1.2.1      SR 3.2.2.1      SR 3.2.3.1    SR 3.2.3.3 NUREG-1433:          SR 3.1.4.2      SR 3.3.1.1.6 NUREG-1434:          SR 3.1.4.2      SR 3.3.1.1.6


The TSTF requests that the Traveler be made available under the Consolidated Line Item Improvement Process.  
===Response===
We disagree that the methodology in NEI 04-10 does not allow for the evaluation of Frequency changes for Surveillances whose Frequency is based on core exposure.
NEI 04-10, Revision 1, Step 10, "Perform Qualitative or Bounding Risk Analysis," and Step 10a, "Qualitative Analysis Sufficient for IDP?" specifically address situations in which the change in Frequency cannot be explicitly modeled in the plant PRA. Those sections are applicable to evaluation of Surveillances with a Frequency expressed in terms of core exposure.
The Limerick pilot application of Initiative 5b did not relocate Frequencies based on core exposure. However, the Diablo Canyon pilot application (ADAMS Accession Number ML072950183) relocated these core exposure based Frequencies. (The BWR/4 Standard Technical Specifications contain only one Surveillance with a Frequency based on core exposure while the Westinghouse plant Standard Technical Specifications contain twelve.)
Enclosure 5 of the Diablo Canyon submittal, "Surveillance Test Interval Evaluation Forms,"
included a successful evaluation of the extension of the Frequency of SR 3.1.2.1 (Verify Measured Core Reactivity) from 31 Effective Full Power Days (EFPD) to 92 EFPD using the Step 10a of the methodology in NEI 04-10. Given this successful demonstration that the methodology of NEI 04-10 can be used to evaluate Frequencies based on core exposure, TSTF-425, Revision 2, retained the relocation of the noted Surveillances.
: 2. Question:
In NUREG-1433 SR 3.8.6.6, and NUREG-1434 SR 3.8.6.6, TSTF-425 will relocate the 12-month and 24-month surveillance frequencies associated with degraded batteries, or batteries exceeding 85 percent of their expected life based on available capacity. This is inconsistent


TSTF 07-34 January 17, 2008 Page 2 Contact Name: Brian Mann Mailing Address: EXCEL Services Corporation 11921 Rockville, Pike, Suite 100 Rockville, MD 20852 E-Mail Address: brianm@excelservices.com Phone Number: 301-984-4400
Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007 with the proposed changes to similar SRs in NUREG-1430, NUREG-1431, and NUREG-1432, which would only relocate the 60-month frequency associated with non-degraded batteries. The staff considers the specific conditions of battery degradation, age, and capacity as not within the scope of NEI 04-10. Provide a revision to TSTF-425 which retains, in NUREG-1433 and NUREG-1434, the SRs for degraded or old batteries.


Document Components:  
===Response===
The TSTF agrees that the specific conditions of battery degradation, age, and capacity are not within the scope of NEI 04-10. Surveillance 3.8.6.6 in NUREG-1430, -1431, -1432, -1433, and -1434 is revised to retain the conditions of battery degradation, age, and capacity, while relocating the Frequencies consistent with the NRC-approved Limerick lead plant submittal.
The Limerick Surveillances, 4.8.2.1.e and 4.8.2.1.f, contain the same requirements as ISTS Surveillance 3.8.6.6. The 60 month Frequency is relocated to the Surveillance Frequency Control Program (SFCP). The 12 month and 24 month Frequencies associated with degraded batteries, or batteries exceeding 85 percent of their expected life based on available capacity are relocated to the SFCP, but the criteria related to battery degradation, age, and capacity are retained.
: 3. Question:
TSTF-425 proposes to relocate a TS note from NUREG-1433 SR 3.6.1.1.2, which defines the condition for which the increased frequency of testing of drywell to suppression chamber differential pressure decrease [sic]. Relocating conditions for the performance of a SR are not within the scope of changes involving the SFCP, and are not appropriate for inclusion in TSTF-425. Provide a revision to TSTF-425 which retains the note.


One CD-ROM is included in this submission. The CD-ROM labeled "TSTF-425, Rev. 2" contains the following two (2) files:
===Response===
Comment incorporated in TSTF-425, Revision 2 (TS and Bases).
: 4. Question:
SR 3.4.14.1 in NUREG-1430, NUREG-1431, and NUREG-1432 are not consistently revised by TSTF-425. In NUREG-1430 the TSTF proposes to retain In accordance with the Inservice Testing Program, while the in [sic] NUREG-1433 and NUREG-1434 these words would be eliminated if the Surveillance Frequency Control Program is applied. The current SR 3.4.14.1 requires testing both in accordance with the Inservice Testing Program and on a time based 18 month interval as well. Provide a revision to TSTF-425 which retains the requirement to perform the SR in accordance with the Inservice Testing Program in NUREG-1431 and NUREG-1432, consistent with the current NUREGs and the proposed change to NUREG-1430.


TSTF-07-34 resp to RAI on TSTF-425R 2.pdf, 202,288 bytes, publicly available
===Response===
Comment incorporated in TSTF-425, Revision 2 (TS and Bases). The NUREG-1430, -1431, and -1432 Bases were revised to make them consistent with the revised Frequency.
: 5. Question:
NUREG-1430 SR 3.6.3.5 time-based frequency of 92 days, which is an alternative to the Inservice Testing Program, was not proposed to be relocated, but the same SR in NUREG-


TSTF-425,Rev2.pdf, 57,824,756 bytes, publicly available
Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007 1431, NUREG-1432, and SR 3.6.1.3.6 in NUREG-1433 and NUREG-1434, are to be relocated. Provide a revision to TSTF-425 which corrects this inconsistency.


Should you have any questions, please do not hesitate to contact us.  
===Response===
The revision to NUREG-1430, SR 3.6.3.5 was omitted from Revision 1 of TSTF-425. It is incorporated in TSTF-425, Revision 2. Note that the corresponding Bases change was included in TSTF-425, Revision 1.
: 6. Question:
NUREG-1431 SR 3.3.1.8, the note prior to the event-specific requirements for SR performance is bracketed. It is not clear why the note is not still needed to support the event-driven test requirements, and should therefore be retained. Provide a revision to TSTF-425 which retains the note.


Bert Yates (PWROG/W) John Messina (BWROG)
===Response===
NUREG-1431, SR 3.3.1.8, has a fixed frequency of 184 days. The fixed frequency is relocated to the Surveillance Frequency Control Program. The SR also has three event-driven Frequencies. These event-driven Frequencies are modified by a Note which states, "Only required when not performed within previous 184 days." The 184 day limit in the Note is directly tied to the fixed 184 day fixed Frequency. We agree that retaining the Note is necessary. However, instead of retaining the Note without change, we will provide an alternative wording that would be applied when adopting TSTF-425. The Note is revised to state, "Only required when not performed within [the Frequency specified in the Surveillance Frequency Control Program or the previous 184 days]." Corresponding changes were made to the Bases. This change is incorporated in TSTF-425, Revision 2.
: 7. Question:
NUREG-1430 SR 3.3.16.2 and 3.3.16.3 - The bracketing does not appear to be correctly implemented by enclosing the existing time-based intervals. Provide a revision to TSTF-425 which corrects the bracketing.


David Bice (PWROG/CE) Reene' Gambrell (PWROG/B&W)
===Response===
Comment incorporated in TSTF-425, Revision 2. Note that the corresponding Bases changes were included in TSTF-425, Revision 1.
: 8. Question:
Proposed revisions to the standard TS bases for all five documents appropriately eliminates
[sic] all the specific surveillance frequencies. However, TSTF-425 would also eliminate the unique qualitative basis for each item, replacing this with a generic NEI 04-10 basis statement. The staff does not agree that the plant-specific TS bases for licensees implementing TSTF-425 and NEI 04-10 should not identify the unique qualitative basis for establishing the test frequencies. Revisions to test frequencies under NEI 04-10 would be expected to justify that the revised test frequency still assures the qualitative basis is satisfied.
Provide a revision to TSTF-425 which retains the qualitative basis for the SRs in the STS bases.


Enclosure
Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007


cc: Gerald Waig, Technical Specifications Branch, NRC Matthew Hamm, Technical Sp ecifications Branch, NRC
===Response===
 
We agree that licensees should not lose the qualitative basis for the test frequencies relocated to the Surveillance Frequency Control Program. However, it is inconsistent with the regulations to require that information to be retained in the Technical Specification Bases.
Response to NRC Request for Addi tional Information Regarding  TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007 The following is the Technical Specification Task Force (TSTF) response to NRC's October 2, 2007, letter requesting additional information needed to complete the review of TSTF-425.
The Bases fulfill the 10 CFR 50.36 requirement that the Technical Specifications contain a "summary statement of the bases or reasons for such specifications." Once a Frequency is relocated out of the Technical Specifications to licensee control, the regulations do not require the Bases to describe the basis for the Frequency.
: 1. Question:
The existing description of the basis for those Frequencies relocated from the Technical Specifications will be maintained by licensees adopting this change. However, the location of that information will be at the discretion of the licensee. The licensee may chose to retain that information in the Technical Specification Bases or the license may chose to maintain the information in the licensee-controlled Surveillance Frequency Control Program.
Surveillance requirements (SR) with frequenc ies based on reactor core exposures (i.e., effective full power days, cumulative time operating in mode 1, or megawatt-days per ton) will be relocated by TSTF-425 to the Surveillance Frequency Control Program (SFCP).
Licensees may choose to relocate the information to the SFCP to eliminate an error-prone situation of having the value in the licensee-controlled program and the description of the value in the Technical Specification Bases. In addition, changes to the Bases are made under the Technical Specification Bases Control Program, which utilizes a 10 CFR 50-59 evaluation. Changes to the Frequency will be made under the Surveillance Frequency Control Program. It would be inefficient to revise the description of a Frequency under the Technical Specification Bases Control Program to simply reflect a change in the Frequency made under the Surveillance Frequency Control Program.
However, the pilot application of NEI 04-10, Rev. 0, did not relocate these types of surveillance frequencies, and NEI 04-10 does not address evaluation of core exposure based tests. Provide a revision to TSTF-425 whic h retains these core exposure based SRs.
In the transmittal letter for TSTF-425, Revision 1, the TSTF requested that the NRC reflect that appropriate plant-specific changes will be made to the Technical Specifications Bases by the licensees under the Technical Specification Bases Control Program and that, therefore, revised Bases pages need not be included. This will significantly reduce the size of the plant-specific license amendment requests submitted to adopt TSTF-425.This provides the licensee the option to retain the information in the Bases or to move the information to another licensee-controlled document.
In addition to the changes to TSTF-425, Revision 1, identified above, additional changes have been identified and have been incorporated in Revision 2:
* NUREG-1431, SR 3.3.1.4 Bases, is revised to delete the phrase "on a STAGGERED TEST BASIS" in the first sentence to be consistent with the revision to SR 3.3.1.4.
* NUREG-1431, SR 3.3.1.5 Bases, is revised to delete the phrase "on a STAGGERED TEST BASIS" in the first sentence to be consistent with the revision to SR 3.3.1.5.
* NUREG-1431, SR 3.3.2.3 Bases, is revised to move the starting bracket to include the previous sentence to be consistent with the revision to SR 3.3.2.3.


The scope of this comment is for the following SRs:
Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007
 
NUREG-1430:  SR 3.1.2.1 NUREG-1431:  SR 3.1.2.1  SR 3.2.1.1  SR 3.2.1.2  SR 3.2.2.1 SR 3.2.3.2  SR 3.2.3.3  SR 3.3.1.3  SR 3.3.1.6 NUREG-1432:  SR 3.1.2.1  SR 3.2.2.1  SR 3.2.3.1  SR 3.2.3.3 NUREG-1433:  SR 3.1.4.2  SR 3.3.1.1.6 NUREG-1434:  SR 3.1.4.2  SR 3.3.1.1.6 Response: We disagree that the methodology in NEI 04-10 does not allow for the evaluation of Frequency changes for Surveillances whose Frequency is based on core exposure. NEI 04-10, Revision 1, Step 10, "Perform Qualita tive or Bounding Risk An alysis," and Step 10a, "Qualitative Analysis Sufficient for IDP?" specifically address situations in which the change in Frequency cannot be explicitly modeled in the plant PRA. Those sections are applicable to evaluation of Surveillances with a Frequency expressed in terms of core exposure. The Limerick pilot application of Initiative 5b did not relocate Frequencies based on core exposure. However, the Diablo Canyon pilot application (ADAMS Accession Number ML072950183) relocated these core exposure based Frequencies.  (The BWR/4 Standard Technical Specifications contain only one Su rveillance with a Frequency based on core exposure while the Westinghouse plant Standard Technical Specifications contain twelve.)  Enclosure 5 of the Diablo Canyon submittal, "Surveillance Test Interval Evaluation Forms," included a successful evaluation of the exte nsion of the Frequency of SR 3.1.2.1 (Verify Measured Core Reactivity) from 31 Effective Full Power Days (EFPD) to 92 EFPD using the Step 10a of the methodology in NEI 04-10. Give n this successful demonstration that the methodology of NEI 04-10 can be used to eval uate Frequencies based on core exposure, TSTF-425, Revision 2, retained the relocation of the noted Surveillances.
: 2. Question
: In NUREG-1433 SR 3.8.6.6, and NUREG-1434 SR 3.8.6.6, TSTF-425 will relocate the 12-month and 24-month surveillance frequencies associ ated with degraded batteries, or batteries exceeding 85 percent of their expected life based on available capacity. This is inconsistent Response to NRC Request for Addi tional Information Regarding  TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007 with the proposed changes to simila r SRs in NUREG-1430, NUREG-1431, and NUREG-1432, which would only relocate the 60-month frequency associated with non-degraded batteries. The staff considers the specific conditi ons of battery degradation, age, and capacity as not within the scope of NEI 04-10. Provide a revision to TSTF-425 which retains, in NUREG-1433 and NUREG-1434, the SRs for degraded or old batteries.
Response: The TSTF agrees that the speci fic conditions of battery degrad ation, age, and capacity are not within the scope of NEI 04-10. Surv eillance 3.8.6.6 in NUREG-1430, -1431, -1432, -1433, and -1434 is revised to retain the conditions of battery degradation, ag e, and capacity, while relocating the Frequencies consistent with the NRC-approved Limerick lead plant submittal. The Limerick Surveillances, 4.8.2.1.e and 4.8.2.1.f, contain the same requirements as ISTS Surveillance 3.8.6.6. The 60 month Frequency is relocated to the Surveillance Frequency Control Program (SFCP). The 12 month and 24 m onth Frequencies associated with degraded batteries, or batteries exceedi ng 85 percent of their expected life based on available capacity are relocated to the SFCP, but the criteria relate d to battery degradation, age, and capacity are retained.
: 3. Question
: TSTF-425 proposes to relocate a TS note from NUREG-1433 SR 3.6.1.1.2, which defines the condition for which the increased frequency of testing of drywell to suppression chamber differential pressure decrease [sic]. Relocati ng conditions for the performance of a SR are not within the scope of changes involving the SFCP, and are not appropriate for inclusion in TSTF-425. Provide a revision to TSTF-425 which retains the note.
Response: Comment incorporated in TSTF
-425, Revision 2 (TS and Bases).
: 4. Question
: SR 3.4.14.1 in NUREG-1430, NUREG-1431, and NUREG
-1432 are not consistently revised by TSTF-425. In NUREG-1430 the TSTF proposes to retain "In accordance with the Inservice Testing Program," while the in [sic] NUREG-1433 and NUREG-1434 these words would be eliminated if the Surveillance Frequency Control Program is applied. The current
 
SR 3.4.14.1 requires testing both in accordance with the Inservice Testing Program and on a time based 18 month interval as well. Provide a revision to TSTF-425 which retains the requirement to perform the SR in accordance with the Inservice Testing Program in NUREG-1431 and NUREG-1432, consistent with the cu rrent NUREGs and the proposed change to NUREG-1430.
Response: Comment incorporated in TSTF-425, Revisi on 2 (TS and Bases). The NUREG-1430, -1431, and -1432 Bases were revised to make them consistent with the revised Frequency.
: 5. Question
: NUREG-1430 SR 3.6.3.5 time-based frequency of 92 days, which is an alternative to the Inservice Testing Program, was not proposed to be relocated, but the same SR in NUREG-Response to NRC Request for Addi tional Information Regarding  TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007 1431, NUREG-1432, and SR 3.6.1.3.6 in NUREG-1433 and NUREG-1434, are to be relocated. Provide a revision to TSTF
-425 which corrects this inconsistency.
Response: The revision to NUREG-1430, SR 3.6.3.5 was omitted from Revision 1 of TSTF-425. It is incorporated in TSTF-425, Revision 2. Note that the corresponding Bases change was included in TSTF-425, Revision 1.
: 6. Question
: NUREG-1431 SR 3.3.1.8, the note prior to the event-specific requirements for SR performance is bracketed. It is not clear why the note is not still needed to support the event-driven test requirements, and should therefore be retained.
Provide a revision to TSTF-425 which retains the note.
Response: NUREG-1431, SR 3.3.1.8, has a fixed frequency of 184 days. The fixed frequency is relocated to the Surveillance Frequency Control Program. The SR also has three event-driven Frequencies. These event-driven Frequencies are modified by a Note which states, "Only required when not performed within previous 184 days."  The 184 day limit in
 
the Note is directly tied to the fixed 184 day fixed Frequency. We agree that retaining the Note is necessary. However, instead of retaining the Note without change, we will provide an alternative wording that would be applied when adopting TSTF-425. The Note is revised to state, "Only required when not performe d within [the Frequency specified in the Surveillance Frequency Control Program or th e previous 184 days]."  Corresponding changes were made to the Bases. This change is incorporated in TSTF-425, Revision 2.
: 7. Question
: NUREG-1430 SR 3.3.16.2 and 3.3.16.3 - The bracketing does not appear to be correctly implemented by enclosing the existing time-based intervals. Provide a revision to TSTF-425 which corrects the bracketing.
Response: Comment incorporated in TSTF-425, Revision 2.
Note that the corresponding Bases changes were included in TSTF-425, Revision 1.
: 8. Question
: Proposed revisions to the standard TS bases for all five documents appropriately eliminates
[sic] all the specific surveillan ce frequencies. However, TSTF-425 would also eliminate the unique qualitative basis for each item, replacing this with a generic NEI 04-10 basis statement. The staff does not agree that the plant-specific TS bases for licensees implementing TSTF-425 and NEI 04-10 should not identify the unique qualitative basis for establishing the test frequenc ies. Revisions to test fre quencies under NEI 04-10 would be expected to justify that the revi sed test frequency still assures th e qualitative basis is satisfied. Provide a revision to TSTF-425 which retains th e qualitative basis fo r the SRs in the STS bases.
Response to NRC Request for Addi tional Information Regarding  TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007 Response: We agree that licensees should not lose the qualitative basis fo r the test frequencies relocated to the Surveillance Frequency Control Program. However, it is inconsistent with the regulations to require that information to be retained in the Technical Specification Bases. The Bases fulfill the 10 CFR 50.36 requirement that the Technical Specifications contain a "summary statement of the bases or reasons fo r such specifications."  Once a Frequency is relocated out of the Technical Specifications to licensee control, the regulations do not require the Bases to describe the basis for the Frequency.
The existing description of th e basis for those Frequencies relocated from the Technical Specifications will be maintained by licensees adopting this change. However, the location of that information will be at the discretion of the licensee. The licensee may chose to retain that information in the Technical Specification Bases or the license may chose to maintain the information in the licensee-controlled Surveillance Frequency Control Program. Licensees may choose to relocate the information to the SFCP to eliminate an error-prone situation of having the value in the licensee-controlled program and the description of the value in the Technical Specifica tion Bases. In addition, changes to the Bases are made under the Technical Specification Bases Control Program, which utilizes a 10 CFR 50-59 evaluation. Changes to the Frequency will be made under the Surveillance Frequency Control Program. It would be inefficient to revise the description of a Frequency under the Technical Specification Bases Control Program to simply reflect a change in the Frequency made under the Surveillance Frequency Control Program. In the transmittal letter for TSTF-425, Revision 1, the TSTF requested that the NRC reflect that appropriate plant-specific changes will be made to the Technical Specifications Bases by the licensees under the Technica l Specification Bases Control Program and that, therefore, revised Bases pages need not be included. This will significantly reduce the size of the plant-specific license amendment requests submitted to adopt TSTF-425.This provides the licensee the option to retain the information in the Bases or to move the information to another licensee-controlled document.
In addition to the changes to TSTF-425, Revision 1, identified above, additional changes have been identified and have been incorporated in Revision 2:
* NUREG-1431, SR 3.3.1.4 Bases, is revised to delete the phrase "on a STAGGERED TEST BASIS" in the first sentence to be co nsistent with the revision to SR 3.3.1.4.
* NUREG-1431, SR 3.3.1.5 Bases, is revised to delete the phrase "on a STAGGERED TEST BASIS" in the first sentence to be co nsistent with the revision to SR 3.3.1.5.
* NUREG-1431, SR 3.3.2.3 Bases, is revised to mo ve the starting bracket to include the previous sentence to be consiste nt with the revision to SR 3.3.2.3.
Response to NRC Request for Addi tional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007
* NUREG-1431, SR 3.6.8.4 Bases, is revised to bracket the sentence "The Shield Building Air Cleanup System train used for this Surveillance is staggered to ensure that in addition to the requirements of LCO 3.6.8.4, either train will perform this test," to be consistent with the revision to SR 3.6.8.4.
* NUREG-1431, SR 3.6.8.4 Bases, is revised to bracket the sentence "The Shield Building Air Cleanup System train used for this Surveillance is staggered to ensure that in addition to the requirements of LCO 3.6.8.4, either train will perform this test," to be consistent with the revision to SR 3.6.8.4.
* NUREG-1432, SR 3.6.11.4 Bases, is revised to bracket the sentence "The SBEACS train used for this Surveillance is staggered to ensure that in addition to the requirements of LCO 3.6.11.4, either train will perform this test," to be consistent with the revision to SR 3.6.11.4.
* NUREG-1432, SR 3.6.11.4 Bases, is revised to bracket the sentence "The SBEACS train used for this Surveillance is staggered to ensure that in addition to the requirements of LCO 3.6.11.4, either train will perform this test," to be consistent with the revision to SR 3.6.11.4.
* NUREG-1434, SR 3.3.6.2.6 Bases, last paragraph, is revised to move the inserted opening bracket to the beginning of the paragraph.}}
* NUREG-1434, SR 3.3.6.2.6 Bases, last paragraph, is revised to move the inserted opening bracket to the beginning of the paragraph.}}

Latest revision as of 20:09, 14 November 2019

Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b, Dated October 2, 2007
ML080280272
Person / Time
Site: Technical Specifications Task Force
Issue date: 01/17/2008
From: David Bice, Gambrell R, Joseph Messina, Yates B
BWR Owners Group, PWR Owners Group, Technical Specifications Task Force
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
TSTF-425, Rev 1
Download: ML080280272 (7)
v • d • e


Text

TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY January 17, 2008 TSTF-07-34 PROJ0753 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007

REFERENCE:

Letter from Timothy Kobetz (NRC) to the Technical Specifications Task Force, "Request For Additional Information (RAI) Regarding TSTF Traveler 425, Revision 1, 'Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5'," dated October 2, 2007.

Dear Sir or Madam:

In the referenced letter, the NRC provided a Request for Additional Information (RAI) regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b." This letter responds to the NRC's request.

In responding to the RAI, the TSTF identified changes to TSTF-425. The changes are described in the enclosure. A complete revision of TSTF-425 is on the enclosed CD-ROM.

The NRC's review of TSTF-425 was granted a fee waiver in the NRC letter to A. R. Pietrangelo dated January 10, 2003. We request that the NRC review of the revision to TSTF-425 continue to be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. Specifically, the request is to support NRC generic regulatory improvements (risk management technical specifications),

in accordance with 10 CFR 170.11(a)(1)(iii).

The TSTF requests that the Traveler be made available under the Consolidated Line Item Improvement Process.

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Email: tstf@excelservices.com Administered by EXCEL Services Corporation

TSTF 07-34 January 17, 2008 Page 2 Contact Name: Brian Mann Mailing Address: EXCEL Services Corporation 11921 Rockville, Pike, Suite 100 Rockville, MD 20852 E-Mail Address: brianm@excelservices.com Phone Number: 301-984-4400 Document Components:

One CD-ROM is included in this submission. The CD-ROM labeled "TSTF-425, Rev. 2" contains the following two (2) files:

TSTF-07-34 resp to RAI on TSTF-425R2.pdf, 202,288 bytes, publicly available TSTF-425,Rev2.pdf, 57,824,756 bytes, publicly available Should you have any questions, please do not hesitate to contact us.

Bert Yates (PWROG/W) John Messina (BWROG)

David Bice (PWROG/CE) Reene' Gambrell (PWROG/B&W)

Enclosure cc: Gerald Waig, Technical Specifications Branch, NRC Matthew Hamm, Technical Specifications Branch, NRC

Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007 The following is the Technical Specification Task Force (TSTF) response to NRCs October 2, 2007, letter requesting additional information needed to complete the review of TSTF-425.

1. Question:

Surveillance requirements (SR) with frequencies based on reactor core exposures (i.e.,

effective full power days, cumulative time operating in mode 1, or megawatt-days per ton) will be relocated by TSTF-425 to the Surveillance Frequency Control Program (SFCP).

However, the pilot application of NEI 04-10, Rev. 0, did not relocate these types of surveillance frequencies, and NEI 04-10 does not address evaluation of core exposure based tests. Provide a revision to TSTF-425 which retains these core exposure based SRs.

The scope of this comment is for the following SRs:

NUREG-1430: SR 3.1.2.1 NUREG-1431: SR 3.1.2.1 SR 3.2.1.1 SR 3.2.1.2 SR 3.2.2.1 SR 3.2.3.2 SR 3.2.3.3 SR 3.3.1.3 SR 3.3.1.6 NUREG-1432: SR 3.1.2.1 SR 3.2.2.1 SR 3.2.3.1 SR 3.2.3.3 NUREG-1433: SR 3.1.4.2 SR 3.3.1.1.6 NUREG-1434: SR 3.1.4.2 SR 3.3.1.1.6

Response

We disagree that the methodology in NEI 04-10 does not allow for the evaluation of Frequency changes for Surveillances whose Frequency is based on core exposure.

NEI 04-10, Revision 1, Step 10, "Perform Qualitative or Bounding Risk Analysis," and Step 10a, "Qualitative Analysis Sufficient for IDP?" specifically address situations in which the change in Frequency cannot be explicitly modeled in the plant PRA. Those sections are applicable to evaluation of Surveillances with a Frequency expressed in terms of core exposure.

The Limerick pilot application of Initiative 5b did not relocate Frequencies based on core exposure. However, the Diablo Canyon pilot application (ADAMS Accession Number ML072950183) relocated these core exposure based Frequencies. (The BWR/4 Standard Technical Specifications contain only one Surveillance with a Frequency based on core exposure while the Westinghouse plant Standard Technical Specifications contain twelve.)

Enclosure 5 of the Diablo Canyon submittal, "Surveillance Test Interval Evaluation Forms,"

included a successful evaluation of the extension of the Frequency of SR 3.1.2.1 (Verify Measured Core Reactivity) from 31 Effective Full Power Days (EFPD) to 92 EFPD using the Step 10a of the methodology in NEI 04-10. Given this successful demonstration that the methodology of NEI 04-10 can be used to evaluate Frequencies based on core exposure, TSTF-425, Revision 2, retained the relocation of the noted Surveillances.

2. Question:

In NUREG-1433 SR 3.8.6.6, and NUREG-1434 SR 3.8.6.6, TSTF-425 will relocate the 12-month and 24-month surveillance frequencies associated with degraded batteries, or batteries exceeding 85 percent of their expected life based on available capacity. This is inconsistent

Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007 with the proposed changes to similar SRs in NUREG-1430, NUREG-1431, and NUREG-1432, which would only relocate the 60-month frequency associated with non-degraded batteries. The staff considers the specific conditions of battery degradation, age, and capacity as not within the scope of NEI 04-10. Provide a revision to TSTF-425 which retains, in NUREG-1433 and NUREG-1434, the SRs for degraded or old batteries.

Response

The TSTF agrees that the specific conditions of battery degradation, age, and capacity are not within the scope of NEI 04-10. Surveillance 3.8.6.6 in NUREG-1430, -1431, -1432, -1433, and -1434 is revised to retain the conditions of battery degradation, age, and capacity, while relocating the Frequencies consistent with the NRC-approved Limerick lead plant submittal.

The Limerick Surveillances, 4.8.2.1.e and 4.8.2.1.f, contain the same requirements as ISTS Surveillance 3.8.6.6. The 60 month Frequency is relocated to the Surveillance Frequency Control Program (SFCP). The 12 month and 24 month Frequencies associated with degraded batteries, or batteries exceeding 85 percent of their expected life based on available capacity are relocated to the SFCP, but the criteria related to battery degradation, age, and capacity are retained.

3. Question:

TSTF-425 proposes to relocate a TS note from NUREG-1433 SR 3.6.1.1.2, which defines the condition for which the increased frequency of testing of drywell to suppression chamber differential pressure decrease [sic]. Relocating conditions for the performance of a SR are not within the scope of changes involving the SFCP, and are not appropriate for inclusion in TSTF-425. Provide a revision to TSTF-425 which retains the note.

Response

Comment incorporated in TSTF-425, Revision 2 (TS and Bases).

4. Question:

SR 3.4.14.1 in NUREG-1430, NUREG-1431, and NUREG-1432 are not consistently revised by TSTF-425. In NUREG-1430 the TSTF proposes to retain In accordance with the Inservice Testing Program, while the in [sic] NUREG-1433 and NUREG-1434 these words would be eliminated if the Surveillance Frequency Control Program is applied. The current SR 3.4.14.1 requires testing both in accordance with the Inservice Testing Program and on a time based 18 month interval as well. Provide a revision to TSTF-425 which retains the requirement to perform the SR in accordance with the Inservice Testing Program in NUREG-1431 and NUREG-1432, consistent with the current NUREGs and the proposed change to NUREG-1430.

Response

Comment incorporated in TSTF-425, Revision 2 (TS and Bases). The NUREG-1430, -1431, and -1432 Bases were revised to make them consistent with the revised Frequency.

5. Question:

NUREG-1430 SR 3.6.3.5 time-based frequency of 92 days, which is an alternative to the Inservice Testing Program, was not proposed to be relocated, but the same SR in NUREG-

Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007 1431, NUREG-1432, and SR 3.6.1.3.6 in NUREG-1433 and NUREG-1434, are to be relocated. Provide a revision to TSTF-425 which corrects this inconsistency.

Response

The revision to NUREG-1430, SR 3.6.3.5 was omitted from Revision 1 of TSTF-425. It is incorporated in TSTF-425, Revision 2. Note that the corresponding Bases change was included in TSTF-425, Revision 1.

6. Question:

NUREG-1431 SR 3.3.1.8, the note prior to the event-specific requirements for SR performance is bracketed. It is not clear why the note is not still needed to support the event-driven test requirements, and should therefore be retained. Provide a revision to TSTF-425 which retains the note.

Response

NUREG-1431, SR 3.3.1.8, has a fixed frequency of 184 days. The fixed frequency is relocated to the Surveillance Frequency Control Program. The SR also has three event-driven Frequencies. These event-driven Frequencies are modified by a Note which states, "Only required when not performed within previous 184 days." The 184 day limit in the Note is directly tied to the fixed 184 day fixed Frequency. We agree that retaining the Note is necessary. However, instead of retaining the Note without change, we will provide an alternative wording that would be applied when adopting TSTF-425. The Note is revised to state, "Only required when not performed within [the Frequency specified in the Surveillance Frequency Control Program or the previous 184 days]." Corresponding changes were made to the Bases. This change is incorporated in TSTF-425, Revision 2.

7. Question:

NUREG-1430 SR 3.3.16.2 and 3.3.16.3 - The bracketing does not appear to be correctly implemented by enclosing the existing time-based intervals. Provide a revision to TSTF-425 which corrects the bracketing.

Response

Comment incorporated in TSTF-425, Revision 2. Note that the corresponding Bases changes were included in TSTF-425, Revision 1.

8. Question:

Proposed revisions to the standard TS bases for all five documents appropriately eliminates

[sic] all the specific surveillance frequencies. However, TSTF-425 would also eliminate the unique qualitative basis for each item, replacing this with a generic NEI 04-10 basis statement. The staff does not agree that the plant-specific TS bases for licensees implementing TSTF-425 and NEI 04-10 should not identify the unique qualitative basis for establishing the test frequencies. Revisions to test frequencies under NEI 04-10 would be expected to justify that the revised test frequency still assures the qualitative basis is satisfied.

Provide a revision to TSTF-425 which retains the qualitative basis for the SRs in the STS bases.

Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007

Response

We agree that licensees should not lose the qualitative basis for the test frequencies relocated to the Surveillance Frequency Control Program. However, it is inconsistent with the regulations to require that information to be retained in the Technical Specification Bases.

The Bases fulfill the 10 CFR 50.36 requirement that the Technical Specifications contain a "summary statement of the bases or reasons for such specifications." Once a Frequency is relocated out of the Technical Specifications to licensee control, the regulations do not require the Bases to describe the basis for the Frequency.

The existing description of the basis for those Frequencies relocated from the Technical Specifications will be maintained by licensees adopting this change. However, the location of that information will be at the discretion of the licensee. The licensee may chose to retain that information in the Technical Specification Bases or the license may chose to maintain the information in the licensee-controlled Surveillance Frequency Control Program.

Licensees may choose to relocate the information to the SFCP to eliminate an error-prone situation of having the value in the licensee-controlled program and the description of the value in the Technical Specification Bases. In addition, changes to the Bases are made under the Technical Specification Bases Control Program, which utilizes a 10 CFR 50-59 evaluation. Changes to the Frequency will be made under the Surveillance Frequency Control Program. It would be inefficient to revise the description of a Frequency under the Technical Specification Bases Control Program to simply reflect a change in the Frequency made under the Surveillance Frequency Control Program.

In the transmittal letter for TSTF-425, Revision 1, the TSTF requested that the NRC reflect that appropriate plant-specific changes will be made to the Technical Specifications Bases by the licensees under the Technical Specification Bases Control Program and that, therefore, revised Bases pages need not be included. This will significantly reduce the size of the plant-specific license amendment requests submitted to adopt TSTF-425.This provides the licensee the option to retain the information in the Bases or to move the information to another licensee-controlled document.

In addition to the changes to TSTF-425, Revision 1, identified above, additional changes have been identified and have been incorporated in Revision 2:

  • NUREG-1431, SR 3.3.1.4 Bases, is revised to delete the phrase "on a STAGGERED TEST BASIS" in the first sentence to be consistent with the revision to SR 3.3.1.4.
  • NUREG-1431, SR 3.3.1.5 Bases, is revised to delete the phrase "on a STAGGERED TEST BASIS" in the first sentence to be consistent with the revision to SR 3.3.1.5.
  • NUREG-1431, SR 3.3.2.3 Bases, is revised to move the starting bracket to include the previous sentence to be consistent with the revision to SR 3.3.2.3.

Response to NRC Request for Additional Information Regarding TSTF-425, Revision 1, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," dated October 2, 2007

  • NUREG-1431, SR 3.6.8.4 Bases, is revised to bracket the sentence "The Shield Building Air Cleanup System train used for this Surveillance is staggered to ensure that in addition to the requirements of LCO 3.6.8.4, either train will perform this test," to be consistent with the revision to SR 3.6.8.4.
  • NUREG-1432, SR 3.6.11.4 Bases, is revised to bracket the sentence "The SBEACS train used for this Surveillance is staggered to ensure that in addition to the requirements of LCO 3.6.11.4, either train will perform this test," to be consistent with the revision to SR 3.6.11.4.
  • NUREG-1434, SR 3.3.6.2.6 Bases, last paragraph, is revised to move the inserted opening bracket to the beginning of the paragraph.
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