[Federal Register Volume 71, Number 139 (Thursday, July 20, 2006)]
[Notices]
[Pages 41264-41280]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 06-6364]


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NUCLEAR REGULATORY COMMISSION


Technical Specification Improvement for Combustion Engineering 
Plants to Risk-Inform Requirements Regarding Conditions Leading to 
Exigent Plant Shutdown Using the Consolidated Line Item Improvement 
Process

AGENCY: Nuclear Regulatory Commission.

ACTION: Request for comment.

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SUMMARY: Notice is hereby given that the staff of the Nuclear 
Regulatory Commission (NRC) has prepared a model safety evaluation (SE) 
relating to changes in Combustion Engineering (CE) plant conditions 
leading to exigent plant shutdown in technical specifications (TS). The 
NRC staff has also prepared a model no-significant-hazards-
consideration (NSHC) determination relating to this matter and a model 
license amendment request (LAR). The purpose of these models is to 
permit the NRC to efficiently process amendments that propose to adopt 
technical specifications changes, designated as TSTF-426, related to 
Topical Report WCAP-16125-NP, Revision 0 (Rev 0), September 2003 
(previously CE NPSD-1208, Rev. 0), ``Justification for the Risk 
Informed Modifications to Selected Technical Specifications for 
Conditions Leading to Exigent Plant Shutdown,'' which was approved by 
an NRC SE dated July 9, 2004. Licensees of CE nuclear power reactors to 
which the models apply could then request amendments, confirming the 
applicability of the SE and NSHC determination to their reactors. The 
NRC staff is requesting comment on the model SE and model NSHC 
determination prior to announcing their availability for referencing in 
license amendment applications.

DATES: The comment period expires August 21, 2006. Comments received 
after this date will be considered if it is practical to do so, but the 
Commission is able to ensure consideration only for comments received 
on or before this date.

ADDRESSES: Comments may be submitted either electronically or via U.S. 
mail. Submit written comments to Chief, Rules and Directives Branch, 
Division of Administrative Services, Office of Administration, Mail 
Stop: T-6 D59, U.S. Nuclear Regulatory Commission, Washington, DC 
20555-0001. Hand deliver comments to: 11545 Rockville Pike, Rockville, 
Maryland, between 7:45 a.m. and 4:15 p.m. on Federal workdays. Copies 
of comments received may be examined at the NRC's Public Document Room, 
11555 Rockville Pike (Room O-1F21), Rockville, Maryland. Comments may 
be submitted by electronic mail to [email protected].

FOR FURTHER INFORMATION CONTACT: T.R. Tjader, Mail Stop: O-12H2, 
Division of Inspection & Regional Support, Office of Nuclear Reactor 
Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555-
0001, telephone 301-415-1187.

SUPPLEMENTARY INFORMATION:

Background

    Regulatory Issue Summary 2000-06, ``Consolidated Line Item 
Improvement Process for Adopting Standard Technical Specifications 
Changes for Power Reactors,'' was issued on March 20, 2000. The 
consolidated line item improvement process (CLIIP) is intended to 
improve the efficiency of NRC licensing processes, by processing 
proposed changes to the standard technical specifications (STS) in a 
manner that supports subsequent license amendment applications. The 
CLIIP includes an opportunity for the public to comment on proposed 
changes to the STS after a preliminary assessment by the NRC staff and 
finding that the change will likely be offered for adoption by 
licensees. This notice solicits comment on a proposed change to the STS 
that allows changes in CE plant conditions leading to exigent plant 
shutdown in technical specifications (TS), if risk is assessed and 
managed. The CLIIP directs the NRC staff to evaluate any comments 
received for a proposed change to the STS and to either reconsider the 
change or announce the availability of the change for adoption by 
licensees. Licensees opting to apply for this TS change are responsible 
for reviewing the staff's evaluation, referencing the applicable 
technical justifications, and providing any necessary plant-specific 
information. Each amendment application made in response to the notice 
of availability will be processed and noticed in accordance with 
applicable NRC rules and procedures.
    This notice involves the changes in CE plant conditions leading to 
exigent plant shutdown in TS, if risk is assessed and managed. The 
change was proposed in Topical Report WCAP-16125-NP Rev 0, September 
2003 (previously CE NPSD-1208, Rev 0), ``Justification for the Risk 
Informed Modifications to Selected Technical Specifications for 
Conditions Leading to Exigent Plant Shutdown,'' which was approved by 
an NRC SE dated July 9, 2004. This change was proposed for 
incorporation into the STS by the owners groups participants in the 
Technical Specification Task Force (TSTF) and is designated TSTF-426, 
Rev 0. TSTF-426, Rev 0, can be viewed on the NRC's web page at http://www.nrc.gov/reactors/operating/licensing/techspecs.html.

Applicability

    This proposal to modify TS requirements by the adoption of TSTF-
426, Rev 0, is applicable to all licensees of CE plants who commit to 
WCAP-16446-NP, Rev 0, ``Actions to Preclude Entry into LCO 3.0.3 
Implementation Guidance (PA-RMCS-0196),'' June 2005.
    To efficiently process the incoming license amendment applications, 
the staff requests that each licensee applying for the changes proposed 
in TSTF-426 include Bases for the proposed TS consistent with the Bases 
proposed in TSTF-426. The CLIIP does not prevent licensees from 
requesting an alternative approach or proposing the changes without the 
requested Bases. However, deviations from the approach recommended in 
this notice may require additional review by the NRC staff and may 
increase the time and resources needed for the review. Significant 
variations from the approach, or

[[Page 41265]]

inclusion of additional changes to the license, will result in staff 
rejection of the submittal. Instead, licensees desiring significant 
variations and/or additional changes should submit a LAR that does not 
claim to adopt TSTF-426.

Public Notices

    This notice requests comments from interested members of the public 
within 30 days of the date of publication in the Federal Register. 
After evaluating the comments received as a result of this notice, the 
staff will either reconsider the proposed change or announce the 
availability of the change in a subsequent notice (perhaps with some 
changes to the safety evaluation or the proposed NSHC determination as 
a result of public comments). If the staff announces the availability 
of the change, licensees wishing to adopt the change must submit an 
application in accordance with applicable rules and other regulatory 
requirements. For each application, the staff will publish a notice of 
consideration of issuance of amendment to facility operating licenses, 
a proposed NSHC determination, and a notice of opportunity for a 
hearing. The staff will also publish a notice of issuance of an 
amendment to operating license to announce the modifications of 
conditions leading to exigent plant shutdown in selected technical 
specifications.

    Dated at Rockville, Maryland, this 13th day of July 2006.

    For the Nuclear Regulatory Commission.
Carl S. Schulten,
Acting Chief, Technical Specifications Branch, Division of Inspection & 
Regional Support, Office of Nuclear Reactor Regulation.

Attachment--Proposed Safety Evaluation, United States Nuclear 
Regulatory Commission; Office of Nuclear Reactor Regulation; 
Consolidated Line Item Improvement Technical Specification Task Force 
(TSTF) Change TSTF-426 Risk Informed Modifications to Selected 
Technical Specifications for Conditions Leading to Exigent Plant 
Shutdown

1.0 Introduction

    On August 30, 2004, the Owners Group (OG) Technical Specifications 
Task Force (TSTF) submitted a proposed change, TSTF-426, Revision 0 
(Rev 0), to the Combustion Engineering (CE) standard technical 
specifications (STS) (NUREG-1432) on behalf of the industry. TSTF-426, 
Rev 0, is a proposal to incorporate WCAP-16125-NP Rev 0, (previously CE 
NPSD-1208, Rev 0), of September 2003, ``Justification for the Risk 
Informed Modifications to Selected Technical Specifications for 
Conditions Leading to Exigent Plant Shutdown,'' which was approved by 
an NRC safety evaluation (SE) dated July 9, 2004 into the CE STS. This 
proposal is part of Nuclear Energy Institute (NEI) Risk Informed 
Technical Specifications Task Force (RITSTF) Initiative 6, one of the 
industry's initiatives being developed under the Risk Management 
Technical Specifications (RMTS) program. These initiatives are intended 
to maintain or improve safety through the incorporation of risk 
assessment and management techniques in technical specifications (TS), 
while reducing unnecessary burden and making technical specification 
requirements consistent with the Commission's other risk-informed 
regulatory requirements.
    The Code of Federal Regulations, 10 CFR 50.36(c)(2)(I), ``Technical 
Specifications; Limiting Conditions for Operation,'' states: ``When a 
limiting condition for operation of a nuclear reactor is not met, the 
licensee shall shut down the reactor or follow any remedial action 
permitted by the technical specifications until the condition can be 
met.'' TS provide a completion time (CT) limit for following any 
remedial action permitted by the TS until the limiting condition for 
operation (LCO) can be met. If the LCO or the remedial action cannot be 
met on the specified CT, then the reactor is required to be shutdown.
    The Required Action for Conditions that imply a loss of function, 
related to a system or component included within the scope of the plant 
TS, is entry into LCO 3.0.3. Currently, upon entering LCO 3.0.3, one 
hour is allowed to prepare for an orderly shutdown before initiating a 
change in plant operation. This includes time to permit the operator to 
coordinate the reduction in electrical generation with the load 
dispatcher to ensure the stability and availability of the electrical 
grid. The OG is proposing to define and/or modify various TS Conditions 
to accommodate extension of the currently required time of one hour to 
initiate plant shutdown for members with Combustion Engineering (CE) 
Nuclear Steam Supply Systems (NSSS) designs. The proposed extension, 
related to specific systems or components, is based on the system's 
risk significance and varies from 4 hours to 72 hours.
    The proposed changes are typically associated with plant conditions 
where both trains of a two-train redundant system are declared 
inoperable and at the same time there is either no specified action in 
the TS for the condition (requiring a default LCO 3.0.3 entry) or 
conditions exist where the defined action includes an explicit LCO 
3.0.3 entry. The intent of the proposed TS changes is to provide a 
risk-informed alternative to the current LCO 3.0.3 requirements such 
that the plant staff has adequate time to fully evaluate the situation 
or restore loss of function while the plant remains operating at power, 
thus avoiding unnecessary unscheduled plant shutdowns and minimizing 
transition and realignment risks.
    WCAP-16125-NP also provides system-specific integrated 
justifications (i.e., risk and defense-in-depth arguments) for several 
proposed TS Required Action statement changes to allow a MODE 4 (hot 
shutdown) end state, for repair purposes of two-train redundant systems 
that do not have explicit LCO 3.0.3 entry requirements, when the 
proposed extended time cannot be met.
    The intent of the proposed TS changes is to provide needed 
flexibility in the performance of corrective maintenance during power 
operation and at the same time enhance overall plant safety by:
     Avoiding unnecessary unscheduled plant shutdowns,
     Minimizing plant transitions and associated transition and 
realignment risks,
     Providing increased flexibility in scheduling and 
performing maintenance and surveillance activities, and
     Providing explicit guidance in areas that currently does 
not exist.

It should be noted that many of the proposed TS changes affect the 
existing plant shutdown requirements for plant conditions where the 
plant operation is not in explicit compliance with the plant design 
basis. The proposed actions provide a risk-informed process for 
establishing shutdown priorities aiming at reducing overall plant risk 
and increasing public health and safety protection.

2.0 Regulatory Evaluation

    In 10 CFR 50.36, the Commission established its regulatory 
requirements related to the content of TS. Pursuant to 10 CFR 
50.36(c)(1)-(5), TS are required to include items in the following five 
specific categories related to station operation: (1) Safety limits, 
limiting safety system settings, and limiting control settings; (2) 
limiting conditions for operation (LCOs); (3) surveillance requirements 
(SRs); (4) design features; and (5) administrative controls. The rule 
does not specify the particular requirements to be included in a 
plant's TS. As stated in 10 CFR 50.36(c)(2)(i), the ``Limiting 
conditions for operation

[[Page 41266]]

are the lowest functional capability or performance levels of equipment 
required for safe operation of the facility. When a limiting condition 
for operation of a nuclear reactor is not met, the licensee shall shut 
down the reactor or follow any remedial action permitted by the 
technical specifications * * *.'' Topical Report WCAP-16125, 
``Justification for Risk-Informed Modifications to Selected Technical 
Specifications for Conditions Leading to Exigent plant Shutdown'' 
(Reference 1), justifies modifications to various TS Action Statements 
for conditions that result in a loss of safety function related to a 
system or component included within the scope of the plant TS. It 
revises the current Required Actions from either a default or explicit 
LCO 3.0.3 entry to a risk-informed action based on the system's risk 
significance with an associated completion time (CT). In most 
instances, a CT of 24 hours is justified.

3.0 Technical Evaluation

    The changes proposed in TSTF-426, Rev 0, are consistent with the 
changes proposed and justified in Topical Report WCAP-16125-NP Rev 0, 
and approved by the associated NRC SE of July 9, 2004 (Reference 2). 
The evaluation included in Reference 2, as appropriate and applicable 
to the changes of TSTF-426, Rev 0, (Reference 3), is not reiterated 
here, except where differences from the SE are justified and in 
discussing the TSTF-426 changes with respect to the individual 
specifications. In its application the licensee commits to PA-RMSC-
0196, ``Actions to Preclude Entry into LCO 3.0.3, Implementation 
Guidance'' (Reference 4) for implementing TSTF-426, Rev 0, which 
addresses a variety of issues such as considerations and compensatory 
actions for risk-significant plant configurations. An overview of the 
generic evaluation and associated risk assessment is provided below, 
along with a summary of the associated TS changes justified by 
Reference 1.
    The proposed TS changes, including end state changes (i.e., 
approved TSTF-422 end state changes), are summarized in Table 1 of this 
safety evaluation report (SER). Such changes cover a diverse range of 
systems and components with essentially four separate impacts on plant 
risk. They are:
     TS changes related to systems or components contributing 
to accident prevention. The removal of these systems/components has the 
potential to increase the plant risk through the increased potential 
for plant upsets (i.e., potential for increased initiated event 
frequencies). A typical example in this category are the pressurizer 
heaters whose unavailability could complicate plant pressure control 
and lead to a plant trip.
     TS changes related to systems or components contributing 
to accident mitigation. These systems are in standby during normal 
plant operation and are intended to function during accidents to 
prevent core damage. Typical examples in this category are the 
Emergency Core Cooling System (ECCS) and the pressurizer Power Operated 
Relief Valves (PORVs).
     TS changes related to systems or components contributing 
to large early release prevention. The primary role of these systems is 
to function during a core damage accident to prevent large releases of 
radioactive materials. A typical example in this category is the 
containment (the only component in this category for which a TS change 
is proposed).
     TS changes related to systems/components contributing to 
control of delayed radiation releases to the environment. The primary 
role of these systems is to prevent radiation releases above TS limits 
and meet design basis requirements. Thus, the unavailability of these 
systems has no impact on the surrogate risk metrics associated with 
core damage and large early releases. Typical examples in this category 
are the ECCS room ventilation system and the containment iodine cleanup 
system.
    Although the improved standard technical specification (STS) 
numbering system (NUREG-1432, Reference 5) is used for convenience in 
Table 1, the analyses provided in WCAP-16125-NP support these changes 
for all CE designed NSSS plants.

                     Table 1.--Summary of Proposed Modifications to Technical Specifications
----------------------------------------------------------------------------------------------------------------
                                                                       Current action and     Proposed changes:
     STS               System             Inoperability           associated       completion time (CT)
                                                     condition        completion time (CT)      and end state
----------------------------------------------------------------------------------------------------------------
LCO 3.4.9.............  Pressurizer Heaters..  Both groups of class   No condition          24 hrs CT for
                                                1E heaters             defined. Default      restoring one
                                                inoperable.            LCO 3.0.3 entry.      group.
LCO 3.4.11............  Pressurizer Power      STS LCO 3.4.11         Varies with plant.    STS LCO 3.4.11
                         Operated Relief        CONDITION E (or       STS LCO 3.4.11         CONDITION E (or
                         Valves (PORVs) and     equivalent): Two       CONDITION E (or       equivalent): Allow
                         Associated Block       PORVs inoperable and   equivalent): Close    8 hours CT to
                         Valves (BVs).          not capable of being   associated block      restore one PORV,
                                                manually cycled.       valve in 1 hour AND   for conditions
                                               STS LCO 3.4.11          remove power from     where a PORV is
                                                CONDITION F (or        associated block      unable to reclose
                                                equivalent): Two BVs   valve in one hour,    once challenged but
                                                inoperable..           AND be in MODE 3 in   may be isolated.
                                                                       6 hours AND MODE 4   STS LCO 3.4.11
                                                                       in [12] hours..       CONDITION F (or
                                                                      STS LCO 3.4.11         equivalent): Allow
                                                                       CONDITION F (or       8 hours to restore
                                                                       equivalent):          one BV.
                                                                       Restore one block
                                                                       valve to operable
                                                                       in 2 hours. STS
                                                                       Condition G
                                                                       requires MODE 3 in
                                                                       6 hours and MODE 4
                                                                       in [12] hours if
                                                                       Condition F not
                                                                       met..
LCO 3.5.1.............  Safety Injection       Two or more SITs       Explicit 3.0.3 entry  Revise STS Condition
                         Tanks (SITs).          inoperable (STS                              D to allow 24 hours
                                                CONDITION D).                                CT for restoring
                                                                                             one SIT.
LCO 3.5.2.............  Low Pressure Safety    Two LPSI subsystems    Default 3.0.3 entry.  24 hours for
                         Injection (LPSI).      inoperable.                                  restoring one LPSI
                                                                                             subsystem (STS
                                                                                             Condition D would
                                                                                             be deleted).
LCO 3.5.2.............  High Pressure Safety   Two HPSI subsystems    Explicit 3.0.3 entry  4 hours CT for
                         Injection (HPSI).      inoperable (STS                              restoring one HPSI
                                                Condition D).                                subsystem.

[[Page 41267]]

 
LCO 3.6.1.............  Containment (CTMT)...  Inoperable...........  Defined 1 hour        8 hours CT restoring
                                                                       shutdown (MODE 5 in   containment
                                                                       36 hours).            operability. Allow
                                                                                             MODE 4 end state.
LCO 3.6.6A&B..........  Containment Spray      Two CS trains          Explicit 3.0.3 entry  12 hrs CT for
                         System (CS).           inoperable OR any                            restoring one CS
                                                combination of three                         train if CAC is not
                                                or more trains                               available. 72 hours
                                                inoperable (i.e.,                            CT for restoring
                                                containment air                              one CS if one train
                                                coolers (CAC*)) (STS                         of CAC is
                                                Condition F).                                available.
LCO 3.6.10............  Iodine Cleanup System  Two ICS trains         No condition          24 hours CT for
                         (ICS).                 inoperable.            defined. Default      restoring one
                                                                       3.0.3 entry.          train. Allow MODE 4
                                                                                             end state.
LCO 3.6.13............  Shield Building        Two trains inoperable  No condition          24 hours CT for
                         Exhaust Air Cleanup                           defined. Default      restoring one
                         System (SBEACS).                              3.0.3 entry.          train. Allow MODE 4
                                                                                             end state.
LCO 3.7.11............  Control Room           Two trains inoperable  No condition          24 hours CT for
                         Emergency Air                                 defined. Default      restoring one train
                         Cleanup System                                3.0.3 entry.          (or the time to
                         (CREACS).                                                           reach 5 REM, which
                                                                                             may be less than 24
                                                                                             hours). Proposed
                                                                                             change applies to
                                                                                             radiation
                                                                                             protection function
                                                                                             only. Allow MODE 4
                                                                                             end state.
LCO 3.7.12............  Control Room           Two trains inoperable  Explicit 3.0.3......  24 hours CT for
                         Emergency Air          (STS Condition E).                           restoring one
                         Temperature Control                                                 train. Allow MODE 4
                         System (CREATCS).                                                   end state.
LCO 3.7.13............  Emergency Core         Two trains inoperable  No condition          24 hours CT for
                         Cooling System                                defined. Default      restoring one
                         (ECCS), Pump Room                             3.0.3 entry.          train. Allow MODE 4
                         Exhaust Air Cleanup                                                 end state.
                         System (ECCS PREACS).
LCO 3.7.15............  Penetration Room,      Two trains inoperable  No condition          24 hours CT for
                         Exhaust Air Cleanup                           defined. Default      restoring one
                         System (PREACS).                              3.0.3 entry.          train. Allow MODE 4
                                                                                             end state.
----------------------------------------------------------------------------------------------------------------
* Also known as containment air recirculation coolers (CARC)

    WCAP-16125-NP documents a risk-informed analysis of the proposed TS 
changes. Probabilistic Risk Assessment (PRA) results and insights are 
used, in combination with results of deterministic assessments, to 
identify and justify the proposed TS changes for all CE NSSS design 
plants. This is in accordance with guidance provided in Regulatory 
Guides (RGs) 1.174 and 1.177 (References 6 and 7, respectively).
    The approach used to assess the risk impact of the proposed changes 
is discussed and evaluated in Section 3.0. Section 3.1 evaluates the 
results of the risk assessment. Section 3.2 provides integrated 
justifications (i.e., both probabilistic and deterministic arguments) 
for each of the proposed system-specific TS changes. Finally, Section 
3.3 summarizes the staff's conclusions from the review of the proposed 
TS changes.
3.1 Risk Assessment
    The objective of the OG's risk assessment was to show that the 
implementation of the proposed TS changes are not expected to lead to 
any significant risk increases. In performing the risk-informed 
assessments and interpreting the results, the following two assumptions 
are tacitly made:
     A condition resulting in the inoperability of a system or 
component which currently results in the need for an immediate shutdown 
is an infrequent event. This is evidenced by the fact that plant 
shutdowns due to entries into LCO 3.0.3 conditions are rare. 
Furthermore, when such a condition does arise, the actual cause of the 
inoperability is often due to an incomplete ``paper trail'' or a 
partial system failure rather than a deleterious common-cause failure 
of critical components leading to a functional failure of an entire 
system.
     The risk incurred by increasing the required shutdown 
action time is controlled to acceptable levels using a risk informed 
approach that considers the component risk worth and offsetting 
benefits of avoiding plant transitions.
    The risk impact of the proposed TS changes was assessed following 
the three-tiered approach recommended in RG 1.177 for evaluating 
proposed extensions in currently allowed Completion Times (CTs):
     The first tier involves the assessment of the change in 
plant risk due to the proposed TS change. Such risk change is expressed 
(1) by the change in the average yearly core damage frequency 
([Delta]CDF) and the average yearly large early release frequency 
([Delta]LERF) and (2) by the incremental conditional core damage 
probability (ICCDP) and the incremental conditional large early release 
probability (ICLERP). The assessed [Delta]CDF and [Delta]LERF values 
are compared to acceptance guidelines, consistent with the Commission's 
Safety Goal Policy Statement as documented in RG 1.174, so that the 
plant's average baseline risk is maintained within a minimal range. The 
assessed ICCDP and ICLERP values are compared to acceptance guidelines 
provided in RG 1.177 which aim at ensuring that the plant risk does not 
increase unacceptably during the period the equipment is taken out of 
service.
     The second tier involves the identification of potentially 
high-risk configurations that could exist if equipment in addition to 
that associated with the change were to be taken out of service 
simultaneously, or other risk-significant operational factors such as 
concurrent equipment testing were also involved. The objective is to 
ensure that appropriate restrictions are in place to avoid any 
potential high-risk configurations.

[[Page 41268]]

     The third tier involves the establishment of an overall 
configuration risk management program (CRMP) to ensure that potentially 
risk-significant configurations resulting from maintenance and other 
operational activities are identified. The objective of the CRMP is to 
manage configuration-specific risk by appropriate scheduling of plant 
activities and/or appropriate compensatory measures.
    The approach used in implementing the three-tiered approach of RG 
1.177 to support the proposed TS changes is fully evaluated in the SE 
(Reference 2) to WCAP-16125-NP Rev 0. The staff found that the risk 
assessment results support the proposed changes. The risk increases 
associated with the proposed TS changes, if any, will be insignificant 
based on guidance provided in RGs 1.174 and 1.177. Furthermore, the 
sensitivity studies and the many conservative assumptions used in the 
analyses provide adequate assurance about the robustness of the results 
used to support the proposed TS changes.
3.2 Assessment of Technical Specification Changes
    There are two categories of proposed system-specific TS changes. 
The first category includes changes associated with plant conditions 
requiring entry into LCO 3.0.3 to extend the time for restoring the 
system's or component's loss of function, thus avoiding unnecessary 
unscheduled plant shutdowns and minimizing transition and realignment 
risks. The second category includes changes to TS Required Action 
statements to allow a MODE 4 (hot shutdown) end state, for repair 
purposes of two-train redundant systems that do not have implicit LCO 
3.0.3 entry requirements, when the proposed extended time cannot be 
met. The generic risk assessment for the proposed end state changes is 
documented in topical report CE-NPSD-1186 (Reference 8) which has been 
reviewed and approved by the staff. While all proposed system-specific 
TS changes include changes to extend the time for restoring the 
system's or component's loss of function (first category changes), some 
proposed system-specific TS changes include changes to modify the end 
state (second category changes). Therefore, the integrated 
justifications, discussed in this section, include insights from the 
generic risk assessments documented in both topical reports WCAP-16125-
NP (Reference 1) and CE-NPSD-1186 (Reference 8).
    Due to the nature of the plant conditions associated with the 
proposed TS changes (i.e., loss of a system's or component's function), 
the redundancy and diversity typically associated with ensuring the 
deterministic aspect of defense-in-depth position is not always 
strictly possible. In these cases, defense-in-depth is considered by 
(1) controlling the outage time for related equipment, (2) restricting 
activities which may challenge the unavailable systems or functions, 
(3) allowing only small time intervals for plant operation at power 
with a system or function unavailable, (4) using, whenever possible, 
contingency actions to limit concurrent unavailabilities appropriately, 
and (5) evaluating repair activities and alternatives. Defense-in-depth 
is evaluated in conjunction with the generic risk assessment results 
which conclude that the proposed system-specific TS changes would lead 
to insignificant risk increases and in most cases to net risk 
reductions. This conclusion is a consequence of the low expected 
challenge frequency of the systems or functions associated with the 
proposed TS changes, the very short proposed exposure times to the 
specified plant conditions and the offsetting benefits of avoiding 
plant transitions.
    The proposed change in shutdown mode end states will result in 
plants remaining within the applicability of the specific LCOs for the 
length of time it takes to restore the LCO conditions. Since corrective 
maintenance will be necessary, the 10 CFR 50.65(a)(4) requirement to 
assess and manage risk will apply, and should confirm that remaining in 
the shutdown mode that is within the applicability of the LCO is 
acceptable for the plant specific configuration. NRC Regulatory Guide 
1.182 (Reference 9) endorses NUMARC 93-01 Section 11 guidance for 
implementation of 10 CFR 50.65(a)(4), and shall be followed; including 
the conduct of an (a)(4) reevaluation for emergent conditions.
3.2.1 Pressurizer Heaters (STS LCO 3.4.9)
    The pressurizer provides a point in the RCS where the liquid and 
vapor water phases are maintained in equilibrium under saturated 
conditions for pressure control purposes to prevent bulk boiling in the 
remainder of the RCS. The pressure control components addressed by this 
LCO include the pressurizer, the required groups of heaters and their 
controls and the Class 1E power supplies. The liquid to vapor interface 
permits RCS pressure control by using the sprays and heaters during 
normal operation and in response to anticipated design basis accidents. 
The unavailability of Class 1E pressurizer heaters covered by the TS 
may complicate steady state plant pressure control and, thus, increase 
the potential for an unplanned reactor trip.
    Another function of the Class 1E pressurizer heaters is to maintain 
plant subcooling during post accident cooldown by natural circulation. 
Although the unavailability of pressurizer heaters during natural 
circulation cooldown will extend the time to reach the shutdown cooling 
system entry conditions, heat removal will be adequately established 
via steam generator cooling.
    Plant Applicability: All OG member plants with CE NSSS designs 
except St Lucie-2.
    Limiting Condition for Operation (LCO): Two groups of pressurizer 
heaters, [capable of being powered from an emergency power supply], 
must be operable in MODES 1, 2 and 3.
    Condition Requiring Entry into Shutdown Required Action: Two 
safety-related pressurizer heater groups inoperable (default entry into 
LCO 3.0.3 is required).
    Proposed Modification to Shutdown Required Actions: Increase the 
time available to take action to restore one group of safety-related 
heaters before entry into STS LCO 3.4.9 Condition C to 24 hours.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 24-hour completion time for restoring one group of 
safety-related pressurizer heaters before entering STS LCO 3.4.9 
Condition C will not lead to a significant increase in risk and may 
actually decrease risk. The risk impact of the proposed completion time 
extension was assessed to be well within the acceptance criteria 
reported in Regulatory Guides 1.174 and 1.177. Specifically, the 
proposed completion time extension would lead to the following risk 
increases: (1) The probability of core damage when the safety-related 
pressurizer heaters are inoperable will increase by about 3E-7 (the 
acceptance guideline for ICCDP is 5E-7); (2) the CDF will increase by 
about 6E-8/year (the acceptance guideline for [Delta]CDF is 1E-6/year); 
(3) the large early release probability when the safety-related 
pressurizer heaters are inoperable will increase by less than 1E-8 (the 
acceptance guideline for ICLERP is 5E-8); and (4) the LERF will 
increase by about 2E-9/year (the acceptance guideline for [Delta]LERF 
is 1E-7/year). Furthermore, the proposed time extension may actually be 
risk neutral or result in a decrease in risk if credit for avoiding the 
transition to shutdown risk is taken.

[[Page 41269]]

    The risk impact argument is consistent with the following 
observations. TS include requirements for both groups of safety-related 
pressurizer heaters to have minimum heating power [and emergency power 
supply capability]. The safety-related pressurizer heaters have two 
primary functions. One function is to keep the reactor coolant in a 
subcooled condition with natural circulation following a loss of 
offsite power (LOOP) event during which the normally available station 
powered non-safety related heaters become unavailable. Although no 
credit is taken in design basis accident analyses for the pressurizer 
heaters, they have been included in the TS because they are needed to 
maintain long term subcooling during a LOOP event. However, pressurizer 
heaters are not required to achieve a post-trip plant cooldown since 
successful cooldown can be achieved, with minimal impact on plant risk, 
due to the availability of reactor vessel and pressurizer vents. 
Consequently, the pressurizer heaters do not have a significant role in 
the mitigation of core damage events. A second function of the safety-
related pressurizer heaters is to back up the station powered non-
safety related heaters which are normally available to control reactor 
coolant pressure during steady state operation. The unavailability of 
these heaters would reduce the plant's ability to control the normal 
operating parameters and consequently will increase the potential of 
plant trip.
    The presence of both safety-related and non-safety-related heaters 
provides considerable defense-in-depth for many transient events, 
except following a LOOP event. For LOOP events and without the safety-
related pressurizer heaters, a natural circulation cooldown may be 
required. Such cooldowns can be conducted via use of reactor vessel and 
pressurizer vents or SG venting via the atmospheric dump valves (ADVs).
    The intent of the proposed completion time extension is to extend 
plant operation at power when the ability to control normal plant 
operation is not significantly degraded. Therefore, the proposed 
completion time extension should not be utilized when there is reason 
to believe that plant pressure and level cannot be controlled within 
operating bounds, as is the case when both the safety and non-safety 
pressurizer heaters are unavailable. This restriction should be 
reflected in the TS bases.
    Finding: The requested change to increase the time available to 
take action to restore one pressurizer heater group to 24 hours for 
cases when both groups are inoperable is acceptable.
    Tier 2 Restrictions: None.
3.2.2 Pressurizer PORVs and Associated Block Valves (STS LCO 3.4.11)
    PORVs are automatically opened at a specific set pressure when the 
pressurizer pressure increases and automatically closed on decreasing 
pressure. The PORVs may be manually operated using controls installed 
in the control room. An electric, normally open, block valve (BV) is 
installed between the pressurizer and the PORV. The function of the BV 
is to ensure RCS integrity by isolating a leaking or stuck-open PORV to 
permit continued power operation. Most importantly, the BV is used to 
isolate a stuck open PORV and terminate the RCS depressurization and 
coolant inventory loss.
    Plant Applicability: Calvert Cliffs 1 & 2, St Lucie 1 & 2 (block 
valves), Millstone 2, Palisades, and Fort Calhoun Station.
    Limiting Condition for Operation (LCO): Each PORV and associated 
block valve shall be operable in MODES 1, 2 and 3.
    Condition Requiring Entry into Shutdown Required Action: Two PORVs 
inoperable and not capable of being manually cycled (STS LCO 3.4.11 
Condition E or equivalent) or two BVs inoperable (STS LCO 3.4.11 
Condition F or equivalent). There is a variability in LCO entry 
requirements among OG member plants with CE NSSS designs for conditions 
with both PORVs inoperable or both BVs inoperable. Typically, a plant 
shutdown is required if the PORVs are not isolated and one PORV is not 
restored within one hour (STS LCO 3.4.11 Condition E or equivalent) or 
when the PORVs are not placed in manual control within one hour and one 
BV is not recovered within two hours (STS LCO 3.4.11 Condition F or 
equivalent).
    Proposed Modification to Shutdown Required Actions: Revise STS LCO 
3.4.11 Condition E (or equivalent to allow an 8-hour completion time 
(CT) to restore one PORV for conditions where a PORV is unable to re-
close once challenged, but may be isolated). This extension would not 
apply to PORVs that are leaking, and that cannot be isolated by block 
valves, or to PORVs that are not expected to be isolable following a 
demand.
    Revise STS LCO 3.4.11 Required Action F.2 to allow 8 hours to 
restore one BV, for conditions where the associated PORV is unable to 
reclose.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 8-hour completion time for the actions required by TS 
(i.e., actions associated with STS LCO 3.4.11 Conditions E and F or 
equivalent) will not lead to a significant increase in risk and, 
actually, may decrease risk by avoiding the risk associated with the 
transition to shutdown. The risk impact of the proposed completion time 
extension, without credit for avoiding the transition to shutdown risk, 
was assessed to be within the acceptance criteria reported in 
Regulatory Guides 1.174 and 1.177. Specifically, the proposed time 
extension would lead to the following risk increases: (1) The 
probability of core damage will increase by about 8E-7, which is close 
to the numerical guideline of 5E-7 for ICCDP used in RG 1.177; (2) the 
CDF will increase by about 2E-7/year, which is significantly less than 
the acceptance guideline of 1E-6/year for [Delta]CDF; (3) the large 
early release probability will increase by less than 7E-8, which is 
close to the numerical guideline of 5E-8 for ICLERP and in agreement 
with guidance provided in RG 1.177; and (4) the LERF will increase by 
about 1E-8/year, which is significantly less than the acceptance 
guideline of 1E-7/year for [Delta]LERF. Furthermore, the proposed time 
extension may actually be risk neutral or result in a decrease in risk 
if credit for avoiding the transition to shutdown risk is taken.
    The risk impact argument is consistent with the following defense-
in-depth argument where the impact of STS LCO 3.4.11 Conditions E and F 
on defense-in-depth is discussed. The primary purpose of this LCO is to 
ensure that the PORVs and the BVs are operable so the potential for a 
small break LOCA through the PORV pathway is minimized, or if a small 
LOCA were to occur through a failed open PORV, the block valve could be 
manually operated to isolate the path. In addition, one of the 
functions of the PORVs is to limit the number of pressure transients 
that may challenge the primary safety valves (PSVs) since the PSVs, 
unlike the PORVs, cannot be isolated.
    When both PORVs are found inoperable (i.e., STS LCO 3.4.11 
Condition E or equivalent), the associated BVs are manually closed, 
within one hour, to isolate both PORV paths. With none of the PORVs 
available to open, the PSVs could be challenged to provide overpressure 
protection. However, a challenge to the PSVs during the proposed 
completion time extension to restore one PORV is extremely unlikely and 
the PSVs are available and highly reliable (i.e., even if they are 
challenged, they would close properly when the pressure is reduced

[[Page 41270]]

below their setpoint). It should be noted that overpressure protection 
is provided by the PSVs in the design basis analyses, without any 
credit for PORV opening for accident mitigation (in fact there are some 
plants built without PORVs). For these reasons, there is defense-in-
depth against LOCA accidents through the PORV and the PSV paths as well 
as against overpressure accidents during the very short time interval 
when STS LCO 3.4.11 Condition E is proposed to be allowed with the 
plant operating at power.
    When both BVs are found inoperable (i.e., STS LCO 3.4.11 Condition 
F or equivalent), the PORVs are placed in manual control, within one 
hour, to ensure that they do not open automatically in the unlikely 
event they are challenged. Therefore, there is defense-in-depth against 
small LOCA accidents through the PORV paths. However, in the unlikely 
event of a pressure transient during the proposed completion time 
extension, the PSVs could be challenged to provide overpressure 
protection. This is the same scenario discussed above for STS LCO 
3.4.11 Condition E. For these reasons, there is defense-in-depth 
against LOCA accidents through the PORV and the PSV paths as well as 
against overpressure accidents during the very short time interval when 
STS LCO 3.4.11 Condition F is proposed to be allowed with the plant 
operating at power.
    The PORV paths provide an alternative means of core cooling by feed 
and bleed (once-through core cooling) in the case of multiple equipment 
failure events that are not within the design basis, such as a total 
loss of feedwater. The unavailability of feed and bleed for core 
cooling, the dominant contributor to risk associated with the proposed 
changes to LCO 3.4.11. As discussed above, such risk is very small.
    Finding: The requested changes to allow 8 hours for completing the 
actions required by TS (i.e., actions associated with STS LCO 3.4.11 
Conditions E and F or equivalent) are acceptable.
    Tier 2 Restrictions: None.
3.2.3 Safety Injection Tanks (STS LCO 3.5.1)
    The Safety Injection Tanks (SITs) are pressurized passive injection 
devices whose primary safety function is to inject large quantities of 
borated water into the reactor vessel during the blowdown phase of a 
large LOCA and to provide inventory to help accomplish the refill phase 
that follows the blowdown phase.
    Plant Applicability: Applicable to all OG member plants with CE 
NSSS designs.
    Limiting Condition for Operation (LCO): All SITs shall be operable 
during MODES 1 and 2 as well as during MODE 3 when the pressurizer 
pressure is above [700] psia.
    Condition Requiring Entry into Shutdown Required Action: When two 
or more SITs are inoperable (STS LCO 3.5.1 Condition D), immediate 
entry into LCO 3.0.3 is required.
    Proposed Modification to Shutdown Required Actions: Increase the 
time available to restore one SIT before entry into LCO 3.0.3 to 24 
hours.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 24-hour completion time for restoring one SIT before 
entering LCO 3.0.3 will not lead to a significant increase in risk and 
may actually decrease risk. The risk impact of the proposed 23-hour 
extension, without credit for avoiding the transition to shutdown risk, 
was assessed to be well within the acceptance criteria reported in 
Regulatory Guides 1.174 and 1.177. Specifically, the proposed time 
extension would lead to the following risk increases: (1) The 
probability of core damage will increase by about 1E-8, which is less 
than the numerical guideline of 5E-7 for ICCDP; (2) the CDF will 
increase by about 3E-9/year, which is significantly less than the 
acceptance guideline of 1E-6/year for DCDF; (3) the large early release 
probability will increase by about 4E-11, which is much less than the 
numerical guideline of 5E-8 for ICLERP; and (4) the LERF will increase 
by about 9E-12/year, which is much less than the acceptance guideline 
of 1E-7/year for [Delta]LERF. Furthermore, the proposed time extension 
would, most likely, result in a risk reduction if credit for avoiding 
the transition to shutdown risk is taken.
    The risk impact argument is also supported by the following 
defense-in-depth discussion. The SITs are needed primarily to mitigate 
large LOCAs. The unavailability of two or more SITs will compromise the 
ability of the plant to respond to a large LOCA. However, as discussed 
above, even if it is conservatively assumed that all large LOCAs 
proceed to core damage, the risk impact is negligible (much less than 
the risk estimated to incur during plant transition to shutdown). On 
the other hand, the unavailability of two or more SITs may alter the 
progression of some smaller break size LOCAs and the extent of core 
damage. However, their impact on the core damage potential is 
negligible. In addition, long term core cooling, provided via the 
plant's LPSI and HPSI systems, partially offsets the impact of SIT 
unavailability.
    Finding: The requested change to increase the time available to 
take action to restore all SITs (from one to 24 hours) for cases when 
two or more SITs are inoperable is acceptable.
    Tier 2 Restrictions: None.
3.2.4 Low Pressure Safety Injection (STS LCO 3.5.2)
    The low pressure safety injection (LPSI) system is part of the 
emergency core cooling system (ECCS). The function of the ECCS is to 
provide core cooling and negative reactivity to ensure that the reactor 
core is protected following certain accidents, such as LOCAs, SGTRs and 
loss of feedwater. There are two phases of ECCS operation: injection 
and recirculation. In the injection phase, borated water is injected 
into the RCS via the cold legs. After the blowdown stage of the LOCA 
stabilizes, injection flow is split equally between the hot and cold 
legs. After the RWST is depleted, the ECCS recirculation phase is 
entered as the ECCS suction is automatically transferred to the 
containment sump. TS require that in MODES 1, 2 and 3, with pressurizer 
pressure greater than or equal to [1700] psia, both redundant (100% 
capacity) ECCS trains must be operable. Each ECCS train consists of a 
high pressure safety injection (HPSI) subsystem, a low pressure safety 
injection (LPSI) subsystem and a charging subsystem.
    Plant Applicability: Applicable to all OG member plants with CE 
NSSS designs.
    Limiting Condition for Operation (LCO): Two redundant, 100% 
capacity LPSI trains must be operable in MODES 1 and 2 as well as in 
MODE 3 when the pressurizer pressure is greater than or equal to [1700] 
psia.
    Condition Requiring Entry into Shutdown Required Action: When both 
LPSI trains are inoperable, the design basis assumptions for the large 
break LOCA analyses are not met and a default entry into LCO 3.0.3 is 
required.
    Proposed Modification to Shutdown Required Actions: Add separate 
condition for both LPSI trains inoperable to restore at least one LPSI 
train to operable in 24 hours. In addition, with the proposed condition 
taken with the proposed changes to HPSI discussed below, the existing 
condition (STS LCO 3.5.2 Condition D) of ``Less than 100% of the ECCS 
flow equivalent to a single OPERABLE train available'' will no longer 
be required since that condition will be addressed by the conditions 
for two HPSI

[[Page 41271]]

subsystems inoperable or two LPSI subsystems inoperable.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 24-hour completion time for restoring one LPSI train 
will not lead to a significant increase in risk and may actually 
decrease risk. The risk impact of the proposed completion time 
extension, without credit for avoiding the transition to shutdown risk, 
was assessed to be well within the acceptance criteria reported in 
Regulatory Guides 1.174 and 1.177. Specifically, the proposed 
completion time extension would lead to the following risk increases: 
(1) The probability of core damage will increase by about 1E-7, which 
is less than the numerical guideline of 5E-7 for ICCDP; (2) the CDF 
will increase by about 2E-8/year, which is significantly less than the 
acceptance guideline of 1E-6/year for [Dgr]CDF; (3) the large early 
release probability will increase by about 4E-10, which is much less 
than the numerical guideline of 5E-8 for ICLERP; and (4) the LERF will 
increase by about 8E-11/year, which is much less than the acceptance 
guideline of 1E-7/year for [Dgr]LERF. Furthermore, the proposed 
completion time extension would, most likely, result in a risk 
reduction if credit for avoiding the transition to shutdown risk is 
taken.
    The risk impact argument is also supported by the following 
defense-in-depth discussion. The primary impact of the unavailability 
of the LPSI system will be the reduction in the capability of the plant 
to provide RCS inventory makeup to mitigate a large LOCA. However, the 
unavailability of the LPSI system will impair the ability of the plant 
to maneuver to shutdown cooling. Therefore, the proposed 24-hour 
completion time to repair one LPSI train is reasonable due to the very 
small incremental risk associated with the continued plant operation at 
power and the inadvisability of a plant shutdown without the LPSI pumps 
which are needed for shutdown cooling.
    STS LCO 3.5.2 Condition D requires that for a condition where the 
ECCS flow is less than 100% of the ECCS flow assumed in the LOCA 
analysis. WCAP-16125-NP proposed to delete this condition because it 
would no longer be necessary, based on the new conditions for two HPSI 
trains or two LPSI trains inoperable. The NRC staff has concluded that 
an adequate basis has not been provided to justify the deletion of STS 
LCO 3.5.2 Condition D. Specifically, licensees should discuss the 
functions of the HPSI and LPSI systems in terms of reactivity control, 
RCS inventory control, RCS pressure control, and core heat removal for 
system operations such as safety injection and recirculation, hot leg 
injection and once through core cooling to mitigate the consequences of 
LOCAs, SLB, and SGTR events. The licensees should also discuss the 
safety and nonsafety related accident mitigation systems, and show 
that, for a condition when the ECCS flow is less than 100% of the ECCS 
flow equivalent to a single OPERABLE train, alternative flow injection 
systems and backup accident management strategies are available and 
effective. Licensees should also list specific compensatory measures 
(including a description of pertinent operating procedures, maintenance 
process and training programs) and contingency plans with acceptable 
justification for the proposed deletion of STS LCO 3.5.2 Condition D.
    Finding: The requested change to increase the time available to 
restore an LPSI train to operable is acceptable. The proposed change to 
delete STS LCO 3.5.2 Condition D needs to be adequately justified on a 
plant-specific basis.
    Tier 2 Restrictions: None.
3.2.5 High Pressure Safety Injection (STS LCO 3.5.2)
    The high pressure safety injection system is part of the ECCS. The 
function of the ECCS is to provide core cooling and negative reactivity 
to ensure that the reactor core is protected following certain 
accidents, such as LOCAs, SGTRs and loss of feedwater. There are two 
phases of ECCS operation: injection and recirculation. In the injection 
phase, borated water is injected into the RCS via the cold legs. After 
the blowdown stage of the LOCA stabilizes injection flow is split 
equally between the hot and cold legs. After the RWST is depleted, the 
ECCS recirculation phase is entered as the ECCS suction is 
automatically transferred to the containment sump. TS require that in 
MODES 1, 2 and 3, with pressurizer pressure greater than or equal to 
[1700] psia, both redundant (100% capacity) ECCS trains must be 
operable. Each ECCS train consists of a high pressure safety injection 
subsystem, a low pressure safety injection subsystem and a charging 
subsystem.
    Plant Applicability: Applicable to all OG member plants with CE 
NSSS designs.
    Limiting Condition for Operation (LCO): In MODES 1 and 2 as well as 
in MODE 3 when the pressurizer pressure is greater than or equal to 
[1700] psia, both trains of HPSI must be operable.
    Condition Requiring Entry into Shutdown Required Action: When both 
HPSI trains are inoperable, a default entry into LCO 3.0.3 is required.
    Proposed Modification to Shutdown Required Actions: Increase the 
time for restoring one HPSI pump or subsystem, before initiating 
shutdown per LCO 3.0.3, to four hours.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 4-hour completion time for the actions required by TS 
before entering LCO 3.0.3 will not lead to a significant increase in 
risk and, actually, may decrease risk by avoiding the risk associated 
with the transition to shutdown. The risk impact of the proposed 
completion time extension, without credit for avoiding the transition 
to shutdown risk, was assessed to be in agreement with the acceptance 
guidelines reported in Regulatory Guides 1.174 and 1.177. Specifically, 
the proposed completion time extension would lead to the following risk 
increases: (1) An ICCDP of 1.7E-6 for plants with PORVs and 1.1E-6 for 
plants without PORVs, which are close to the numerical guideline of 5E-
7 for ICCDP used in RG 1.177; (2) a [Delta]CDF of 3.5E-7/year for 
plants with PORVs and 2.1E-7 for plants without PORVs, which are 
significantly less than the acceptance guideline of 1E-6/year for 
[Delta]CDF; (3) an ICLERP of about 4E-8 for plants with PORVs and less 
than 3E-8 for plants without PORVs, which are less than the numerical 
guideline of 5E-8 for ICLERP; and (4) a [Delta]LERF of about 8E-9/year 
for plants with PORVs and about 5E-9 for plants without PORVs, which 
are much less than the acceptance guideline of 1E-7/year for 
[Delta]LERF. Furthermore, the proposed time extension may actually be 
risk neutral or result in a decrease in risk if credit for avoiding the 
transition to shutdown risk is taken.
    The risk impact argument is also supported by the following 
defense-in-depth discussion. The subject LCO requires the operability 
of a number of independent subsystems. In many instances due to the 
redundancy of trains and the diversity of subsystems, the inoperability 
of one component in a train does not necessarily render the HPSI 
incapable of performing its function. Neither does the inoperability of 
two different components, each in a different train, necessarily result 
in a loss of function for the ECCS. Examples of typical inoperabilities 
would include the unavailability of a single header injection valve or 
degradation of HPSI delivery curves below minimum design basis levels. 
The proposed completion time extension allows for potential resolution 
of minor HPSI system inoperabilities and provides time to

[[Page 41272]]

prepare for a controlled plant shutdown without increasing the plant's 
risk significantly.
    Finding: The requested change to allow four hours to resolve the 
inoperability and restore one pump or subsystem of HPSI capability 
before required to commence a plant shutdown per LCO 3.0.3, is 
acceptable.
    Tier 2 Restrictions: None.
3.2.6 Containment (STS LCO 3.6.1)
    The requirements stated in this LCO define the performance of the 
containment as a fission barrier. Specifically, LCO 3.6.1 requires that 
the containment maximum leakage rate be limited in accordance with 10 
CFR part 50 Appendix J. Other LCOs place additional restrictions on 
containment air locks and containment isolation valves. The integrated 
effect of these TSs is to ensure that the containment leakage is well 
controlled within limits which assure that the post accident whole body 
and thyroid dose limits of 10 CFR 100.11 or 10 CFR 50.67, as 
applicable, are satisfied following a Maximum Hypothetical Accident 
(MHA) initiated from full power. Inability to meet this leakage limit 
renders the containment inoperable.
    Plant Applicability: Applicable to all OG member plants with CE 
NSSS designs.
    Limiting Condition for Operation (LCO): Containment shall be 
operable in MODES 1, 2, 3 and 4.
    Condition Requiring Entry into Shutdown Required Action: 
Containment is declared to be inoperable due to excessive leakage, 
including leakage from air locks and isolation valves, for a time 
period greater than one hour. If the containment is not restored to 
operable status within one hour, a plant shutdown is required.
    Proposed Modification to Shutdown Required Actions: Define a 
specific action to allow 8 hours to restore an inoperable containment 
to operable. Allow MODE 4 to become a designated end state for 
correcting containment impairments for conditions where the containment 
leakage is excessive due to reasons other than the inoperability of two 
or more containment isolation valves (CIVs) in the same flow paths.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 8-hour completion time for restoring an inoperable 
containment to operable status will not lead to a significant increase 
in risk and may actually decrease risk. The risk impact of the proposed 
completion time extension was assessed to be well within the acceptance 
criteria reported in Regulatory Guides 1.174 and 1.177. Specifically, 
the proposed time extension would lead to the following conservatively 
assessed risk increases: (1) The large early release probability will 
increase by about 9E-8, which is close to the numerical guideline of 
5E-8 for ICLERP; and (2) the LERF will increase by about 2E-8/year, 
which is significantly less than the acceptance guideline of 1E-7/year 
for [Delta]LERF. Furthermore, the proposed completion time extension 
may actually be risk neutral or result in a decrease in risk if credit 
for avoiding the transition to shutdown risk is taken.
    The proposed changes apply to containment conditions where 
containment integrity is essentially maintained and adequate ECCS net 
positive suction head (NPSH) is expected following an event. 
Containment ``leakage'' at or near design basis levels is not 
explicitly modeled in PRAs. The PRA implicitly requires that 
containment ``gross'' integrity must be available to ensure adequate 
NPSH for ECCS pumps. Even though the PRA models do not consider that 
containment ``leakage'' contributes to a large early release, the 
assessed risk impact of the proposed completion time extension is based 
on the assumption that all core damage events will proceed to a large 
early release.
    The requirement for an immediate (within one hour) shutdown is 
based on the philosophy that inoperability of the containment is a 
violation of the plant design basis and, therefore, a plant shutdown 
must be initiated as soon as possible. The selection of one hour was 
based on the requirement for ``immediate shutdown'' and the assumption 
that one hour is adequate time for operators to effect shutdown plans. 
The goal was to place the plant in a condition where the health and 
safety of the public could be better assured. No specific risk 
assessments were performed. In fact, it is more appropriate from the 
health and safety objective viewpoint to consider the risk of continued 
plant operation as well as that introduced by the shutdown. In 
consideration of the total plant risk, it is more risk beneficial to 
allow a small increase in risk at power to resolve a TS inoperability 
rather than to undertake an immediate (within one hour) shutdown.
    In addition to the completion time extension, it is also proposed 
that MODE 4 be allowed as the end state to repair the containment. This 
is supported by the following arguments. If accidents were to occur in 
MODE 4, resulting containment pressures would be significantly less 
than the design basis accident (DBA) conditions. Hence, leakage would 
be further reduced. While in MODE 4, the probability of LOCA or MSLB is 
significantly reduced from MODE 1 levels. The implied licensing basis 
assumption that MODE 5 is inherently of lower operational risk than 
MODE 4 is not supported by risk evaluations (Reference 8). MODE 5 risks 
are either about equal to or likely greater than equivalent risks in 
MODE 4, and therefore produce radiation releases to containment on par 
with those of MODE 4. Thus, remaining in MODE 4, while the containment 
excess leakage condition is being corrected, is an appropriate action.
    The STS LCO 3.6.1 requirement that the plant be brought to MODE 5 
end state is not based on consideration of risks. Accidents initiated 
from MODE 4 are far less challenging to the containment than those 
initiated from MODE 1. The lower energy content in MODE 4 results in 
containment pressures and potential leakage approximately one half of 
that associated with MODE 1 releases. Furthermore, by having the plant 
in a shutdown condition in advance, fission product releases are 
significantly reduced. Thus, while leakage restrictions should be 
maintained, MODE 4 leakage in excess of that allowed in MODE 1 can be 
safely allowed for a limited time sufficient to resolve the 
inoperability and return the plant to power operation.
    From a deterministic perspective, MODE 4 with SG heat removal would 
maintain more mitigating systems available, as compared to MODE 5, to 
respond to loss of RCS inventory or decay heat removal events and 
therefore reduce the overall public risk. In MODE 4, the Safety 
Injection Actuation Signal (SIAS) and the Containment Isolation 
Actuation Signal (CIAS) will be available to aid the operators in 
responding to events that threaten the reactor or containment 
integrity. Therefore, the proposed TS end state change does not 
adversely affect the plant defense-in-depth.
    Finding: The requested changes to (1) increase the time available 
to take action to restore the containment to 8 hours and (2) allow MODE 
4 as the repair end state, are acceptable.
    Tier 2 Restrictions: None.
3.2.7 Containment Spray System (STS LCO 3.6.6 A)
    The containment spray (CS) and containment cooling (CC) systems 
provide containment atmosphere cooling to limit post accident pressure 
and temperature in containment to less than the design values. For most 
CE

[[Page 41273]]

NSSS design plants the containment sprays represent a portion of a 
diverse and redundant heat removal system. In addition to containment 
heat removal, CSs enhance post-accident fission product removal.
    Plant Applicability: Applicable to all OG member plants with CE 
NSSS designs.
    Limiting Condition for Operation (LCO): Two containment spray 
trains and two containment cooling (CAC or CARC) trains shall be 
operable in MODES 1, 2, 3 and [4].
    Condition Requiring Entry into Shutdown Required Action: 
Inoperability of both CS trains or any combination of three or more 
trains inoperable (STS LCO 3.6.6.A Condition F), immediate entry into 
LCO 3.0.3 is required.
    Proposed Modification to Shutdown Required Actions: (1) Increase 
the time available for restoring one CS train to 72 hours when at least 
one CARC train is available for containment heat removal; (2) increase 
the time available for restoring one CS train to 12 hours when two 
trains of the CARC system is unavailable for containment heat removal. 
Based on Table 5.2.3-2 of WCAP-16125-NP, STS LCO 3.6.6.A would be 
revised to allow shutdown modes of MODE 3 in 6 hours and MODE 5 in 36 
hours versus the current requirement of immediate entry into LCO 3.0.3 
if the Required Action and associated Completion Time not met.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 12-hour completion time for restoring one CS train 
when two trains of the CARC system is unavailable for containment heat 
removal before entering LCO 3.0.3 will not lead to a significant 
increase in risk and may actually decrease risk. The risk impact of the 
proposed completion time extension was assessed to be well within the 
acceptance criteria reported in Regulatory Guides 1.174 and 1.177. 
Specifically, the proposed completion time extension would lead to the 
following risk increases: (1) The probability of core damage will 
increase by less than 7E-7 which is close to the numerical guideline of 
5E-7 for ICCDP used in RG 1.177; (2) the CDF will increase by about 
1.4E-7/year (acceptance criteria for [Delta]CDF about 1E-6/year); (3) 
the large early release probability during the condition will increase 
by about 1E-8 (acceptance criteria for ICLERP is 5E-8); and (4) the 
LERF will increase by about 2.5E-9/year (acceptance criteria for 
[Delta]LERF is 1E-7/year). Furthermore, the proposed completion time 
extension may actually be risk neutral or result in a decrease in risk 
if credit for avoiding the transition to shutdown risk is taken.
    When at least one CARC train is available for containment heat 
removal, the risk impact in terms of CDF and LERF is insignificant. 
However, credit is taken for post accident fission product removal by 
the CS system. The radiation release ``non-LER'' risk impact associated 
with the proposed increase of the time available for restoring one CS 
train to 72 hours was conservatively assessed. Specifically, the 
proposed completion time extension would lead to the following ``non-
LER'' risk increases: (1) The probability of a ``non-LER'' release 
during the completion time extension would increase by about 8E-7; and 
(2) the ``non-LER'' frequency would increase by 1.6E-7/year. These 
increases in ``non-LER'' risk are slightly above the values used in the 
criteria discussed in Section 3.1 of this report. However, such 
increases in ``non-LER'' risk are still comparable in magnitude to what 
is considered acceptable for increases in the much higher consequence 
risks associated with core damage and large early release. Furthermore, 
the proposed completion time extension is definitely risk beneficial 
when the averted core damage and large early release risks associated 
with avoiding plant shutdown are taken into consideration.
    In addition to the risk argument, the proposed 72-hour completion 
time is selected for compatibility with improved standard technical 
specification (STS) LCO 3.6.6B. STS LCO 3.6.6B calls for a Completion 
Time of 72 hours when two CS trains are inoperable (Condition C) and is 
applicable to conditions where the sprays are not credited for fission 
product removal. Inoperability of the CS or CARC will degrade the 
capability of the plant to respond to a containment threat. However, 
provided the other system is available the plant remains capable of 
controlling pressure. The loss of sprays will expose some plant 
equipment to beyond environmental qualification temperature limits 
should a MSLB occur. However, the probability of such an event during 
the proposed completion time extension is very small (about 1E-3/year 
or less than 1E-5 per 71 hours). Furthermore, the ability of the plant 
to cope with a MSLB event is not compromised.
    Finding: The requested changes to (1) increase the time available 
for restoring one CS train to 72 hours when at least one CARC train is 
available for containment heat removal; and (2) increase the time 
available for restoring one CS train to 12 hours when two trains of the 
CARC system is unavailable for containment heat removal, are 
acceptable. The requested change described in Table 5.2.3-2 of WCAP-
16125-NP, that is, STS LCO 3.6.6.A would be revised to allow shutdown 
modes of MODE 3 in 6 hours and MODE 5 in 36 hours versus the current 
requirement of immediate entry into LCO 3.0.3 if the Required Action 
and associated Completion Time is not met, was not justified in the 
topical report. Therefore, the proposed change is not acceptable 
without further justification.
    Tier 2 Restrictions: None.
3.2.8 Iodine Cleanup System (ICS) (STS LCO 3.6.10)
    The purpose of the ICS is to remove elemental iodine from the post-
accident containment atmosphere. These systems were initially 
incorporated into plants in the belief that radiological iodine 
releases would be predominantly in elemental form. However, extensive 
research has indicated that most iodine will be released in the form of 
Cesium Iodine (CsI) particulates. Consequently, the actual impact of 
system functionality on actual public doses is negligible. ICS consists 
of two 100% capacity trains.
    Plant Applicability: Calvert Cliffs 1 & 2, St Lucie 1 & 2.
    Limiting Condition for Operation (LCO): Two ICS trains shall be 
operable in MODES 1, 2, 3 & 4.
    Condition Requiring Entry into LCO 3.0.3: Both ICS trains 
inoperable. Currently a default entry into LCO 3.0.3 is required.
    Proposed Modification to Shutdown Required Actions: Add a condition 
to (1) allow 24 hours to restore one train to operable status, and (2) 
allow MODE 4 as the final end state for repairing the inoperable 
system.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 24-hour completion time for restoring one train of 
ICS will not lead to a significant increase in risk and may actually 
decrease risk. The proposed completion time extension will not 
contribute to any risk increases, in terms of core damage and large 
early release. The radiation release ``non-LER'' risk impact associated 
with the proposed time increase was conservatively assessed. 
Specifically, the proposed completion time extension would lead to the 
following ``non-LER'' risk increases: (1) The probability of a ``non-
LER'' release during the completion time extension would increase by 
about 2.6E-7; and (2) the ``non-LER'' frequency would increase by about 
5.0E-8/year. These increases in ``non-LER'' risk, which are comparable 
in magnitude to what is considered

[[Page 41274]]

acceptable for core damage and large early release risk increases, are 
very small. Furthermore, the proposed completion time extension is risk 
beneficial when the averted core damage and large early release risks 
associated with avoiding plant shutdown are taken into consideration.
    The proposed change to allow MODE 4 as the final end state for 
repairing the inoperable system is supported by risk assessments 
(Reference 8) which indicated that, in general, there is less risk 
associated with staying in MODE 4 to repair the inoperable system than 
proceeding to MODE 5. This is due to the fact that there are more 
systems available in MODE 4 than in MODE 5 to mitigate accidents 
initiated at shutdown and the risk of transition between MODES 4 and 5 
is avoided.
    The ICS functions together with the containment spray and the 
containment cooling systems following a design basis accident (DBA) 
that causes failure of the fuel cladding, and release of radioactive 
material (principally iodine) to the containment. The ICS is 
specifically designed to respond to the maximum hypothetical accident 
with a large assumed contribution due to elemental iodine. The DBAs 
that result in a release of radioactive iodine within containment are 
LOCA and MSLB or a control element assembly (CEA) ejection accident. In 
the analysis for each of these accidents, it is assumed that adequate 
containment leak tightness is present at event initiation to limit 
potential leakage to the environment. Additionally, it is assumed that 
the amount of radioactive iodine release is limited by reducing the 
iodine concentration in the containment atmosphere via use of 
containment sprays. The unavailability of the ICS will have no 
significant impact on anticipated radiological releases to the public 
or the control room. This is due to the fact that: (1) Iodine releases 
are predominantly particulate and removal via sprays and precipitation 
is effective, (2) availability of elemental iodine is low so that ICS 
has limited utility, and (3) containment leak tightness significantly 
limits potential releases. Significant release events that contribute 
to large early release, such as containment bypass and SGTR with loss 
of secondary isolation events, will bypass these filters regardless of 
their availability.
    Finding: The requested changes to (1) increase the time available 
to restore one ICS train to 24 hours and (2) allow MODE 4 as the final 
end state, for cases when both ICS trains are inoperable, are 
acceptable.
    Tier 2 Restrictions: None.
3.2.9 Shield Building Exhaust Air Cleanup System (STS LCO 3.6.13)
    The shield building exhaust air cleanup system (SBEACS) provides 
radionuclide removal capability for fission products leaked into the 
shield building. The SBEACS consists of two separate and redundant 
trains. Each train includes a heater, cooling coils, a prefilter, a 
moisture separator, a high efficiency particulate air (HEPA) filter, an 
activated charcoal absorber section for removal of radionuclides and a 
fan. Ductwork, valves and/or dampers and instrumentation also form part 
of the system.
    Plant Applicability: St Lucie 1 & 2, Waterford 3 and Millstone 2.
    Limiting Condition for Operation (LCO): Two SBEACS trains shall be 
operable in MODES 1, 2, 3 and 4.
    Condition Requiring Entry into Shutdown Required Action:Both SBEACS 
trains inoperable. Currently a default entry into LCO 3.0.3 is 
required.
    Proposed Modification to Shutdown Required Actions: Add a condition 
to (1) allow 24 hours to take action for both SBEACS trains 
unavailable, and (2) allow MODE 4 as the final end state for repairing 
the inoperable system.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 24-hour completion time for restoring one train of 
SBEACS will not lead to a significant increase in risk and may actually 
decrease risk. The proposed completion time extension will not 
contribute to any risk increases, in terms of core damage and large 
early release. The radiation release ``non-LER'' risk impact associated 
with the proposed time increase was conservatively assessed. 
Specifically, the proposed completion time extension would lead to the 
following ``non-LER'' risk increases: (1) The probability of a ``non-
LER'' release during the completion time extension would increase by 
about 2.6E-7; and (2) the ``non-LER'' frequency would increase by about 
5.0E-8/year. These increases in ``non-LER'' risk, which are comparable 
in magnitude to what is considered acceptable for core damage and large 
early release risk increases, are very small. Furthermore, the proposed 
completion time extension is definitely risk beneficial when the 
averted core damage and large early release risks associated with 
avoiding plant shutdown are taken into consideration.
    The proposed change to allow MODE 4 as the final end state for 
repairing the inoperable system is supported by risk assessments 
(Reference 8) which indicated that, in general, there is less risk 
associated with staying in MODE 4 to repair the inoperable system than 
proceeding to MODE 5. This is due to the fact that there are more 
systems available in MODE 4 than in MODE 5 to mitigate accidents 
initiated at shutdown and the risk of transition between MODES 4 and 5 
is avoided.
    The proposed changes are also supported by the following 
qualitative discussion. The SBEACS is required to ensure that the 
radioactive material leaking from the primary containment of a dual 
containment into the Shield Building (secondary containment) following 
a DBA are filtered and absorbed prior to exhausting to the environment. 
Loss of the SBEACS could cause site boundary doses, in the event of a 
DBA, to exceed the values given in the licensing basis. However, 
containment ``leakage'' at or near design basis levels is not 
explicitly modeled in PRAs. PRAs implicitly require that containment 
``gross'' integrity must be available to ensure NPSH for ECCS pumps. In 
the PRA Level 2 models, containment ``leakage'' is not considered to 
contribute to large early release. If accidents were to occur in MODE 
4, resulting containment pressures would be significantly less than the 
DBA conditions. Hence, leakage would be further reduced. In addition, 
while in MODE 4, the probability of LOCA and MSLB is significantly 
reduced from MODE 1 levels. By keeping the plant in MODE 4, operator 
actions required for entry into shutdown cooling and which introduce 
potential containment bypass risks are avoided.
    Finding: The requested changes to (1) increase the time available 
to restore one SBEACS train to 24 hours and (2) allow MODE 4 as the 
final end state, for cases when both SBEACS trains are inoperable, are 
acceptable.
    Tier 2 Restrictions: None.
3.2.10 Control Room Emergency Air Cleanup System (STS LCO 3.7.11)
    The control room emergency air cleanup system (CREACS) provides a 
protected environment from which operators can control the plant 
following an uncontrolled release of radioactivity, chemicals or toxic 
gas. Alternate designations of this system include the acronyms 
CREACUS, CREACS, CREVAS, CREVS, or CREAFS. The current TS require 
operability of CREACS from MODE 1 through MODE 4 to support operator 
response to a DBA. The system's operability in MODES 5 and 6 may also 
be required at some plants for chemical and toxic gas concerns. The 
CREACS is needed to protect the control room (CR) in a wide variety of 
circumstances.

[[Page 41275]]

    Plant Applicability: Applicable to all OG member plants with CE 
NSSS designs.
    Limiting Condition for Operation (LCO): Two CREACS trains shall be 
operable in MODES 1, 2, 3 and 4 and during movement of [recently] 
irradiated fuel assemblies in MODES [5 and 6].
    Condition Requiring Entry into Shutdown Required Action: Both 
trains inoperable for conditions other than inoperable control room 
boundary in MODES 1, 2, 3, and 4. Explicit entry into LCO 3.0.3 
required (STS LCO 3.7.11 Condition F).
    Proposed Modification to Shutdown Required Actions: (1) Increase 
the time available to take action to 24 hours (or the time to reach 5 
REM, which may be less than 24 hours, from the radiation field 
associated with main steam safety valves lifting concurrent with a 
SGTR) for the cases in which both CREACS trains are unavailable, and 
(2) allow MODE 4 as the final end state for repairing the inoperable 
system. This modification applies to the radiation protection function 
only. Site specific validation is necessary to support extension to 
toxic gas and chemical protection functions.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 24-hour completion time for restoring one train of 
CREACS before entering LCO 3.0.3 will not lead to a significant 
increase in risk and may actually decrease risk. The proposed 
completion time extension will not contribute to any risk increases, in 
terms of core damage and large early release. The radiation release 
``non-LER'' risk impact associated with the proposed time increase was 
conservatively assessed. Specifically, the proposed completion time 
extension would lead to the following ``non-LER'' risk increases: (1) 
The probability of a ``non-LER'' release during the completion time 
extension would increase by about 2.6E-7; and (2) the ``non-LER'' 
frequency would increase by about 5.0E-8/year. These increases in 
``non-LER'' risk, which are comparable in magnitude to what is 
considered acceptable for core damage and large early release risk 
increases, are very small. Furthermore, the proposed completion time 
extension is definitely risk beneficial when the averted core damage 
and large early release risks associated with avoiding plant shutdown 
are taken into consideration.
    The proposed change to allow MODE 4 as the final end state for 
repairing the inoperable system is not justified. STS LCO 3.7.11 
Condition F has an explicit LCO 3.0.3 entry. WCAP-16125-NP does not 
provide justification for modifying Condition F Required Action from 
``Enter LCO 3.0.3'' to an end state of MODE 4.
    Finding: The requested change to increase the time available to 
take action to restore one CREACS train to 24 hours for the radiation 
protection function only is acceptable. The requested change to allow 
MODE 4 as the final end state, for cases when both CREACS trains are 
inoperable, is not justified in WCAP-16125-NP and is not acceptable.
    Tier 2 Restrictions: None.
3.2.11 Control Room Emergency Air Temperature Control System (STS LCO 
3.7.12)
    The control room emergency air temperature control system (CREATCS) 
provides temperature control for the CR following isolation of the CR. 
The CREATCS consists of two independent, redundant trains that provide 
cooling and heating of recirculated CR air. Each train consists of 
heating coils, cooling coils, instrumentation and controls to provide 
for CR temperature control.
    Plant Applicability: Applicable to Calvert Cliffs 1 & 2, Fort 
Calhoun, Palisades, PVNGS 1, 2, & 3, Waterford 3 and ANO 2. It is noted 
that cooling for the St Lucie units are included in the air cleanup 
system discussed in TS 3.7.11 but the cooling system arguments 
contained in this section apply to St Lucie Units 1 & 2.
    Limiting Condition for Operation (LCO): Two CREATCS trains shall be 
operable in MODES 1, 2, 3 and 4 and during movement of [recently] 
irradiated fuel assemblies in MODES [5 and 6].
    Condition Requiring Entry into Shutdown Required Action: Both 
trains inoperable in MODES 1, 2, 3, and 4 requires an explicit LCO 
3.0.3 entry (STS LCO 3.7.12 Condition E).
    Proposed Modification to Shutdown Required Actions: Modify STS LCO 
3.7.12 Condition E to (1) increase the time available to take action 
under LCO 3.0.3 to 24 hours for the cases in which both CREATCS trains 
are unavailable, and (2) allow MODE 4 as the final end state for 
repairing the inoperable system.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 24-hour completion time for restoring one train of 
CREATCS before entering LCO 3.0.3 will not lead to a significant 
increase in risk and may actually decrease risk. The proposed 
completion time extension will not contribute to any risk increases, in 
terms of core damage and large early release. The radiation release 
``non-LER'' risk impact associated with the proposed completion time 
increase was conservatively assessed. Specifically, the proposed 
completion time extension would lead to the following ``non-LER'' risk 
increases: (1) The probability of a ``non-LER'' release during the 
completion time extension would increase by about 2.6E-7; and (2) the 
``non-LER'' frequency would increase by about 5.0E-8/year. These 
increases in ``non-LER'' risk, which are comparable in magnitude to 
what is considered acceptable for core damage and large early release 
risk increases, are very small. Furthermore, the proposed completion 
time extension is definitely risk beneficial when the averted core 
damage and large early release risks associated with avoiding plant 
shutdown are taken into consideration.
    The proposed change to allow MODE 4 as the final end state for 
repairing the inoperable system is not justified. STS LCO 3.7.12 
Condition E has an explicit LCO 3.0.3 entry. WCAP-16125-NP does not 
provide justification for modifying Condition E Required Action from 
``Enter LCO 3.0.3'' to an end state of MODE 4.
    Several short term actions associated with cooling the CR may be 
implemented to mitigate risk consequences further. These actions 
include use of portable fans and propping open doors. Several plants 
have such actions in procedures.
    Finding: The requested change to increase the time available to 
take action to restore one CREATCS train to 24 hours is acceptable. The 
requested change to allow MODE 4 as the final end state, for cases when 
both trains are inoperable, is not justified in WCAP-16125-NP and is 
not acceptable.
    Tier 2 Restrictions: None.
3.2.12 Emergency Core Cooling System (ECCS) Pump Room Exhaust Air 
Cleanup System (PREACS) (STS LCO 3.7.13)
    The ECCS pump room exhaust air cleanup system (ECCS PREACS) is an 
emergency system that filters air from the area of the active 
Engineered Safety Features (ESF) components during the recirculation 
phase of a LOCA. The ECCS PREACS consists of two independent, redundant 
trains of equipment that provide filtering of air in the ECCS pump 
rooms during post-LOCA recirculation cooling.
    Plant Applicability: Calvert Cliffs 1 & 2, St Lucie 1 & 2, 
Waterford 3. It is noted that at Waterford 3 the functions of the ECCS 
PREACS and Penetration Room Exhaust Air Cleanup System (PREACS), which 
is discussed below under LCO 3.7.15, are combined within the

[[Page 41276]]

Controlled Ventilation Area System (CVAS) TS.
    Limiting Condition for Operation (LCO): Two ECCS PREACS trains 
shall be operable in MODES 1, 2, 3 and 4.
    Condition Requiring Entry into Shutdown Required Action: Both 
trains inoperable, default entry into LCO 3.0.3.
    Proposed Modification to Shutdown Required Actions: (1) Increase 
the time available to restore one train to 24 hours, and (2) allow MODE 
4 as the final end state for repairing the inoperable system.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 24-hour completion time for restoring one train of 
ECCS PREACS will not lead to a significant increase in risk and may 
actually decrease risk. The proposed completion time extension will not 
contribute to any risk increases, in terms of core damage and large 
early release. The radiation release ``non-LER'' risk impact associated 
with the proposed completion time increase was conservatively assessed. 
Specifically, the proposed completion time extension would lead to the 
following ``non-LER'' risk increases: (1) The probability of a ``non-
LER'' release during the completion time extension would increase by 
about 1.1E-7; and (2) the ``non-LER'' frequency would increase by about 
2.0E-8/year. These increases in ``non-LER'' risk, which are comparable 
in magnitude to what is considered acceptable for core damage and large 
early release risk increases, are very small. Furthermore, the proposed 
completion time extension is definitely risk beneficial when the 
averted core damage and large early release risks associated with 
avoiding plant shutdown are taken into consideration.
    The proposed change to allow MODE 4 as the final end state for 
repairing the inoperable system is supported by risk assessments 
(Reference 8) which indicated that, in general, there is less risk 
associated with staying in MODE 4 to repair the inoperable system than 
proceeding to MODE 5. This is due to the fact that there are more 
systems available in MODE 4 than in MODE 5 to mitigate accidents 
initiated at shutdown and the risk of transition between MODES 4 and 5 
is avoided.
    The unavailability of the ECCS PREACS only impacts radiation 
releases to the public when the ECCS recirculation is in progress 
during a LOCA. Since successful recirculation also implies successful 
event mitigation, the releases this system is designed to mitigate are 
relatively low.
    Finding: The requested changes to (1) increase the time available 
to take action to restore one ECCS-PREACS train to 24 hours and (2) 
allow MODE 4 as the final end state, for cases when both trains are 
inoperable, are acceptable.
    Tier 2 Restrictions: None.
3.2.13 Penetration Room Exhaust Air Cleanup System (PREACS) (STS LCO 
3.7.15)
    The Penetration Room Exhaust Air Cleanup System (PREACS) filters 
air from the penetration area between the containment and the auxiliary 
building. The PREACS consists of two independent, redundant trains. 
Each train consists of a heater, demister or prefilter, HEPA filter, 
activated charcoal absorber and a fan.
    Plant Applicability: Calvert Cliffs 1 & 2, and Waterford 3. It is 
noted that at Waterford 3 the functions of the PREACS and ECCS PREACS, 
which is discussed above under LCO 3.7.13, are combined within the 
Controlled Ventilation Area System (CVAS) TS.
    Limiting Condition for Operation (LCO): Two PREACS trains shall be 
operable in MODES 1, 2, 3 and 4.
    Condition Requiring Entry into Shutdown Required Action: Both 
trains inoperable for reasons other than an inoperable penetration room 
boundary, default entry into LCO 3.0.3 is required.
    Proposed Modification to Shutdown Required Actions: (1) Increase 
the time available to restore one train to 24 hours, and (2) allow MODE 
4 as the final end state for repairing the inoperable system.
    Assessment: The risk assessment results (in Reference 2) indicate 
that the proposed 24-hour completion time for restoring one train of 
PREACS will not lead to a significant increase in risk and may actually 
decrease risk. The proposed completion time extension will not 
contribute to any risk increases, in terms of core damage and large 
early release. The radiation release ``non-LER'' risk impact associated 
with the proposed completion time increase was conservatively assessed. 
Specifically, the proposed completion time extension would lead to the 
following ``non-LER'' risk increases: (1) The probability of a ``non-
LER'' release during the completion time extension would increase by 
about 2.6E-7; and (2) the ``non-LER'' frequency would increase by about 
5.0E-8/year. These increases in ``non-LER'' risk, which are comparable 
in magnitude to what is considered acceptable for core damage and large 
early release risk increases, are very small. Furthermore, the proposed 
completion time extension is definitely risk beneficial when the 
averted core damage and large early release risks associated with 
avoiding plant shutdown are taken into consideration.
    The proposed change to allow MODE 4 as the final end state for 
repairing the inoperable system is supported by risk assessments 
(Reference 8) which indicated that, in general, there is less risk 
associated with staying in MODE 4 to repair the inoperable system than 
proceeding to MODE 5. This is due to the fact that there are more 
systems available in MODE 4 than in MODE 5 to mitigate accidents 
initiated at shutdown and the risk of transition between MODES 4 and 5 
is avoided.
    Finding: The requested changes to (1) increase the time available 
to take action to restore one PREACS train to 24 hours and (2) allow 
MODE 4 as the final end state, for cases when both trains are 
inoperable, are acceptable.
    Tier 2 Restrictions: None.
3.3 Summary and Conclusions
    The above requested changes are found acceptable by the staff. The 
staff approval applies only to operation as described and acceptably 
justified in References 2 and 8. To be consistent with the staff's 
approval, any licensee requesting to operate in accordance with TSTF-
426, as approved in this safety evaluation, should commit to operate in 
accordance with WCAP-16446-NP, Rev 0, ``Actions to Preclude Entry into 
LCO 3.0.3 Implementation Guidance (PA-RMCS-0196),'' June 2005, which 
includes a requirement for the licensee to commit to adhere to the 
guidance of the revised Section 11 of NUMARC-93-01, Revision 3. The 
implementation guidance includes alternative systems that must be 
operable and compensating measures for the systems included in TSTF-
426. The licensees shall update relevant operating procedures, 
maintenance procedures, and training programs to reflect this change.
    The required action for conditions that imply a loss of function, 
is entry into LCO 3.0.3. Currently, upon entering LCO 3.0.3, one hour 
is allowed to prepare for an orderly shutdown before initiating a 
change in plant operation. The OG is proposing to define or modify 
various TS Conditions to accommodate extension of the currently 
required time of one hour to initiate plant shutdown for member plants 
with CE NSSS designs. The proposed extension, related to specific 
systems or components, is based on the system's risk significance. In 
addition, WCAP-16125-NP provides a proposal to modify several Required 
Action statements, related to specific systems or components, to allow 
for a MODE 4 (hot shutdown) end state for repair purposes of two-train 
redundant systems that do not have explicit LCO 3.0.3 entry 
requirements, when the time

[[Page 41277]]

requirements of the action statement for staying at power cannot be 
met.
    The intent of the proposed TS changes is to provide needed 
flexibility in the performance of corrective maintenance during power 
operation to fully evaluate the situation or restore loss of function 
and at the same time enhance overall plant safety by:
     Avoiding unnecessary unscheduled plant shutdowns,
     Minimizing plant transitions and associated transition and 
realignment risks,
     Providing increased flexibility in scheduling and 
performing maintenance and surveillance activities, and
     Providing explicit guidance in areas that currently does 
not exist.
    It should be noted that many of the proposed TS changes affect the 
existing plant shutdown requirements for plant conditions where the 
plant operation is not in explicit compliance with the plant design 
basis. The proposed actions provide a risk-informed process for 
establishing shutdown priorities aiming at reducing overall plant risk 
and increasing public health and safety protection. In performing the 
risk-informed assessments and interpreting the results, the following 
assumptions were made:
     A condition resulting in the inoperability of a system or 
component which currently results in the need for an immediate shutdown 
is a low frequency event.
     The frequency of events leading to LCO 3.0.3 is not 
expected to increase significantly following the proposed change 
because such events may be reportable and may require a licensee event 
report. In addition, events leading to LCO 3.0.3 are used in 
performance indicators and the reactor oversight program. Therefore, 
licensees will have no incentive to allow the current low frequency of 
these events to increase after the proposed extensions are granted.
     The risk incurred by increasing the required shutdown 
action time is controlled to acceptable levels using a risk informed 
approach that considers the component risk worth and offsetting 
benefits of avoiding plant transitions.
    The risk impact of the proposed TS changes was assessed following 
the three-tiered approach recommended in RG 1.177 for evaluating 
proposed extensions in currently allowed Completion Times (CTs):
     The first tier involves the assessment of the change in 
plant risk due to the proposed TS change;
     The second tier involves the identification of potentially 
high-risk configurations that could exist if equipment in addition to 
that associated with the change were to be taken out of service 
simultaneously;
     The third tier involves the implementation of the proposed 
changes in conjunction with a configuration risk management program 
(CRMP).
    The impact of each proposed system-specific TS change on defense-
in-depth was evaluated in conjunction with the risk assessment results. 
Due to the nature of the plant conditions associated with the proposed 
TS changes (i.e., loss of a system's or component's function), the 
redundancy and diversity typically associated with ensuring the 
deterministic aspect of defense-in-depth position is not always 
strictly possible. In these cases defense-in-depth was considered by 
identifying specific restrictions to the implementation of the proposed 
changes. Such restrictions aim at (1) controlling the outage time for 
related equipment, (2) restricting activities which may challenge the 
unavailable systems or functions, (3) allowing only small time 
intervals for plant operation at power with a system or function 
unavailable, (4) using, whenever possible, contingency actions to limit 
concurrent outages, and (5) evaluating repair activities and 
alternatives.
    Based on this integrated evaluation, the staff concludes that the 
proposed system-specific TS changes would at most lead to acceptably 
small risk increases. In addition, defense-in-depth is taken into 
consideration. This conclusion is a consequence of the low expected 
challenge frequency of the systems or functions associated with the 
proposed TS changes, the very short proposed exposure times to the 
specified plant conditions, the offsetting benefits of avoiding plant 
transitions, and the identification of specific restrictions to the 
implementation of the proposed changes.

4.0 Verifications and Commitments

    In order to efficiently process incoming license amendment 
applications and ensure consistent implementation of the change by the 
various licensees, the NRC staff requested each licensee requesting the 
changes addressed by TSTF-426, Rev 0, using the CLIIP to address the 
following plant-specific regulatory commitments.
    4.1 Each licensee should make a regulatory commitment to follow the 
implementation guidance of WCAP-16446-NP, Rev 0, ``Actions to Preclude 
Entry into LCO 3.0.3 Implementation Guidance (PA-RMCS-0196),'' June 
2005.
    4.2 Each licensee should make a regulatory commitment to follow 
Section 11 of NUMARC-93-01, Revision 3.
    The licensee has made a regulatory commitment to follow the 
implementation guidance of WCAP-16446-NP and Section 11 of NUMARC-93-
01, Revision 3.
    The NRC staff finds that reasonable controls for the implementation 
and for subsequent evaluation of proposed changes pertaining to the 
above regulatory commitment(s) can be provided by the licensee's 
administrative processes, including its commitment management program. 
The NRC staff has agreed that NEI 99-04, Revision 0, ``Guidelines for 
Managing NRC Commitment Changes,'' provides reasonable guidance for the 
control of regulatory commitments made to the NRC staff (see Regulatory 
Issue Summary 2000-17, ``Managing Regulatory Commitments Made by Power 
Reactor Licensees to the NRC Staff,'' dated September 21, 2000). The 
NRC staff notes that NEI 99-04 establishes a voluntary reporting system 
for the operating data that is similar to the system established for 
the ROP PI program. Should the licensee choose to incorporate a 
regulatory commitment into the final safety analysis report or other 
document with established regulatory controls, the associated 
regulations would define the appropriate change-control and reporting 
requirements.

5.0 State Consultation

    In accordance with the Commission's regulations, the [ ] State 
official was notified of the proposed issuance of the amendment. The 
State official had [(1) no comments or (2) the following comments--with 
subsequent disposition by the staff].

6.0 Environmental Consideration

    The amendments change a requirement with respect to the 
installation or use of a facility component located within the 
restricted area as defined in 10 CFR part 20 and change surveillance 
requirements. The NRC staff has determined that the amendments involve 
no significant increase in the amounts and no significant change in the 
types of any effluents that may be released offsite, and that there is 
no significant increase in individual or cumulative occupational 
radiation exposure. The Commission has previously issued a proposed 
finding that the amendments involve no-significant-hazards-
considerations, and there has been no public comment on the finding [FR 
].

[[Page 41278]]

Accordingly, the amendments meet the eligibility criteria for 
categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 
CFR 51.22(b), no environmental impact statement or environmental 
assessment need be prepared in connection with the issuance of the 
amendments.

7.0 Conclusion

    The Commission has concluded, on the basis of the considerations 
discussed above, that (1) there is reasonable assurance that the health 
and safety of the public will not be endangered by operation in the 
proposed manner, (2) such activities will be conducted in compliance 
with the Commission's regulations, and (3) the issuance of the 
amendments will not be inimical to the common defense and security or 
to the health and safety of the public.

8.0 References

    1. WCAP-16125-NP, Revision 0, ``Justification for Risk-Informed 
Modifications to Selected Technical Specifications for Conditions 
Leading to Exigent Plant Shutdown,'' October 3, 2003.
    2. Beckner, William D., ``Safety Evaluation of WCAP-16125-NP, Rev 
0, ``Justification for Risk-Informed Modifications to Selected 
Technical Specifications for Conditions Leading to Exigent Plant 
Shutdown,'' Letter to Gordon Bischoff, Westinghouse
    3. TSTF-426, Revision 0, ``Revise or Add Actions to Preclude Entry 
into LCO 3.0.3,'' August 2004.
    4. WCAP-16446-NP, Revision 0, ``Actions to Preclude Entry into LCO 
3.0.3, Implementation Guidance,'' June 2005.
    5. NUREG-1432, ``Standard Technical Specifications, Combustion 
Engineering Plants,'' Revision 2, USNRC, June 2001.
    6. Regulatory Guide 1.174, ``An Approach for Using Probabilistic 
Risk Assessment in Risk-Informed Decision Making on Plant Specific 
Changes to the Licensing Basis,'' USNRC, August 1998.
    7. Regulatory Guide 1.177, ``An Approach for Plant Specific Risk-
Informed Decision Making: Technical Specifications,'' USNRC, August 
1998.
    8. CE-NPSD-1186, ``Technical Justification for the Risk-Informed 
Modification to Selected Required Action End States for CEOG PWRs,'' CE 
Owner's Group, April 2000.
    9. Regulatory Guide 1.182, ``Assessing and Managing Risk Before 
Maintenance Activities at Nuclear Power Plants,'' May 2000.

Attachment--For Inclusion on the Technical Specification Web Page

    The following example of an application was prepared by the NRC 
staff to facilitate use of the consolidated line item improvement 
process (CLIIP). The model provides the expected level of detail and 
content for an application to adopt TSTF-426, Revision 0, ``Risk-
Informed modifications to selected technical specifications for 
conditions leading to exigent plant shutdowns,'' for CE plants using 
CLIIP. Licensees remain responsible for ensuring that their actual 
application fulfills their administrative requirements as well as 
Nuclear Regulatory Commission regulations.

U.S. Nuclear Regular Commission,
Document Control Desk, Washington, DC 20555.

Subject: Plant Name, Docket No. 50--Application for Technical 
Specification Change TSTF-426, Risk Informed Modification to Selected 
Technical Specifications for Conditions Leading to Exigent Plant 
Shutdowns Using the Consolidated Line Item Improvement Process

    Gentleman: In accordance with the provisions of 10 CFR 50.90 
[LICENSEE] is submitting a request for an amendment to the technical 
specifications (TS) for [PLANT NAME, UNIT NOS.].
    The proposed amendment would modify TS to risk-inform requirements 
regarding selected technical specifications for conditions leading to 
exigent plant shutdowns.
    Attachment 1 provides a description of the proposed change, the 
requested confirmation of applicability, and plant-specific 
verifications. Attachment 2 provides the existing TS pages marked up to 
show the proposed change. Attachment 3 provides revised (clean) TS 
pages. Attachment 4 provides a summary of the regulatory commitments 
made in this submittal. Attachment 5 provides the existing TS Bases 
pages marked up to show the proposed change (for information only).)
    [LICENSEE] requests approval of the proposed license amendment by 
[DATE], with the amendment being implemented [BY DATE OR WITHIN X 
DAYS].
    In accordance with 10 CFR 50.91, a copy of this application, with 
attachments, is being provided to the designated [STATE] Official.
    I declare under penalty of perjury under the laws of the United 
States of America that I am authorized by [LICENSEE] to make this 
request and that the foregoing and the attachment are true and correct. 
(Note that request may be notarized in lieu of using this oath or 
affirmation statement).
    If you should have any questions regarding this submittal, please 
contact [NAME, TELEPHONE NUMBER].

 Sincerely,

[Name, Title]

Attachments:
    1. Description and Assessment.
    2. Proposed Technical Specification Changes.
    3. Revised Technical Specification Pages.
    4. Regulatory Commitments.
    5. Proposed Technical Specification Bases Changes.

cc: NRC Project Manager
    NRC Regional Office
    NRC Resident Inspector
    State Contact

Attachment 1--Description and Assessment

1.0 Description

    The proposed amendment would modify technical specifications to 
risk-inform requirements regarding selected technical specifications 
for conditions leading to exigent plant shutdowns.
    The changes are consistent with Nuclear Regulatory Commission (NRC) 
approved Industry/Technical Specification Task Force (TSTF) TSTF-426, 
Revision 0. The availability of this Technical Specification (TS) 
improvement was published in the Federal Register on [DATE] as part of 
the consolidated line item improvement process (CLIIP).

2.0 Assessment

2.1 Applicability of Topical Report, TSTF-426, and Published Safety 
Evaluation
    [LICENSEE] has reviewed GE topical report (Reference 1), TSTF-426 
(Reference 2), and the NRC model safety evaluation (Reference 3) as 
part of the CLIIP. [LICENSEE] has concluded that the information in the 
GE topical report and TSTF-426, as well as the safety evaluation 
prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and 
justify this amendment for the incorporation of the changes to the 
[PLANT] TS. [NOTE: Only those changes proposed in TSTF-426 are 
addressed in the model SE. The model SE and associated topical report 
address the entire fleet of CE plants, and the plants adopting TSTF-426 
must confirm the applicability of the changes to their plant.]
2.2 Optional Changes and Variations
    [LICENSEE] is not proposing any variations or deviations from the 
GE

[[Page 41279]]

topical report and the TS changes described in the TSTF-426, Revision 0 
or the NRC staff's model safety evaluation dated [DATE]. [NOTE: The 
CLIIP does not prevent licensees from requesting an alternate approach 
or proposing changes without the requested Bases or Bases control 
program. However, deviations from the approach recommended in this 
notice may require additional review by the NRC staff and may increase 
the time and resources needed for the review. Significant variations 
from the approach, or inclusion of additional changes to the license, 
will result in staff rejection of the submittal. Instead, licensees 
desiring significant variations and/or additional changes should submit 
a LAR that does not claim to adopt TSTF-426.]

3.0 Regulatory Analysis

3.1 No Significant Hazards Consideration Determination
    [LICENSEE] has reviewed the proposed no significant hazards 
consideration determination (NSHCD) published in the Federal Register 
as part of the CLIIP. [LICENSEE] has concluded that the proposed NSHCD 
presented in the Federal Register notice is applicable to [PLANT] and 
is hereby incorporated by reference to satisfy the requirements of 10 
CFR 50.91(a).
3.2 Verification and Commitments
    As discussed in the notice of availability published in the Federal 
Register on [DATE] for this TS improvement, plant-specific 
verifications were performed as follows:
    [LICENSEE] commits to the regulatory commitments in Attachment 4. 
In addition, [LICENSEE] has proposed TS Bases consistent with the 
Westinghouse topical report and TSTF-426, which provide guidance and 
details on how to implement the new requirements. Implementation of 
TSTF-426 requires that risk be managed and assessed, and the licensee's 
configuration risk management program is adequate to satisfy this 
requirement. The risk assessment need not be quantified, but may be a 
qualitative assessment of the vulnerability of systems and components 
when one or more systems are not able to perform their associated 
function.

4.0 Environmental Evaluation

    The amendment changes requirements with respect to the installation 
or use of a facility component located within the restricted area as 
defined in 10 CFR part 20. The NRC staff has determined that the 
amendment adopting TSTF-426, Rev. 0, involves no significant increase 
in the amounts and no significant change in the types of any effluents 
that may be released offsite, and that there is no significant increase 
in individual or cumulative occupational radiation exposure. The 
Commission has previously issued a proposed finding that TSTF-426, Rev. 
0, involves no significant hazards considerations, and there has been 
no public comment on the finding in Federal Register Notice [ 
and [DATE]]. Accordingly, the amendment meets the eligibility criteria 
for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 
10 CFR 51.22(b), no environmental impact statement or environmental 
assessment need be prepared in connection with the issuance of the 
amendment.

5.0 References

    1. WCAP-16125-NP, Revision 0, ``Justification for Risk-Informed 
Modifications to Selected Technical Specifications for Conditions 
Leading to Exigent Plant Shutdown,'' October 3, 2003.
    2. TSTF-426, Revision 0, ``Revise or Add Actions to Preclude Entry 
into LCO 3.0.3,'' August 2004.
    3. Federal Register, Vol. XX, No. XX, p. XXXXX, ``Notice of 
Availability of Model Application Concerning Technical Specification 
Improvement for Combustion Engineering Plants To Risk-Inform 
Requirements Regarding Conditions Leading to Exigent Plant Shutdown 
Using the Consolidated Line Item Improvement Process,'' [DATE].

Attachment 2--Proposed Technical Specification Changes (Mark-Up)

Attachment 3--Proposed Technical Specification Pages

    [Clean copies of Licensee specific Technical Specification (TS) 
pages, corresponding to the TS pages changed by TSTF-426, Rev. 0, are 
to be included in Attachment 3]

Attachment 4--List of Regulatory Commitments

    The following table identifies those actions committed to by 
[LICENSEE] in this document. Any other statements in this submittal are 
provided for information purposes and are not considered to be 
regulatory commitments. Please direct questions regarding these 
commitments to [CONTACT NAME].

------------------------------------------------------------------------
           Regulatory commitments                   Due date/event
------------------------------------------------------------------------
[LICENSEE] will follow the guidance          [Ongoing, or implement with
 established in Section 11 of NUMARC 93-01,   amendment].
 ``Industry Guidance for Monitoring the
 Effectiveness of Maintenance at Nuclear
 Power Plants,'' Nuclear Management and
 Resource Council, Revision 3, July 2000.
[LICENSEE] will follow the guidance          [Implement with amendment,
 established in WCAP-16446-NP, Revision       when TS Required Action
 [No.] ``Actions to Preclude Entry into LCO   End State remains within
 3.0.3, Implementation Guidance,'' [DATE].    the APPLICABILITY of TS].
------------------------------------------------------------------------

Attachment 5--Proposed Changes to Technical Specification Bases Pages

Proposed No Significant Hazards Consideration Determination

    Description of Amendment Request: On August 30, 2004, the Owners 
Group (OG) Technical Specifications Task Force (TSTF) submitted a 
proposed change, TSTF-426, Revision 0 (Rev. 0), to the Combustion 
Engineering (CE) standard technical specifications (STS) (NUREG-1432) 
on behalf of the industry. TSTF-426, Rev. 0, is a proposal to 
incorporate WCAP-16125-NP, Rev. 0, of September 2003, ``Justification 
for the Risk Informed Modifications to Selected Technical 
Specifications for Conditions Leading to Exigent Plant Shutdown,'' 
which was approved by an NRC safety evaluation (SE) dated July 9, 2004 
into the CE STS. This proposal is part of Nuclear Energy Institute 
(NEI) Risk Informed Technical Specifications Task Force (RITSTF) 
Initiative 6, one of the industry's initiatives being developed under 
the Risk Management Technical Specifications (RMTS) program.
    WCAP-16125-NP, Rev. 0 provides technical justification for the 
modification of various TS to define and/or modify Actions to extend 
the time required to initiate a plant shutdown from 1 hour in 
accordance with LCO 3.0.3 to a risk-informed time

[[Page 41280]]

varying from 4 hours to 72 hours. The intent of the proposed 
modifications to the plant TS is to enhance overall plant safety by:
    a. Avoiding unnecessary plant shutdowns.
    b. Minimizing plant transitions and associated transition and 
realignment risks.
    c. Providing for increased flexibility in scheduling and performing 
maintenance and surveillance activities.
    d. Providing explicit guidance where none currently exists.
    Basis for proposed no-significant-hazards-consideration 
determination: As required by 10 CFR 50.91(a), an analysis of the issue 
of no-significant-hazards-consideration is presented below:
Criterion 1--The Proposed Change Does Not Involve a Significant 
Increase in the Probability or Consequences of an Accident Previously 
Evaluated
    The proposed change provides a short Completion Time to restore an 
inoperable system for conditions under which the existing Technical 
Specifications require a plant shutdown to begin within one hour in 
accordance with Limiting Condition for Operation (LCO) 3.0.3. Entering 
into Technical Specification Actions is not an initiator of any 
accident previously evaluated. As a result, the probability of an 
accident previously evaluated is not significantly increased. The 
consequences of any accident previously evaluated that may occur during 
the proposed Completion Times are no different from the consequences of 
the same accident during the existing one hour allowance. As a result, 
the consequences of any accident previously evaluated are not 
significantly increased. Therefore, the proposed change does not 
involve a significant increase in the probability or consequences of an 
accident previously evaluated.
Criterion 2--The Proposed Change Does Not Create the Possibility of a 
New or Different Kind of Accident From Any Previously Evaluated
    No new or different accidents result from utilizing the proposed 
change. The changes do not involve a physical alteration of the plant 
(i.e., no new or different type of equipment will be installed) or a 
change in the methods governing normal plant operation. In addition, 
the changes do not impose any new or different requirements. The 
changes do not alter assumptions made in the safety analysis. 
Therefore, the proposed change does not create the possibility of a new 
or different kind of accident from any previously evaluated.
Criterion 3--The Proposed Change Does Not Involve a Significant 
Reduction in the Margin of Safety
    The proposed change increases the time the plant may operate 
without the ability to perform an assumed safety function. The analyses 
in WCAP-16125-NP, Rev. 0, ``Justification for Risk-Informed 
Modifications to Selected Technical Specifications for Conditions 
Leading to Exigent Plant Shutdown,'' Revision 0, September 2003, 
demonstrated that there is an acceptably small increase in risk due to 
a limited period of continued operation in these conditions and that 
this risk is balanced by avoiding the risks associated with a plant 
shutdown. As a result, the change to the margin of safety provided by 
requiring a plant shutdown within one hour is not significant. 
Therefore, the proposed change does not involve a significant reduction 
in a margin of safety.
    Based upon the reasoning presented above and the previous 
discussion of the amendment request, the requested change does not 
involve a significant hazards consideration.

Dated at Rockville, Maryland, this 13th day of July 2006.

    For the Nuclear Regulatory Commission.

Carl S. Schutlen,
Chief, Technical Specifications Branch, Division of Inspection & 
Regional Support, Office of Nuclear Reactor Regulation.
[FR Doc. 06-6364 Filed 7-19-06; 8:45 am]
BILLING CODE 7590-01-P