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WASHINGTON. D.C. 20566-0001January 24, 1994 .

.."-•'•'•••"• ' :' ... • • -jMEMORANDUM FOR: All NRR Employees ••

;' " ... . •iFROM: Thomas E. Murley, Director .' A

Office of Nuclear Reactor Regulation

SUBJECT: RELATIONSHIP BETWEEN THE GENERAL DESIGN CRITERIA (GDC) ANDTECHNICAL SPECIFICATIONS

Questions routinely arise regarding differences between design requirements inthe regulations, particularly the General Design Criteria (GDC), and technicalspecification requirements. This question was recently addressed 1n responseto a Differing Professional Opinion regarding the requirements for residual .heat removal systems during shutdown conditions. The enclosed response tothat concern provides a detailed comparison between the GDC and technicalspecification requirements.

The particular concern regarding the technical specification requirements forresidual heat removal capability during shutdown conditions will be resolvedas part of the staff's resolution of low-power and shutdown risks.Nevertheless, 1t 1s Important to understand that there are differences betweenthe GDC and technical specifications. I request, therefore, that youcarefully review the enclosure to understand how the NRC regulations work 1nconcert with the technical specifications to control plant safety.

The positions reflected in the enclosure will be Incorporated into theinspection guidance on operabllity, and Issued 1n a supplement to GenericLetter 91-18. In the interim, the Technical Specifications Branchesavailable to assist with plant-specific questions that may arise.

"7^^>kx^-FThomas E. Murley, DlrectoiOffice of Nuclear Reactor Regulation

Enclosure:

Relationship Between the General Design Criteria(GDC) and Exceptions to the GDC Allowed byTechnical Specifications, dated August 1, 1993

cc: T. Martin, Region IS. Ebneter, Region IIJ. Martin, Region IIIJ. Milhoan, Region IVB. Faulkenberry, Region VE. Jordan, AEODE. Beckjord, RESJ. Lieberman, OE

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January 24, 1994

MEMORANDUM FOR:

FROM:

SUBJECT:

All NRR Employees

Thomas E. Murley, DirectorOffice of Nuclear Reactor Regulation

RELATIONSHIP BETWEEN THE GENERAL DESIGN CRITERIA (GDC) ANDTECHNICAL SPECIFICATIONS

Questions routinely arise regarding differences between design requirements inthe regulations, particularly the General Design Criteria (GDC), and technicalspecification requirements. This question was recently addressed 1n responseto a Differing Professional Opinion regarding the requirements for residualheat removal systems during shutdown conditions. The enclosed response tothat concern provides a detailed comparison between the GDC and technicalspecification requirements.

The particular concern regarding the technical specification requirements forresidual heat removal capability during shutdown conditions will be resolvedas part of the staff's resolution of low-power and shutdown risks.Nevertheless, it 1s important to understand that there are differences betweenthe GDC and technical specifications. I request, therefore, that youcarefully review the enclosure to understand how the NRC regulations work 1nconcert with the technical specifications to control plant safety.

The positions reflected in the enclosure will be Incorporated Into theinspection guidance on operability, and issued in a supplement to GenericLetter 91-18. In the interim, the Technical Specifications Branch 1savailable to assist with plant-specific questions that may arise.

Orlginol Dign&d by.Thoma3 S« Hurley,

2G0K0Thomas E. Murley, DirectorOffice of Nuclear Reactor Regulation

Enclosure:


cc: T. Martin, Region IS. Ebneter, Region IIJ. Martin, Region IIIJ. Milhoan, Region IVB. Faulkenberry, RegE. Jordan, AEODE. Beckjord, RESJ. Lieberman, OE

DOCUMENT: G:\GDC-TS.R2

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MEMORANDUM FOR: All NRR Employees

FROM: Thomas E. Murley, DirectorOffico of Nuclear Reactor Regulation

SUBJECT: RELATIONSHIP BETWEEN THE GENERAL DESIGN CRITERIA (GDC) ANDTECHNICAL SPECIFICATIONS

Questions routinely arise regarding differences between design requirements inthe regulations, particularly the General Design Criteria (GDC), and technicalspecification requirements. This question was recently addressed 1n responseto a Differring Professional Opinion regarding the requirements for residualheat removal systems during shutdown conditions. The enclosed response tothat concern provides a detailed comparison between the GDC and technicalspecification requirements.

The particular concern regarding the technical specification requirements forresidual heat removal capability during shutdown conditions will be resolvedas part of the staff's resolution of low-power and shutdown risks.Nevertheless, the it is important to understand that there are differencesbetween the GDC and technical specifications. I request, therefore, that youcarefully review the enclosure to understand how the NRC regulations work Inconcert with the technical specifications to control plant safety.

This memorandum is being placed In the public document room so that you mayrefer to it when licensees raise questions about the GDC and technicalspecifications. In the event that more complex questions arise about the wayin which other regulations and regulatory guidance work 1n concert with thetechnical specifications to ensure plant safety, please refer these questionsto the Technical Specifications Branch.


Enclosure:


cc: T. Martin, Region I DISTRIBUTION:S. Ebneter, Region II Central FilesJ. Martin, Region III PDRJ. Milhoan, Region IV JMTaylorB. Faulkenberry, Region V TEMurleyE. Jordan, AEOD FJMIragliaE. Beckjord, RES NRR Mallroom (#0920213)J. Leiberman, OE DORS R/F

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DOCUMENT: G:\GDC-TS.REV * See previous concurrence

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MEMORANDUM FOR: NRR Staff

FROM:

SUBJECT:


RELATIONSHIP BETWEEN THE GENERAL DESIGN CRITERIA (GDC)REQUIREMENTS AND TECHNICAL SPECIFICATIONS

Questions raised concerning the relationship between General Design Criteria(GDC) requirements related to residual heat removal (RHR) systems andtechnical specification (TS) limits during shutdown conditions have beenaddressed by my enclosed memorandum of August 1, 1993. The enclosure providesa detailed comparison between the GDC and TS requirements. The staff ispursuing appropriate administrative and TS requirements related to low powerand shutdown conditions through a dedicated task force, and RHR systems willbe thoroughly addressed with respect to those conditions.

It is important to understand the differences between GDC and TS requirements.The enclosure should be carefully reviewed to understand how the NRCadministers regulations related to plant safety.

This memorandum is being placed in the public document room (PDR) so it can beutilized as a reference document when questions arise about the relationshipbetween the GDC and the TS.

Enclosure:

As stated

cc w/enclosure:E. BeckjordE. Jordan

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NUCLEAR REGULATORY COMMISSIONWASHINGTON, D.C. 20SS5-0001 <r ,'fe

August 1, 1993 -: ;:: T

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MEMORANDUM FOR: James M. Taylor •'i^;^^H^Executive Director for Operations

FROM:

SUBJECT:


RELATIONSHIP BETWEEN THE GENERAL DESIGN CRITERIA (GDC) ANDEXCEPTIONS TO THE GDC ALLOWED BY TECHNICAL SPECIFICATIONS

BACKGROUND ',•'./,;;w^;;:•^-;_;i^:>vr';,:_• -./::;-;-;^,;^ :• ;^^:::;^{.-; -^ .

In your memorandum of September 9, 1992, you directed the staff to address the 'issues raised by the Differing Professional Opinion (DPO), "Regulatory andTechnical Specification Requirements for Electrical Power Systems." Hymemorandum of October 7, 1992, described three tasks to address the Issues.This memorandum presents the results of the first task which was to:

Clarify the relationship between the General Design Criteria (GDC)and the exceptions to the GDC allowed by the TechnicalSpecifications. Include examples, one of which should be thesubject of the DPO, the RHR system during cold shutdown andrefueling.

RELATIONSHIP OF GDC TO TECHNICAL SPECIFICATIONS

As the DPO panel that reviewed this matter noted, the GDC and technicalspecifications differ 1n that the GDC generally set forth requirements fordesign of nuclear power reactors; whereas, technical specifications generallyrelate to requirements for operation of nuclear power reactors. The abilityto comply with both sets of requirements, the GDC and technical specifications, 1s required for the finding under 10 CFR 50.57 that "(t)he facilitywill operate 1n conformity with...the regulations of the Commission."Although the design criteria of the GDC and the operation requirements of thetechnical specifications are related, as discussed below, It 1s not a one-to-one correspondence. • ,v ...

The GDC (10 CFR Part 50, Appendix A) "establish the necessary design, -{fabrication, construction, testing, and performance requirements for , '.structures, systems, and components [SSCs] Important to safety." .'ThusV abroad spectrum of SSCs Important to safety Is covered by the GDC^ Not all theGDC, however, are directly reflected 1n the technical specifications. ]The GDCare reflected 1n the plant design as documented 1n the FSAR. The analyses 1nthe FSAR and the staff safety evaluation form the bases from which the .technical specifications are to be derived.

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Although a variety of features must be Included in the design of a nuclearpower reactor, only those aspects of the design and plant conditions that arerequired to assure adequate protection to the health and safety of the public;need be controlled by the technical specifications required by.lO CFR 50.36. :;•Technical specifications are to be "derived from the analyses and evaluationIncluded 1n the safety analysis report." They do not cover every aspect of kv-the design but rather, they establish, among other things, limiting conditionsfor operation which are "the lowest functional capability or performance:^ :levels of equipment required for safe operation of the Yacility."^The^^o' -Commission provided guidance 1n the Policy Statement on Technical ^^^^^vSpecification Improvements (52 FR 3788) and the recently approved final }-statement. This provides guidance on Identifying SSCs and plant conditions ofcontrolling Importance to safety which are to be included in technical a ^specifications. These technical specification requirements recognize, - -however, that even for those design features and plant conditions that requireclose regulatory control, there are varying degrees of safety importance.Thus, In most cases, whenever a limiting condition for operation is notsatisfied, remedial action, rather than a plant shutdown, is usually v:appropriate and specified. The allowed outage times associated with theremedial actions generally vary with safety .importance.-.;^'§sf^'':'y'^^

Section 182 of the Atomic Energy Act as Implemented by 10 CFR 50.36 requires*that those design features of the facility which, if altered or modified,would have a significant effect on safety be Included in technical^- - • 'specifications. Pursuant to 10 CFR 50.59 specific aspects of those SSCs thatare described in the FSAR may be changed by the licensee without prior NRCapproval unless the changes are unreviewed safety questions or a change in thetechnical specifications. ••'.•;.: •:,'-K-h';-l'; -.•

Changes to the facility at a level of detail below that covered in the FSARare not restricted by Commission regulations, provided that such changes.donot result in changes to the FSAR and do not also have the effect of resultingin noncompliance with Commission regulations, orders, or license conditions.However, certain such changes are controlled by the design control process ofthe QA program required by 10 CFR Part 50 Appendix B.

Changes to systems, components, or procedures described in the FSAR are *allowed pursuant to 10 CFR 50.59 provided such changes do not introduce *accidents or malfunctions not previously evaluated, do not increase the:probability or consequences of accidents previously evaluated, and do notdecrease margins of safety defined 1n the basis of any technical specification. The staff believes that the tests of 10 CFR 50.59 could not be,satisfied 1f compliance with a GDC, as reflected in the FSAR and staff safetyevaluation, were violated by a proposed change.

1 Termed "completion times" in the Improved standard technicalspecifications.- ^'-, V;V''.'::'v^.-.':;v'^^

••^.-.v

James M. Taylor - 3 - August 1, 1993

Both the provisions of 10 CFR Part 50, Appendix B and the remedial actionprovisions of the technical specifications recognize the need to carefullymanage the response to equipment failures and to manage the maintenance that1s an expected part of plant operation.

EXAMPLE

The different aspects covered by the GDC and the technical specifications canbe Illustrated by how the requirements of the GDC and technical specificationsare applied to the RHR system.

Criteria 34, "Residual heat removal," and 35, "Emergency core cooling" of theGDC state In part:

"A system to remove residual heat shall be provided. The systemsafety function shall be to transfer fission product decay heatand other residual heat from the reactor core at a rate such thatspecified acceptable fuel design limits and the design conditionsof the reactor coolant pressure boundary are not exceeded."

"A system to provide abundant emergency core cooling shall be provided.The system safety function shall be to transfer heat from the reactorcore following any loss of reactor coolant at a rate such that (1) fueland clad damage that could Interfere with continued effective corecooling 1s prevented and (2) clad metal-water reaction is limited tonegligible amounts."

These criteria are implemented in the design by specifying design parameters,such as the flow rates that must be delivered under shutdown and accidentconditions. These parameters assure that the completed facility Is capable ofachieving the performance required by the GDC. The licensee commitments inthe FSAR and the staff assumptions stated in safety evaluations form the basisfor staff approval of the design.

Technical specifications, on the other hand, do not directly specify flowrates under accident and shutdown conditions,'but rather specify conditionsunder which the approved design can be operated within the conditions of thelicense. The technical specifications might, for example, specify the numberof trains to be normally operating in various operational modes, or mightspecify operability 1n some modes and remain silent with respect to others.However, the specific values or functions required by the technicalspecifications for continued operation under normal conditions should beselected so as to assure that the system or component will be able to carryout its design functions under accident and transient conditions.Similarly, surveillance are used to demonstrate that the most safetysignificant measurable functions are satisfied. Surveillance to determineflow rates under test (as opposed to accident) conditions may be specified inthe technical specifications, or these may be left to the control of plant

James M. Taylor ^-4-'^*^•rdf; ,

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procedural controls, depending on the perceived safety significance of (theVtests at the time of licensing.'. . '^"W^

Further, Criteria 34, "Residual heat removal,f and 35, "Emergency core ::cooling" of the GDC state 1n part, with respect to electrical systems: •

•Suitable redundancy 1n components and features ••• shall be -"provided to assure that for onslte electric power system operation '(assuming offslte power 1s not available) and for offsite electric :power system operation (assuming onslte power is not available) uthe system safety function can be accomplished, assuming a single^ :failure." • • ,-.•• v//, \,^s^

With respect to redundancy of power supplies, the 'staff has "not required-:1automatic responses to all single failures 1n shutdown modes because of, atleast in part, the additional time available to react manually to provide heatremoval during transients 1n shutdown modes/This is further discussed in theDPO panel response dated August 14, 1992, and below under the discussion oflow-power and shutdown conditions. Thus, the technical specifications areIntended to assure that the most safety significant design features (thosewhich 1f altered or modified, would have a significant effect on safety) ofthe design, as determined by the safety analysis, are satisfied.

GENERAL COMPARISON /•.',:•;' •••"- ^. •\ ..••IjH)-^;'^The enclosed summary table provides a general comparison between the GDC andspecific technical specification requirements. The major areas of differencebetween the GDC and technical specifications are as follows:

•. ' ' ' .. '• i"

• Some GDC establish broad requirements. The operational aspects of someof these requirements are controlled by technical specifications whileothers are not. Such GDC Include GDC 1, "Quality standards andrecords;" GDC 2, "Design bases for protection against naturalphenomena;" GDC 4, "Environmental and dynamic effects design bases;" andGDC 5, "Sharing of structures, systems, and components." •

• Some GDC establish specific requirements for design features and :capabilities that apply to abnormal operational occurrences or accidentconditions. These GDC have related but not comprehensive I1m1t1naconditions for operation or safety limits. Such requirements includeGDC 11, "Reactor Inherent protection;" GDC 12, "Suppression of reactor/power oscillations;" GDC 22, "Protection system independence;" GDC 23,"Protection system failure modes;" GDC 24, "Separation of protection andcontrol systems;" GDC 25, "Protection system requirements for reactivitycontrol malfunctions;" GDC 29, "Protection against anticipated•'•;::operational occurrences;" and GDC 51, "Fracture prevention of 'containment pressure boundary."

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Some GDC establish specific design requirements for which technicalspecification limiting conditions for operation or safety'limits apply;only over part of the range of operating modes; JThese limited ^^ 4^applications are noted 1n the enclosure. These GDC relate primarily todesign capabilities for (1) abnormal occurrences and accidentconditions, and (2) SSC operabdllty, redundancies, or applicabilities,for hot shutdown, cold shutdown, or refueling conditions.

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Technical specifications specify operational (LCO) requirements under normalconditions which are Intended to assure, for the most safety significant >;functions, (I.e., the lowest functional capability requirements for safe c>operation) that the design functions evaluated 1n the safety analysis will beassured for abnormal transient or accident conditions/;';;-i-}, r';y;: i^-^•;''::%'• '^

The summary table notes various other differences between the GDC requirementsand technical specifications requirements which are justified by considerationof the difference between design performance capabilities and control ofImportant operational parameters.

[ffl-PWER ANP SHUTDOWN ;

Requirements for low-power and shatdown conditions are not addressedconsistently in current technical specifications. Low-power and shutdownconditions have long been considered to have a high degree of Inherent safety,as 1s reflected by the requirement in Section 50.36 to shut down the plantwhen the technical specifications requirements are not met. ':;';

With the application of probabilistic safety analyses to events during low-power and shutdown conditions, certain transients and accidents during low-power and shutdown conditions were found to be significant to overall plantrisk. For this reason, the NRC Initiated a comprehensive study of low-powerand shutdown risk in order to determine what actions should be taken toenhance plant safety in these operating modes. That study, which is nearingcompletion, will recommend actions to control plant conditions during low-power and shutdown modes.

Those recommendations that are approved for generic Implementation willestablish the means of control for those SSCs and plant conditions judged tobe Important to plant safety during low-power and shutdown conditions.. Theevaluation basis for those actions approved for generic implementation willprovide the documented justification for the operational requirements thatmust be controlled 1n the license.

On the basis of the low-power and shutdown assessment thus far, certain modes ,of RHR operation may be Important enough to plant safety to warrant ;:requirements for the RHR system to be fully redundant and capable of • :withstanding a single failure for either the onslte or offsite electricalpower systems. Other less vulnerable periods of RHR operation may warrant

'i*.^

James M. Taylor - 6 - August 1, 1*993

fewer restrictions to provide for system maintenance and testing. Proceduralconstraints for fuel handling and spent fuel cooling provide reasonableassurance that public health and safety would be maintained during defueledplant conditions.

SUMMARY

In summary,operationalcations arethese analylicensing aexplanationthe techniccase-by-casfacts or re

operabilityanalyses in

both the design capability of the facility to meet the GDC and therestrictions which are to be Included In the technical specifl-descrlbed in the FSAR. The staff Judgment on the acceptability ofses 1s given in the staff safety evaluation which accompanies action. While neither of these documents provides a po1nt-by-po1ntof all the design capabilities that are or are not specified 1n

al specifications, the NRC staff has justified their judgment on ae basis when necessary. This judgment may require revision 1f newasoning are brought forward or, as 1s the case of RHR systemin shutdown modes, 1f operational experience and probabilistic

dicate that changes to the technical specifications are warranted.

This concludes our work on the first task.

Enclosure:

As stated


ENCLOSURE

General Comparison of GDC and Technical Specification Requirements

QDC TITLE T8 REMARKS 4. DIFFERENCES

1 Quality standards andrecords.

Partial TS Include an administrative control for specificrecords. The Quality Assurance Program for safety-related SSCs is required by 150.54(a) and Appendix Bto Part 60.

2 Design bases for protectionagainst natural phenomena.

No However, applicable natural phenomena sre Inherentlyconsidered In the operability of safety-related SSCs thatsatisfy the criteria for inclusion in TS.

3 Fire protection. Partial The Fire Protection Program Is an administrative controlin the improved STS as well as for some operatingreactors. Other operating reactors have TS foralternate shutdown capability, including the remoteshutdown equipment.

4 Environmental and dynamiceffects of design bases.

No However, applicable environmental and dynamic effects-are inherently considered in the operability of safety-related SSCs that satisfy the criteria for inclusion in TS.

5 Sharing of structures,systems, and components.

Partial Limitations on the operability of shared SSCs should bereflected in the LCOs for each unit of a multi-unit site,consistent with the licensing, basis.

10 Reactor design. Partial TS include limits for RCS pressure and temperatureover the range of normal operating conditions, but notabnormal operational occurrences. The improved STSinclude an administrative control to recalculate the

pressure-temperature limits. BWR safety valveoperability is excluded for hot shutdown. The BWRSTS do not have an LCO for low temperatureoverpressure protection; while overpressure protectionmay be provided by RHR relief valves, there is no LCOand the RHR is not required to be operable in hotshutdown if a recirculation pump ia running.

11 Reactor inherent protection. No

These are inherent design capabilities that are implicitin the safety limits for reactor operation.12 Suppression of reactor

power oscillations,No

13 Instrumentation and control. Partial LCOs for accident monitoring instruments are notapplicable for cold shutdown and refueling modes. TheLCOs for BWRs exclude the hot shutdown mode foraccident monitoring instruments associated with theRCS, drywell, and suppression pool.

14 Reactor coo/ant pressureboundary.

Partial Same as GDC 10. TS include an administrative controlfor ISI & 1ST; material limits and surveillancerequirements are administered by Appendices G & H.

15 Reactor coo/ant systemdesign.

Partial

16 Containment design. Partial Containment integrity Is required in TS for poweroperation; design requirements apply to accidentconditions. |

QDC TITLE T8 REMARKS & DIFFERENCES

17 Electric power systems. Partial LCOs for electric power systems do not requireredundant offsite and onslte qualified power sources inshutdown conditions (PWR modes 5 & 6 snd BWRmodes 4 St 5).

18 Inspection and testing ofelectric power systems.

Yes TS Include specific surveillance requirements forselected features of onslte and offsite ac powersystems, under conditions "as close to design aspractical,-

19 Control room. Partial LCOs are provided for design features associated withmaintaining control room habitabitity through thecourse of an accident. The LCO for remote shutdown

equipment Is not applicable in hot shutdown; the GDCreaulres the caoabiiitv to achieve and maintain a hot

shutdown condition. TS for operating reactors IncludeLCO and surveillance requirements for control roomsafety-grade filters to ensure the capability to limitradiation doses to the operators; the improved STSaccomplishes this objective with an administrativecontrol for safety-grade filter testing.

20 Protection systemfunctions.

Partial TS include an LCO for the protection system over therange of normal operating conditions.

21 Protection system reliability. Yes TS Include specific surveillance requirements forselected features of the protection system.

22 Protection systemindependence.

No

However, applicable features are implicit in theoperability of the protection system.

23 Protection system failuremodes.

No

24 Separation of protection andcontrol systems.

No

25 Protection systemrequirements for reactivitycontrol malfunctions.

No

26 Reactivity control systemredundancy and capability.

Partial

TS include LCOs for the reactivity control, reactor trip,and ESFAS systems over the range of normal operatingconditions.

27 Combined reactivity controlsystems capability.

Partial

28 Reactivity limits. Partial

29 Protection againstanticipated operationaloccurrences.

No However, applicable capabilities are implicit in theoperability of the protection and reactivity controlsystems.

-2-

GDC TITLE T8 REMARKS a\ DIFFERENCES

30 Quality of reactor coolantpressure boundary.

Partial TS Include LCO %nd surveillance requirements for RCSIdentified and unidentified leakage. LCO for RCSleakage detection Is not applicable during coldshutdown and refueling modes (PWR modes S & 6 andBWR modes 4 & 5).

31 Fracture prevention ofreactor coolant pressureboundary,

PartialTS include an administrative control for ISI & 1ST;msterisl limits are administered by Appendix G.

32 Inspection of reactorcoolant pressure boundary.

Partial

33 Reactor coolant makeup. Partial LCOs are provided for the makeup systems over therange of normal operating conditions; certain Injectionsystems must be rendered Inoperable to protect egalnstLTOP conditions during shutdown conditions.

34 Residual heat removal. Partial The GDC requires the capability to remove decay heatto ensure fuel limits are not exceeded for abnormaloccurrences assuming a single failure for either onslteor offsite power. The LCO for RHR during refuelingdoes not require redundancy when the water level Isat 23 feet above the vessel flange.

35 Emergency core cooling. Partial The GDC requires the capability to prevent fuel damagefor "any loss of coolant" (not limited to accidents) andassuming a single failure. The ECCS LCO does norrequire redundancy during shutdown end refueling, endwhen the water level Is a: 23 feet, amongst otherconditions, for BWRs.

36 Inspection of emergencycore cooling system.

No Not applicable, except to the extent that surveillancerequirements are provided for ECCS equipment tosatisfy the LCOs associated with GDC 35 end 37.

37 Testing of emergency corecooling system.

Yea TS include specific surveillance requirements forselected features of the ECCS system.

38 Containment heat removal. Partial The LCO for containment heat removal Is onlyapplicable down to the hot shutdown condition.

39 Inspection of containmentheat removal system.

No Not applicable, except to the extent that surveillancerequirements are provided for ECCS equipment tosatisfy the LCOs associated with GDC 38 and 40.

40 Testing of containment heatremoval system.

Yes TS Include specific surveillance requirements forselected features of the containment heet removelsystem.

41 . Containment atmospherecleanup.

Partial The LCO for containment spray and hydrogen control laonly applicable down to the hot shutdown condition.The TS for operating reactore Include LCOa andsurveillance requirements for safety-grade filters uaedfor containment etmosphere cleenup; the Improved STSinclude an administrative control for eefety-grede filtertesting.

GDC TITLE IS REMARKS & DIFFERENCES

42 Inspection of containmentatmosphere cleanupsystems.

No Not applicable, except to the extent that surveillancerequirements are provided for engineered safetyfeatures to satisfy the LCOs and surveillancerequirements essociated with GDC 41 and 43.

43 Testing of containmentatmosphere cleanupsystems,

Yes TS include specific surveillance requirements forselected features of the containment atmospherecleanup system, Including containment spray, hydrogoncontrol systems, and safety-grade filter systems.

44 Cooling water. Partial The GDC requires that such systems be able to transferheat assuming a single failure. GDC 34 requires RHRredundancy independent of any other GDC requirementfor redundancy. The BWR service water system LCOdoes not require redundancy when the water level Is* 23 feet above the vessel. The PWR componentcooling end service water system LCOs exclude theshutdown and refueling modes.

45 Inspection of cooling watersystem.

No Not applicable, except to the extent that surveillance -requirements are provided for cooling water systems tosatisfy the LCOs associated with GDC 44 and 46.

46 Testing of cooling watersystem.

Yes TS include specific surveillance requirements forselected features of the cooling water system.

50 Containment design basis. Partial TS include an LCO for containment operability(integrity), including access openings and containmentisolation valves.

51 Fracture prevention ofcontainment pressureboundary.

Partial TS include an administrative control for ISI & 1ST, tothe extent that those programs are applicable to thesafety-related containment SSCs.

52 Capability for containmentleakage rate testing.

Yes Surveillance requirements consistent with 10 CFR 50,Appendix J are required to demonstrate containmentoperability.

53 Provisions for containmenttesting and inspection.

No Not applicable, except to the extent that surveillancerequirements are provided for containment systems tosatisfy the LCOs associated with GDC 50.

54 Piping systems penetratingcontainment.

No Not applicable, except to the extent that operability andsurveillance requirements are specified for containmentisolation valves to satisfy the containment LCO underGDCs 50, 55, 56, and 57.

GDC TITLE TS REMARKS & DIFFERENCES

55 Reactor coolant pressureboundary penetratingcontainment.

PartialTS include an LCO requiring operability of altcontainment isolation vaives during normal plantoperation, although the listing of containment isolationvalves may be maintained outside the TS.56 Primary containment

isolation.Partial

57 Closed system isolationvalves.

Partial

60 Control of releases of

radioactive materials to the

environment.

Partial jSome operating reactors and the improved STS have anadministrative control for the Radiological EffluentTreatment System (RETS), as permitted by GenericLetter 89*01. Other operating reactors have LCOs andsurveillance requirementa for RETS. 10 CFR 20requirements apply.

61 Fuel storage and handlingand radioactivity control.

Partial TS include LCOs for RHR and cooling systems, vessellevel during refueling, and pool level. LCOs are alsoprovided for containment integrity for fuel handlingareas prior to and during fuel movement.

62 Prevention of criticality infuel storage and handling.

Partial PWRs include LCO limits on boron concentration to

prevent criticality during refueling. BWRs include LCOsand surveillance requirements for control rod positionduring fuel handling. Both PWRs and BWRs have TSand surveillance requirements for fuel elementconfiguration in the spent fuel storage racks to preventcriticality.

63 Monitoring fuel and wastestorage.

Partial TS Include LCOs for radiation monitors.

64 Monitoring radioactivityreleases.

Partial Some operating reactora and the Improved STS have anadministrative control for RETS. Other operatingreactors have LCOs and surveillance requirements forthe radioactivity monitoring systems. 10 CFR 20applies.

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