[Federal Register Volume 74, Number 7 (Monday, January 12, 2009)]
[Notices]
[Pages 1252-1262]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E9-345]
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NUCLEAR REGULATORY COMMISSION
[NRC-2008-0065]
Notice of Availability of Model Application Concerning Technical
Specification Improvement To Revise Containment Isolation Valve
Completion Times (TSTF-498, Revision 1, for Babcock & Wilcox Plants)
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)
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 is to permit the NRC to efficiently process amendments
that propose to modify TS Completion Times (CTs) for CIVs. Licensees of
nuclear power reactors to which the models apply can then request
amendments after confirming
[[Page 1253]]
the applicability of the SE and NSHC determination to their reactors.
Licensees of nuclear power reactors to which the model applies may
request amendments using the model application.
DATES: The NRC staff issued a Federal Register (FR) notice (73 FR 6529-
6537; February 4, 2008), which provided an opportunity for comment on a
model SE, model application, and model NSHC determination relating to
the CT extension for TS actions related to inoperable CIVs at Babcock &
Wilcox (B&W) plants. Similarly, the NRC staff herein provides a revised
model SE, revised model LAR, and model NSHC determination incorporating
changes based on the public comments received. The NRC staff can most
efficiently consider applications based on 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: Robert Elliott, 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 301-415-8585.
SUPPLEMENTARY INFORMATION:
Background
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.
Note: This notice was published in the NRC's Federal Register
(Vol. 73 FR 6529-6537, dated 02/04/2008) as ``Notice of Opportunity
to Comment'' stating that the subject TSTF is available for adoption
using the NRC's Consolidated Line Item Improvement Process (CLIIP).
The NRC has determined that this TSTF does not qualify for the CLIIP
process.
Those licensees opting to apply for the subject change to TSs 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. Note that containment
isolation valve (CIV) configurations and extended completion times
(CTs) not specifically evaluated by TR BAW-2461, or non-bounding risk
parameter values outside the scope of the TR, will require NRC staff's
review and licensee development of the specific penetrations and
related justifications for the proposed CTs.
TSTF-498 can be viewed on the NRC's Web page at: http://www.nrc.gov/reactors/operating/licensing/techspecs.html.
Applicability
The staff is requesting that the methodologies 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
The staff issued a Federal Register notice (73 FR 6529-6537,
February 4, 2008) that requested public comment on the NRC's pending
action to revise the TS completion times for selected CIVs at B&W
plants as proposed in TSTF-498, Revision 1. TSTF-498, Revision 1, 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 the proposed changes to TS regarding CIV
completion times, the staff received one set of comments (from the TSTF
Owners Groups, representing licensees). The specific comments are
provided and discussed below. Note that some of the public comments
pertain to the NRC's CLIIP process. As stated previously, the NRC has
determined that the subject TSTF does not qualify for the CLIIP
process.
1. Comment: Model SE, Section 2.0, ``Regulatory Evaluation,''
second paragraph, of the proposed Safety Evaluation states,
``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).'' The TSTF disagrees with the technical
accuracy of this statement. The Technical Specification Limiting
Conditions for Operation (LCOs) are based on providing ``reasonable
assurance that the safety functions * * * will be performed in
accordance with the design basis accidents (DBAs) identified in Chapter
15 of the licensee's final safety analysis report (FSAR).'' When an LCO
is not met, the Required Actions are required to be followed within the
specified Completion Times. By definition, when an LCO is not met, the
safety functions cannot be performed as identified in Chapter 15 of the
FSAR. We recommend that the sentence be deleted. This sentence is
unnecessary as it only expands on a previous statement that there must
be reasonable protection of public health and safety during the
proposed Completion Times.
Response: The NRC agrees with the comment and the referenced
sentence has been deleted. Additionally, wording has been added which
describes the function of CTs.
2. Comment: Section 3.2 of the Model Application, ``Verification
and Commitments,'' first paragraph, of the model application states,
``[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).'' The section then repeats the eleven conditions in the
NRC's Safety Evaluation for BAW-2461.
This approach is inconsistent with previous CLIIP model
applications and other license amendments that are based on the
technical justification provided in a Topical Report. Licensees do not
typically repeat, verbatim, conditions on NRC approval of a Topical
Report in a license amendment request. Furthermore, the proposed text
adds no value as it states the conditions without addressing how the
conditions are
[[Page 1254]]
satisfied by the license amendment request.
The TSTF recommends that the quoted sentence, above, be revised to
delete the word ``following'' in the phrase ``the following Limitations
and Conditions,'' and that the listing of the eleven conditions be
removed from the model application.
We recommend that the discussion of the eleven conditions in the
model Safety Evaluation be expanded to include a discussion of how each
Limitation and Condition is addressed.
For those Limitations and Conditions that require
verification of the applicability of information in the Topical Report
and the Safety Evaluation (i.e., Conditions 1, 2, 3, 4, 5, 7, 9, 10,
11), the revised sentence provides the necessary affirmative statement.
For those Limitations and Conditions addressed by the
Technical Specification provisions in TSTF-498 (i.e., Condition 4,
bullets 1 and 3, Condition 6), the model Safety Evaluation should
discuss how the Condition is satisfied by the proposed Technical
Specification requirements.
For those Limitations and Conditions that state that the
licensee must discuss a topic in their submittal (i.e., Conditions 5,
8), either an affirmative statement should be added to the model
application confirming that the Limitation and Condition is met or
guidance should be provided on what information must be included. Note
that Limitation and
Condition 5 is addressed below by a proposed commitment.
Particular attention should be paid to ensuring that the model
application, when used as the basis for a plant-specific license
amendment request, can be processed by the NRC under the CLIIP.
Response: The NRC agrees with the comment that the current wording
which repeats the Limitations and Conditions from the staff's Safety
Evaluation for Topical Report BAW-2461-A does not address how the
conditions are satisfied. The model application has been revised to
require a specific verification by the licensee that each of the 11
Limitations and Conditions have been met. This change ensures that each
licensee adopting TSTF-498 has met all the Limitations and Conditions
without relying exclusively on cross-referencing another document.
Additionally, Limitation and Condition 3, as specified in
section 3.2, Verification and Commitments, of the Model Application has
been revised such that the specific details describing what must be
submitted in the application regarding external events, fire risk and
seismic evaluations has been deleted. This was necessary to maintain
consistency with the staff's resolution of comments on the draft safety
evaluation for TR BAW-2461 by the Pressurized Water Reactor Owners
Group (PWROG) (ADAMS ML072330227). Furthermore, the word ``following''
has been deleted from the phrase ``the following Limitations and
Conditions,'' since it is no longer required.
3. Comment: Section 4, ``Environmental Evaluation,'' of the model
application states that the NRC staff's environmental evaluation is
applicable and is submitted as an attachment to the application.
Submitting a copy of the NRC staff's environmental evaluation as an
attachment to the license amendment request is inconsistent with
previous CLIIP items and serves no purpose since the amendment request
has already stated that the environmental evaluation is applicable.
The TSTF recommends that Section 4 be revised to be consistent with
earlier CLIIP model applications, similar to, ``[LICENSEE] has reviewed
the environmental evaluation included in the safety evaluation (SE)
published on [DATE]([ ] FR [ ]) as part of the CLIIP Notice of
Availability. [LICENSEE] has concluded that the staff's findings
presented in that evaluation are applicable to [PLANT, NO.] and the
evaluation is hereby incorporated by reference for this application.
Response: The NRC disagrees with the comment and the model
application has been revised to clearly state that the Environmental
Evaluation must be attached to the amendment request to satisfy the
requirements of 10 CFR 50.91(a). Additionally, section 3.1, No
Significant Hazards Determination (NSHD), has been revised to state
that the NSHD must be attached to the amendment request to meet the
requirements of 10 CFR 50.91(a).
4. Comment: Attachment 4, ``List of Regulatory Commitments,''
contains an example table with no commitments listed. This is
inconsistent with other CLIIP model applications, which list any needed
commitments. By not specifying whether any commitments are needed or
what those commitments might be, the NRC is making it unlikely that any
application submitted following the model application can be processed
by the NRC under the CLIIP. The TSTF identified the following
commitments that are appropriate to include in the model application.
This is consistent with previous CLIIP model applications for risk
informed Completion Times and with the proposed Safety Evaluation.
[LICENSEE] commits to implement Bases consistent with the
Bases provided in TSTF-498 under the Technical Specification Bases
Control Program with a Due Date concurrent with the implementation of a
license amendment based on TSTF-498.
[LICENSEE] commits to implementing a methodology for
assessing the effect on large early release frequency (LERF) and
incremental conditional large early release probability (ICLERP) when
utilizing the extended CIV CTs in the program for managing risk in
accordance with 10 CFR 50.65(a)(4) with a Due Date concurrent with the
implementation of a license amendment based on TSTF-498.
[LICENSEE] commits to the guidance of NUMARC 93-01,
Revision 2, section 11, which provides guidance and details on the
assessment and management of risk during maintenance as an ongoing
commitment.
Response: The NRC agrees with the comment with the exception of the
first commitment concerning bases implementation. The bases are
required to be submitted per the 10 CFR 50.36(a) criteria. The 10 CFR
50.36(a) states that a summary statement of the bases or reasons for
such specifications, other than those covering administrative controls,
shall also be included in the application, but shall not become part of
the technical specifications. After the NRC approves the Technical
Specifications, the licensee can revise bases under its Bases Control
Program or/and 10 CFR 50.59 process. The remaining suggested
commitments have been added to the model application. Additionally, as
stated before, this is not a CLIIP model application.
Additional changes to the proposed Safety Evaluation:
Editorial changes have been made to correct spelling and
grammar errors.
Wording has been removed from the Applicability statement
related to the requirement for licensees to submit Technical
Specification Bases along with the application. This statement was
unnecessary since 10 CFR 50.36(a) requires the application for a
Technical Specification change to include Technical Specification
Bases.
Per the Commission's Final Policy Statement on Technical
Specifications Improvements for Nuclear Power Reactors (58 FR 39132-
39134, July 22, 1993), the Commission expects improved Bases to
accompany requests for improved Technical specifications. Safety
Evaluation section 3.0, Technical Evaluation, has been revised to
clarify
[[Page 1255]]
that the TS Bases are not part of the Technical Specifications but must
be submitted as required by 10 CFR 50.36(a).
Wording has been added to the Summary that states the
changes are consistent with the staff's Safety Evaluation for BAW-2461-
A and are therefore acceptable.
Dated at Rockville, Maryland, this 5th day of January 2009.
For the Nuclear Regulatory Commission.
Robert B. Elliott,
Chief, Technical Specifications Branch, Division of Inspection and
Regional Support, Office of Nuclear Reactor Regulation.
THE FOLLOWING EXAMPLE OF AN APPLICATION WAS PREPARED BY THE NRC STAFF.
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. 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 RISK-
INFORMED JUSTIFICATION FOR CONTAINMENT ISOLATION VALVE ALLOWED
OUTAGE TIME CHANGE
Dear Sir/Madam: 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. Attachment 6 provides No Significant
Hazards Consideration Determination. Attachment 7 provides
Environmental Evaluation.
[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 certify, verify, state] under penalty of perjury
that the foregoing is true and correct.
Executed on [date] [Signature]
If you should have any questions regarding this submittal,
please contact [NAME, TELEPHONE NUMBER]
Sincerely,
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[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
6. No Significant Hazards Consideration Determination
7. Environmental Evaluation
cc: NRC Regional Office
NRC Resident Inspector
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, (ADAMS Accession No. ML080280275).
The Federal Register notice published on [DATE] announced the
availability of this TS improvement.
2.0 ASSESSMENT
2.1 Applicability of Published Safety Evaluation
[LICENSEE] has reviewed the safety evaluation dated [DATE]. 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 NAME, UNIT NOS.] 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].
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 [DATE]([ ] FR [ ]). [LICENSEE] has concluded that the
proposed NSHCD presented in the Federal Register notice is
applicable to [PLANT NAME, UNIT NOS.] and is provided as an
attachment to this 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 NAME,
UNIT NOS.], and commits to adopting the requirements specified in
BAW-2461-A. Additionally, [LICENSEE] verifies that each of the
Limitations and Conditions specified in Section 4.1, Staff Findings
and Conditions and Limitations, of the NRC's Safety Evaluation for
BAW-2461 (ML072330227) as noted below for items (1) through (11),
also apply.
(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.
[LICENSEE] confirms that the information provided supports the
applicability of TR BAW-2461 to be used to evaluate an extended CIV
CT to 168 hours.
(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].[LICENSEE] confirms that TR BAW-2461 is applicable to [PLANT
NAME, UNIT NOS.]. This confirmation includes verification that: (a)
The CIV configurations for [PLANT NAME, UNIT NOS.] 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 [PLANT NAME, UNIT
NOS.].
[[LICENSEE] has provided additional information to support
additional CIV configurations, CT extensions, or non-bounding risk
parameter values not evaluated by TR BAW-2461].
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(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.
[LICENSEE] confirms that the plant-specific risk assessment,
both internal and external events, is within the assumptions of TR
BAW-2461 and the acceptance guidelines of RG 1.174 and 1.177.
Additionally, [LICENSEE] 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.
(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 for BAW-2461. 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 for BAW-2461.
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.
[LICENSEE] confirms that the Tier 2 and Tier 3 conclusions of
the TR are applicable to [PLANT NAME, UNIT NOS.] 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. Additionally, [LICENSEE] confirms that processes or
procedures are in place to ensure the above items are met.
(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 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 for BAW-2461.
[LICENSEE] has confirmed that the plant-specific Tier 3 information
for [PLANT NAME, UNIT NOS.] is consistent with the generic plant
characteristics used in TR BAW-2461. Also, [LICENSEE] has confirmed
that [PLANT NAME, UNIT NOS.] conforms to the requirements of the
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
maintenance rule program, with respect to CIVs, includes a LERF and
ICLERP assessment as part of the maintenance rule process.
(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 for BAW-2461.
[LICENSEE] confirms that the Technical Specification Required
Actions as proposed by adoption of TSTF-498 provides a requirement
to isolate all but one penetration flow path within 4 hours if there
are two or more penetration flow paths with one CIV inoperable.
(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 for BAW-2461.
[LICENSEE] confirms that [PLANT NAME, UNIT NOS.] PRA quality is
acceptable with respect to its use for Tier 3 in accordance with the
guidelines given in RG 1.174. Additionally, [LICENSEE] confirms
additional information on PRA quality with respect to Tier 3
identified in Section 3.4.1.1 of the staff's SE for BAW-2461 has
been provided.
(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 for BAW-
2461.
[LICENSEE] confirms that the cumulative risk has been evaluated
for [PLANT NAME, UNIT NOS.] in accordance with guidance in RG 1.174,
Section 2.2.6 and 3.3.2, with respect to past [PLANT NAME, UNIT
NOS.] license amendments or additional [PLANT NAME, UNIT NOS.]
applications for a TS change under NRC review that have not been
incorporated into the baseline PRA used to evaluate the proposed
change. This evaluation is provided in this application.
(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 for BAW-2461.
[LICENSEE] verifies that all closed systems inside and outside
containment, which are considered to be containment isolation
barriers, meet the provisions of NUREG-0800, Section 6.2.4,
``Containment Isolation System.''
(10) With an extended CIV CT, the possibility exists that the
CIV unavailability will be impacted. Depending on the penetration
risk significance and the
[[Page 1257]]
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 for BAW-2461.
[LICENSEE] confirms that [PLANT NAME, UNIT NOS.] has established
performance criteria and tracks maintenance unavailability in
accordance with the maintenance rule program, 10 CFR 50.65.
(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 online 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 for BAW-2461.
[LICENSEE] has assessed the [Delta]CDF and [Delta]LERF
acceptance guidance for [PLANT NAME, UNIT NOS.] in accordance with
RG 1.174 and provided information pertaining to the expected
frequency of entering the proposed CT and the expected mean CT for
CIV maintenance. This assessment and information is provided in this
application.
4.0 ENVIRONMENTAL EVALUATION
[LICENSEE] has reviewed the environmental evaluation included in
the model safety evaluation dated [DATE]. [LICENSEE] has concluded
that the proposed determination presented in the notice is
applicable to [PLANT NAME, UNIT NOS.] and the determination is
provided as an attachment to this amendment request to satisfy the
requirements of 10 CFR 50.91(a).
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
----------------------------------------------------------------------------------------------------------------
[LICENSEE] commits to implementing a methodology for Concurrently with the implementation of a license
assessing the effect on large early release frequency amendment based on TSTF-498.
(LERF) and incremental conditional large early release
probability (ICLERP) when utilizing the extended CIV CTs
in the program for managing risk in accordance with 10 CFR
50.65(a)(4).
[LICENSEE] commits to the guidance of NUMARC 93-01, Ongoing commitment.
``Industry Guideline for monitoring the effectiveness of
maintenance at nuclear power plants,'' Revision 2, Section
11, which provides guidance and details on the assessment
and management of risk during maintenance.
----------------------------------------------------------------------------------------------------------------
ATTACHMENT 5--PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES
ATTACHMENT 6--NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION
ATTACHMENT 7--ENVIRONMENTAL EVALUATION
Proposed No Significant Hazards Consideration Determination
Description of Amendment Request: [PLANT NAME, UNIT NOS.] 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 up to 7 days for Babcock & Wilcox (B&W) NSSS
plants. This change is applicable to containment penetrations with one
or more containment isolation valves in which one containment isolation
valve is inoperable [for reasons other than purge valve [shield
building bypass] 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:
1. Does the Proposed Change Involve a Significant Increase in the
Probability or Consequences of an Accident Previously Evaluated?
Response: No.
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 up 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 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.
2. Does the Proposed Change Create the Possibility of a New or
Different Kind of Accident from any Accident Previously Evaluated?
Response: No.
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
[[Page 1258]]
a new or different kind of accident from any accident previously
evaluated.
3. Does the Proposed Change Involve a Significant Reduction in the
Margin of Safety?
Response: No.
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).
Model Safety Evaluation
U.S. Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
Technical Specification Task Force (TSTF) Change TSTF-498, Revision 1,
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 (7 days). 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 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. As set forth in
10 CFR 50.36, a licensee's TS must establish the LCOs that are the
lowest functional capability or performance levels of equipment
required for safe operation of the facility. This requirement includes
CTs for structures, systems, and components (SSCs), such as CIVs. These
CTs allow a certain amount of time to correct the condition for not
meeting the LCO until the reactor must be brought to a condition which
exits the mode of applicability, in most cases resulting in the reactor
being shutdown.
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
[[Page 1259]]
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 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 as 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.
[[Page 1260]]
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 is consistent with NRC's Safety Evaluation
for BAW-2461-A and is therefore acceptable.
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. New Condition B for Main Steam Line Isolation Valves
was added to conform with the NRC's Safety Evaluation for BAW-2461-A
since main steam line isolation valves were explicitly excluded from
the Topical Report CT extension 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 conforms to 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
[[Page 1261]]
Conditions and Required Actions need to be re-numbered. This change is
editorial and results in no technical change and is therefore
acceptable.
The following B&W STS Bases changes are being made and shall be
submitted as required by 10 CFR 50.36(a). In all cases, the commission
expects improved Bases to accompany requests for improved Technical
specifications. The Staff's approval of the amendment was based on the
information provided by the licensee, which includes the TS Bases. The
changes to the Bases discussed below revise the current information in
the STS Bases to support the changes made to the Technical
Specifications. The Bases changes continue to meet the criteria
specified in the Final Policy Statement on ``Technical Specifications
Improvements for Nuclear Power Reactors'' (58 FR 39132, 39139, July 22,
1993) by providing information necessary to support the Technical
Specifications. After incorporation of the amendment, the licensee may
follow TS 5.5.14, Bases Control Program, should it desire to make
additional changes to the Bases.
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. Since the
changes are supported by risk-informed analyses, the Final Policy
Statement on Technical Specifications Improvements for Nuclear Power
Reactors, is satisfied. The Policy states, ``The Commission expects
that licensees, in preparing their Technical Specification related
submittals, will utilize any plant-specific probabilistic safety
assessment (PSA) or risk survey and any available literature on risk
insights and PSAs.''
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 change
supports the changes made to the Technical Specifications and meets the
Final Policy Statement (as stated above).
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 [ ]. This change provides a more accurate description
of the Applicability of Condition B and Required Actions B.1 and B.2.
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 provides supporting
information to ensure proper use and application of the changes made to
the Technical Specifications based on TR BAW-2461-A.
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. The change corrects the format for the
subject Conditions.
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.
Additionally, the proposed changes are consistent with the NRC staff's
safety evaluation which included a PRA evaluation for BAW-2461-A, and
are therefore 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. 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 (73
FR 6529,6537, February 4, 2008). Accordingly, the amendments meet the
eligibility criteria for categorical exclusion set forth in 10 CFR
51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact
statement or environmental assessment need be prepared in connection
with the issuance of the amendments.
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
[[Page 1262]]
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).
[FR Doc. E9-345 Filed 1-9-09; 8:45 am]
BILLING CODE 7590-01-P