TSTF-09-06, Notification of Industry Guidance Regarding Commitment in TSTF-372-A, Revision 4, Addition of LCO 3.0.8, Inoperability of Snubbers.

Notification of Industry Guidance Regarding Commitment in TSTF-372-A, Revision 4, Addition of LCO 3.0.8, Inoperability of Snubbers.

ML090510663
Person / Time
Site:	Technical Specifications Task Force
Issue date:	02/20/2009
From:	Gambrell R, Joseph Messina, Raidy T W, Schrader K J Babcock & Wilcox, BWR Owners Group, PWR Owners Group, Technical Specifications Task Force
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TSTF-09-06
Download: ML090510663 (2)

Text

TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVIT Y TSTF February 20, 2009 TSTF-09-06 PROJ0753

U. S. Nuclear Regulatory Commission Attn: Document Control Desk

Washington, DC 20555-0001

SUBJECT:

Notification of Industry Guidance Regarding Commitment in TSTF-372-A, Revision 4, "Addition of LCO 3.0.8, Inoperability of Snubbers"

Dear Sir or Madam:

TSTF-372-A, Revision 4, "Addition of LCO 3.0.8, Inoperability of Snubbers," was approved by the NRC in a Notice of Availability published on May 4, 2005. The model Safety Evaluation for TSTF-372 contains a commitment for Pressurized Water Reactor (PWR) plan ts regarding the use of paragraph 'a' of the new LCO 3.0.8. The commitment requires the availa bility of a train of Auxiliary Feedwater System (A FW) not associated with the inoperable snubber when LCO 3.0.8.a is used.

The wording of the commitment has resulted in an unintended restrictio

n. Most snubbers are tested during shutdown. The rando m testing of snubbers requires expansion of the test sample when failures are discovered. This may occur at a point in the outage when the expanded sample results in a need for application of LCO 3.0.8.a when AFW is not available.

This situation is specific to use of LCO 3.0.8.a. The Safety Evaluation commitment for use of LCO 3.0.8.b states, "At least one AFW train - not associated with the in operable snubber(s), or some alternative means of core cooling - must be available." The corresponding commitment for use of LCO 3.0.8.a at Boiling Water Reactors does not have this limitation.

NEI 99-04, "Guidelines for Managing NRC Commitment Change s," contains a process for changing regulatory commitments. NEI 99-04 was endorsed by the NRC in RIS-2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," as an acceptable way for licensees to control regulatory commitments. The process in NEI 99-04 allows licensees that have adopted TSTF-372 to revise the regulatory commitment to require the availability of a train of AFW, or some alternative means of core cooling, not associated with the inoperable snubber when LCO 3.0.8.a is used.

This change to the commitment has no effect on the LCO 3.0.8 Specifications or Bases. The TSTF is recommending revision of the commitment to licensees operating PWRs that submit amendment requests to adopt TSTF-372. Arkansas Nuclear One Unit 1 recently 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administered by EXCEL Services Corporation

TSTF 09-06 February 20, 2009 Page 2 submitted an amendment request to adopt TSTF-372 and also requested a change to the commitment. The amendment request was approved by the NRC on January 28, 2009.

The TSTF is not requesting any action by the NRC. We are informing the NRC that future amendment requests to adopt TSTF-372 may request a change to the commitment in the model Safety Evaluation.

Should you have any questions, please do not hesitate to contact us.

Kenneth J. Schrader (PWROG/W) John Messina (BWROG)

Thomas W. Raidy (PWROG/CE)

Reene' Gambrell (PWROG/B&W)

Enclosure

cc: Robert Elliott, Technical Specifications Branch, NRC Joseph Williams, Special Projects Branch, NRC