NUREG-0737 Technical Specifications (Generic Letter No.83-02)

                               UNITED STATES 
                          WASHINGTON, D. C. 20555 

                              January 10, 1983 



Subject:  NUREG-0737 Technical Specifications (Generic Letter No.83-02) 

NUREG-0737, "Clarification of TMI Action Plan Requirements," identifies 
those items for which Technical Specifications are required. Technical 
Specifications are required to provide 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 limiting conditions for operation cannot be met. 
Relevant surveillance requirements for installed equipment should also be 

A number of NUREG-0737 items which require Technical Specifications were 
scheduled for implementation by December 31, 1981. Each of those items is 
present in Enclosure 1. Included in the enclosure 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 the boiling 
water reactor owners group 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. The Bases Section should be revised, as appropriate, to 
reflect the changes made in Technical Specifications. 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 letter. 

This request for information was approved by the Office of Management and 
Budget under clearance number 3150-0065 which expires May 31, 1983 


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

cc: See next page 


                                                             ENCLOSURE 1  


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

     Our July 2, 1980, letter provided model Technical Specifications (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 
     consideration by the Commission. Further guidance will be provided 
     pending decision regarding engineering expertise on shift by the 

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

     On June 15, 1982 we transmitted to licensees 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 to 
     NUREG-0737 (Item 1.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)  Dedicated Hydrogen Penetrations (II.E.4.1) 

     Plants that use external recombiners or purge/repressurization systems 
     for post-accident combustible gas control of the containment atmosphere
     should provide containment penetrations dedicated to that service. The 
     acceptable alternative is a combined design for use by either external 
     recombiners or purge/repressurization systems and other systems which 
     meet the requirements of Section 50.44 of 10 CFR Part 50. 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. 

(4)  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 justifications by separate 
     correspondence. The remaining plants have submitted a change to the TSs
     with the lower containment pressure setpoint. No further actions are 


(5)  Containment Purge Valves (II.E.4.2.6) 

     Model TSs are being sent separately to each plant as part of the 
     overall containment purge and vent system review, Technical 
     Specifications will be reviewed separately for each plant. In general, 
     these TSs include the requirement that: 

     a.   Containment purge or vent valves be locked closed if found not f 
          qualified for operation during a LOCA, and be verified locked 
          closed at least every 31 days; 

     b.   Containment purge or vent valves be used only when needed for 
          safety related reasons; 

     c.   Containment purge or vent valves with resilient seals be sub-
          jected to leakage testing and periodic resilient seal replacement.

     Allowable time period in each year for purge/vent operation at each 
     plant will be considered on a case-by-case basis. 

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

     NUREG-0737 requires that containment purge and vent isolation valves 
     must close on a high radiation signal to reduce the amount of radiation
     released outside containment following a release of radioactive 
     materials to containment. The BWR Owners' Group has taken exception to 
     this requirement and submitted their evaluation to NRC. NRC is 
     currently reviewing the latest submittal of the Owners' Group. 
     Technical Specifications for this item will be established after the 
     technical resolution of this issue is completed. 

(7)  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. 

                                    - 3 -  

(8)  RCIC Restart and RCIC Suction (II.K.3.13, II.K.3.22) 

     The design of RCIC should be modified such that: 

     1)   The system will restart on subsequent low water level after it has
          been terminated by a high water level signal; 

     2)   RCIC system suction will automatically switchover from the 
          condensate storage tank to the suppression pool when the 
          condensate storage tank level is low. 

     Provide technical specifications for both of the above modifications.It
     could be included with other technical specifications for the RCIC 
     system. Typical acceptable limiting conditions for operation (LCO) and 
     surveillance requirements, for instrumentation and system operational 
     capability, are given in Enclosure 2. 

(9)  Isolation of HPCI and RCIC Modification (III.K.3.15) 

     The pipe break-detection circuitry should be modified so that pressure 
     spikes resulting from HPCI and RCIC system initiation will not cause 
     inadvertent system isolation. The plants using a time delay relay for 
     this modification should change their technical specification to 
     include the time delay added by the relay in the isolation system 
     instrumentation response time. The minimum and maximum expected 
     response time should be provided as discussed in the sample TSs (in 
     Enclosure 2). 

     The minimum expected response time is a plant specific value. The 
     maximum expected response time should not be higher than seven seconds 
     unless the licensee provides proper justification for selecting a 
     higher response time. The plants which don't have isolation system 
     response time in their Technical Specifications, should include the 
     setpoint and the surveillance requirements on the time delay relay in 
     the TSs. 

(10) Interlock on Recirculation Pump Loops (II.K.3.19) 

     Interlocks are required on nonjet pump plants (other than Humboldt Bay)
     to assure that at least two recirculation loops are open for 
     recirculation flow for modes other than cold shutdown. This is to 
     assure that the level measurements in the downcomer region are 
     representative of the level in the core region. 

     Since there are very few plants affected by this modification and the 
     change may be plant specific, we advise these plants to develop the 
     technical specification and submit to the staff. The technical 
     specification should include some surveillance requirements on the 
     instrumentations and the corrective actions to be taken in case of 
     instrumentation malfunction or failure. 

                                    - 4 - 

(11) Common Reference Level (II.K.3.27) 

     All level instruments should be referenced to the same point. If a 
     figure defining reactor vessel water levels is included in the 
     Technical Specifications of your plant, it should be changed to reflect 
     the common reference level established by this Action Plan Item. A 
     sample figure is given in Enclosure 2. 

(12) Manual Depressurization (II.K.3.45) 

     Technical resolution of this Action Plan Item has just been completed. 
     The staff will not require any modifications in plant design and 
     operation. Therefore no changes to Technical Specifications will be 

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