United States Nuclear Regulatory Commission - Protecting People and the Environment

NUREG-0737 Technical Specifications (Generic Letter No. 82-16)

                               UNITED STATES 
                          WASHINGTON, D. C. 20555 

                             September 20, 1982 




NUREG-0737 "Clarification of TMI Action Plan Requirements" identifies those 
items for which Technical Specifications are required. Technical 
Specifications are required to provide necessary assurance that facility 
operation is maintained within the limits determined acceptable following 
implementation at each facility. The scope and type of specification should 
include appropriate actions if a limiting condition for operation cannot be 
met, and for installed equipment, relevant surveillance requirements. 

A number of NUREG-0737 items which require Technical Specifications were 
scheduled for implementation by December 31, 1981. Each of those items is 
discussed in Enclosure 1. Included in the discussion is guidance on the 
scope of a specification which the staff would find acceptable. Enclosure 2 
are samples in Standard Technical Specification format with blanks or 
parentheses appearing where the information is plant specific. It includes 
appropriate pages as background information for facilities that do not have 
Standard Technical Specifications. These samples are for your information 

We solicited comments on proposed Technical Specifications from all 
pressurized water reactor owners groups and Atomic Industrial Forum. 
Appropriate comments have been incorporated. We request that you review your
facility's Technical Specifications to determine if they are consistent with
the guidance provided in Enclosure 1. For those items where you identify 
deviations or absence of a specification, we request that you submit an 
application for a license amendment. If some of the items are not yet 
implemented at your facility, you should submit an amendment request at the 
time they are implemented. Please respond within 90 days of receipt of this 

This request for information was approved by the Office of Management and 
Budget under clearance number 3150-0065 which expires May 31, 1983. Comments
on burden and duplication may be directed to the Office of Management and 
Budget, Reports Management Room 3208, New Executive Office Building, 
Washington, D.C. 20503. 


                                   Darrell G. Eisenhut, Director 
                                   Division of Licensing  
                                   Office of Nuclear Reactor Regulation 


Multiple Addressees                 - 2 - 

1. Technical Specification 
2. Sample Technical Specification  

                                                               ENCLOSURE 1 

                  (ITEMS SCHEDULED BY DECEMBER 31, 1981) 

(1)  A Training (I.A.1.1.3) 

     Our July 2, 1980 letter provided model TSs for TMI lessons learned 
     Category "A" items. Included were TSs that specified the 
     qualifications, training and on-duty requirements for the Shift 
     Technical Advisors (STA). STA training requirements are under the 
     consideration by the Commission. Further guidance will be provided 
     pending the decision on the requirements by the Commission. 

(2)  Limit Overtime (I.A.1.3) 

     On June 15, 1982 we transmitted to licensees of operating plants a 
     revised version of the Commission's Policy Statement on nuclear power 
     plant staff working hours. In the same letter we also transmitted 
     revised pages of NUREG-0737 (Item I.A.1.3). The administrative section 
     of the technical specifications should be revised to require procedures
     that follow the policy statement guidelines. An acceptable 
     specification would be the amount of overtime worked by plant staff 
     members performing safety-related functions must be limited in 
     accordance with the NRC Policy Statement on working hours (Generic 
     Letter No. 82-12)," or following the model TSs in Enclosure 2. 

(3)  Short Term Auxiliary Feedwater System Evaluation (II.E.1.1) 

     The objective of this item is to improve the reliability and 
     performance of the auxiliary feedwater (AFW) system. TSs depend on the 
     results of the licensee's evaluation and the staff review, and are 
     being developed separately for each plant. The limiting conditions of 
     operation (LCO's) and surveillance requirements for the AFW system 
     should be similar to other safety-related systems. 

(4)  Safety grade AFW System Initiation and Flow Indication (II.E.1.2) 

     The AFW system automatic initiation system was to have been control 
     grade by June 1, 1980 and safety grade by July 1, 1981; the AFW system 
     flow indication was to have been control grade by January 1, 1980 and 
     safety grade by July 1, 1981. The control grade requirement was part of
     the short tem lessons learned activities, and model TSs were included 
     with our July 2, 1980 letter. These TSs are considered adequate as TSs 
     for the safety grade requirement. 

                                     - 2 - 

(5)  Dedicated Hydrogen Penetrations (II.E.4.1) 

     Plants that use external recombiners or purge systems for post-accident
     combustible gas control of the Containment atmosphere should provide 
     containment penetrations dedicated to that service. In satisfying this 
     item, some plants may have to add some additional piping and valves. If
     so, these valves should be subjected to the requirements of Appendix J,
     and the TSs should be modified accordingly. 

(6)  Containment Pressure Setpoint (II.E.4.2.5) 

     The containment pressure setpoint that initiates containment isolation 
     must be reduced to the minimum compatible with normal operating 
     conditions. Most plants provided justification for not changing their 
     setpoint and we approved their justification by separate 
     correspondence. The remaining plants must submit a change to the TSs 
     with the lower containment pressure setpoint and provide justification 
     if this setpoint is more than 1 psi above maximum expected containment 
     pressure during normal operation. 

(7)  Containment Purge Valve (II.E.4.2.6) 

     Model TSs are being sent separately to each plant as part of the 
     overall containment purge review. These TSs include the requirement 
     that the containment purge valves be locked closed except for 
     safety-related activities, verified closed at least every 31 days, and 
     be subjected to leakage rate limits. 

(8)  Radiation Signal on Purge Valves (II.E.4.2.7) 

     The containment purge valves must close promptly to reduce the amount 
     of radiation released outside containment following a release of 
     radioactive materials to containment. TSs should include the 
     requirement that at least one radiation monitor that automatically 
     closes the purge valves upon sensing high radiation in the containment 
     atmosphere be operable at all times except cold shutdowns and refueling 
     outages. If not operable, either the plant should being proceeding to 
     cold shutdown within 24 hours or the purge valves should be closed 
     within 24 hours. Model TSs are provided in Enclosure 2 in Standard 
     Technical Specifications format for those plants that are using 
     safety-grade components to satisfy the requirement. 

(9)  Upgrade B&W AFW System (II.K.2.8) 

     Acceptance criteria for proposed TSs are identical to that described in
     (2) and (3) above. 

                                    - 3 -

(11) B&W Thermal-Mechanical Report (II.K.2.13) 

     Licensees of B&W operating reactors are required to submit by January 
     1, 1981 an analysis of the thermal-mechanic conditions in the reactor 
     vessel during recovery from small breaks with an extended loss of all 
     feedwater. TSs, if required, will be determined following staff review.

(12) Reporting SV and RV Failures and Challenges (II.K.3.3) 

     NUREG-0660 stated that safety and relief valve failures be reported 
     promptly and challenges be reported annually. The sections of your TSs 
     that discuss reporting requirements should be accordingly changed; 
     model TSs are given in Enclosure 2. Note that an acceptable alternative 
     would be to report challenges monthly. 

(13) Anticipatory Trip on Turbine Trip (II.K.3.12) 

     Licensees with Westinghouse-designed operating plants have confirmed 
     that their plants have an anticipatory reactor trip upon turbine trip. 
     Many of these plants already have this trip in their TSs. For those 
     that do not, the anticipatory trip should be added to the TSs. Model 
     TSs are included in Enclosure 2 in the format of Standard Technical 
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