ML24274A158
| ML24274A158 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 01/28/2025 |
| From: | NRC/NRR/DSS/STSB |
| To: | Technical Specifications Task Force |
| References | |
| Download: ML24274A158 (1) | |
Text
NRC Comments Draft TSTF-604, Revise Ventilation System Actions (ML24169A406)
REVIEWERS NOTE-------------------------
Adoption of Condition X is dependent on a commitment from the licensee to have written procedures available describing compensatory measures to be taken in the event of an intentional or unintentional entry into Condition X.
How will this commitment be captured in the model application for preplanned mitigating actions?
- 2. The acceptability of this STS change is based on the mitigating actions providing adequate protection. To ensure adequate protection, the word should must be changed to shall in the STS Bases for control room ventilation systems where immediately initiating action to implement mitigating actions is a TS requirement.
Example bases excerpt:
If both CREFS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e., Condition C), the CREFS may not be capable of performing the intended function. Therefore, immediate action must be initiated to implement mitigating actions to lessen the effect on the CRE occupants from potential hazards such as radioactive contamination, toxic chemicals, smoke, temperature, relative humidity, and temperature. Preplanned measures should be available to address these concerns. At least one CREFS train must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions.
- 3. Draft TSTF-604 states that preplanned measures will be available to address these concerns for intentional or unintentional entry into Condition [B] and that this will be stated in the STS Bases. Please discuss, as applicable, any deviations of the proposed preplanned measures with respect to the application and implementation to operators.