ML20206E905

From kanterella
Revision as of 06:14, 11 December 2020 by StriderTol (talk | contribs) (StriderTol Bot insert)
(diff) ← Older revision | Latest revision (diff) | Newer revision → (diff)
Jump to navigation Jump to search
Summary of 881005-06 Meetings W/Util in Rockville,Md Re Proposed Changes to Tech Specs.Related Info,Including Meeting Notice W/Agenda,List of Attendees & Annotated Summary of All Unreviewed Generic Changes Encl
ML20206E905
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 10/31/1988
From: Malloy M
NRC OFFICE OF SPECIAL PROJECTS
To:
NRC OFFICE OF SPECIAL PROJECTS
References
NUDOCS 8811180237
Download: ML20206E905 (29)
v • d • e


Text

__-_ _ _ _ _ _ _ _ _ _ _ _ . _. . _ _ _

U%ITE0 $TATes t * ((p >.< ase %,Id..

NUCLEAQ REGULATORY COMMISSION  ;

i wAssiwotoN. o c.nosos ,

j.f ,

October 31, 1988 ,

+.... ,

Docket No. 50-445 APPLICANT: Texas Utilities Electric Company (TV Electric) j FACILITY: Comanche Peak Steam Electric Station (CPSES), Unit 1

SUBJECT:

SUMMARY

OF MEETING ON OCTOBER 5-6, 1988 - COMANCHE PEAK ,

UNIT 1 TECHNICAL SPECIFICATIONS On October 5-6, 1988, the NRC staff met with representatives of TV Electric in Rockville, Maryland to discuss TV Electric's proposed changes to the CPSES Unit 1 Technical Specifications (TS). The meeting notice with agenda  !

and the list of attendees are provided as Enclosures 1 and 2, respectively, -

to this susenary. ,

s v This meeting was a follow-up to the meeting held on September 22, 1988

  • c at which the 64 unreviewed TS changes addressed in T.tX-88605 (W. G. Counsil i to NRC) dated August 5, 1988 were discussed in detail. The staff advised ,

TU Electric that it ha:. placed the changes of TXX 88605 into three categories:  !

(1) thatgeneric itemsdiscussion need further NRC is presently working)on (6 items); (3 generic (22 items);

items (2) generic that may be plant-items -

specific (8 items). TXX-88605 contained 28 other unreviewed generic changes that were not placed in any of these three categories, as the staff feels they are beyond the staff's resources to review as generic changes and are not crucial to plant safety. TU Electric susenarized all the unreviewed generic changes by category in a handout (Enclosure 3) which was used durint, l the meeting to complement the prepared agenda. Enclosure 3 is annotated to show the summary status or disposition of changes resulting from this meeting.

Mr. Giardina of the Technical Specification Branch (OTSB) described the generic letters under development by the staff addressing the unreviewed TS changes in Category 1, generic items NRC is presently workinti on. He stressed that in some cases, the staff work is preliminary and the fina; form of the issuance has not yet been determined. Included in this discussion was the content of 2 pre.

liminary draft generic letters, one addressing remov.1 of tables on response time Itaits from TS and the other regarding removal of component Itsts from TS (Enclossess 4 and 5). Details are noted in Enclosure ;. For those Cate-gory 1 specs' proposed for relocation and the items in Category 2 (generic items that need M O discussion). TV Electric needs to strengthen the justification for rencving the specs and they need to be included in the Comanche Peak Steam Electric Station TS leprovement Program (CPSES-TSIP).

' See "5usanary of Meeting on September 22, 1988 - CPSES Unit 1 Technicsl Specifications. Docket 50-445, dated October 4, 1988.

m"nisMONP $ Yoi s

, S ip

. i Sumary of October 5-6, 1938 meeting TV Electric explained the purpose, scope, applicability, organization, revision control, and document control for the CPSES-TSIP, the administrative program that will control technical specifications to be removeo from the Unit 1 TS. i The CPSES TSIP will need to be reviewed and approved by the staff prior to reroyal of the specs from the Unit 1 TS. TV Electric provided a preliminary ,

outline of the program for the staff's consideration (Enclosure 6). The staff i acknowledged that the outline described an acceptable program and requested TU Electric to docket the written program for staff review several weeks before '

issuance of the Unit 1 "Proof & Review" version TS (expected in early December 1988).

The staff advised TU Electric to include the details of those items for which i Mr. Giardina has agreed can be removed from the Unit 1 TS in this docketed program.

The staff and applicant discussed the Category 3 items (generic items that may  ;

beplant-specific). Enclosure 3 is annotated to show the staff's determination t following the discussions as to whether these changes are "plant-specific" or "generic" (i.e., could be applicable to all other 4 loop Westinghouse pres-  !

surized water reactors). For the piant-specific changes, the staff will in- l corporate the changes or consider the changes further upon receipt of the plant- 7 specific justifications. For the generic changes, the staff does not plan to j incorporate any of the items in the Unit 1 TS or review the items further due to resource limitations. It should be noted that the applicant does not neces-  !

sarily agree with the staff's designation of certain changes as generic and  ;

objects to the staff's unwillingness to review them further. l 7;ie 28 non-categorized generic changes were examined next. Again the results ofthesediscussions,andstaff'sdecisions,areannotatedinEnclosure3.

In general,18 items retained their "generic" label, 6 items were shown to be plant-specific and will be incorporated in the Unit 1 TS, 2 items are still open pending further staff / applicant consideration, and 1 item was withdrawn by the applicant. Part of one other item was considered plant specific and l the other part was considered generic (see item 7 - priority 10). l At the meeting's conclusion on October 6,1968, Mr. Giardina advised TV Electric that for the items requiring the submittal of additional information, he could assure the incorporation of the changes in the Proof and Review version of the j TS if he receives the infomation in 2-3 weeks. l The applicant requested the staff to provide a copy of the marked-up proof l and Review Unit 1 TS once they are ready for word processing, since changes are -

easier to identify in the mark-up. The staff agreed to formally transmit the  !

mark-up to T5 Electric, as well as the typed version, and stated that this i could occur as early as November 23, 1988.

Mr. Moon of 0TSB advised TU Electric that the staff will be comparing  ;

Table 5.7-1 of the TS on component cyclic or transient limits very carefully l I

with the F6AR. He suggested the applicant to do the same and propose any r.ecessary TS changes.

Mr. Giardina briefly described the process for staff review of generic TS  !

changes addressed in NRR Office Letter 803, "Technical Specifications Review l Procedures." He also provided an update on Westinghouse submittal of new l Standard TS.  !

[

I r

?

Sumary of October 5-6, 1988 meeting '

The staff and applicants agreed to ineet again on October 19-20, 1988 to discuss the incorporation of other changes proposed to the second draf t TS by TXX 88512 dated June 23, 1988.

Enclosure 7 is a listing of specific action items generated during this meeting.

1 ,

d A. qO Melinda Malloy, Proje anager

! Comanche Peak Project vision

Office of Special Projects i

Enclosures:

1. Meetinghotice(w/ Agenda)
2. List of Attendees
3. Annotated Sumary of All U reviewed Generic Changes
4. Proposed G.L. on Removal of Tables on Response Times from TS
5. Proposed G.L. on Removal of Component Lists from TS
6. CPSES-TSIP Outline
7. Action Items cc: See next page

I .,

October 31, 1988 Surrnary of October 5-6, 1988 meeting The staff and applicants agreed to meet again on Oc.tober 19-20, 1988 to discuss the incorporation of other changes proposed to the second draf t TS by TXX-88512 dated June 23, 1988.

Enclosure 7 is a listing of specific action items generated during this meeting.

(original signed by)

Melinda Malloy, Project Manager Comanche Peak Project Divisien Office of Special Projects

Enclosures:

1. t'eeting Notice (w/ Agenda)
2. List of Attendees
3. Annotated Sumary of All Unreviewed Generic Changes 4 Proposed G.L. on Removal of Tables on Response Times from TS
5. Proposed G.L. on Removal of Corponent Lists from TS
6. CPSES-TSIP Outline
7. Action Items cc: See next page DISTRIBUTION Docket file NRC PDR Local POR OSP Reading CPPD Reading JPartlow CGrires/FMcKee JLyons RWarnick JHWilson MMsiloy JWiebe/SBurris DCrutchfield Edordan BGrimes CRossi EButcher CMoon RGiaroina ACRS(10)

]b- j)v7 CPPD:0SP AD:CPPD:05P Mf'e lloy : cm 4 % Wilson fi>\

10h:788 D10/N/6b )

\

t W. G. Counsil Comanche Peak Steam Electric Station '

Texas Utilities Electric Company Units 1 and 2 CCI Jack R. Newman Esq Asst. Director for Inspec. Programs Newman&HoltzInger., P.C. Comanche Peak Project Division Suite 1000 U.S. Nuclear Regulatory Comission 1615 L Street, N.W. P. O. Box 1029 Washington, D.C. 20036 Granbury. Texas 76048 Robert A. Wooldridge, Esq. Regional Administrator, Region IV Worsham, Forsythe, Sampels & U.4. Nuclear Regulatory Comission  !

Wooldridge 611 Ryan Plaza Drive, Suite 1000 t 2001 Bryan Tower, Suite 2500 Arlington, Texas 76011 l Dallas, Texas 75201 '

Lanr.y A. Sinkin Mr. Homer C. Schmidt Christic Institute Director of Nuclear Services 1324 North Capitol Street Texas Utilities Electric Company Washington, D.C. 20002 Skyway Tower 400 North Olive Street, L.B. 81 Ms. Billie Pirner Garde. Esq.

Dallas, Texas 75201 Government Accountability Project i Midwest Office Mr. R. W. Ackley 104 East Wisconsin Avenue  !

Stone & Webster Appleton, Wisconsin 54911 Comanche Peak Steam Electric Station P. O. Box 1002 David R. Pigott, Esq.

Glen Rose, Texas 76043 Orrick, Herrington & Sutcliffe 600 Montgomery Street ,

Mr. J. L. Vota San Francisco, California 94111  ;

Westinghouse Electric Corporation P. O. Box 355 Anthony Z. Roisman, Esq.

Pittsburgh, Pennsylvania 15230 Suite 600 1401 New York Avenue, NW Susan M. Theisen Washington, D.C. 20005 ,

Assistant Attorney Gentral Environmental Protection Division Robert Jablon [

P. O. Box 12548 Capitol Station Bonnie S. Blair Austin, Tetaar - 74711-1548 Spiegel & McDiarmid ,

1350 New York Avenue, NW r Mrs. Juanita Ellis, President Washir,gton, D.C. 20005-4798 i' Citizens Association for Sound Energy 1426 South Polk George A. Parter, Chairman f Dallas, Texas 75224 Public Utility Comittec l Senior Citizans Alliance Of Ms. Nancy H. Williams Tarrant County, Inc.

CYGNA Energy Services 6048 Wonder Drive 2121 N. California Blvd., Suite 390 Fort Worth. Texas 76133 Walnut Creek, CA 94596

+ .

W. G. ' wnsil Comanche Peak Electric Station Texas 'Jttlities Electric Company Units 1 and 2 CC:

Joseph F. Fulbright Fulbright & Jaworski 1301 McKinney Street Houston, Texas 77010 Roger D. Walker Manager, Nuclear Licensing Texas Utilities Electric Company Skyway Tower 400 horth Olive Street, L.B. 81 Dallas, Texas 75201 Texas Utilities Electric Company c/o Bethesda Licensing 3 Metro Center, Suite 610 Bethesda, Maryland 20814 William A. Burchette Esq.

CounselforTex-LaElectricCooperative of Texas Heron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson Street, NW Washington, D.C. 20007 GDS ASSOCIATES, INC.

Suite 720 1850 Parkway Place Marietta, Georgia 30067-8237

e ENCLOSURE 1

'. . ##pa a g,#'*,**

UNITED STATt3 l'. - NUCLEAR REGULATORY COMMISSION wasm%otoN.o.c notis i 1 I*

<,' s .__..

-.s . ..

.,+e

'/

CHwes ienec + i Docket ho. 50 445 N)!

PEMORANDLH FOR: Cnetstopher 1. Grtres Director Comanche Peak Project Otvision Office of Special Projects Jares H. Wilson, Assistant Dira!' tor QM THRU:

for Projects ,

Comanche Peak Project Division Office of Special Projects FROM: Melinda Malloy. Project Manager Comanche Peak Project Division Office of Special Projects SLSJECT: FORTHCOMING MEETING WITH TU ELECTRIC Date and Time: October 5 - 6, 1988 .

8:00 am - 5:00 pm each day Location: One ahtte Flint North 11555 kockv111e Pike Pockville, l'D 20852 Room Nos.: 10B11 (October 5)

SB11 (October 6)

Turpose: Discussion of proposed cranges to the Comancie Peat Unit 1 technical specifications

Participants:

NRC TU Electric F 8411oy R. Giardira < ^ /. o. .coolan, et al 

                                                                                       . t. . <,1 .t.      W 4 . ,'
                                                                     ,._ Ibe/   ltnca l' alley, Pdject Manage ComancreFeakProjectDivisio/r' Qyp [                          y                           Office of Special Projects cc:      See next page Meetings between HEC technical staff ano applicants for licenses are open for interesteo remoers of the public, petitioners, intervenors, or otrer parties to attend as obse rvers pursuant to "Open Peettngs are Staterent of I.RC Staff Policy." O Eeceral Recister 2S058, 6/2S/78.

EY M 9h 1lt6 k tO b' $ M N Ag&b_, 

                            /)     f e f   ,9   -*g 1
                      ~QQ1hQ/DQJ(5                    .1_    I     h        '

l - [ . . t Comanche Peak Steam Electric Sta:icn W. G. Counstl Units 1 and 2 Texas Utilities Elec.tria Company , Cc: Asst. Director for lnscoc. Progrtes Jack R. Newman,*Eso. l Nowman & Holt:inger, P.C. Comanche Peak Project 01 vision l 1 U.S. Nuclear Regulatory "cmisstce , Suite 1000 l l 1 1615 L Street, N.W. P. O. Box IC29 

        'masnington, D.C. 20036                  Grarbury. Texas 76C48                                                                                    l r

Robert A. Wooldridge, Esq. Regional Aostnistrator, Regicn M  ; korsham, Forsythe, Sarpels & U.S. Nuclear Regulatory Comission . 611 Ryan Plaza Drive, suite ICC0 I Wooldridge 2001 Bryan Tower, Suite 2500 Arlington, Texas 16011 t Dallas, Texas 75201 1 1.anny A. Sinkin f Mr. Homer C. Schmidt Christic Institute 1324 t; orth Capitol Street  ! Director of Nuclear Services 'nasnington. 0.C. 20002  ! Texas Utilitte's Electric Company  ; Skyway Tower ' 400 North Olive Street, L.S. 81 Ns. Billie Pirner Garde, Esq... - Government Accountability Pro 3* ct  ! 041145, Texas 75201 Micwest Office 

                                                   .C4 East Wisconsin Avenue                                                                              :

Mr. R. W. Ackley Appleton, Wisconsin 54911  : Stone & hebster  ! Ccranche Peat Steam Electric Station David :. Pigott, Esq. P. O. Box 1002 Orrict, rerrington & Sutcliffe  ; Glen Rose, Texas 76C43 600 Fcntgomery Street San Fr rcisco, California 54111 l Mr. J. L. Vota  ! Westing %ouse Electric Cor;cration Ar.tneny Z. Roisman, Esq. , P. O. aux 355 Suite 6CO Pittsburgh, Pennsylvania 15230 

                     '                              1401 New Yors Avenue, tiW dasnington, D.C. 20005                                                                                ,

Susan M. Iteisen j Assistant Attorney General Rccert wablen ' Environrental Protection Divisiten Son".te S. Liair Capitol Station P. O. Eca 12544,8711 Austin, Teaes 7 1548 Sp'egel s McDiarmid  ; 13';0 fiew fort Avenue, NW l Mrs. Juanita Ellis, Presicent 'iashingten, 

                                                    .                                                                                   0.C. 2CCC5-4718 l

Citt: ens Association for Sourd Energy 04crge A. Parker, Cnatrran  ; 1426 South Polk Public ' tility Comittee 041145. Texas F5224 Senior Cittzens Alliance Of Tarririt County , Irc. Ms. f.'ancy H. ailliams 049 der vr trive CYGMA Energy Serv tr.es Purt acr!n. Te us Tf D) 2121 N. C4tifornia Elvd., Sui'( 3; 

          .airut Crees, CA 94536 l                                                                                                                                                          >

I l  !

e i W. G. Counstl 

                             *                  *i- Comanche Peak Electric !!ation i

Tenas utiltties Electric Ceegany knits 1 ar,o 2 i cc: Joseph F. Fulbright i Fulbright.&-Ja orskt 1301 PcKinney Street buustor., Texas 77010 l t Roger D. Walker L Manager, Nuclear Licensing Texas Utilities Electric Ccepany , l Skywa) Tower [ 400 North Olive Street, L.S. 31 Dallas, Texas 15201 r Texas Utilities Electric Company  ; c/o Bethesda Licensing , 3 Metro Center. Suite 610  : Uethesda, Maryland 20h14  ! t wilitam A. 8vrchette. Esq. Ccunsel for Ten La Electric Cooperative , of Texas [ Heren. Surchette, Auckert & Rothwell  ; Suite 700  ! l 1025 Thomas Jefferson Street NW l l Washington, D.C. 20007 t I GOS AS CCIATES, INC. t Suite 720 l 1650 Parkway Place Partetta. Georgte 30C67 8231 l 1  ! l  ! r e i r I' t ( l  ! 1 . , t [ f i l t i 

                         .                                      E!4Ct.05URE 4RC/TU ELECTRIC MEETING ON CPSES Ut!!T 1 7ECHNICAL SPECIFICAT!0h5 (TS)

OCTOBER 5 AND 6. 1988 AGENDA 1 l (10/5/84) 8:00 8:15 1. Opening remarks and agenda review (10/5/88) 8:15 12:00 2. Olseuss the generic items en which the NRC is presentTy working This will be a discussion of the 22 items of TXX-68605 dated 8/5/68 identified in the September 22, 1968 TS 

                      .         reeting as already being worked on by the NRC. This is to ensure the extent to which the changes being proposed by TU Electric are being encompassed by the NRC work in progress.                                                    ,

(10/5/88) Discuss the generic items that need further discussien 1:00 - 2:00 3. This will be a discussion of the 6 items of TXX-68605 toentifico ir. the Septeober 22, 1964 reeting as reeding further infor:4 tion from TV Electric and l additional discussicn. (10/5/88) 2:00 - 3:00 4 Otscuss the generic items that may be plant-specific This will be a discussion of the 8 iters of TXX 68605 identified t..'the September 22 1988 meeting as teing plant specific and will identify any iters that ray te generic vice plant-specific. (10/5/88) Diseass the other generic tssues that were not 3:00 - 4:00 5. categorized (10/6/88) 8:00 11:00 This will be a discussion of the 28 itees of TXX-86605 that were not categorizee in the Septercer 22,1988 meeting to identify retential plant specific items. nute: Times are approximate

e. ,
        .         ,                                                                         t
)         October 5 'and 6.1968                      Z-
;             AGENDA, continued i

t (10/6/64) 11:00 - 12:45 6. Discuss the handifne of the plant specific charges [ 16enttried in TIX 55517 j This will be a discussion of other changas proposeo & to the second draft TS by TXI 84512 dated 6/23/84  : that were not addressed in discussions above. i (10/6/64) 'l 12:45 - 1:00 7. Summary of actions and plans for future meetinst i [ i h i b 

                                                                                         . t 1

I t r i i 4 [ i  ! i 16 I l 4 

)

9 > f I I l i

4 CNCLOSURE 2 l NAC/TL' ELECTRIC NEETING ON CPSES UNIT 1 TECHNICAL SPECIFICATIONS h '.+e r S . 1988 t October 6. 1988  : ATTENDEES Name_ Organiza tion Title I s'n k& (x l{ O O ' AYV V im Kcet.tv r a t.tec +-c, c use. A.w Ceu.mn-s W Sk T u G k /ne- Ta l .<d Assa N l Aneu asu n g u e. ,- e c sua roc.,~ u e w u, n v. +. c e-.s- n l l w td..d k To Flee %- u c e a s .3 y?  ; l Tam J . G . 4 4.'~ ^ N *"' ##" ' #""' " f 

          $lhL bde                       C     E l

i ! i l u l l t L l t

) - e * . SuMMAgy_gE_g6L_yNew igNgp_gENg81G_QHONggs_t TSIP - Technical Soectficatson Isaorovement Prograra REEMM - Radioactive Effluent and Environssental Monitoring Manual Blanta_Wete_the_GESES_chen:2et_9r_a_ ele 11st_channe.__ ban _been_eter199mly_sent9yed P,1be.'!C A - Catawba l B - Byron C - Callaway D - Diablo Canyon , G - McGuire H - Shearon Harris M - Millstone S - Seabrook l T - South TLxas l V - Vogtle l W - Wolfjt Creek X - Waterford l HENEglG_11(2.. NBG_EggggNILy_NQBKINQ_QN (NAC. C e7 i) l It ems Plant _N9t ItS __N91. Iltle Er19c11r 39emety_9f_Ghange God, 'Ptscussion so/5/ss G.L N drkEk 5

2. 3. 0.1 Aoolicability 1 Change Bases to clarify voluntary entry into',an efted amplaio TS Action Statement. weging.

Un.+ a tT3. g 44.

7. 3. 3.1 RTS 54 Re1ocate RTS response time to S, V, H ) as.. unke m'+. "AW

( # ewlJ lue e ed 1* G es. Inst ruraent at ion the TSIP. Y Unit ( %4( Re& &(M T5. AS=**5 "T5 iES^5 Engineering 55 Relocate ESFAS resoonse times S,V,H *

8. 3.3.2 .

y Safeguards to the TSIP. , Q, yg geg3 4, g Features j g gh to C/scs- g T5s F. o

  • Reference - TU Electric Latter TXX-88512 dated June 23, 1988. All other changes proposed 2 by TU Electric in this l et t en- are considered plant-specifte and a full NRC review is A ewu?cted. w w Table relocated only.

GENERIG_ ITEMS _NRQ_PRESENTLL WORKING _ON (continued) Item Plant _No. I. S. _No._ Iltlg Rad;d:en Assn, catet:aa Prigrity SuLmary_gf_GhqDge Ggde DN8 0M lo/f/96

14. 3.3.3.11 L _ ur 5.- t ; 25 N"- ac4veu rec seed Gays
                                                                     - * - - + ' - "-- '-  ^ -

b h M y""'- 0; t . .-. ", . ce. te tt TC I P.

24. 3.6.3 Cont a a rsaent 58 Relocate containment G.L. E S Alon 4kse T,S,V,H (or Ima5 7 Isolation Valves isolation valve table reev af" A to the TSIP. Id**+i d h gg'll k.
25. 3.7.1.2 Auxi1iary 39 Change surve111ance frequency " #
  • Feedwater frora 31 days to 92 days. Wk det G '
32. 3.8.4.2 Overcurrent 64 Relocate table of orotectave V,S,H,T 6ee. .'G a M ah* W .

Protectave dev1ces to the T3IP. Devaces n &;ay G.t.. wn'69

33. 3.11.1.1 L1ould Effluents 41 Relocate ther Liould Effluent M, T {Yorost (tlocah' set st-Table to the REEM;4. 4.11 4ak 4. @CM;SW, I

LCDS, action:t 1( Wli ca-45 Add 3.O.3 and 3.3.4 exceotion. B. V bil.f oot Sont, Ecos 5 lila.,co leC+ * . y

34. 3.11.1.3 Lacund Radwaste 42 Relocate entire Soecafication M g 4 1l not SaltsCeo(

Treatraent to the REEMM. w;% forsiad. 2-3 A.

35. 3.11.1.4 Liound Holduo 43
                                                                                                           }nGes, & maill know Relocate entire Soecafseatnon   M y

Tanks to the REEMM. .g g.

36. 3.11.2.1 Gaseous Eff1s. .t 44 Add 3.0.3 and 3.0.4 exception B, '1 (Dose Rate) 46 Relocate the Gaseous Effluent M, T Table t- 'he REEMM.
37. 3.11.2.4 Gaseous Radwaste 47 Relocate entare Soccafication M Treatment to the REEMM.

o Changed frecuency to 7 days. O Table relocated on t v. 

                                                                                                            ~

GENE 81G _ I IEMS_N8g_E RESENI(y_NQBNINQ_Q$ (continued) Item Plant _Not I.Sm_No.. Iitle ertority summary _of_QhtDge Qode  ?.$Ct5Ss0M #5/09 ,

39. 3.11.2.6 Gas Storage Tanks 53 Relocate entire Soecifscatson to the REEMM.

M ) <gg,ggg,3 33_37 g,p q g 29 Change sam;21e frequency from C .W # 24 hours to 92 days. b~ dd adda"b'M E M G.L.

40. 3.11.3 Solid Red Waste 40 Relocate entire Soecification M I to the REEMM
41. 3.11.4 Total Dose 48 Relocate entire Specifacation to the REEMM.
42. 3.12.1 Mon' tori ng 49 Relocate entire Soectftcation M, T Program to the REEMM.

50 Rdd the allowance to confirm V analysis results.

43. 3.12.2 Land Use Census 51 Relocate entire Specification M to the REEMM.
44. 3.12.3 Interoolators 52 Relocate entire Specifiration M Comoarsson to the REEMM.

Program

  1. Table relocated only.
                                                                                                                                    .'      .~

4 Item GE NE R I Q _I IE MS_lHOI_ME D_EURIW'j_ QlSGy@SlQN (*c. % g d Plant _h Is.Et_Ng=, litle Priority Sungary_of_Chagge Ggde M*M lh/B%

10. 3.3.3.2 Moveable Incore 63 Relocate entire Spectfacation Detectors to the TSZP. TV
  • needs le (*fode.

ys9N4catiew6.

11. 3.3.3.3 Sensuse 59 Relocate entire Soectfication S, V i YO -

Inst 5umentatzon to the TSIP. ' N 84/84 Yo C#JES~ 75ary.sh.c4 steeds

12. 3.3.3.4 Meteorological 62 Relocate entire Soectfication $ladF st4Kew ( apl.

Instrumentation to the TSIP.

13. 3.3.3.9 Loose Parts 56 Relocate entire Specification V,S,H,T ,

Detection to the TSIP.

27. 3.7.9 Snubbers 27 Revise and relocate entire S, H Soecification to the TSIP or at least relocate Surveillance requiremer.ts to the TSIP.
28. 3.7.10 Scaled Source 60 Relocate enttre Soecification Contamination to the TSIP.

3) GENER[G_IIEMS_IU@LM@L@G_EL@NI_SEEGIElG h'4c. 6 - Item P an Ngt L S t _Ng. 11tle Brigrity Su!amery_gLGhange Ggde D5cu% c4 to[S/86 

 . 4. 3.1.3.3    Positson            36     Add note to al1ow                        k eerlC.                      .

I r41 cat ion Doerability testang after System maintenance. s Tu cu rovide lod (' 7. 3.3.1 RTS Instrumentatton 9 Delete requirement for Reactor Trip Byoans Breaker Testing. peggc, g;ff w _si3,a w ,y d g, (Will require review of sfa.f (ti/ lev. WCAP-11312.) 3.4.5 61 Gem

17. Steam Generators Relocate entire Soecification gfo "en$hrf
                                                                                                      .p t.cowill  conslJrr y morg, a                                                 to the TSIP.                           f50Cc=+1on as C.c Gf. 2 dem6
18. 3.4.6.2 Ooerational 30 Change the check on seal flow Leakage to agree with the way ECCS Generic.

A" ' ** Y'unless CN' TU'sO relo system is checked. - D C" Mc.. TI> need3

22. 3.6.1.4 Internal Pressure 32 Change Action time l i w;i t frora 1 hour to 8 hourn Ouf-[Y g y pgj%
26. 3.7.1.5 Main Steam 7
  • C Add allowance for oost Isolation maintenance testing on MSIV in ,

Modes 2 and 3.

29. 3. 8.1.1 A. C. Sources - 34 Exoand on what is the largest ,

Ot,erating load to be re.jected.

32. 3.8.4.2 Overcurrent 28 Add clarification to the Action b M - M 'Cg D y Protect 1ve Dev1ces Statessents to aoply 'to fuses as well as breakers.
                                                                                              /     d       j   **g g;        ,4 of cirtotF kratter.s.

a l 

                                                                                                                   ^
  • QIUE8_QENEBIC_COBNGES_NQI_CBIEGQRIZED -

Item Plant _N9t T t s,,_ygt Ittle Priority guaLungry_gf_Chenge Cgde DMN NM

23. 3.6.1.7 Containment 2 Change allows for the pressure T,S,V TV b frovide- PlaM .

Ventslation relief valve to be oown as Sf8 M C- h 9h N M 0^- Syster. necessary for pressure relief with no t ime restrict 1ons. - i 7. 3.3.1 RTS 10 Split SRNI spec. for S, M, D 'b'"0" D I nstrunnent at ion reactor trip breakers open 45 PMTd't - or shut and change Actiore @#

  • Statements.
5. 3.2.3 Hot Channel 19 Move the requirements for V,S,T n adl NAC-and Factor and RCS flow verification fiom be on nedc 3.2.5 DNB Parameters Hot Channel Factor to the DNB "PPI*'OLb**! /*

Parameters Soecification.

18. 3.4.6.2 Doerational 6 Add allowance for reduced T,V,C,W Pr ,e- sr'c'#i' Leakage pressure testing.
24. 3.6.3 Containment 33 Remove requirement to test D, X Generic Isolation Valves during Cold Shutdown or Refue1139 Modes. ,
15. 3.4.2 RCS Safety 31 Remove requirement to have X C#* fiC Valves Safety Valves when in Modes 4 ,

and 5.

32. 3.8.4.2 Overcurrent 22 Change testing requirement to V,C,W,B 6eneric Drotective allow use of the nianufacturers Device provided data
24. 3.6.3 Containment 4 Add provisions to allow S/U V, B l'U W *fh4/* u/

Isolation Valves or cont inued operat ion while meeting the action reouirements. e

38. 3.11.2.5 Exolosive Gas 17 Remove requirement to D,H,T Maxture continuously monitor. Toefackg;,

Spedfh plhE-o Only monitors gas entering the system. e 

                                                                                                                                 .L3
                                                                                                                            ~

DIVE 2_GENCBIG_COONGES NDI_GOIEGOBIIED (continued) Item Plant . _N9t I. S.__gg. Ittle PC igCity summary _gf_gtienne ggde DMoN 88 ( IM

20. 3.5.1 18 @C Accurmul at ors Add new Action Statement to address boron concentration T,G D M' ISSL O" M~

out of soecification. dfM - 16 R2toove the Analog Channel V,C,B,W 6eeenc. Doerational Test and Ch arinel Calibrat ion requirement's.

1. 2.2.1 RTS Instrument 37 Make the P-10 satooint a C,D,W,B 6 tee 7U Set or s at Peadi n+

nominal value (10%). Mcf*C se pe4 hod y-

9. 3.3.3.1 Radiation 38 Change applicability for CVI H, V 6ene n'C Monitoring requirement.

g g--- ----~ 2'3. A. C. Sources - bEh

3. 8.1.1 Ooerating 15 Change Action Statements to address Generic Letter 84-15.

T, V 

                                                                                                 +n P( R. TS . O%E 12    Change to minimize to ccid      V, S         C***^E starts on the diesel generators (DG).                                                           -

e 14 Remove loading of the D3 time V, T requirements. Od -Sf8(LOC. - 35 Add allowances for grid V b8ac o'C disturbances. 13 Remove testing of mechanical C,W,V dbS" *4c. interlocks. 11 Remove reporting and C,W,V,S,H, $bWG6CL recualification M, T,0, D reouirersent s. O Extended the time from 10 seconds to le minutes.

W OIME8_ GENE 81G_GUBMGES_NOI_CBIEGQBIZED (conttnued) Item Plant _No t ItS._ Mot litle Prigrity S e gry_9f_Ct!qDge God _e pgN IOkB9 .

30. 3. 8.1. 2 A. C. Sources - 23 dodify the depressurizat2on V (Epuufc Shutdown requirement in the Action Statement to reference the Overoressure Protection System Soectfication.
31. 3.8.3.2 Onsite Power 24 Modify the depressurizatacn V (remedC.

Dist. - Shutdown reouirement in the Action Statement to reference the . Overpressure Protection System Specification.

3. 3.1.3.1 Movable Control 5 Change Action Statements to V,S,T (Neae n*c.

Rods Grouo ~ cover the situation of more Height than one rod trippable but inoperable.

6. 3.2.4 Quadrant Power 20 Simolify the Action S, T dS*dk1'C-Tilt Ratto Statement for increased usability. *
7. 3.3.1 RTS 26 Change power limit from G dbb"WTC-Instrumentation 75% to 50% as to when an -

incore-excore calibration for axial flux difference is reouired.

16. 3. 4. ', RCS Relaef Valves 21 Change Action Statements to apply within the applicability.

M, V N M #M d%E f P( & T5,

18. 3.4.6.2 loeratsonal 3 Change the inventory balance S d~* **k1'c-Leakage to allow for plant start uo.
21. 3. 6.1. 3 Containment 8 Add allowance to open the one S,V,M 6Hk*WTc-Atriocks Doerable airlock for maintenance.
19. 3. 4. 9.1 Pressure 57 Relocate the reactor vessel V,H.S dNb*WTC Temoerature material irratiation Lamats surveillance to the TSIP.

WLiMIW AR.Y T)PAFT~  % c. 7 A f 

            **    o .,,,'g.                           UNITED 8TATES ENCLOSURE 4 8         e     g                 NUCLE AR REGULATORY COMMISSION                                      '

Wu A SHING TON, D. C. 20$55 7. 

          *\,.....,f MEMORANDUM FOR:

Scott Newberry, Chief Instrumentation and Control Systems Branch Division of Engineering and Systems Technology, NRR FRON: Edward J. Butcher, Chief Technical Specifications Branch Division of Operational Events Assessment NRR

SUBJECT:

FROF0 SED GENERIC LETTER Oh REMCVAL OF TABLES ON RESPO TlHE LlHITS FRCM TECHNICAL SPECIFICATIONS Ericlosed is a proposed Generic Letter that provides guidance on the renoval of Reactor Trip and Engineered Saf ety Feature Actuation System instrumentation response tin,t. limits from Technical Specifications (TS). This is a line 16.a. improvement for 15 that had oeen liiccrporated in TS for some plants on a plant-specific basis. The guidance in the enclosed proposal addresses matters under the cognizance of the instrumentation and Control Systems Branch's technical responsibility. Therefore, your review of this proposal is requested prior to finalizing this proposal for CCGR review. Comments on this proposal are requested by August 31, 19ES. Edward J. Butcher, Chief Technical Specifications Branch Division of Operational Events Assessmerit

Enclosure:

As noteo ( i l [ . . __ .

MLIM14RY' ?MU  ! MEMORACE. FCL; Scott Newberry, Chief ' Instrumentation and Control Systems Branch Division of Engineering and Systems Technclogy, NRP, FR0li: Edward J. Butcher Chief Technical Specifications Branch Division of Operational Events Assessment. NRR

SUBJECT:

PROF 0 SED GENERIC LETTER ON REMOYAL OF TABLES ON RESPONS T!!!E LlfitTS FRCM TECHNICAL SPECIFICATIONS Enclosed is a proposed Generic Letter that provides guidance on the removal of Reactor Trip and Engineered Saf ety Feature Actuation System instrumentation response tint limits from Technical Specifications (TS). This is a line itent improvement for 15 that had been incorporated in TS for some plants on a plant-specific basis. The guidance in the enclosed proposal addresses matters under the cognizance of the instiumentation and Control Systems Branch's technical responsibility. Therefore, y:::r review of this proposal is requested prior to finalizing this proposal for CRGR review. Cosaents on this proposal are requested by August 31, 19ES. Edward J. Butcher, Chief Technical Specifications Branch Division of Operational Events Assessment

Enclosure:

As noted Distribution: DI M /F DOEA R/F Central Files JHSniezek TTMartin CERcssi LCShao RLEmch TG0unning I d + Tab.00E A:llRR TSB:00EA:NRR C:TSB:00EA:NRR TG0unnit.g:tgd RLEmch EJButcher 07/ /88 07/ /88 07/ /6B

9AE4-I M N A RY IMAFr [a...\ UNITED STATES 

           ?                 a                NUCLEAR REGULATORY COMMISSION
  • W ASHINGTON, D. C. 20666 9 r 5
             %,....,Y TO ALL LIGHT WATER REACTOR LICENSEES AND APPLICANTS

SUBJECT:

REl'0 VAL OF RESP 0hSF T1hE TABLES FROM TECHhlCAL SPECIFICATIO (Generic Letter 88 } This Generic Letter provides guidance for a license amend ient request to remove the tables providing Aeacter Trip (RT) ard Engineared Safety limits from Feature Technical Actuation Specifica-System tions(15). (CSFAS) instrumentation response tis 41his is a line item imprcveinent t The removal of Technical Specifications (TS) for recent operating licenses. these tables of instrument response times from the TS does not alter the sur-veillance requireunts to verify that the response time of each RT and ESFAS It does, however, permit administrative control function is within its limit. of these limits, without requiring a license amendment to implement changes to update these limits. Any change to a facility that involves components associated with or affecting response time limits, as described in the Final Saf ety Analysis Report (FSAR). is subject to the requirements of 10 CFR 50.59. Therefore, acequate measures exist to control changes to these limits without having them listec in TS. The response time for Engineered Safety Features (ESF) is defined in the TS as the time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equinnent is capable of perform-ing its safety function (i.e. valves travel to ticir required The positions pump Definition also discharge pressures reach their required values, etc.). notes that th sequence loading delays where applicable. The intent of specifying response tiines for RT and ESFAS functions is to establish the specific limits which must be met when performias the surveillance to verify the system response is within the bounds assuned in the safety analysis. An increase in the response time of an individual component may be indicative of a pending failure of that cosipon-ent or it may indicate that the component is not capable of performing its in-tended function and is, therefore, inoperable. From a practical standpoint, the specification of the overall system response does not provide a limit that is very meaningful in verifying that Theindividual major part components of a system function are respond (ng as they should. of the response time limit is often associated with adjustable time delays that are an integral part of the diesel generator load sequence program. Hence, small changes in overall response could occur within the specified tiuits that would not be significant if associated with those adjustabla time delays, yet might be sign;ficant if associated with the majority of the remain-ing system cumponents. Also the specification of a time interval (limit) is not a meaningful acceptance criteria for the responso of system functions that include dynamic response con,ponents such as lead / lag compensation circuits. Finally, a respense time 11mit for a system function that includes niultiple l actions would be specified based on that action whi,h has the icngest tire response and is not r,eaningful for actions having a shorter response time.

4 kbl Ml MQ 2-Rg7 The perforcance o' response tir'e tests are not t,qically performed in a manner that ceasures the overall response time of a system function. Generally, these te:ts are performed in multiple overlaping steps that confirm that the overall response tiew limit has been met. This is a practical consideration due to those coeponents associated with a function that are coesnon to other functions and would be subject to multiple testing or because other surveillance require-ments have been preforred to determine the response of individual components. L'sually this occurs on a more frequent basis due to the inservice testing re-quirements for pumps and valves or the periodic testing of diesel generator load sequence time delays. In sumary, the RT and ESFAS instrumentation response time limits as specified in TS, do not alone constitute a meaningful criterion for assuring From athat these practical systems are capable of performing the specified functions. standpoint, both the testing and verification of acceptable system response include greater detail than defined by an overall response tire limit for each Therefore, because the important aspect of instrument RT and ESFAS fumetion. response time testing rests with considerations that are not specifically addressed in the TS, the removal of the RT and ESFAS instrument response time limits does not alter the objective of the surveillance requirements which is to verify tnat system functions will be performed with a response time that is consistent with the assumptions of the safety analysis. The Limiting Cor ditions for Operation (LCO) for the RT and ESFAS instrumenta-tion typically note that tre instrumentation "shall be OPERABLE A change to with the LCO RESPONSE could T1!!ES as shown in Table 3.3-2" or "Table 3.3-5." simply state that this instrumentation "shall be OPERABLE (period)" and remove the referenced tables. Licensees and applicants are encouraged to propose changes to theirProposed plant T5 that are consistent with the guidance provided in the enclosure. license amendments conforming to this guidance will be expeditiously reviewed by the hRC Project Manager for the f acility. Proposed license amendments that deviate f orm this guidance will require a longer, more detailed review, Please contact the Project Manager if you have any questions on this matter. Sincerely,  ; Frank J. Miraglia Associate Director for Projects Office of Nuclear Reactor Regulation l l 1 -. ._ _.

e hLlN h ENCLOSURE 5 i MEMORANDUM FOR: Marvin W. Hodges. Chief Reactor Systems Branch Division of Engineering and Systems Technology, NRR Faust Rosa, Chief Electrical Systems Branch Division of Engineering and Systems Technology, NRR FROM: Edward J. Butcher, Chief Technical Specifications Branch Division of Operational Events Assessment, NRR

SUBJECT:

PROPOSED GENERIC LETTER ON REMOVAL OF COMPONENT LISTS FROM TECHNICAL SPECIFICATIONS Enclosed is a proposed Generic Letter that provides guidance on the removal of component lists from Technical Specifications (TS). Previously. quidance has been provided to licensees and applicants on the removal of the list of snubbers from T5 by Generic Letter 84-13. In addition, component lists have been removed from TS issued for new licenses, as well as for some plant,s on a plant-specific basis. The guidance in the enclosed proposal addresses technical matters that are the responsibility of the Reactor Systems Brant i and the Electrical Systems Branch. Any suggestions to describe a specifi class of components to which a particular specification applies or suggeste changes to the descriptions provided would be useful because it is desirabee to standardize such descrip. tions. Your review and suggestions on this matter are requested before we finalize this proposal for CRGR review. Connents on this proposal are requested by September 2, 1988. .I Edward J. Butcher, Chief Technical Specifications Branch Division of Operational Events Assessment Distribution: OT58 R/F 00EA R / Centeil Files JHSnit:ek TTMartIn CERoss LCShao CHBerliner i W0Lanning , RLEmch TG0unning OTSB Members TS I"A NRR TSB:00EA:NRR C:TSB:00EA:NRR TG r g:tgd RLEmch EJButcher l 08/ /88 08/ /88 08/ /88 l ( 

         ,,4*'gaAfg      %,                         UNITED STATES                                             )
                  'e      n NUCLEAR REGULATORY COMMISSION

[ - wasmNotos. o. c.aosss 

  . r.                            -

y ..... )! l TO ALL POWER REACTOR LICENSEES AND APPLICANTS

SUBJECT:

REMOVAL 0F COMPONENT LISTS FROM TECHNICAL SPECIFICATIONS (Gen Letter 88- ) This Generic Letter provides guidance for a license amendment request to rerove component lists fron Technical Specifications (TS). This is a line item improvement that was identified in investigations of TS problems by the nuclear industry and NRC. Previous guidance was provided on removing the list of srubbers from TS by Generic letter 84-13. There are three major considerations that are applicable for removing component lists from the TS. The first is the revision of a specification to remove the 

             .eferences te the list of components and the list itself. The second is the modification of the specification to state the requirements in terms that clearly define the scope of the components for which the specified requirements apply and to incorporata in the specification any information or notes from the tables that would no longer exist due to the removal of the component list.

Finally, the Bases that provides the reason for the scope of components includ-ed in the specified requirerents should be revised if such clarification is Each essential to ensure the proper application of the specified requirements. of these considerations is addressed in the enclosed guidance. i The removal of component lists from TS does not alter the requirements that are applicable to those components, it does. however, permit administrative con-trol of these 11sts, without requiring a license amendment to implement changes to update a list. Any change tc a facility that involves these components, as i described in the Final Safety Analysis Report (FSAR), is subject to the require-rents of 10 CFR 50.59. Therefore, adequate measures exist to control changes to the f acility without having these components listed in TS. Licensees and applicants are encouraged to propose changes to TS that are consistent with the guidance provided in the enclosure. Conforming amendeent requests will be expeditiously reviewed by the NRC Project Manager for the facility. Proposed amendments that deviate from this guidance will require a longer, acre detailed review. Please contact the Project Manager if you have questions on this matter. Sincerely. Frank J. Miraglia Associate Director fnr Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated

e I" 794u MN AA.Y' TAAFT' Enclosure Genarie Letter 88 _ 4 REMOVAL OF COMPONENT LISTS FROM TECHNICAL SPECIFICATION (TS) BACKGROUND The NRC provided guidance to permit the removal of the list of snubbers from Technical Specifications (TS) by Generic Letter 84-13. dated May 3. 1984 Subsequently, a number of licensees and license applicants have submitted proposals to remove other component lists from TS on a plant-specific basis. The removal of component lists from TS has also been an irdustry recomendation for improved TS. This guidance for preparing a license amendment request to remove component lists from TS is provided on the basis of this experience. The guidance provided on removal of the list of snubbers from TS noted that a large number of license amendments have been required to add, delete or modify the snubber list and it was concluded that the table listing snubbers is not necessary, provided the snubber TS is modified to specify which snubbers are required to be operable. F'nally, it was noted that any changes in snubber quantities, types or locations would be a change to the f ilit) that would be subject to the provisions of 10 CFR 50.59. The snubber specification was mod-ified to clarify that the only snubbers excluded from the specified require-ments are those installed on non saf ety related systems, and then only if their f ailure, or f ailure of the system on which they are installed. would have no adverse ef f ect on any saf ety-related system. The table with the Ifst of snub-bers and references thereto were removed from the Limiting Conditions for Oper-ation (LCO) and the associated surveillance requirements. GUIDANCE ON THE REMOVAL OF COMPONENT LISTS FROM TS The appracch taken in Generic Letter 84-13 for removal of the list of snubbers from TS is extended for the removal of other component lists. Specificelly, this includes the revision of the applicable specifications to include an ex-plicit description of those components to which the specification requirements apply. Any change in the facility involving these corponents as described in the Final Safety Analysis Report (FSAR) would be subject to the requirements of 10 CFR 50.59. A list of these components are typically included in plant pro-cedures that impleeent the surveillance requirements included in the TS. Furthermore, changes to these procedures are subject to theTherefore, change control pro. upon con-visions of the Administrative Controis section of the TS. firemation that these list exist in controlled plant procedures or other suit-ably controlled plant documents, the removal of these lists from the TS need not introduce problems for licensee personnel or NRC inspectors with regard to the identification of the individual components to which the specified require- j ments apply. While some corponents are listed in the FSAR. generally it should not be reited on as the prirary source document to 4dentify these components because it is , coly required to be updated annually and then it only needs to reflect changes up ti a maximum of 6 months prior to the date of filing. The Bases section of the 15 may reference a docurent where these lists are located, however, compon-ent lists should not be included in the Bases since changes to the Bases are generally implemented by the license amendment process.

f" . 96LI M nJ AM TF.M T 2 Consistent with the a60ve approach for removing component lists from TS the following provides guidance for changing individual specifications to describe those components for which a specification applies. An alternative would be to describe these components in the Definition section of the TS if such would facilitate the description the components and the statement of the requirements that apply to them. In this case the defined term would be typed in capitol In some letters in the specification to designate that it is a defined ters. cases it may be appropriate to provide a further discutsien e' the scope of corponents that are included under the specified requirements in the Bases for those specifications. Considerations which may be unique to specific types of component lists are eddressed in the following examples. A. CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES The list of containment penetration conductor overcurrent protective devices include those primary and backup fuses and/or breekers that preclude the existence of credible faults of a magnitude and duration that could degrade an electrical conductor penetration's capability of maintaining containment integ. rity. Since the number of overcurrent protective devices associated with electrical circuits penetrating containment may exceed the basic requirerents for primary and backup protection, the functional description of the components requirements should be stated in manner that clarifies the scope these compon-ents to which the specified requirements apply. An example would be an LCO which states the following: 

                 "Primary and backup containment penetration conductor overcurrent protec-tive devices associated with eaa,h containment electrical penetration cir-cuit shall be operable. The scope of these protective devices includes those for which credible fault currents would exceed the electrical penetration design rating."

Another alternative would be the addition of a definition of containment penetration conductor overcurrent protective devices to the Definitions section of the TS and to modify the specification to state the requirements in terms of this definition. B. CONTAINMENT ISOLATION VALVES The requirements for containment isolation valves are specified in the General Design Criteria (GDC) of Appendix A to 10 CFR Part 50. GOC-55. 56. 4 57 establish those applications which are classified as containrent isolation valves and, therefore, the term "containment isolation valves" has been defined by these requirements. The specification for containment isolation valves is, however, stated in terns of those valves listed in the referenced table that do not include all valves in the plant that are defined as containment isolation The list of containment isolation valves has typically valves by the GDC. included information such as valve closure times and notes that modify Therefore, the require-removal eents included in the LCO or surveillance requirements. of the table of containment isolation valves would result in the applicability

  • of the specified requirerents to all containment isolation valves if the scope of the specification requirerents were stated simply in terms of ' containment isolation valves."

t

V-TRe u M A A . wwr Therefore, in order to maintain the applicability of the specified requirements to those valves which are included in the list of containment isolation valves, A the r*Quirements should be stated in terms that capture those components. suggested statement to encompass these valves is: 

                   "Reinote operated containment isolation valves that do not perform any specified safety function other than containment isolation.'

The description of these containment isolation valves as remote operated would encoepass those valves that are automatically closed in response to containment isolation sfonals as well as valves that are not automatically closed but could be remote manually closed. However, containment isolation valves that perform other safety functions would be addressed by separate specifications that address those functions. With regard to infnrration contained in the list removed from the TS such as valve closure times, the inservice inspection and testing requirements, requir-ed by Section XI of the A5ME Boiler and Pressure Vessel Code. include the ver-ification of valve stroke times for a broader class of valves than containment isolation valves. Because the T5 do not specify the closure times for other valves, the relocation of the list of containrent isolation valves and their accompanying valve closure times is not inconsistent with the fact that valve closure times are not included in the TS for those inservice testing require-ments. However other information or notes in the tables that clarify or modify the specifications, would have to be incorporated in the associated LC0 or sur-veillance requirements to remain offective. Since the types of notes included in these tables ray be based on plant-specific considerations, exceptions or modifications of the specified requirements should be stated in functional terms, rather than by component number if practica). This also applies to any other component list removed from TS that includes notes that alter specifica-tion requirements. C. REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES A list of reacto coolant system pressure isolation valves is referenced in the surveillance requirerents for the specification on operational leakage for the reactor coolant system. The list identifies the redundant isolation valves, that isolate the reactor coolant system from low pressure systems, that are subject to the specified surveillance requirements. In addition to the ident-ification of these isolation valves, some TS include a specified leakage rate for each valve that typica))y is in the range of 10 to 50 percent of the spec. ified reactor coolant system leakage rate. Also, the list of valves generally do not include all valves that isolate the reactor coolant system from low pressure systems; e.g., reactor coolant system vent valves. With regard to specified leakage rates for reactor coolant pressure isolation valves, the limits specified represent a beunding leakage limit for each in-dividual valve and are inTherefore, addition since to other limits other LCOsin include the TS specified for reactor bounding coolant system leakage. reactor coolant system leakage limits, the removal of the 11st of reactor coolant system pressure isolation valves and their associatto leakage limits would not result in a relaxation of the overall leakage limits. With the re. royal of this list of valves. the surveillance requirements could be stated in terms of "redundant reactor coolant system pressure isolation valves" to

clarify the scope of the valves to which the specified requirements apply. If the scope of these requirements is to be maintained consistent with existing requirements, exceptions should be stated in functional terms rather than by , valve number if practical. D. SECONDARY CONTAINMENT BYPASS LEAKAGE PATHS A list of secondary containment bypass leakage paths is provided in the the specification on containment leakage for containment systems. The list ident-ifies the secondary containment leakage paths by penetration number for dual containments. The combined leakage rate for all penetrations identified as secondary containrent bypass leakage paths is specified. The Standard Review Plan. NUREG 0800. "Standard Review Plan for the Review of Safety Analysis , Reports for Nuclear Power Plants". LWR Edition includes 8 ranch Technical ' Position. BTP CSB 6-3. "Determination of Bypass Leakage Paths in Oual Contain. ment Plants.' This BTP contains guidance that provides a definition of the Therefore, i panetrations that are secondary containment bypass leakage paths. secondary containment bypass leakage paths are adequately defined such that that applicab'11ty of the specified requirements do not require further cler-ification with the removal of this list from the TS. The Bases for this spec-ification could reference these documents for the definition of the scope of secondary containment bypass leakage paths.

f. B'. HOTOR-0PERATED VALVES THERHAL OVERLOAD PROTECTION A list of valves that have thermal overload protection and bypass devices in-tegral with the motor starter for valves in safety systems is provided in the specification of these features. The table list the valves by number, the bypass device, and the system af fected. With the removal of this list of valves, the requirements could be stated om terms of "valves'in safety systems" to clarify the scope of the valves with thermal overload protection and bypass devices te which the specified requirements apply.

l r E. OTHER COMP 0NENT LISTS l l Corponent lists other than the examples provided herein may be candidates for removal from the TS on a p) ant-specific basis. The approach taken for en amend-eent request to remove these lists from TS should be based on the above guidance and any specific censiderations associated with each list. SUMMApY In sumary, request to remove corponent lists from TS should address the l following: l 1. That the specifications currently include an adequate description of ! the scope of the components to which the specified requirement s apply or a change is proposed to appropriately modify the specification to i provide a functional description of those components. Alternstly. this may be done through additions to the Definitions section of the 15 to define th9 scope of components and by stating the specification i requirements in terrs of a defined class of components. Components which are defined by reculatory requirements or guidance need not be defined further, however, the Bases of the TS could reference the I 1 r I

4 

                                  $ L.) M l &hk                     ?T j

applicable r'equirements or guidance which defines e the scope of the components includ

  • in the specification, m.

{

2. If the removal of a component list results in'the. loss of inforsation s '

or notes that modify the specified requirements, the specification should be modified to incorporate that infore'ation which should be retained. Such clarification of a specification should be stated in functional terms, rather than by a component identification number if practical.

3. The list of components removed from TS are confirmed to be lvcated in appropriately controlled plant documents. The Bases of the individ.

ual specifications may reference the documents tVt identify the applicable component lists.

  • 0 I.

I.' . i b att 2. c ',_ 'd ..,. 

                                                                            . I' IYb                  .4 O
  • 5 8
                                                                           ., ~ n                               ,,.

l

s. '
                                                                                                                 >c
i. .,e e I I
                                                                                                 .o                 3
                                                                             }g
                                                                                                                 ,J ill          'i i. : l

e

  • 4
  ,..   .                                                           ENCLOSURE 6 1%eAc                      io/s/se CPSE'S TECHNICAL SPECIFICATION IMPROVEMENT PROGRAM (TSIP)          ;

1.0 Purpose The TSIP is intended to supplement the CPSES Techn!. cal Specifications by prescribing the Limiting Conditions for Operation, Action i Statements, and Surveillance Requirements for those systems, components and structures listed under Scope. In some cases, the , Limiting Condition for Operation and the Action Statements were retained in the Technical Specifications and oniv the Surveillance [ Requirements and/or associated tables relocated to the TSIP. 2.0 Scope and Applicability The systems, components and structures to which the TSIP applies are 4 listed in the Index to Attachment 1. The TSIP incorporates, by reference, those definitions contained in the CPSES Technical Specifications which are applicable to this document. i Section 3/4.0. Limiting Conditions for Operation and Surveillance Requirements to the CPSES Technical Specifications shall apply to the TSIP, with the exception of Specifications 3.0.3. 3.0.4. or as otherwise explicitly stated in each individual Technical Requirement. 3.0 oreanization The body of the TSIP shall be arranged in the sase format as that used in the CPSES Technical Specificttions with the exception that the Bases are at the end of each section. In those cases where some aspect of the requirement was retained in the CPSES Technical . Specifications, the part retained shall be repeated in the TSIP, and [ will be clearly identified as being pe-t of the Technical Specifications in the right-hand margin of the applicable pages. , 4.0 Revision Control P.evisions to the TSIP shall be reviewed and approved prior to implementation. Such reviews shall meet the reouirements of CPSES Technical Specifications Section 6.5, and 10CTR50.59(a). Proposed changes shall be approved by the Vice President. Nuclear Operations, prior to implementation. The ORC nhall review safety evaluations related to changes to the TSIP. . Changes to the TSIP shall be reported to the NRC in accordance with the requirements of 10CTR50.59(b). 5.0 Document Control Distribution of the TSIP shall be identical to that for the CPSES Technical Specifications. Rev. O

c a EliCLOSURE 7 NRC/TU ELECTRIC TS MEETING ACTION ITEMS - October 5. 1988 ITEM NO.*/TS SECTION ACTION 24(58) 3.6.3 TV should propose changes to surveillance requirements to incorporate notes for table being relocated to the TU-TSIP.  : la 3.3.3.11 For radioactive effluent and environmental 33 3.11.1.1 monitoring specs, staff will propose to PRPB 34 3.11.1.3 and 0TSB reviewers that consulting with utility 35 3.11.1.4 users prior to finalizing the generic letter 36 3.11.2.1 permitting reiocation of specs to an admini-37 3.11.2.4 stratively controlled program would be bene-39(53),39(29)3.11.2.6 ficial. 40 3.11.3 41 3.11.4 42(49),42(50)3.12.1 43 3.12.2 44 3.12.3 7(54) 3.3.1 TV should describe in the CPSES-TSIP. Need to 8 3.3.2 describe and docket for staff review several 24(58) 3.6.3 weeks before issuance of Unit 1 "Proof and 32(64) 3.8.4.2 Review" TS. Describe controls over specs to be relocated, review process for changes and updates, etc. Detailed program requires staff review and approval before final TS are issued. 10 3.3.3.2 See Action for items 7(54),8,24(58), 11 3.3.3.3 and 32(64) directly above. TV should 12 3.3.3.4 also expand the change justification 13 3.3.3.9 for these items, similar to that in 27 3.7.9 (sury, only) HERITS pkg., using plant-specific PAA 28 3.7.10 or risk survey. 7(9) 3.3.1 TU to provide plant-specific change 4 justification, submit WCAP-11312 for staff review, and show specific applica-bility of WCAP-10271 to CPSES. ] 17 3.4.5 TU to provide a risk survey to justify j LCO relocation and propose changes r.oving surveillance requirements in TS. t i = Item nos, correspond to those in TXX 88605 (W. G. Counsil to NRC) dated ! 6/b/66, Attachtrer.t A. Where ar item listed more than one proposed TS change, j the distinguishing priority re. follows the item no, in parentheses.

4 4 - g. w A :, t i u. I t c. , - O c tc'y, E . IgCC. cer.tiruc ITEk NO.*/TS SECTION ACTION 22 3.6.1.4 TU to provide improved plant-specific justification. Staff to highlight spec to SPLB for review of pressure b,3nd and action statement time. 26 3.7.1.E Staff to review OTSB interpretaticns and reconsider position that change is "generic." (NRC concluded on 10/6/88 that change is generic.) 32(28) 3.8.4.2 TV to clarify justification to indicate that fuses are used as back-up protective devices in some cases. 23 3.6.1.7 TV to resubmit w/ plant-specific justification. 7(10) 3.3.1 NRC will treat boron mitigation system changes as plant-specific. 5 3.2.3 NRC to reconsider after discussing plant-3.2.5 specific vs. "generic" w/SRXB. S t. 3.11.2.5 Tentatively considered plant-specific pending OTSB discussions w/SPLB to verify. 20(18) 3.5.1 NRC to reconsider position that change is "generic." 20(16) 3.5.1 NRC tu reconsider after discussing lant-specific vs. "generic" w/SICB. p(NRC concluded on 10/6/88 that change isgeneric.) 1 2.2.1 NRC to check with SICB reviewer before changing staff position that change is "generic." (NRC concluded on 10/6/88 that change is indeed generic.) ACTION ITEMS - OCTOBER 6. 1988 1 2.2.1 TV to recheck setpoint methodology to determine if this change needs to be pursued as plant-specific. 29(15) 3.8.1.1 NRC to add change to TS. 29(14) 3.8.1.1.2 NRC to make change in a.5 to 80 sec. 10 3.4.4 NRC to add change to TS. 18(6) 3.4.6.2 NRC to add change to TS. 2-

F, h  ? 1 tion ltu? - October C, !?88, continut:0 iTEMNO.*/TSSECTIOk ACTION h/A N/A NRC to provide mark-up version of "Proof and Review" Unit 1 TS to TV in advance of typed copy. 3}}

Retrieved from "https://kanterella.com/w/index.php?title=ML20206E905&oldid=3014653"