[Federal Register Volume 72, Number 172 (Thursday, September 6, 2007)]
[Notices]
[Pages 51259-51264]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E7-17601]
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NUCLEAR REGULATORY COMMISSION
Notice of Availability of Model Application Concerning Technical
Specification Improvement To Revise Moderator Temperature Coefficient
(MTC) Surveillance for Startup Test Activity Reduction (STAR) Program
(WCAP-16011)
AGENCY: Nuclear Regulatory Commission.
ACTION: Notice of Availability.
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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)
and model license amendment request (LAR) relating to the modification
of technical specification (TS) moderator temperature coefficient (MTC)
surveillance requirements (SR) associated with implementation of WCAP-
16011-P-A, ``Startup Test Activity Reduction (STAR) Program.'' The NRC
staff has also prepared a model no significant hazards consideration
(NSHC) determination relating to this matter. The purpose of these
models are to permit the NRC to efficiently process amendments that
propose to modify TS MTC surveillance requirements for implementing the
STAR Program. Licensees of nuclear power reactors to which the models
apply could then request amendments, confirming the applicability of
the SE and NSHC determination to their reactors.
DATES: The NRC staff issued a Federal Register notice (72 FR 41360,
July 27, 2007) which provided a model SE, model application, and model
NSHC related to modification of TS MTC surveillance requirements.
Similarly, the NRC staff herein provides a revised model SE, model LAR,
and model NSHC incorporating changes based upon the public comments
received. The NRC staff can most efficiently consider applications
based upon the model LAR, which references the model SE, if the LAR is
submitted within one year of this Federal Register Notice.
FOR FURTHER INFORMATION CONTACT: Timothy Kobetz, Mail Stop: O-12H2,
Technical Specifications Branch, Division of Inspection & Regional
Support, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001, telephone 301-415-1932.
SUPPLEMENTARY INFORMATION:
Background
Regulatory Issue Summary 2000-06, ``Consolidated Line Item
Improvement Process for Adopting Standard Technical Specification
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 following a preliminary assessment by the NRC staff
and finding that the change will likely be offered for adoption by
licensees. 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 to proceed with announcing the availability of the change for
proposed adoption by licensees. Those licensees opting to apply for the
subject change to technical specifications 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 rules and NRC procedures.
This notice involves the modification of TS MTC surveillance
requirements for implementing the STAR Program. This change was
proposed for incorporation into the standard technical specifications
by the owners groups participants in the Technical Specification Task
Force (TSTF) and is designated TSTF-486, Revision 2. TSTF-486, Revision
2, 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 MTC surveillance requirements for
implementing the STAR Program, as proposed in TSTF-486, Revision 2, is
applicable to Combustion Engineering (CE) design plants.
To efficiently process the incoming license amendment applications,
the staff requests that each licensee applying for the changes proposed
in TSTF-486, Revision 2, include TS Bases for the proposed TS
consistent with the TS Bases proposed in TSTF-486, Revision 2. The
staff is requesting that the TS Bases be included with the proposed
license amendments in this case because the changes to the TS and the
changes to the associated TS Bases form an integral change to a plant's
licensing basis. To ensure that the overall change, including the TS
Bases, includes appropriate regulatory controls, the staff plans to
condition the issuance of each license amendment on the licensee's
incorporation of the changes into the TS Bases document and that the
licensee control changes to the TS Bases in accordance with the
licensees TS Bases Control Program. The CLIIP does not prevent
licensees from requesting an alternative approach or proposing the
changes without the requested TS 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 inclusion of
additional changes to the license, will result in staff rejection of
[[Page 51260]]
the submittal. Instead, licensees desiring significant variations and/
or additional changes should submit a LAR that does not request to
adopt TSTF-486, Revision 2, under CLIIP.
Public Notices
The staff issued a Federal Register Notice (72 FR 41360, July 27,
2007) that requested public comment on the NRC's pending action to
approve modification of TS MTC surveillance requirements for
implementing the STAR Program, as proposed in TSTF-486, Revision 2. The
TSTF-486, Revision 2, can be viewed on the NRC's Web page at http://www.nrc.gov/reactors/operating/licensing/techspecs.html. TSTF-486,
Revision 2, may be examined, and/or copied for a fee, at the NRC's
Public Document Room, located at One White Flint North, 11555 Rockville
Pike (first floor), Rockville, Maryland. Publicly available records are
accessible electronically from the ADAMS Public Library component on
the NRC Web site, (the Electronic Reading Room) at http://www.nrc.gov/reading-rm/adams.html.
In response to the notice soliciting comments from interested
members of the public about modifying TS MTC surveillance requirements,
the staff received one set of comments (from the TSTF Owners Groups,
representing licensees). The specific comments are provided and
discussed below:
1. Comment: The Summary states that the NRC staff has prepared a
model SE, model LAR, and a model NSHC. However, the last sentence of
the section requests comments only on the model SE and model NSHC.
Comments should also be requested on the model license amendment
request as well.
Response: The staff agrees with the comment, and has accepted and
addressed comments to the model license amendment below.
2. Comment: Model SE, section 2.1, Proposed Change, eighth bullet.
This bullet describes changes to digital SR 3.1.3.2 (in STS NUREG-
1432), not analog SR 3.1.3.2 as stated.
Response: The staff agrees with the comment, and the model SE,
section 2.1, Proposed Change, is corrected in the notice of
availability.
3. Comment: Model SE, section 7.0, References, Reference 4. Change
``Tevision'' to ``Revision.''
Response: The staff agrees with the comment, and the model SE,
section 7.0 References, Reference 4 is corrected in the notice of
availability.
4. Comment: Model Application, the third paragraph omits Attachment
5, which is shown in the list of Attachments below the signature.
Response: The staff agrees with the comment, and Attachment 5 is
now added in the third paragraph of the model application.
5. Comment: Model Application. The model Application states, ``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 is true and correct.'' This statement is not
consistent with the recommended statement given in RIS 2001-18,
``Requirements for Oath or Affirmation.'' RIS 2001-18 recommends the
statement, ``I declare [or certify, verify, state] under penalty of
perjury that the foregoing is true and correct.'' Note that RIS 2001-18
states that this statement must be used verbatim. We recommend that the
model Application be revised to be consistent with RIS 2001-18.
Response: The staff agrees with the comment, and the model
Application is revised to be consistent with RIS 2001-18.
6. Comment: Model Application Attachment 4, the regulatory
commitment states ``[LICENSEE] will establish the Technical
Specification Bases for TS [3.1.3] as adopted with the applicable
license amendment.'' This statement is incorrect as the Bases changes
included for information with the license amendment request are not
``adopted'' with the license amendment. Bases changes are made under
licensee control under the Technical Specification Bases Control
Program as stated in the model Safety Evaluation. We recommend revising
the commitment to state ``[LICENSEE] will implement Technical
Specification Bases for TS [3.1.3] consistent with those shown in the
license amendment.''
Response: The staff agrees with the comment that the commitments
paragraph needs to be reworded. The paragraph now reads, ``[LICENSEE]
will establish Technical Specification Bases for TS [3.1.3] consistent
with those shown in the license amendment.''
7. Comment: Model NSHC, to be consistent with 10 CFR 50.91(a), the
title of Criterion 2 should be revised to add the word ``Accident''
before ``Previously Evaluated.'' Specifically, it should state, ``The
Proposed Change Does Not Create the Possibility of a New or Different
Kind of Accident from any Accident Previously Evaluated.''
Response: The staff agrees with the comment, and the model NSHC is
corrected in the notice of availability.
Dated at Rockville, Maryland, this 29th day of August, 2007.
For the Nuclear Regulatory Commission.
Timothy J. Kobetz,
Chief, Technical Specifications Branch, Division of Inspection and
Regional Support, Office of Nuclear Reactor Regulation.
Model Safety Evaluation, U.S. Nuclear Regulatory Commission, Office of
Nuclear Reactor Regulation, Consolidated Line Item Improvement,
Technical Specification Task Force (TSTF) Change TSTF-486, Revision 2,
Modification of Technical Specification Moderator Temperature
Coefficient Surveillance Requirements Associated With Implementation of
the Startup Test Activity Reduction (STAR) Program
1.0 Introduction
By letter dated June 3, 2005, (Reference 1) the Technical
Specifications Task Force (TSTF), a joint owners group activity,
submitted TSTF-486, ``Revise MTC Surveillance for Startup Test Activity
Reduction (STAR) Program (WCAP-16011),'' Revision 0, for NRC review. By
letter dated February 20, 2007, (Reference 2) the TSTF submitted TSTF-
486, Revision 1, for NRC review. By letter dated March 10, 2007,
(Reference 3) the TSTF submitted TSTF-486, Revision 2, for NRC review.
TSTF-486 is proposing to change NUREG 1432, ``Standard Technical
Specifications Combustion Engineering Plants,'' (CE STS) Revision 3.1
(Reference 4), to generically implement moderator temperature
coefficient (MTC) surveillance requirement changes associated with
implementation of WCAP-16011-P-A, ``Startup Test Activity Reduction
(STAR) Program,'' (Reference 5).
WCAP-16011-P-A describes methods to reduce the time required for
startup testing. To this end, WCAP-16011-P-A proposes methods to
eliminate the control element assembly (CEA) worth and isothermal
temperature coefficient (ITC) measurements at hot zero power (HZP). The
measured ITC is used to calculate the HZP MTC. WCAP-16011-P-A includes
a method to substitute the measured verification of MTC at HZP with an
alternate MTC verification consisting of the predicted (calculated) MTC
and measured critical boron concentration (CBC) at HZP. When this
alternate MTC verification is utilized, WCAP-16011-P-A adds the
requirement for the early in cycle MTC measurement to verify MTC is not
more negative than allowed is also used to verify MTC is not more
positive than allowed. WCAP-16011-P-A adds an ITC measurement at
intermediate to hot full power (HFP) and applicability requirements for
core design,
[[Page 51261]]
fabrication, refueling, startup testing, and CEA lifetime viability
requirements. WCAP-16011-P-A methods can only be applied to cores that
are well characterized by an existing database. WCAP-16011-P-A is only
applicable to the particular plants that participated in its
development, as indicated in the document.
TSTF-486 will provide standardized wording in the CE STS for plants
implementing the WCAP-16011-P-A alternate MTC verification at startup.
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, 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 regulations do not
specify the particular requirements to be included in a plant's TS and
do not explicitly prescribe specific post-refueling startup testing.
However, the genesis for post-refueling startup testing can be traced
to the pre-operational testing required to be specified in the Final
Safety Analysis Report by 10 CFR 50.34. Additionally, 10 CFR 50.36
specifies SRs relating to test, calibration, or inspection to assure
that the necessary quality of systems and components is maintained,
that facility operation will be within safety limits, and that the
limiting conditions for operation will be met. Additionally, 10 CFR
Part 50, Appendix A, ``General Design Criteria'' (GDC) apply, in that
the GDC establish the necessary design, fabrication, construction,
testing, and performance requirements for structures, systems, and
components important to safety. Additionally, 10 CFR Part 50, Appendix
B, ``Quality Assurance Criteria for Nuclear Power Plants and Fuel
Reprocessing Plants'' apply, in that Criterion III ``Design Control''
requires that `` * * * measures shall provide for verifying or checking
the adequacy of design, such as by the performance of design reviews,
by the use of alternate or simplified calculational methods, or by the
performance of a suitable testing program.'' Specifically, MTC is a
parameter controlled in the licensee's TS, including surveillance
requirements. As a value in the TS, MTC and the applicable SRs are
subject to regulatory oversight.
2.1 Proposed Change
TSTF-486 would make the following changes to the CE STS contained
in NUREG-1432.
[squ] The proposed change revises the MTC (Analog) Surveillance
Requirement (SR) 3.1.3.1, Surveillance, to indicate the MTC upper limit
is specified in the Core Operating Limits Report (COLR).
[squ] The proposed change revises the MTC (Analog) SR 3.1.3.1,
Frequency, to add a requirement to verify MTC is within the upper limit
within seven (7) effective full power days (EFPD) of reaching 40 EFPD
of core burnup. This verification would only be required if the MTC
determined prior to entering Mode 1 is determined using an adjusted,
predicted MTC.
[squ] The proposed change revises MTC (Analog) surveillance
requirement (SR) 3.1.3.2, Note, to indicate the MTC lower limit is
specified in the COLR.
[squ] The proposed change revises MTC (Analog) SR 3.1.3.2,
Frequency, to replace the phrase `effective full power days' with the
acronym `EFPD.'
[squ] The proposed change revises MTC (Digital) SR 3.1.3.1,
Surveillance, to indicate the MTC upper limit is specified in the Core
Operating Limits Report (COLR).
[squ] The proposed change revises MTC (Digital) SR 3.1.3.1,
Frequency, to add a requirement to verify MTC is within the upper limit
within seven (7) EFPD of reaching 40 EFPD of core burnup. This
verification would only be required if the MTC determined prior to
entering Mode 1 is determined using an adjusted predicted MTC.
[squ] The proposed change revises MTC (Digital) SR 3.1.3.2,
Surveillance, and accompanying Note to indicate the MTC lower limit is
specified in the COLR.
[squ] The proposed change revises MTC (Digital) SR 3.1.3.2,
Frequency, to replace the phrase `effective full power days' with the
acronym `EFPD.' TSTF-486 includes changes to the CE STS Bases B 3.1.3
contained in NUREG-1432.
[squ] Deletes the last sentence of the second paragraph of the
Background section. (Analog) (Digital)
[squ] Modifies the first sentence of the first paragraph in the LCO
section to state that the COLR contains both positive and negative MTC
limits. Modifies the third sentence of the first paragraph in the LCO
section to state the purpose of the positive MTC limit in the COLR.
(Analog) (Digital).
[squ] Inserts a new paragraph in the LCO section, between the
existing first and second paragraphs, into the LCO section to explain
the positive MTC limits contained in CE STS LCO 3.1.3. (Analog)
(Digital).
[squ] Modifies the current second paragraph in the LCO section to
include a discussion of how MTC may be controlled using CEA position
and boron concentration. (Analog) (Digital).
[squ] Modifies the Surveillance Requirements section by adding a
Reviewer Note describing the use of the Alternate MTC verification
method contained in WCAP-16011-P-A. (Analog) (Digital).
[squ] Modifies the first paragraph of the Surveillance Requirements
section, breaking it into three paragraphs. The new first paragraph
consists of the first and second sentences and precedes the Reviewer's
Note; the text is otherwise unchanged. The new second paragraph is the
third sentence of the current first paragraph; the text is otherwise
unchanged. The new third paragraph is the remainder of the current
first paragraph, it is modified to state the MTC verification must
occur within seven (7) effective full power days of reaching 40
effective full power days and that the MTC limits are in the COLR.
(Analog) (Digital).
[squ] The existing second paragraph of the Surveillance
Requirements section becomes the fourth paragraph and is modified to
state the end of cycle MTC limit is specified in the COLR. (Analog)
(Digital).
[squ] The References section is modified to add, in brackets, WCAP-
16011-P-A. (Analog) (Digital).
3.0 Technical Evaluation
As stated previously, WCAP-16011-P-A describes methods to reduce
the time required for startup testing. The NRC approved WCAP-16011-P-A
on January 14, 2005, for referencing in license applications to the
extent specified and under the limitations stated in the topical report
and NRC evaluation.
CE STS SR 3.1.3.1 (Analog) and SR 3.1.3.1 (Digital) are being
revised to add a frequency that is required by WCAP-16011-P-A when the
alternate MTC verification method is used to verify MTC is within the
upper limit during startup testing. That frequency coincides with the
SR 3.1.3.2 verification that MTC is within the lower limit at 40 EFPD.
This frequency is consistent with WCAP-16011-P-A and therefore
acceptable.
CE STS SR 3.1.3.1 (Analog), and SR 3.1.3.1 (Digital) are also being
revised to state the upper MTC limit is in the COLR. Currently, the
location of the upper limit is not specified in either Analog or
Digital CE STS SR. CE STS 3.1.3 (Analog) LCO states, ``The MTC
[[Page 51262]]
shall be maintained within the limits specified in the COLR. The
maximum positive limit shall be that specified in Figure 3.1.3-1.''
Figure 3.1.3-1 is contained in the CE STS. CE STS 3.1.3 (Digital) LCO
states, ``The MTC shall be maintained within the limits specified in
the COLR, and a maximum positive limit as specified below:'' Two
equations then follow for determining the maximum positive limit. The
use of the plural in the LCO statements indicate the STS expect there
to be upper and lower limits in the COLR, of which the upper limit
would be bounded by the value in the TS. Therefore, specifying in the
SR that the upper limit be within the COLR limit is consistent with the
CE STS. The specific wording is also consistent with current phrasing
in the CE STS. Therefore, this change is acceptable.
CE STS SR 3.1.3.2 (Digital) is also being revised to state the
lower MTC limit is in the COLR. Currently, the location of the lower
limit is specified in the Note. This change makes the CE STS SR 3.1.3.2
(Digital) consistent with the analog equivalent. The specific wording
is also consistent with current phrasing in the CE STS. Therefore, this
change is acceptable.
The first sentence of the Note in CE STS SR 3.1.3.2 (Analog) and SR
3.1.3.2 (Digital) is being revised from, ``If the MTC is more negative
than the COLR limit * * *'' to ``If the MTC is more negative than the
limit specified in the COLR * * *'' SR 3.1.3.2 (Digital) is being
revised from ``Verify MTC is within the lower limit.'' to ``Verify MTC
is within the lower limit specified in the COLR.'' In all instances the
MTC lower limit is specified in the COLR. The revised wording is
consistent with other CE STS references to the COLR. Therefore, this
change is acceptable.
The revision to the CE STS Bases for B 3.1.3 (Analog) and B 3.1.3
(Digital) Background section is removing an incorrect statement in the
CE STS that was identified during the staff's review associated with
Reference 1. The TSTF has agreed to remove the sentence as part of
TSTF-486 Revision 2. Therefore, this change is acceptable.
The modification of the first paragraph in the CE STS Bases for B
3.1.3 (Analog) and B 3.1.3 (Digital) LCO section is intended to
identify the location of the upper and lower MTC limits. This change is
consistent with the proposed changes to CE STS described above and
therefore acceptable.
The addition of a new second paragraph in the CE STS Bases for B
3.1.3 (Analog) and B 3.1.3 (Digital) LCO section is intended to
describe the purpose of the limits and reinforce that the upper MTC
limit in the COLR must be bounded by that in the TS. This change is
consistent with the proposed changes to CE STS described above and
therefore acceptable.
The modification to the current second paragraph in the LCO section
adds a discussion of how MTC may be controlled using CEA position and
boron concentration. While staff acknowledges that the combination of
CEA position and boron concentration can be used to control MTC, the
staff believes it is an incomplete discussion that ignores the effects
of temperature, pressure, and power level. However, there is no
intention that the STS Basis become a tutorial. Therefore, while the
discussion is incomplete it is not detrimental to safety and the change
is acceptable.
The Reviewer's Note added to the Surveillance Requirements section
describes the restrictions on the use of the Alternate MTC
surveillance. The Reviewer's Note is consistent with WCAP-16011-P-A and
therefore acceptable.
The current first paragraph of the Surveillance Requirements
section is being modified by breaking it into three paragraphs.
[squ] The new first paragraph consists of the first and second
sentences and precedes the Reviewer Note, the text is otherwise
unchanged. This is an editorial change and acceptable.
[squ] The new second paragraph is the third sentence of the current
first paragraph, the text is otherwise unchanged. Making the sentence a
separate paragraph is an editorial change and acceptable.
[squ] The new third paragraph is the remainder of the current first
paragraph; it is modified to state the MTC verification must occur
within seven (7) effective full power days of reaching 40 effective
full power days and that the MTC limits are in the COLR. These changes
are editorial and acceptable.
Moving the existing second paragraph of the Surveillance
Requirements section to become the fourth paragraph and modifying it to
state the end of cycle MTC limit is specified in the COLR are editorial
changes. These changes are acceptable.
Adding WCAP-16011-P-A, in brackets, to the References section is
appropriate. The brackets indicate WCAP-16011-P-A is an optional
reference. It would only be included on plants that have implemented
the Alternate MTC surveillance. This change is acceptable.
3.1 Summary
TSTF-486 would provide standardized wording in the CE STS for
plants implementing the WCAP-16011-P-A alternate MTC verification at
startup. The changes to NUREG-1432 proposed by TSTF-486 have been
reviewed for consistency with the current NUREG-1432 and WCAP-16011-P-
A. The proposed changes have been found to be consistent with NUREG-
1432 and WCAP-16011-P-A, therefore the proposed changes are acceptable.
4.0 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].
5.0 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. [For licensees adding a TS Bases Control Program: The
amendment also changes record keeping, reporting, or administrative
procedures or 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 ]. Accordingly, the amendments meet the
eligibility criteria for categorical exclusion set forth in 10 CFR
51.22(c)(9) [and (c)(10)]. 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.
6.0 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
[[Page 51263]]
common defense and security or to the health and safety of the public.
7.0 References
1. Letter from the Technical Specifications Task Force (TSTF), a
joint owners group activity, re: ``TSTF-486, ``Revise MTC Surveillance
for Startup Test Activity Reduction (STAR) Program (WCAP-16011),''
``dated June 3, 2005. (ADAMS ML051580191).
2. Letter from the Technical Specifications Task Force (TSTF), a
joint owners group activity, re: ``Response to NRC Request for
Additional Information Regarding TSTF-486, Revision 0, ``Revise MTC
Surveillance for Startup Test Activity Reduction (STAR) Program (WCAP-
16011),'' and Submittal of Revision 1,'' dated February 20, 2007.
(ADAMS ML070510667)
3. Letter from the Technical Specifications Task Force (TSTF), a
joint owners group activity, re: ``TSTF-486, Revision 2, ``Revise MTC
Surveillance for Startup Test Activity Reduction (STAR) Program (WCAP-
16011),'' dated March 10, 2007. (ADAMS ML071300267).
4. NUREG 1432, ``Standard Technical Specifications Combustion
Engineering Plants,'' Revision 3.1. (ADAMS ML062510040 and
ML062510042).
5. WCAP-16011-P-A, ``Startup Test Activity Reduction Program,''
dated February 2005. (ADAMS ML050660127).
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 revise technical specifications regarding
moderator temperature coefficient surveillance for Startup Test
Activity Reduction (STAR) program 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 Regulatory Commission,
Document Control Desk,
Washington, DC 20555.
SUBJECT: PLANT NAME
DOCKET NO. 50-APPLICATION FOR TECHNICAL SPECIFICATION CHANGE
REGARDING MODERATOR TEMPERATURE COEFFICIENT (MTC) SURVEILLANCE FOR
STARTUP TEST ACTIVITY REDUCTION (STAR) PROGRAM 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 requirements for
moderator temperature coefficient (MTC) surveillance requirements
(SR) associated with implementation of WCAP-16011-P-A, ``Startup
Test Activity Reduction (STAR) Program.''
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
proposed changes to Technical Specification Bases pages.
[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 [or clarify, verify, state] under penalty of perjury
that the foregoing is 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 TS requirements for
moderator temperature coefficient (MTC) surveillance requirements
(SR) associated with implementation of WCAP-16011-P-A, ``Startup
Test Activity Reduction (STAR) Program.''
The changes are consistent with Nuclear Regulatory Commission
(NRC) approved Industry/Technical Specification Task Force (TSTF)
STS change TSTF-486 Revision 2. The Federal Register notice
published on [DATE] announced the availability of this TS
improvement through the consolidated line item improvement process
(CLIIP).
2.0 Assessment
2.1 Applicability of Published Safety Evaluation
[LICENSEE] has reviewed the safety evaluation dated [DATE] as
part of the CLIIP. This review included a review of the NRC staff's
evaluation, as well as the supporting information provided to
support TSTF-486 Revision 2. [LICENSEE] has concluded that the
justifications presented in the TSTF proposal and 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.
2.2 Optional Changes and Variations
[LICENSEE] is not proposing any variations or deviations from
the TS changes described in the modified TSTF-486 Revision 2 and the
NRC staff's model safety evaluation dated [DATE].
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, the [LICENSEE]
verifies the applicability of TSTF-486 to [PLANT], and commits to
establishing Technical Specification Bases for TS [3.1.3] as
proposed in TSTF-486, Revision 2.
The proposed TSTF-486 change revises SR 3.1.3.1 in the digital
and analog Combustion Engineering STS (NUREG-1432) by adding a
second Frequency. This second Frequency requires verifying that MTC
is within the upper limit each fuel cycle within 7 EFPD after
reaching 40 EFPD of core burnup, but only when the MTC determined
prior to entering MODE 1 is verified using predicted MTC as adjusted
for actual RCS boron concentration. The Frequency is consistent with
the existing MODE 1 MTC Surveillance Frequency. The Bases are
revised to describe the new requirements and to clarify the
analytical basis of the MTC utilizing the suggested changes in WCAP-
16011-P. The Bases modifications clarify the relationship between
the MTC limits specified in the Core Operating Limits Report (COLR)
and the maximum positive MTC value specified in the LCO.
4.0 Environmental Evaluation
[LICENSEE] has reviewed the environmental evaluation included in
the model safety evaluation dated [DATE] as part of the CLIIP.
[LICENSEE] has concluded that the staff's findings presented in that
evaluation are applicable to [PLANT] and the evaluation is hereby
incorporated by reference for this application.
Attachment 2--Proposed Technical Specification Changes (Mark-Up)
Attachment 3--Proposed Technical Specification Pages
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
[[Page 51264]]
regulatory commitments. Please direct questions regarding these
commitments to [CONTACT NAME].
------------------------------------------------------------------------
Regulatory commitments Due date/event
------------------------------------------------------------------------
[LICENSEE] will establish Technical [Complete, implemented with
Specification Bases for TS [3.1.3] amendment OR within X days
consistent with those shown in the of implementation of
license amendment. amendment].
------------------------------------------------------------------------
Attachment 5--Proposed Changes to Technical Specification Bases Pages
Proposed No Significant Hazards Consideration Determination
Description of Amendment Request: [Plant Name] requests adoption
of an approved change to the standard technical specifications (STS)
for Combustion Engineering (CE) Plants (NUREG-1432) and plant
specific technical specifications (TS), to allow modification of TS
moderator temperature coefficient (MTC) surveillance requirements
(SR) associated with implementation of WCAP-16011-P-A, ``Startup
Test Activity Reduction (STAR) Program,'' dated February 2005.'' The
changes are consistent with NRC approved Industry/Technical
Specification Task Force (TSTF) STS Traveler, TSTF-486, Revision 2,
``Revise MTC Surveillance for Startup Test Activity Reduction (STAR)
Program (WCAP-16011).'' WCAP-16011-P-A describes methods to reduce
the time required for startup testing. To this end, WCAP-16011-P-A
proposes methods to eliminate the control element assembly (CEA)
worth and isothermal temperature coefficient (ITC) measurements at
hot zero power (HZP). The measured ITC is then used to calculate the
HZP MTC. WCAP-16011-P-A includes a method to substitute the measured
verification of MTC at HZP with an alternate MTC verification
consisting of the predicted (calculated) MTC and measured critical
boron concentration (CBC) at HZP. When this alternate MTC
verification is utilized, WCAP-16011-P-A adds the requirement for
the early in cycle MTC measurement to verify MTC is not more
negative than allowed is also used to verify MTC is not more
positive than allowed. WCAP-16011-P-A adds an ITC measurement at
intermediate to hot full power (HFP) and applicability requirements
for core design, fabrication, refueling, startup testing, and CEA
lifetime viability requirements. WCAP-16011-P-A methods can only be
applied to cores that are well characterized by an existing
database.
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 generically implements MTC SR changes
associated with implementation of WCAP-16011-P-A, STAR Program.
WCAP-16011-P-A describes methods to reduce the time required for
startup testing. The consequences of an accident after adopting
TSTF-486 are no different than the consequences of an accident prior
to adoption. Therefore, this 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 Accident Previously
Evaluated
The proposed change does not involve a physical alteration of
the plant (no new or different type of equipment will be installed)
or a change in the methods governing normal plant operation. The
proposed change will not introduce new failure modes or effects and
will not, in the absence of other unrelated failures, lead to an
accident whose consequences exceed the consequences of accidents
previously analyzed. Thus, this change does not create the
possibility of a new or different kind of accident from any accident
previously evaluated.
Criterion 3--The Proposed Change Does Not Involve a Significant
Reduction in the Margin of Safety
TSTF-486 provides the means and standardized wording for CE STS
plants implementing the previously approved WCAP-16011-P-A alternate
MTC verification at startup. MTC is a parameter controlled in the
licensee's TS, including surveillance requirements. As stated
previously WCAP-16011-P-A describes methods to reduce the time
required for startup testing. The changes to NUREG-1432 proposed by
TSTF-486 have been reviewed for and found to be consistent with the
current NUREG-1432 and WCAP-16011-P-A, and therefore the proposed
changes are acceptable and do 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 29th day of August, 2007.
For the Nuclear Regulatory Commission.
Timothy J. Kobetz,
Section Chief, Technical Specifications Branch, Division of Inspection
& Regional Support, Office of Nuclear Reactor Regulation.
[FR Doc. E7-17601 Filed 9-5-07; 8:45 am]
BILLING CODE 7590-01-P