ML20211C352

Informs of Decisions on Changes to Std TS NUREGs Proposed by NEI TS Task Force

ML20211C352
Person / Time
Issue date:	08/16/1999
From:	Beckner W NRC (Affiliation Not Assigned)
To:	Jennifer Davis NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
PROJECT-689 NUDOCS 9908250220
Download: ML20211C352 (6)

Text

i......

August 16, 1999 Mr. J:mes Davis, Director Operations Department Nuclear Energy Institute 1776 i Street, N. W.

Suite 400 Washington, DC 20006-3708

Dear Mr. Davis:

This is to inform ypu of our decisions on changes to the Standard Technical Specification (STS) NUREGs proposed by the NEl Technical Specification Task Force (TSTF). Those travelers Approved are TSTFs -030, R.3; -068, R.2; -190, R.1; -227; -273, R.2; -298; and -

312, R.1. Those travelers Modified, after discussion with the respective Owners Group Chairman, are TSTFs -038, R.3; 231; -276, R.1; -283, R.1; and -346. Please see the '

enclosure for NRC comments with regard to the travelers that were Modified.

For your information, the f.ollowing travelers are pending evaluation by a technical branch:

TSTFs -207, R.3 (SPLB); -226 (SRXB); -264 (SRXB); -295 (EICB); -297 (SPLB); -306 (EICB);

-313 (MCEB); -329 (SRXB); -332 (EICB); -334 (SPLB, SPSB, & MCEB); -335 (SPLB); -336 (SPLB); and -337 (SRXB).

Please contact me at (301) 415-1161 or e-mail wdb@nrc. gov, if you have any questions or need further information Sincerely, Odginal Sigtsd By William D. Beckner, Chief Technical Specifications Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 689 8

Enclosures:

As stated k i' DISTRIBUTION: }

cc: N. Clarkson, BWOG \ FILE CENTER TSB R/F H. Pontious, BWROG PUBLIC TSB Staff T. Weber, CEOG DMatthews/SNewberry D. Buschbaum, WOG . WDBeckner D. Hoffman, EXCEL RLDen:ng Q(g ,[

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.. ' Mr. James Davis, Director i

Operations Department Nuclear Energy institute 1776 i Street, N. W.

Suite 400 Washington, DC 20006-3708

Dear Mr. Davis:

This is to inform you of our decisions on changes to the' Standard Technical Specification-(STS) NUREGs proposed by the NEl Technical Specification Task Force (TSTF). Those travelers Approved are TSTFs -030, R.3; -068, R.2; -190, R.1; -227; -273, R.2; -298; and -

312, R.1. Those travelers Modified, after discussion with the respective Owners Group Chairman, are TSTFs -036, R.3; 231; -276, R.1; -283, R.1; and -346. Please see the enclosure for NRC comments with regard to the travelers that were Modified.

For your information, the following travelers are pending evaluation by a technical branch:

TSTFs -207, R.3 (SPLB); -226 (SRXB); -264 (SRXB); -295 (EICB); -297 (SPLB); -306 (EICB); -313 (MCEB); -329 (SRXB); -332 (EICB); -334 (SPLB, SPSB, & MCEB); -335 (SPLB); -336 (SPLB); and -337 (SRXB).

Please contact me at (301) 415-1161 'or e-mail wdb@nrc. gov, if you have any questions or need furtherinformation.

Sincerely, y AOh William D. Beckner, Chief .

Technical Specifications Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 689 -

Enclosures:

As stated cc: N. Clarkson, BWOG -

H. Pontious, BWROG -

T. Weber, CEOG

~- D. Buschbaum, WOG '

D. Hoffman, EXCEL L

u

)

Nuclear Energy Institute Project No. 689 l

cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director

- Senior Vice President ' Plant Support and Chief Nuclear Officer Nuclear Energy Institute

Nuclear En+roy institute Suite 400 Suite 400 .

1776 l Street, NW 4 1776 l Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charies B. Brinkman, Director Programs . Washington Operations Nuclecr Energy institute ABB-Combustion Engineering, Inc.

Suite 400 12300 Twinbrook Parkway, Suite 330 1776 l Street, NW - Rockville, Maryland 20852 Washington, DC 20006-3708 Mr. David Modeen, Director l Engineering l

Nuclear Energy Institute i Suite 400 1776 l Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Licensing  !

Nuclear Energy Institute I Suite 400 l 1776 i Street, NW Washington, DC 20006 3708  :

Mr. Nicholas J. Liparuto, Manager <

Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corperation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 1776 i Streat, NW Washington, DC 20006-3708

DISPOSITION

SUMMARY

i

- TSTFs -036. R.3: Modify *

. There are two general classes of LCOs for which thic proposed change applies:

1. Required electrical sources during shutdown, and

2. Vanous ventilation systems which are required to mitigate a fuel handling accident.

• elative to the electrical sources, it is difficult to see how the requirements for electrical sources during shutdown should be more restrictive than requirernents for electrical sources while at power. Thus entering the shutdown LCOs due to fuel movement should not impose any additional requirement.

The ventilation systen~.s applicable only to fuel movement do represent a potential problem in that these systems have generally have no relationship to power operation. It would be inappropriate and possibly contrary to safety to require a shutdown due to fuel handling problems. While the addition of the proposed note would solve this potential problem, the staff rejected it based on the low likelihood that such a problem would occur and the potential

. for introducing ambiguities in the TS.

This proposal to exclude LCO 3.0.3 applicability also goes contrary to a desire by the staff to expand applicability of LCO 3.0.3 to all modes of operation. The staff is concemed that if licensees can not comply with LCOs or associated AOTs , there should always be clear requkements. One way of accomplishing this is to expand the applicability of LCO 3.0.3 to shutdown which the staff has proposed as a change to the ISTS. The staff proposal did not address the issue of LCO applicability solely due to movement of fuel. However, the concem I about always having a clear path to follow is directly applicable to the industry concem that, due to an ambiguity in the technical specifications, a fuel handling problem might result in an '

inappropriate plant shutdown. The staff suggests that rather than making LCO 3.0.3 not applicable to these situations, that the staff proposal to change LCO 3.0.3 be further modified to raske it a5o specifically address the case of fuel movement at power.

TSTF-231: Modifv instead of revising to replace "any three" with "the", modify the phrase to read , "...no single instrament failure will preclude a scram from this Function even if one TSV should fail to close."

TSTF-276. R.1: Modify i

The proposed changes are essentially acceptable. However, the proposed Bases should be expanded to more closely reflect the SR NOTES that will be included as part of this change.

As propose 1, the Bases do not address the exception to meeting the power factor requirements or why it is acceptable. The following is a suggested change to the proposed Bases.

3

p ,

n Note 2 (Insert 3) Note 3 (Insert 4) ensures that the DG is tested under load conditions that are

} as close to design basis conditions as possible. When synchronized with offsite power,

' . testing should be performed at a power factor of =< [0.9]. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions.

j. Under certain conditions, however, Note 2 (Insert 3) Note 3 (Insert 4) allows the surveillance

~ to be conducted at a power factor other than =< [0.9]. These conditions occur when grid

- voltage is high, and the additional field excitation needed to get the power factor to =< [0.9]

results in voltages on the emergency busses that are too high. Under these conditions, the power factor should be maintained as close as practicable to [0.9] whl'e still maintaining

- acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obain a power factor of [0.9] may not cause unacceptable voltages on the emergency busses, but the exr.itation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maint'ined as close as pi.cucsble to [0.9) without exceeding the DG excitation limits.

TSTF-283. R.1: Modifv Recommendation to reject is changed to modify. This change is one of industry's key proposals that they feel very strongly about. It also appears that we have made some progress on coming closer to agrsement and discussions should be held with the TSTF in an attempt to reach agreement. These discussions should include the ElCB staff to ensure we can all agree on exact words.

TSTF-346: Modifv The concept is_ acceptable. However, some questions need to be answered and some details worked out. See the following comments / questions.

1. BWRs do not have reactor coolant pumps. Therefore, the proposed change is not directly

' applicable to BWRs. In order to make the proposed change applicable to BWRs, the

~ following questions need to be answered: (1) What systems / components that are only powered from offsite power does a BWR rely on to affect a shutdown to MODE 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />? (2) How long would it take for a BWR to reach MODE 5 using only systems / components powered from an EDG7

2. All plant designs are not the same.' There are some plants which have offsite sources which only power the emergency busses. For such plant designs, the loss of both offsite power sources would not necessarily mean that the reactor coolant pumps are without power.

This has not been addressed in the proposed change. In a plant design with separate offsite power sources to the emergency busses, the offsite power to the reactor coolant pumps would not be covered by TS, and the loss of this power would not invoke any TS Actions.

This has not been address 6d, either.

3. The issue of 3 AC sources inoperable in which 2 of the inoperable sources are EDGs has

' not been addressed in the proposed change.

The staff and the TSTF need to discuss this proposed change with a view towards modifications which would allow all possible scenarios to be addressed.

i...

TECHNICAL BRANCH NAMES AND ACRONYMS Division of Enoineerina (DE)

Materials and Chemical Engineering Branch (EMCB)

Mechanical and Civil Engineering Branch (MCEB)

Electrical and Instrumentation Controls Branch (EICB)

Division of Systems Safety and Analysis (DSSA) -

Plant Systems Branch (SPLB)

Reactor Systems Branch (SRXB)

Probabilistic Safety Assessment Branch (SPSB)

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