[Federal Register Volume 73, Number 23 (Monday, February 4, 2008)]
[Notices]
[Pages 6529-6537]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E8-1943]
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NUCLEAR REGULATORY COMMISSION
Notice of Opportunity To Comment on Model Safety Evaluation on
Technical Specification Improvement To Revise Containment Isolation
Valve Completion Times (TSTF-498, Revision 1) 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 the modification of technical specification (TS) 3.6.3,
Containment Isolation Valves associated with implementation of BAW-
2461-A, ``Risk-Informed Justification for Containment Isolation Valve
Allowed Outage Time Change.'' The NRC staff has also prepared a model
license amendment request and 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 Containment Isolation Valve Completion Times.
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. 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 March 5, 2008. 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, Rulemaking, Directives, and
Editing 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: 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 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 modifies TS Containment Isolation Valve Completion Times. 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
[[Page 6530]]
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 Containment Isolation
Valve Completion Times. 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-498. TSTF-498 can be viewed on the NRC's Web page at: http://www.nrc.gov/reactors/operating/licensing/techspecs.html.
Applicability
To efficiently process the incoming license amendment applications,
the staff requests that each licensee applying for the changes proposed
in TSTF-498 include TS Bases for the proposed TS consistent with the TS
Bases proposed in TSTF-498. 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 (which becomes part of the plant
licensing basis), 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 licensee's 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. Additionally, the staff is requesting that the methodology for
assessing large early release frequency (LERF) and incremental
conditional large early release probability (ICLERP) are to be
documented in the plant-specific application as a regulatory commitment
(i.e., included in the licensee's commitment tracking system in
accordance with NEI 99-04, Revision 0, ``Guidelines for Managing NRC
Commitment Changes'') (Reference 5) in the licensees' plant-specific
applications referencing TR BAW-2461-A. The staff is requesting this
regulatory commitment because a licensee's implementation of Regulatory
Guide (RG) 1.177 Tier 3 guidelines generally implies the assessment of
risk with respect to core damage frequency (CDF). However, the proposed
containment isolation valve (CIV) completion time (CT) impacts
containment isolation and consequently LERF and ICLERP, as well as CDF.
Because the extended CIV CTs are also based on the LERF and ICLERP
metrics, the management of risk in accordance with 10 CFR 50.65(a)(4)
for these extended CIV CTs must also assess LERF and ICLERP.
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 no significant hazards
consideration 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 no
significant hazards consideration determination, and a notice of
opportunity for a hearing. The staff will also publish a notice of
issuance of an amendment to the operating license to announce the
modification of Containment Isolation Valve (CIV) Completion Times for
each plant that receives the requested change.
Proposed Safety Evaluation; U.S. Nuclear Regulatory Commission; Office
of Nuclear Reactor Regulation; Consolidated Line Item Improvement;
Technical Specification Task Force (TSTF) Change TSTF-498; Modification
of Technical Specification Containment Isolation Valve; Completion
Times
1.0 Introduction
By letter dated December 20, 2006, (Reference 1) the Technical
Specifications Task Force (TSTF), a joint owners group activity,
submitted TSTF-498, ``Risk-Informed Containment Isolation Valve
Completion Times (BAW-2461),'' Revision 0, for NRC review. By letter
dated October 10, 2007, (Reference 2) the TSTF submitted Revision 1 to
TSTF-498 based on responses to Requests for Additional Information
(RAI) that resulted in not adopting certain provisions provided by BAW-
2461-A, ``Risk-Informed Justification for Containment Isolation Valve
Allowed Outage Time Change,'' (Reference 3). TSTF-498 is proposing to
change NUREG 1430, ``Standard Technical Specifications Babcock and
Wilcox Plants,'' (BAW STS) Revision 3.0 (Reference 4), to generically
implement containment isolation valve completion time (CT) changes
associated with implementation of BAW-2461-A.
BAW-2461-A and TSTF-498 support extending CTs for CIVs in a
penetration flow path with two [or more] containment isolation valves
from 4 hours to 168 hours. The proposed change revises the TS for B&W
Plants, NUREG-1430, Revision 3, Limiting Condition for Operation (LCO),
Section 3.6.3, ``Containment Isolation Valves,'' Condition A from 4
hours to 7 days. Additionally, a new Required Action is added (Required
Action A.1) which requires verification that the Operable containment
isolation valve in the penetration is not inoperable due to common
cause failure and also results in Required Actions A.1 and A.2 being
relabeled as A.2 and A.3. No change is proposed by the Pressurized
Water Reactor Owners Group (PWROG) for Condition B (relabeled Condition
D)(i.e., a penetration flow path with two inoperable CIVs). A new
Condition, Condition B, is added which is similar to the existing
Condition A. It contains a 4 hour Completion Time to isolate the
affected flow path and is only applicable to the containment isolation
valves excluded from Condition A (e.g., containment isolation valves in
the main steam lines or (as described in a Reviewer's Note) those
identified by plant-specific analysis as having high risk significance
for interfacing systems loss of coolant accidents (ISLOCAs). A new
Condition, Condition C, is added which is applicable when two or more
penetrations have one inoperable containment isolation valve. This
Condition requires isolating all but one of the affected penetrations
within 4 hours (the existing Completion Time for Condition A). This
condition limits the 7 day Completion Time in Condition A to a single
penetration. The extended Completion Time is not applicable to
containment isolation valves in the main steam lines or those
identified by plant-specific analysis as having high risk significance
for ISLOCAs and the existing 4 hour Completion Time applies. BAW-2461-A
is only applicable to Davis Besse, Oconee Nuclear Station Units 1, 2,
and 3, and
[[Page 6531]]
Crystal River Unit 3. Other licensees of B&W designed PWRs requesting
to use the Topical Report (TR) methodology must provide the same level
of information provided by these demonstration plants to ensure that TR
BAW-2461-A is applicable to their plant. TSTF-498 will provide
standardized wording in the B&W STS for plants implementing the changes
specified in BAW-2461-A related to extending AOTs for applicable
inoperable CIVs from 4 hours to 168 hours.
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. However, the regulation does
not specify the particular TSs to be included in a plant's license.
TSTF-498 is proposing changes to the TSs that involve category 2 above.
The LCOs are the lowest functional capability, or performance levels,
of equipment required for safe operation of the facility. When an LCO
of a nuclear reactor is not met, the licensee shall shut down the
reactor, or follow any remedial actions permitted by the TS until the
condition can be met.
Furthermore, the CTs specified in the TSs must be based on
reasonable protection of the public health and safety. Therefore, the
NRC staff must be able to conclude that there is reasonable assurance
that the safety functions affected by the proposed TS CT changes will
be performed in accordance with the design basis accidents (DBAs)
identified in Chapter 15 of the licensee's final safety analysis report
(FSAR). As set forth in 10 CFR 50.36, a licensee's TS must establish
the LCOs that contain certain information. This requirement includes
CTs for structures, systems, and components (SSCs) that are required
for safe operation of the facility, such as CIVs.
The Maintenance Rule, 10 CFR 50.65, ``Requirements for monitoring
the effectiveness of maintenance at nuclear power plants,'' requires
licensees to monitor the performance, or condition, of SSCs against
licensee-established goals in a manner sufficient to provide reasonable
assurance that SSCs are capable of fulfilling their intended functions.
The implementation and monitoring program guidance of Regulatory Guide
(RG) 1.174, section 2.3, and RG 1.177, section 3, states that
monitoring performed in conformance with the Maintenance Rule can be
used when such monitoring is sufficient for the SSCs affected by the
risk-informed application.
In addition, 10 CFR 50.65(a)(4), as it relates to the proposed CIV
CT extension, requires the assessment and management of the increase in
risk that may result from the proposed maintenance activity.
Appendix A of 10 CFR part 50, GDC-54, ``Piping systems penetrating
containment,'' requires those piping systems that penetrate primary
containment be provided with leak detection, isolation, and containment
capabilities having redundancy, reliability, and performance
capabilities that reflect the importance to safety of isolating these
piping systems.
Appendix A of 10 CFR part 50, GDC-55, ``Reactor coolant pressure
boundary penetrating containment,'' requires that each line that is
part of the reactor coolant pressure boundary and that penetrates the
primary containment shall be provided with CIVs.
Appendix A of 10 CFR part 50, GDC-56, ``Primary containment
isolation,'' requires that each line that connects directly to the
containment atmosphere and penetrates the primary reactor containment
shall be provided with CIVs.
The CIVs help ensure that adequate primary containment boundaries
are maintained during and after accidents by minimizing potential
pathways to the environment and help ensure that the primary
containment function assumed in the safety analysis is maintained.
2.1 Proposed Change
TSTF-498 would make the following changes to the B&W STS contained
in NUREG-1430 associated with TS 3.6.3 Containment Isolation Valves
(CIVs):
The proposed change adds a Reviewer's Note prior to
Condition A which states ``The Condition A Note should list the
specific penetrations (if any) identified by the plant specific risk
analysis as having high risk significance for an interfacing systems
loss of coolant accident (ISLOCA).''
The proposed change revises the Condition A NOTE to add
``except containment isolation valves in the main steam lines and [
].''
The proposed change adds the new Required Action A.1,
``Determine the OPERABLE containment isolation valve in the affected
penetration is not inoperable due to common cause failure'' with a
Completion Time of 4 hours. This new Required Action is connected by an
AND statement to the other applicable Required Actions.
The proposed change revises the previous Required Action
A.1 to be A.2 with the completion time changed from 4 hours to 7 days.
The proposed change revises the previous Required Action
A.2 to be A.3.
The proposed change adds a new Condition B for one or more
penetration flow paths with one containment isolation valve inoperable
[for reasons other than purge valve leakage not within limit] with a
Note stating ``Only applicable to penetration flow paths with two [or
more] containment isolation valves in the main steam lines and [ ].''
There is also a Reviewers Note similar to Condition A.
The proposed change provides new Required Action B.1 to
isolate the affected penetration flow path with a completion time of 4
hours and Required Action B.2 to verify the affected penetration flow
path is isolated once per 31 days for isolation devices outside
containment and Prior to entering Mode 4 from Mode 5 if not performed
within the previous 92 days for isolation devices inside containment.
Furthermore, new Required Action B.2 has two notes which state: (1)
Isolation devices in high radiation areas may be verified by use of
administrative means and (2) Isolation devices that are locked, sealed,
or otherwise secured may be verified by use of administrative means.
The proposed change adds a new Condition C for two or more
penetration flow paths with one containment isolation valve inoperable
[for reasons other than Condition[s] [E and F]] with a Note stating
``Only applicable to penetration flow paths with two [or more]
containment isolation valves.
The proposed change provides new Required Action C.1 to
isolate all but one of the affected penetration flow paths by use of at
least one closed and de-activated automatic valve, closed manual valve,
or blind flange with a completion time of 4 hours.
The proposed change revises the previous Condition B and
Required Action B.1 to be new Condition D and Required Action D.1.
The proposed change revises the previous Condition C and
Required Action C.1 and C.2 to be new Condition E and Required Action
E.1 and E.2.
The proposed change revises the previous Condition D and
Required Action D.1, D.2 and D.3 to be new Condition F and Required
Action F.1, F.2 and F.3.
The proposed change revises the previous reference to
Required Action
[[Page 6532]]
D.1 for performance of SR 3.6.3.6 within Required Action D.3 to
Required Action F.1.
The proposed change revises the previous Condition E and
Required Action E.1 and E.2 to be new Condition G and Required Action
G.1 and G.2.
TSTF-498 includes changes to the B&W STS Bases B 3.6.3 contained in
NUREG-1430.
Condition A has been modified by a Note indicating this
Condition is only applicable to those penetration flow paths with two
[or more] containment isolation valves. The Note also states that the
Condition is not applicable to containment isolation valves in the main
steam lines and [any specific penetrations identified by the plant-
specific risk analysis as having high risk significance for an ISLOCA.
The previous discussion about the Note has been deleted. Additionally,
a new Required Action A.1 has been added to determine that the operable
containment isolation valve in the affected penetration is not
inoperable due to a common cause failure with a completion time of 4
hours. The other Condition A Required Actions have been re-numbered and
Required Action A.2 Completion Time has been changed from 4 hours to 7
days.
The bases has been revised to update Required Action A.2
from 4 hours to 7 days based on an analysis of plant risk and the
discussion on considering the time required to isolate the penetration
and the relative importance of supporting containment operability has
been deleted.
A new Condition B has been added with a Note indicating
this Condition is only applicable to those penetration flow paths with
two [or more] containment isolation valves that are containment
isolation valves in the main steam lines or are [any specific
penetrations identified by the plant-specific risk analysis as having
high risk significance for an interfacing systems loss of coolant
accident (ISLOCA)]. Condition B is entered if one containment isolation
valve in one or more penetration flow paths is inoperable, [except for
purge valve leakage not within limit.] The Bases describes Required
Actions B.1 and B.2 Completion Times and Notes as specified in the TS
section.
A new Condition C has been added with a Note indicating
this Condition is only applicable to penetration flow paths with two
[or more] containment isolation valves. Condition C is entered if two
or more penetration flow paths with one containment isolation valve
inoperable [for reasons other than Condition[s] E [and F]]. The Bases
describes the Required Action C.1 Completion Time to isolate all but
one of the affected containment isolation valves within 4 hours.
The bases discussion for Required Action D.1 has been
updated to account for new Conditions B and C and have been added where
applicable.
Condition B and Required Action B.1 has been re-numbered
to Condition D and Required Action D.1.
Condition C and Required Action C.1 and C.2 have been re-
numbered to Condition E and Required Action E.1 and E.2.
Reference to BAW-2461-A has been added as Reference 6.
Previous references 6, 7, and 8 have been re-numbered to references 7,
8 and 9. Applicable changes have been made throughout the Bases.
Condition D and Required Action D.1, D.2 and D.3 have been
re-numbered to Condition F and Required Action F.1, F.2 and F.3.
Condition E and Required Action E.1 and E.2 have been re-
numbered to Condition G and Required Action G.1 and G.2.
3.0 Technical Evaluation
As stated previously, BAW-2461-A describes a method to revise the
Completion Time for specific Conditions per Technical Specification
3.6.3, Containment Isolation Valves. The NRC approved BAW-2461 on
August 29, 2007, for referencing in license applications to the extent
specified and under the limitations and conditions stated in the
topical report and Section 4.1 of the staff's safety evaluation
(Reference 6). TSTF-498 is proposing changes to the B&W STS, NUREG
1430, which are in accordance with Topical Report BAW-2461-A and
subject to the Limitations, Conditions and Regulatory Commitments
specified in the staff Safety Evaluation. Any differences between TR
BAW-2461-A Technical Specification examples and TSTF-498 proposed
Technical Specifications have been evaluated and determined to be
acceptable. BAW-2461-A, Table 2-1, Condition A note states ``Only
applicable to penetration flow paths with two [or more] containment
isolation valves with the exception of containment isolation valves in
the main steam lines [and list of specific penetrations (if any)
identified by the plant-specific risk-informed process to have high
risk significance for ISLOCA.]'' To be consistent with the ITS format
and content rules, the Condition A Note was written as ``Only
applicable to penetration flow paths with two [or more] containment
isolation valves except containment isolation valves in the main steam
lines and [ ].'' The Condition is modified by a Reviewer's Note which
states, ``The Condition A Note should list the specific penetrations
(if any) identified by the plant-specific risk analysis as having high
risk significance for an interfacing systems loss of coolant accident
(ISLOCA).'' This change is editorial and does not affect the
application of the TS. The change in wording meets the requirements
specified in BAW-2461-A and is therefore acceptable.
The July 5, 2006 Request for Additional Information (RAI) response
to NRC Question 1 stated that the following action would be added as
Required Action A.1 with a 4 hour Completion Time, ``Verify that the
redundant CIV on the same penetration is operable [applicable only if
the redundant CIV has an operator and/or body type that is not diverse
from the inoperable CIV depending on which parts are inoperable.]'' In
TSTF-498, Required Action A.1 has a 4 hour Completion Time and states,
``Determine the OPERABLE containment isolation valve in the affected
penetration is not inoperable due to common cause failure.'' The
wording was chosen to be consistent with LCO 3.8.1, Required Action
B.3.1, regarding inoperable diesel generators. The discussion of what
is required to be evaluated, ``applicable only if the redundant CIV has
an operator and/or body type that is not diverse from the inoperable
CIV depending on which parts are inoperable,'' is placed in the
Required Action A.1 Bases. Placing the detailed description of what is
meant by common cause failure in the Bases is consistent with the ITS
format and content rules. This change has been evaluated as a Revision
to BAW-2461-A. TSTF-498 wording is equivalent to the proposed wording
submitted as RAI response 1 and is consistent with NRC's
Safety Evaluation for BAW-2461-A and is therefore acceptable.
B&W STS Required Action A.1 and A.2 are being revised to re-number
these actions to A.2 and A.3. This is necessary to incorporate the new
Required Action A.1 as described above. Additionally, the completion
time for the new Required Action A.2 which states ``isolate the
affected penetration flow path by use of at least one closed and de-
activated automatic valve, closed manual valve, blind flange, or check
valve with flow through the valve secured'' is being revised from 4
hours to 7 days. This change has been evaluated by the staff and is
consistent with NRC's Safety Evaluation for BAW-2461-A and is therefore
acceptable.
[[Page 6533]]
B&W STS is adding a new Condition B for one or more penetration
flow paths with one containment isolation valve inoperable [for reasons
other than purge valve leakage not within limit] with a Note specifying
``Only applicable to penetration flow paths with two [or more]
containment isolation valves in the main steam lines and [ ]. There is
also a Reviewer's Note that states ``The condition B Note should list
the specific penetrations (if any) identified by the plant-specific
risk analysis as having high risk significance for an interfacing
systems loss of coolant accident (ISLOCA). This wording is consistent
with the change made to Condition A and is consistent with the format
and content rules in ITS. Additionally, the Required Actions and
associated Completion Times are consistent with Condition A and the
change evaluated by the staff in the NRC's Safety Evaluation for BAW-
2461-A. This new Condition was required since main steam line isolation
valves were explicitly excluded from the CT extension as stated in the
NRC's Safety Evaluation for BAW-2461-A and is therefore acceptable.
B&W STS Condition B and Required Action B.1 are being revised to be
Condition D and Required Action D.1. With the addition of new
Conditions B and C the remaining Conditions and Required Actions need
to be re-numbered. This change is editorial and results in no technical
change and is therefore acceptable.
B&W STS is adding a new Condition C which is applicable when two or
more penetrations have one inoperable containment isolation valve. This
Condition requires isolating all but one of the affected penetrations
within 4 hours (the existing Completion Time for Condition A). Once
this Completion Time is satisfied and since Condition A is still
applicable then this essentially limits the 7 day Completion Time in
Condition A to a single penetration. This change addresses Condition
and Limitation 6 in the NRC's Safety Evaluation for BAW-2461-A and is
therefore acceptable.
B&W STS Condition C and Required Actions C.1 and C.2 are being
revised to be Condition E and Required Action E.1 and E.2. With the
addition of new Conditions B and C the remaining Conditions and
Required Actions need to be re-numbered. This change is editorial and
results in no technical change and is therefore acceptable.
B&W STS Condition D and Required Action D.1, D.2 and D.3 are being
revised to be Condition F and Required Action F.1, F.2 and F.3. With
the addition of new Conditions B and C the remaining Conditions and
Required Actions need to be re-numbered. This change is editorial and
results in no technical change and is therefore acceptable.
B&W STS Condition E and Required Action E.1 and E.2 are being
revised to be Condition G and Required Action G.1 and G.2. With the
addition of new Conditions B and C the remaining Conditions and
Required Actions need to be re-numbered. This change is editorial and
results in no technical change and is therefore acceptable.
B&W STS Bases for B 3.6.3 Actions A.1, A.2 and A.3 are being
revised to describe the Note that is being added indicating the
Condition is only applicable to those penetration flow paths with two
[or more] containment isolation valves and that the isolation valves in
the main steam line are not applicable along with any specific
penetrations identified by the plant-specific risk analysis. This is
necessary to ensure the correct Required Actions are taken based on the
applicable penetration. This is consistent with all other Bases
descriptions in the B&W STS and is therefore acceptable.
B&W STS Bases for B 3.6.3 Required Action A.2 Completion Time is
being revised from 4 hours to 7 days and indicates that this is based
on an analysis of plant risk. The change is revising wording associated
with the 4 hour completion time to a 7 day completion time. The 7 day
completion time is now based upon a plant risk evaluation instead of a
reasonable time to isolate the penetration. This is consistent with
BAW-2461-A which the staff found acceptable in the Safety Evaluation
for BAW-2461-A and is therefore acceptable.
B&W STS Bases for B 3.6.3 is adding support information for new
Condition B and Required Actions B.1 and B.2 which is applicable for
one or more penetration flow paths with one containment isolation valve
inoperable [for reasons other than purge valve leakage not within
limit]. Condition B is also only applicable to penetration flow paths
with two [or more] containment isolation valves in the main steam lines
and [ ]. The associated Required Actions and Completion Times for new
Condition B are consistent with Actions and Completion Times for
Condition A which the staff found acceptable in the NRC's Safety
Evaluation for BAW-2461-A and is therefore acceptable.
B&W STS Bases for B 3.6.3 is adding support information for new
Condition C and Required Action C.1 which is applicable for two or more
penetration flow paths with one containment isolation valve inoperable
[for reasons other than Condition[s] E [and F]]. Condition C is only
applicable to penetration flow paths with two [or more] containment
isolation valves. The Required Action to isolate all but one of the
affected penetration flow paths by use of at least one closed and de-
activated automatic valve, closed manual valve, or blind flange within
4 hours ensures that simultaneous LCO entry of an inoperable CIV in
separate penetration flow paths such that the proposed 7 day Completion
Time in Condition A is limited to no more than one CIV at any given
time. This change addresses Limitation and Condition 6 as specified in
the NRC's Safety Evaluation for BAW-2461-A and is therefore acceptable.
B&W STS Bases for B 3.6.3 are being revised such that each
Condition and Required Action subsequent to the addition of new
Conditions B and C need to be re-numbered. Additionally, a new
reference has been added (Reference 6) which requires subsequent
references to be re-numbered. These changes are considered editorial
and do not affect any technical aspect of the Bases and are therefore
acceptable.
3.1 Summary
TSTF-498 would provide standardized wording in the B&W STS for
plants implementing BAW-2461-A, ``Risk-Informed Justification for
Containment Isolation Valve Allowed Outage Time Change.'' The changes
to NUREG-1430 proposed by TSTF-498 have been reviewed for consistency
with the current NUREG-1430 and BAW-2461-A. The proposed changes have
been found to be consistent with NUREG-1430 and BAW-2461-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
[[Page 6534]]
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 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-498, Revision 0, ``Risk-
Informed Containment Isolation Valve Completion Times (BAW-2461),''
dated December 20, 2006. (ADAMS ML063560402)
2. Letter from the TSTF re: Response to NRC Request for Additional
Information Regarding TSTF-498, Revision 0, ``Risk-Informed
Containment Isolation Valve Completion Times (BAW-2461),'' dated
October 10, 2007. (ADAMS ML072840444)
3. BAW-2461-A, ``Risk-Informed Justification for Containment
Isolation Valve Allowed Outage Time Change,'' Revision 0, dated
October 2007. (ADAMS ML072980529)
4. NUREG 1430, ``Standard Technical Specifications Babcock and
Wilcox Plants,'' Revision 3.0. (ADAMS ML041830589 and ML041800598)
5. Nuclear Energy Institute 99-04, Revision 0, ``Guidelines for
Managing NRC Commitment Changes,'' July 1999.
6. Final Safety Evaluation for Pressurized Water Reactors Owners
Group, Topical Report, BAW-2461, Revision 0, ``Risk-Informed
Justification for Containment Isolation Valve Allowed Outage Time
Change (TAC No. MD5722),'' (ADAMS ML072330227)
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 Risk-
Informed Justification for Containment Isolation Valve Allowed Outage
Time Change 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 Regarding Risk--
Informed Justification for Containment Isolation Valve Allowed Outage
Time Change Using the Consolidated Line Item Improvement Process
Gentlemen:
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 containment
isolation valve (CIV) allowed outage time changes with implementation
of BAW-2461-A, ``Risk-Informed Justification for Containment Isolation
Valve Allowed Outage Time Change.''
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 TS Bases
changes.
[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 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 containment
isolation valve allowed outage times associated with implementation of
BAW-2461-A, ``Risk-Informed Justification for Containment Isolation
Valve Allowed Outage Time Change.''
The changes are consistent with Nuclear Regulatory Commission (NRC)
approved Industry/Technical Specification Task Force (TSTF) STS change
TSTF-498, Revision 1. 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-498, Revision 1. [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 TSTF-498, Revision 1, and the NRC staff's model
safety evaluation dated [DATE].
[[Page 6535]]
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
has found it acceptable for incorporation into the amendment request
which satisfies 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, [LICENSEE] verifies the
applicability of TSTF-498, Revision 1, to [PLANT], and commits to
adopting the requirements specified in BAW-2461-A which includes the
following Limitations and Conditions specified in Section 4.1, Staff
Findings and Conditions and Limitations, of the NRC's Safety Evaluation
for BAW-2461 (ML072330227):
1. Based on TR BAW-2461, the CIV methodology, PRA parameters,
configurations, and data used to evaluate an extended CIV CT to 168
hours is limited to the following plants.
Davis-Besse
Oconee Units 1, 2, and 3
Crystal River 3
Other licensees of B&W designed PWRs requesting to use the TR
methodology must provide the same level of information provided by
these demonstration plants to ensure that TR BAW-2461 is applicable to
their plant.
2. Because not all penetrations have the same impact on [Delta]CDF,
[Delta]LERF, ICCDP, or ICLERP, verify the applicability of TR BAW-2461
to the specific plant, including verification that: (a) the CIV
configurations for the specific plant match the configurations in TR
BAW-2461, and (b) the risk-parameter values used in TR BAW-2461,
including the sensitivity studies contained in the RAIs, are
representative or bounding for the specific plant. Any additional CIV
configurations, CT extensions, or non-bounding risk parameter values
not evaluated by TR BAW-2461 should be addressed in the plant-specific
analyses. [Note that CIV configurations and extended CTs not
specifically evaluated by TR BAW-2461, or non-bounding risk parameter
values outside the scope of the TR, will require NRC staff review and
licensee development of the specific penetrations and related
justifications for the proposed CTs].
3. Each licensee adopting TR BAW-2461 will need to confirm that the
plant-specific risk assessment including both internal and external
events is within the assumptions of TR BAW-2461 and the acceptance
guidelines of RG 1.174 and 1.177. The licensee's application verifies
that external event risk, including seismic, fires, floods, and high
winds, either through quantitative or qualitative evaluation, is shown
to not have an adverse impact on the conclusions of the plant-specific
analysis for extending the CIV CTs. Specifically: (1) the risk from
external events cannot make the total baseline risk exceed 1E-4/yr CDF,
or 1E-5/yr LERF, without justification, (2) the risk from external
events (i.e., high winds, floods and other) should be specifically
evaluated with respect to the extended CIV CT, and (3) fire risk should
be specifically addressed. The evaluation should include fire-induced
spurious actuation (including containment performance) with respect to
the proposed 168-hour CIV CT.
Additionally, each licensee will need to confirm that the seismic
CDF referenced for TR BAW-2461 is bounding for its plant, or
incorporate a plant-specific seismic CDF estimate. Furthermore, the
seismic initiating event frequency will need to be defined and
justified for each licensee implementing TR BAW-2461. See Section
3.4.1.4 of the staff's SE.
4. For licensees adopting TR BAW-2461, confirmation should be
provided that the Tier 2 and Tier 3 conclusions of the TR are
applicable to the licensee's plant and that plant-specific Tier 2
evaluations including CCF and risk-significant configurations including
interfacing-system LOCA have been evaluated and included under Tier 2
and Tier 3 including the CRMP as applicable.
The proposed 168-hour CIV CT will not be applied to CIVs
in penetrations connected to the RCS that have two NC CIVs if there are
no other valves between the RCS and the environment (i.e., low pressure
piping, or opening) that may be used for backup isolation and cannot be
confirmed closed. In that case, the operable CIV will be verified
closed within the original 4-hour CT, thus satisfying the TS Required
Action. See Section 3.3.4 of the staff's SE. The specific penetrations
where this is applicable or where interfacing-system LOCA is shown to
be risk-significant (as determined by the plant-specific risk-informed
process including plant-specific LOCA analysis) will be identified on a
plant-specific basis prior to implementation of the proposed TS change.
They will be listed explicitly in the proposed TS revision and the
current CT will be retained.
TR BAW-2461 stated that an interfacing-system LOCA is
assumed to lead to core damage and large early release, the
effectiveness of mitigation systems besides containment isolation is
not considered significant. All failed open penetration flow paths with
an RCS connection were assumed to have CDF and LERF contributions in TR
BAW-2461. Licensees incorporating TR BAW-2461 will need to confirm the
above assumption for their plant specific implementation of BAW-2461.
The specific penetrations with CCF potential will be
identified by the licensee on a plant-specific basis. Upon entry into
TS LCO 3.6.3, Condition A, the utility will confirm that the redundant
similarly-designed CIV has not been affected by the same failure mode
as the inoperable CIV. This verification will be performed before
entering into the extended portion of the CT (i.e., within 4 hours).
The specific penetrations with CCF potential will be identified on a
plant-specific basis and listed in a plant-specific TS document or
other administrative source. See Section 3.4.1.2 of the staff's SE.
No action or maintenance activity is performed that will
remove equipment that is functionally redundant to the inoperable CIV,
including the redundant CIV(s) on the same penetration and support
systems for the redundant CIV. See Section 3.3 of TR BAW-2461.
No action or maintenance activity is performed that will
significantly increase the likelihood of challenge to the CIVs.
Challenges to the CIVs include DBAs that result in a release of
radioactive material within containment (LOCA, main steam line break,
and rod ejection accident). Also included is the removal of equipment
from service that may cause a significant increase in the likelihood of
core damage while in the proposed CT, which may increase the large
early release via the inoperable CIV. See Section 3.4 of TR BAW-2461.
No action or maintenance activity is performed that will
remove equipment that supports success paths credited in the CT risk
evaluation. This includes the other series valves, if any, credited in
the risk assessment for RCS penetrations that otherwise would be risk-
significant (i.e., interfacing-system LOCA). See Section 3.4 of TR BAW-
2461.
5. TR BAW-2461 was based on generic-plant characteristics. Each
licensee adopting TR BAW-2461 must confirm plant-specific Tier 3
information in their individual submittals. The licensee must discuss
conformance to the requirements of the
[[Page 6536]]
maintenance rule (10 CFR 50.65(a)(4)), as they relate to the proposed
CIV CTs and the guidance contained in NUMARC 93.01, Section 11, as
endorsed by RG 1.182, including verification that the licensee's
maintenance rule program, with respect to CIVs, includes a LERF/ICLERP
assessment (i.e., CRMP). See Section 3.4.3 of the staff's SE.
6. TS LCO 3.6.3, Note 2, allows separate condition entry for each
penetration flow path. Therefore, each licensee adopting TR BAW-2461
will address the simultaneous LCO entry of an inoperable CIV in
separate penetration flow paths such that the proposed 168-hour CIV CT
LCO will be limited to no more than one CIV at any given time. In
addition, the licensee must confirm that its Tier 3 CRMP addresses
simultaneous inoperable CIV LCOs (i.e., separate condition entry) such
that the cumulative CIV risk, including LERF, are maintained consistent
with the assumptions and conclusions of TR BAW-2461. See Section
3.4.1.2 of the staff's SE.
7. The licensee shall verify that the plant-specific PRA quality is
acceptable with respect to its use for Tier 3 for this application in
accordance with the guidelines given in RG 1.174 and as discussed in
Section 3.4.1.1 of the staff's SE.
8. With respect to past plant-specific license amendments or
additional plant-specific applications for a TS change under NRC review
that have not been incorporated into the baseline PRA used to evaluate
the proposed change, the cumulative risk must be evaluated on a plant-
specific basis consistent with the guidance given in RG 1.174, Section
2.2.6 and 3.3.2, and addressed in a licensee's plant-specific
application. See Section 3.4.1.5 of the staff's SE.
9. Closed systems inside and outside containment, which are
considered to be containment isolation barriers, must meet the
provisions outlined in NUREG-0800, Section 6.2.4, ``Containment
Isolation System.'' See Section 2.2 of the staff's SE.
10. With an extended CIV CT, the possibility exists that the CIV
unavailability will be impacted. Depending on the penetration risk
significance and the frequency and length of time of the CIV CT, the
unavailability of the containment isolation function may also be
impacted. Therefore, licensee's adopting TR BAW-2461 will need to
establish an implementation and monitoring program for CIVs, including
performance criteria, on a plant-specific basis. See Sections 3.4.1.2
and 3.4.4 of the staff's SE.
11. The PWROG did not specifically address [Delta]CDF and
[Delta]LERF in TR BAW-2461 regarding the acceptance guidelines of RG
1.174. The PWROG stated that it is not expecting that on line CIV
preventive maintenance will increase with the proposed 168-hour CIV. To
address this, licensee's adopting TR BAW-2461 will need to assess, on a
plant-specific basis, the [Delta]CDF and [Delta]LERF acceptance
guidance of RG 1.174 including the expected frequency of entering the
proposed CT and the expected mean CT for CIV maintenance. See Section
3.4.1.2 of the staff's SE.
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 and acceptable to [PLANT] and the evaluation
is submitted as an attachment to 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
regulatory commitments. Please direct questions regarding these
commitments to [CONTACT NAME].
------------------------------------------------------------------------
Regulatory commitments Due date/event
------------------------------------------------------------------------
[LICENSEE] will................... [Complete, implemented with
amendment OR within X days of
implementation of 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
Babcock and Wilcox (B&W) Plants (NUREG-1430) and plant specific
technical specifications (TS), to allow modification of containment
isolation valve completion times associated with implementation of BAW-
2461-A, ``Risk-Informed Justification for Containment Isolation Valve
Allowed Outage Time Change,'' dated October 2007. The changes are
consistent with NRC approved Industry/Technical Specification Task
Force (TSTF) STS Traveler, TSTF-498, Revision 1, ``Risk-Informed
Containment Isolation Valve Completion Times (BAW-2461).'' The proposed
change extends the Completion Times for containment penetration flow
paths with one containment isolation valve inoperable from 4 hours to 7
days for Babcock & Wilcox (B&W) NSSS plants. This change is applicable
to containment penetrations with two [or more] containment isolation
valves in which one containment isolation valve is inoperable [for
reasons other than purge valve leakage not within limit]. The extended
Completion Time is not applicable to containment isolation valves in
the main steam lines or those identified by plant-specific analysis as
having high risk significance for interfacing systems loss of coolant
accidents (ISLOCAs) and the existing 4 hour Completion Time applies.
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 changes revise the Completion Times for restoring
an inoperable containment isolation valve (or isolating the affected
penetration) within the scope of Topical Report BAW-2461-A, ``Risk-
Informed Justification for Containment Isolation Valve Allowed
Outage Time Change.'' The Completion Times are extended from 4 hours
to 7 days. Containment isolation valves are not accident initiators
in any accident previously evaluated. Consequently, the probability
of an accident previously evaluated is not significantly increased.
Containment isolation valves control the extent of leakage from the
containment following an accident. As such, containment isolation
valves are instrumental in controlling the consequences of an
accident. However, the consequences of any accident previously
evaluated are no different during the proposed extended Completion
Times than during the existing Completion Times. As a result, the
[[Page 6537]]
consequences of any accident previously evaluated are not
significantly increased. Therefore, the proposed changes do 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
The proposed changes revise the Completion Times for restoring
an inoperable containment isolation valve (or isolating the affected
penetration) within the scope of Topical Report BAW-2461-A, ``Risk-
Informed Justification for Containment Isolation Valve Allowed
Outage Time Change.'' The proposed changes do not change the design,
configuration, or method of operation of the plant. The proposed
changes do not involve a physical alteration of the plant (no new or
different kind of equipment will be installed). Therefore, the
proposed changes do 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
The proposed changes revise the Completion Times for restoring
an inoperable containment isolation valve (or isolating the affected
penetration) within the scope of Topical Report BAW-2461-A, ``Risk-
Informed Justification for Containment Isolation Valve Allowed
Outage Time Change.'' In order to evaluate the proposed Completion
Time extensions, a probabilistic risk evaluation was performed as
documented in Topical Report BAW-2461-A. The risk evaluation
concluded that the proposed increase in the Completion Times does
not result in an unacceptable incremental conditional core damage
probability or incremental conditional large early release
probability according to the guidelines of Regulatory Guide 1.177.
Therefore, the proposed changes 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 as set forth in 10 CFR
50.92(c).
Dated at Rockville, Maryland, this 28th day of January, 2008.
For the Nuclear Regulatory Commission.
Gerald Waig,
Acting Chief, Technical Specifications Branch, Division of Inspection &
Regional Support, Office of Nuclear Reactor Regulation.
[FR Doc. E8-1943 Filed 2-1-08; 8:45 am]
BILLING CODE 7590-01-P