[Federal Register Volume 74, Number 195 (Friday, October 9, 2009)]
[Notices]
[Pages 52268-52274]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E9-24407]
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NUCLEAR REGULATORY COMMISSION
[NRC-2009-0444]
Notice of Opportunity for Public Comment on the Proposed Model
Safety Evaluation for Plant-Specific Adoption of Technical
Specification Task Force Traveler-513, Revision 2, ``Revise PWR
Operability Requirements and Actions for RCS Leakage Instrumentation''
AGENCY: Nuclear Regulatory Commission (NRC).
ACTION: Notice of opportunity for public comment.
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SUMMARY: The NRC is requesting public comment on the enclosed proposed
model safety evaluation, model no significant hazards consideration
determination, and model application for plant-specific adoption of
Technical Specification Task Force (TSTF) Traveler-513, Revision 2,
``Revise PWR Operability Requirements and Actions for RCS Leakage
Instrumentation.'' The TSTF Traveler-513, Revision 2, is available in
the Agencywide Documents Access Management System (ADAMS) under
Accession Number ML091810158. The proposed changes revise Standard
Technical Specification (STS) [3.4.15], ``[Reactor Coolant System (RCS)
Leakage Detection Instrumentation].'' The proposed changes also revise
the STS Bases to clearly define the RCS leakage detection
instrumentation Operability requirements in the Limiting Condition for
Operation (LCO) Bases, eliminate discussion from the STS Bases that
could be erroneously construed as Operability requirements, and reflect
the changes to the TSs. This model safety evaluation will facilitate
expedited approval of plant-specific adoption of TSTF Traveler-513,
Revision 2.
DATES: Comment period expires November 9, 2009 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: You may submit comments by any one of the following methods.
Please include Docket ID NRC-2009-0444 in the subject line of your
comments. Comments submitted in writing or in electronic form will be
posted on the NRC Web site and on the Federal rulemaking Web site
Regulations.gov. Because your comments will not be edited to remove any
identifying or contact information,
[[Page 52269]]
the NRC cautions you against including any information in your
submission that you do not want to be publicly disclosed.
The NRC requests that any party soliciting or aggregating comments
received from other persons for submission to the NRC inform those
persons that the NRC will not edit their comments to remove any
identifying or contact information, and therefore, they should not
include any information in their comments that they do not want
publicly disclosed.
Federal Rulemaking Web site: Go to http://www.regulations.gov and
search for documents filed under Docket ID NRC-2009-0444. Address
questions about NRC dockets to Carol Gallagher 301-492-3668; e-mail
[email protected].
Mail comments to: Michael T. Lesar, Chief, Rulemaking and
Directives Branch (RDB), Division of Administrative Services, Office of
Administration, Mail Stop: TWB-05-B01M, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001, or by fax to RDB at (301) 492-
3446.
You can access publicly available documents related to this notice
using the following methods:
NRC's Public Document Room (PDR): The public may examine and have
copied for a fee publicly available documents at the NRC's PDR, Public
File Area O1 F21, One White Flint North, 11555 Rockville Pike,
Rockville, Maryland.
NRC's Agencywide Documents Access and Management System (ADAMS):
Publicly available documents created or received at the NRC are
available electronically at the NRC's Electronic Reading Room at http://www.nrc.gov/reading-rm/adams.html. From this page, the public can gain
entry into ADAMS, which provides text and image files of NRC's public
documents. If you do not have access to ADAMS or if there are problems
in accessing the documents located in ADAMS, contact the NRC's PDR
reference staff at 1-800-397-4209, 301-415-4737, or by e-mail to
[email protected]. The Proposed Model Safety Evaluation for Plant-
Specific Adoption of TSTF Traveler-513, Revision 2, available
electronically under ADAMS Accession Number ML092460664.
Federal Rulemaking Web site: Public comments and supporting
materials related to this notice can be found at http://www.regulations.gov by searching on Docket ID: NRC-2009-0444.
FOR FURTHER INFORMATION CONTACT: Ms. Michelle C. Honcharik, Senior
Project Manager, Special Projects Branch, Mail Stop: O-12D1, Division
of Policy and Rulemaking, Office of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Commission, Washington, DC, 20555-0001; telephone
301-415-1774 or e-mail at [email protected].
SUPPLEMENTARY INFORMATION:
Background
This notice provides an opportunity for the public to comment on
proposed changes to the Standard TS (STS) after a preliminary
assessment and finding by the NRC staff that the agency will likely
offer the changes for adoption by licensees. This notice solicits
comment on a proposed change to the STS, which if implemented by a
licensee will modify the plant-specific TS. The NRC staff will evaluate
any comments received for the proposed change to the STS and 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 NRC staff's evaluation, referencing the applicable
technical justifications, and providing any necessary plant-specific
information. The NRC will process and note each amendment application
responding to the notice of availability according to applicable NRC
rules and procedures.
Applicability
TSTF Traveler-513, Revision 2, is applicable to pressurized water
reactors. The Traveler revises the TS and TS Bases to clearly define
the RCS leakage detection instrumentation Operability requirements as
well as revise Conditions and Required Actions related to leakage
detection instrumentation.
The proposed change does not prevent licensees from requesting an
alternate approach or proposing changes other than those proposed in
TSTF Traveler-513, Revision 2. However, significant deviations from the
approach recommended in this notice or the inclusion of additional
changes to the license require additional NRC staff review. This may
increase the time and resources needed for the review or result in NRC
staff rejection of the license amendment request (LAR). Licensees
desiring significant deviations or additional changes should instead
submit an LAR that does not claim to adopt TSTF Traveler-513, Revision
2.
Dated at Rockville, Maryland, this 24th day of September 2009.
For the Nuclear Regulatory Commission.
Stacey L. Rosenberg,
Chief, Special Projects Branch, Division of Policy and Rulemaking,
Office of Nuclear Reactor Regulation.
Proposed Model Application for Plant-Specific Adoption of TSTF
Traveler-513, Revision 2, ``Revise PWR Operability Requirements and
Actions for RCS Leakage Instrumentation''
U.S. Nuclear Regulatory Commission, Document Control Desk, Washington,
DC 20555.
Subject: [Plant Name]
DOCKET NO. 50-[XXX]
LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION
TASK FORCE (TSTF) TRAVLER-513, REVISION 2, ``REVISE PWR OPERABILITY
REQUIREMENTS AND ACTIONS FOR RCS LEAKAGE INSTRUMENTATION''
In accordance with the provisions of Section 50.90 of Title 10 of
the Code of Federal Regulations (10 CFR), [LICENSEE] is submitting a
request for an amendment to the Technical Specifications (TS) for
[PLANT NAME, UNIT NO.].
The proposed amendment would revise the TS and TS Bases to clearly
define the Reactor Coolant System (RCS) leakage detection
instrumentation Operability requirements as well as revise Conditions
and Required Actions related to leakage detection instrumentation. The
revised Required Actions employ alternate methods of monitoring RCS
leakage when one or more required monitors are inoperable. This change
is consistent with NRC approved Revision 2 to TSTF Improved Standard
Technical Specification (STS) Change Traveler-513, ``Revise PWR
Operability Requirements and Actions for RCS Leakage Instrumentation''
[Discuss any differences with Traveler-513, Revision 2.] The
availability of this TS improvement was announced in the Federal
Register on [Date] ([ ] FR [ ]) as part of the consolidated line item
improvement process (CLIIP).
The proposed amendment contains a less restrictive TS change. The
less restrictive change is justified because alternate RCS leakage
monitoring methods are required to be performed when no required
monitoring methods are Operable. Further detailed justification is
contained in Attachment 1.
Attachment 1 provides a description of the proposed change.
Attachment 2 provides the existing TS pages marked to show the proposed
change. Attachment 3 provides the existing TS
[[Page 52270]]
Bases pages marked up to show the proposed change. Attachment 4
provides the proposed TS changes in final typed format. Attachment 5
provides the proposed TS Bases changes in final typed format.
Attachment 6 provides the regulatory commitment[s].
[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, ``Notice for Public Comment; State
Consultation,'' 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 correct and true.
Executed on [date] [Signature].
If you should have any questions about this submittal, please
contact [NAME, TELEPHONE NUMBER].
Sincerely,
[Name, Title]
Attachments: 1. Evaluation of Proposed Change
2. Proposed Technical Specification Changes (Mark-Up)
3. Proposed Technical Specification Bases Changes (Mark-Up)
4. Proposed Technical Specification Change (Re-Typed)
5. Proposed Technical Specification Bases Changes (Re-Typed)
6. List of Regulatory Commitments
cc: [NRR Project Manager]
[Regional Office]
[Resident Inspector]
[State Contact]
Evaluation of Proposed Change
1.0 Description
The proposed amendment would revise the Technical Specification
(TS) and TS Bases to clearly define the Reactor Coolant System (RCS)
leakage detection instrumentation Operability requirements as well as
revise Conditions and Required Actions related to leakage detection
instrumentation. This change is consistent with NRC-approved Revision 2
to Technical Specification Task Force (TSTF) Improved Standard
Technical Specification (STS) Change Traveler-513, ``Revise PWR
Operability Requirements and Actions for RCS Leakage Instrumentation.''
[Minor differences between the proposed plant-specific TS changes, and
the changes proposed by Traveler-513 are listed in Section 2.0.] The
availability of this TS improvement was announced in the Federal
Register on [Date] ( ] FR [ ]) as part of the consolidated line item
improvement process (CLIIP).
2.0 Proposed Change
Consistent with the NRC-approved Revision 2 of Traveler-513, the
proposed changes revise and add a new Condition to TS [3.4.15], ``[RCS
Leakage Detection Instrumentation],'' and revise the associated bases.
New Condition [D] is applicable when the containment atmosphere gaseous
radioactivity monitor is the only Operable monitor (i.e., all other
monitors are inoperable). The Required Actions require analyzing grab
samples of the containment atmosphere or performing an RCS water
inventory balance every 12 hours and restoring another monitor within 7
days. Existing Condition [F] applies when all required monitors are
inoperable and requires immediate entry into Limiting Condition for
Operation (LCO) 3.0.3. This Condition is revised to require obtaining
and analyzing a containment atmosphere grab sample and performance of
an RCS water inventory balance every 6 hours. At least one RCS leakage
detection monitor must be restored within 72 hours or a plant shutdown
is required. Existing Condition [E] applies when the Required Actions
and associated Completion Times are not met. It is moved to the last
Condition and applies to all the previous Conditions. The TS Bases are
revised to clearly define the RCS leakage detection instrumentation
Operability requirements in the LCO Bases, eliminate discussion from
the Bases that could be erroneously construed as Operability
requirements, and reflect the changes to the TSs.
[The proposed changes also correct inappropriate references to
``required'' equipment in TS [3.4.15]. In several locations the
specifications incorrectly refer to a ``required'' [equipment name].
The term ``required'' is reserved for situations in which there are
multiple ways to meet the LCO, such as the requirement for either a
gaseous or particulate radiation monitor. The incorrect use of the term
``required'' is removed from TS [3.4.15] Conditions [A, B, and C].
[LICENSEE] is [not] proposing variations or deviations from the TS
changes described in Traveler-513, Revision 2, or the NRC staff's model
safety evaluation published on [DATE] ([ ] FR [ ]) as part of the CLIIP
Notice of Availability. [Discuss any differences with Traveler-513,
Revision 2 and the effect of any changes on the NRC staff's model
safety evaluation.]
3.0 Background
The background for this application is adequately addressed by the
NRC Notice of Availability published on [DATE] ([ ] FR [ ]).
4.0 Technical Analysis
The proposed amendment contains a less restrictive TS change to
existing Condition [F]. The proposed Required Actions for Condition [F]
would eliminate the requirement to immediately enter LCO 3.0.3 and
would add the requirement to analyze grab samples of the containment
atmosphere once per 6 hours, perform an RCS water inventory balance
once per 6 hours per Surveillance Requirement 3.4.13.1, and restore at
least one RCS leakage detection monitor to Operable status within 72
hours. The less restrictive change is justified because alternate RCS
leakage monitoring methods are required to be performed when no
monitoring methods are operable. These alternate methods provide an RCS
leakage detection capability similar to the required methods. The RCS
mass balance is capable of identifying a one gallon per minute (gpm)
RCS leak rate and uses instrumentation readily available to control
room operators. The grab sample has an RCS leakage detection capability
that is comparable to that of the containment particulate radiation
monitor. The proposed Actions and Completion Times for grab samples and
mass balance calculations are adequate because use of frequent grab
samples and RCS mass balance calculations provide assurance that any
significant RCS leakage will be detected prior to significant RCS
pressure boundary degradation. The proposed 72 hour Completion Time for
Restoration of at least one RCS leakage detection monitor to Operable
status is appropriate given the low probability of significant RCS
leakage during the time when no required RCS leakage detection monitors
are Operable, and the need for time to restore at least one monitor to
Operable status.
[LICENSEE] has reviewed the safety evaluation published on [DATE]
([ ] FR [ ]) as part of the CLIIP Notice of Availability. [LICENSEE]
has concluded that the technical justifications presented in the safety
evaluation prepared by the NRC staff are applicable to [PLANT, UNIT
NO.].
5.0 Regulatory Safety Analysis
5.1 No Significant Hazards Determination
[LICENSEE] has reviewed the no significant hazards determination
published on [DATE] ([] FR []) as part of the CLIIP Notice of
Availability. [LICENSEE] and has concluded that the determination
presented in the notice is
[[Page 52271]]
applicable to [PLANT, UNIT NO.]. [LICENSEE] has evaluated the proposed
changes to the TS using the criteria in 10 CFR 50.92 and has determined
that the proposed changes do not involve a significant hazards
consideration. An analysis of the issue of no significant hazards
consideration is presented below:
[LICENSEE INSERT ANALYSIS HERE.]
5.2 Applicable Regulatory Requirements/Criteria
A description of the proposed TS change and its relationship to
applicable regulatory requirements was provided in the NRC Notice of
Availability published on [DATE] ([] FR []). [LICENSEE] has reviewed
the NRC staff's model safety evaluation published on [DATE] ([] FR[])
as part of the CLIIP Notice of Availability and concluded that the
regulatory evaluation section is applicable to [PLANT, UNIT NO.].
6.0 Environmental Consideration
[LICENSEE] has reviewed the environmental evaluation included in
the model safety evaluation published on [DATE] ([] FR []) as part of
the CLIIP Notice of Availability. [LICENSEE] has concluded that the NRC
staff's findings presented in that evaluation are applicable to [PLANT,
NO.].
The proposed change would change a requirement with respect to
installation or use of a facility component located within the
restricted area, as defined in 10 CFR 20, and would change an
inspection or surveillance requirement. However, the proposed change
does not involve (i) a significant hazards consideration, (ii) a
significant change in the types or significant increase in the amounts
of any effluent that may be released offsite, or (iii) a significant
increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed change meets the eligibility criterion for
categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore,
pursuant to 10 CFR 51.22(b), no environmental impact statement or
environmental assessment need be prepared in connection with the
proposed change.
7.0 References
1. Federal Register Notice, Notice of Availability published on
[DATE] ([ ] FR [ ]).
2. TSTF-513, Revision 2, ``Revise PWR Operability Requirements and
Actions for RCS Leakage Instrumentation.''
[3. Other References]
Proposed Model No Significant Hazards Consideration Determination for
Plant-Specific Adoption of TSTF Traveler-513, Revision 2, ``Revise PWR
Operability Requirements and Actions for RCS Leakage Instrumentation''
Description of Amendment Request: The proposed amendment would
revise Technical Specification (TS) [3.4.15], ``[Reactor Coolant System
(RCS) Leakage Detection Instrumentation.]'' Conditions and Required
Actions as well as make associated TS Bases changes for TS [3.4.15].
Basis for proposed no significant hazards consideration: As
required by Title10 of the Code of Federal Regulations (10 CFR) Section
50.91(a), the [LICENSEE] 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 change clarifies the Operability requirements for
the RCS leakage detection instrumentation and reduces the time
allowed for the plant to operate when the only Operable RCS leakage
instrumentation monitor is the containment atmosphere gaseous
radiation monitor. The proposed change also extends the allowed
operating time when all RCS leakage instrumentation is inoperable.
The monitoring of RCS leakage is not a precursor to any accident
previously evaluated. The monitoring of RCS leakage is not used to
mitigate the consequences of any accident previously evaluated.
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 change clarifies the Operability requirements for
the RCS leakage detection instrumentation and reduces the time
allowed for the plant to operate when the only Operable RCS leakage
instrumentation monitor is the containment atmosphere gaseous
radiation monitor. The proposed change also extends the allowed
operating time when all RCS leakage instrumentation is inoperable.
The proposed change does not involve a physical alteration of the
plant (no new or different type of equipment will be installed) or a
change in the methods governing normal plant operation. The proposed
change maintains sufficient continuity and diversity of leak
detection capability that the probability of piping evaluated and
approved for Leak-Before-Break progressing to pipe rupture remains
extremely low. Therefore, the proposed change does not create the
possibility of a new or different kind of accident from any
previously evaluated.
3: Does the Proposed Change Involve a Significant Reduction in a
Margin of Safety?
Response: No.
The proposed change clarifies the Operability requirements for
the RCS leakage detection instrumentation and reduces the time
allowed for the plant to operate when the only Operable RCS leakage
instrumentation monitor is the containment atmosphere gaseous
radiation monitor. The proposed change also extends the allowed
operating time when all RCS leakage instrumentation is inoperable to
allow time to restore at least one RCS leakage monitoring instrument
to Operable status. Reducing the amount of time the plant is allowed
to operate with only the containment atmosphere gaseous radiation
monitor Operable increases the margin of safety by increasing the
likelihood that an increase in RCS leakage will be detected before
it potentially results in gross failure. Allowing a limited period
of time to restore at least one RCS leakage monitoring instrument to
Operable status before requiring a plant shutdown avoids putting the
plant through a thermal transient without RCS leakage monitoring.
Therefore, the proposed change does not involve a significant
reduction in a margin of safety.
Based upon the reasoning presented above, the NRC staff concludes
that the requested change does not involve a significant hazards
consideration, as set forth in 10 CFR 50.92(c), ``Issuance of
Amendment.''
Proposed Model Safety Evaluation for Plant-Specific Adoption of
Technical Specification Task Force Traveler-513, Revision 2, ``Revise
PWR Operability Requirements and Actions for RCS Leakage
Instrumentation''
1.0 Introduction
By letter dated [DATE], [LICENSEE] (the licensee) proposed changes
to the technical specifications (TS) for [PLANT NAME]. The proposed
changes revise TS [3.4.15], ``[Reactor Coolant System (RCS) Leakage
Detection Instrumentation].'' The proposed changes also revise the TS
Bases to clearly define the RCS leakage detection instrumentation
Operability requirements in the Limiting Condition for Operation (LCO)
Bases, eliminate discussion from the TS Bases that could be erroneously
construed as Operability requirements, and reflect the changes to the
TSs.
The licensee stated that the application is consistent with NRC-
approved Revision 2 to Technical Specification Task Force (TSTF)
Improved Standard Technical Specification (STS) Change Traveler-513,
``Revise PWR Operability Requirements and Actions for RCS Leakage
Instrumentation.'' [Discuss any differences with TSTF-513, Revision 2.]
The availability of this TS improvement
[[Page 52272]]
was announced in the Federal Register on [Date] ([ ] FR [ ]) as part of
the consolidated line item improvement process (CLIIP).
2.0 Regulatory Evaluation
The regulation in General Design Criterion (GDC) 30 of Appendix A
to Title 10 of the Code of Federal Regulations (10 CFR) Part 50,
``Quality of Reactor Coolant Pressure Boundary,'' requires means for
detecting and, to the extent practical, identifying the location of the
source of RCS Leakage. Regulatory Guide (RG) 1.45, Revision 0,
``Reactor Coolant Pressure Boundary Leakage Detection Systems,'' May
1973, describes acceptable methods of implementing the GDC 30
requirements with regard to the selection of leakage detection systems
for the Reactor Coolant Pressure Boundary (RCPB). Revision 1 of RG 1.45
was issued in May 2008. RG 1.45, Revision 1, describes different
methods of implementing the GDC 30 requirements compared to RG 1.45,
Revision 0, and was intended to be applicable only to new reactors.
Therefore, operating nuclear power plants are not committed to Revision
1 of RG 1.45.
RG 1.45, Revision 0, Regulatory Position C.2, states that ``Leakage
to the primary reactor containment from unidentified sources should be
collected and the flow rate monitored with an accuracy of one gallon
per minute (gpm) or better.'' Regulatory Position C.3 states, ``At
least three separate detection methods should be employed and two of
these methods should be (1) sump level and flow monitoring and (2)
airborne particulate radioactivity monitoring. The third method may be
selected from the following: (a) monitoring of condensate flow rate
from air coolers or (b) monitoring of airborne gaseous radioactivity.
Humidity, temperature, or pressure monitoring of the containment
atmosphere should be considered as alarms or indirect indication of
leakage to the containment.'' Regulatory Position C.5 states, ``The
sensitivity and response time of each leakage detection system in
regulatory position 3 above employed for unidentified leakage should be
adequate to detect a leakage rate, or its equivalent, of one gpm in
less than one hour.'' RG 1.45, Revision 0, states, ``In analyzing the
sensitivity of leak detection systems using airborne particulate or
gaseous radioactivity, a realistic primary coolant radioactivity
concentration assumption should be used. The expected values used in
the plant environmental report would be acceptable.'' The appropriate
sensitivity of a plant's containment atmosphere gaseous radioactivity
monitors is dependent on the design assumptions and the plant-specific
licensing basis as described in the plant's updated final safety
analysis report (UFSAR).
As stated in NRC Information Notice (IN) 2005-24, ``Nonconservatism
in Leakage Detection Sensitivity,'' the reactor coolant activity
assumptions for containment atmosphere gaseous radioactivity monitors
may be nonconservative. This means the monitors may not be able to
detect a one gpm leak within one hour under all likely operating
conditions.
The NRC's regulatory requirements related to the content of the TS
are contained in 10 CFR Part 50.36. Paragraph (c)(2)(ii) of 10 CFR
50.36 lists criteria for determining whether particular items are
required to be included in the TS LCOs. Criterion 1 of that regulation
applies to installed instrumentation that is used to detect, and
indicate in the control room, a significant abnormal degradation of the
reactor coolant pressure boundary. As described in the Federal Register
Notice associated with this regulation (60 FR 36953, July 16, 1995),
this criterion is intended to apply to process variables that alert the
operator to a situation when accident initiation is more likely.
The NRC's guidance for the format and content of PWR TS can be
found in NUREG-1430, Revision 3.0, ``Standard Technical Specifications
Babcock and Wilcox Plants,'' NUREG-1431, Revision 3.0, ``Standard
Technical Specifications Westinghouse Plants,'' and NUREG-1432,
Revision 3.0, ``Standard Technical Specifications Combustion
Engineering Plants.'' STS 3.4.15, ``RCS Leakage Detection
Instrumentation'' contains the guidance specific to the RCS leakage
detection instrumentation for PWRs. The STS Bases provide a summary
statement of the reasons for the STS. Operability requirements should
be defined in the LCO section of the STS Bases.
The STS Bases for STS 3.4.15 contained in NUREG-1430, Revision 3.0;
NUREG-1431, Revision 3.0; and NUREG-1432, Revision 3.0, included
information that could be construed as Operability requirements in the
Background, Applicable Safety Analysis, and LCO sections. These STS
Bases did not accurately describe the Operability of a detector as
being based on the design assumptions and licensing basis for the
plant. This situation and the issue described in IN 2005-24 have caused
questions to arise regarding the Operability requirements for
containment atmosphere gaseous radioactivity monitors. Traveler-513,
Revision 2, contained changes to the STS Bases that revised PWR
Operability requirements. In addition, Traveler-513, Revision 2,
includes NRC-approved revisions to TS Actions for RCS Leakage
Instrumentation that recognize the potentially reduced sensitivity of
the gaseous radioactivity instrument and more appropriate actions when
all RCS leakage detection instrumentation is inoperable.
2.1 Adoption of Traveler-513, Revision 2, by [Facility Name]
Proper plant-specific adoption of Traveler-513, Revision 2, by
[licensee] will revise the RCS Leakage Detection Instrumentation TS and
TS Bases and clarify the Operability requirements for RCS Leakage
Detection Instrumentation.
The NRC staff reviewed the proposed changes for compliance with 10
CFR 50.36 and agreement with the precedent as established in NUREG-
[1430, 1431, or 1432]. In general, licensees cannot justify technical
specification changes solely on the basis of adopting the model STS. To
ensure this, the NRC staff makes a determination that proposed changes
maintain adequate safety. Changes that result in relaxation (less
restrictive condition) of current TS requirements require detailed
justification.
In general, there are two classes of changes to TSs: (1) Changes
needed to reflect contents of the design basis (TSs are derived from
the design basis), and (2) voluntary changes to take advantage of the
evolution in policy and guidance as to the required content and
preferred format of TSs over time. This amendment request deals with
both classes of change. The amendment request includes proposed changes
to the TS Bases to more accurately reflect the contents of the facility
design basis related to operability of the RCS leakage detection
instrumentation and proposed changes to the TS that take advantage of
revised guidance on required actions for inoperable RCS leakage
detection instrumentation. Guidelines for TS and TS Bases content are
found in NUREG-[1430, 1431, or 1432], as amended by Traveler-513,
Revision 2.
Licensees may revise the TSs to adopt improved STS format and
content provided that plant-specific review supports a finding of
continued adequate safety because: (1) The change is editorial,
administrative or provides clarification (i.e., no requirements are
materially altered), (2) the change is more restrictive than the
licensee's current requirement, or (3) the change is less restrictive
than the licensee's current requirement, but nonetheless still affords
adequate assurance of safety when judged against current regulatory
[[Page 52273]]
standards. The detailed application of this general framework, and
additional specialized guidance, are discussed in Section 3.0 in the
context of specific proposed changes.
3.0 Technical Evaluation
The current Bases for TS [3.4.15], ``[Reactor Coolant System (RCS)
Leakage Detection Instrumentation],'' do not clearly define the basis
for Operability for the RCS Leakage Instrumentation. The current TS
Bases contain information that could be construed as Operability
requirements in the Background, Applicable Safety Analysis, and LCO
sections. In addition, the current TS Bases do not accurately describe
the Operability of a detector as being based on the design assumptions
and licensing basis for the plant.
In adopting Traveler-513, Revision 2, the licensee proposed changes
that would revise the Bases for TS [3.4.15] to clearly define the RCS
leakage detection instrumentation Operability requirements in the LCO
Bases and reflect the changes to the TSs. The proposed changes to the
Operability requirements included in the LCO Bases are acceptable
because they define, consistent with the design basis of the facility,
the minimum set of diverse instruments that must be operable, the plant
parameters monitored by the instrumentation, the design sensitivity of
the leakage detection instruments, and factors that affect the
operational sensitivity of the instrument. These instruments satisfy
Criterion 1 of 10 CFR 50.36(c)(2)(ii) in that they are installed
instrumentation that is used to detect, and indicate in the control
room, a significant abnormal degradation of the reactor coolant
pressure boundary.
In adopting the changes to TS included in Traveler-513, Revision 2,
the licensee also proposed to revise TS [3.4.15], ``[Reactor Coolant
System (RCS) Leakage Detection Instrumentation]'' Conditions and
Required Actions. The licensee proposed adding new Condition [D] to TS
[3.4.15]. New Condition [D] would be applicable when the containment
atmosphere gaseous radioactivity monitor is the only operable RCS
leakage detection monitor. The proposed Required Actions for new
Condition [D] require the licensee to analyze grab samples of the
containment atmosphere once per 12 hours and restore the required
containment sump monitor to Operable status within seven days, or
analyze grab samples of the containment atmosphere once per 12 hours
and restore the containment air cooler condensate flow rate monitor to
Operable status within 7 days. The NRC staff determined that the
proposed change is more restrictive than the current requirement,
because there is no current Condition for the situation when the
containment atmosphere gaseous radioactivity monitor is the only
operable RCS leakage detection monitor. The proposed Actions and
Completion Times are adequate because the grab samples will provide an
alternate method of monitoring RCS leakage when the containment
atmosphere gaseous radioactivity monitor is the only operable RCS
leakage detection monitor and the 12-hour interval is sufficient to
detect increasing RCS leakage. In addition, Surveillance Requirement
(SR) 3.4.13.1 requires verification that RCS operational leakage is
within limits by performance of an RCS water inventory balance at a
frequency of once per 72 hours, which provides periodic confirmation
that RCS leakage is within limits using diverse instrumentation.
Allowing 7 days to restore another RCS leakage monitor to Operable
status ensures that the plant will not be operated in a degraded
configuration for a long time.
Existing TS [3.4.15] Condition [F] is applicable when all required
RCS leakage detection monitors are inoperable. The current Required
Action for Condition [F] is to immediately enter LCO 3.0.3. The
licensee proposed modifying the Required Actions for Condition [F]. The
proposed Required Actions for Condition [F] would eliminate the
requirement to immediately enter LCO 3.0.3 and would add the
requirement to analyze grab samples of the containment atmosphere once
per 6 hours, perform an RCS water inventory balance once per 6 hours
per SR 3.4.13.1, and restore at least one RCS leakage detection monitor
to Operable status within 72 hours. The NRC staff determined that the
proposed change is less restrictive than the current requirement
because it would allow a longer time to operate when all required RCS
leakage detection monitors are inoperable.
The licensee provided justification for the less restrictive change
in its LAR, which the NRC staff reviewed. The grab sample has an RCS
leakage detection capability that is comparable to that of the
containment particulate radiation monitor. The RCS water inventory
balance is capable of identifying a one-gpm RCS leak rate and uses
instrumentation readily available to control room operators. The
proposed Actions and Completion Times for grab samples and water
inventory balance calculations are adequate because use of frequent
grab samples and RCS water inventory balance calculations provide
assurance that any significant RCS leakage will be detected prior to
significant RCS pressure boundary degradation. The proposed 72-hour
Completion Time for Restoration of at least one RCS leakage detection
monitor to Operable status is appropriate given the low probability of
significant RCS leakage during the time when no required RCS leakage
detection monitors are Operable, and the need for time to restore at
least one monitor to Operable status.
[Facility] has been licensed for Leak-Before-Break (LBB). The basic
concept of LBB is that certain piping material has sufficient fracture
toughness (i.e., ductility) to resist rapid flaw propagation. The
licensee has evaluated postulated flaws in [RCS loop] piping and
determined the piping has sufficient fracture toughness that the
postulated flaw would not lead to pipe rupture and potential damage to
adjacent safety related systems, structures and components before the
plant could be placed in a safe, shutdown condition. The NRC staff has
previously reviewed and approved these analyses. Before pipe rupture,
the postulated flaw would lead to limited but detectable leakage, which
would be identified by the leak detection systems in time for the
operator to take action. The proposed actions for inoperable RCS
leakage detection instrumentation maintain sufficient continuity and
diversity of leakage detection capability that an extremely low
probability of undetected leakage leading to pipe rupture is
maintained. This extremely low probability of pipe rupture continues to
satisfy the basis for acceptability of LBB.
The licensee proposed minor changes to ensure continuity of the TS
format. These changes re-lettered current Condition [D], which applies
when the containment sump monitor is the only operable leakage
detection instrument, to Condition [E], and current Condition [E],
which applies when the required action and the associated completion
time are not satisfied, to Condition [G]. Similar changes were made to
the associated Required Actions. The NRC staff determined that these
changes were editorial, and therefore acceptable.
The NRC staff evaluated the licensee's proposed change against the
applicable regulatory requirements listed in Section 2 of this safety
evaluation. The NRC staff also compared the proposed change to the
change made to STS by Traveler-513, Revision 2. The NRC staff
determined that all the proposed changes afford adequate assurance of
safety when judged against current regulatory standards. Therefore, the
[[Page 52274]]
NRC staff finds the proposed changes acceptable.
4.0 Conclusions
The Commission has concluded, based on 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
amendment will not be inimical to the common defense and security or to
the health and safety of the public.
5.0 State Consultation
In accordance with the Commission's regulations, the [ ] State
official was notified of the proposed issuance of the amendment. The
State official had [(1) no comments or (2) the following comments--with
subsequent disposition by the NRC staff].
6.0 Environmental Consideration
The amendment changes 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, ``Standards for
Protection Against Radiation.'' The NRC staff has determined that the
amendment involves no significant increase in the amounts and no
significant change in the types of any effluents that may be released
offsite and that there is no significant increase in individual or
cumulative occupational radiation exposure. The Commission has
previously issued a proposed finding that the amendment involves no
significant hazards considerations, and there has been no public
comment on the finding [FR]. Accordingly, the amendment meets the
eligibility criteria for categorical exclusion set forth in 10 CFR
51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact
statement or environmental assessment need be prepared in connection
with the issuance of the amendments.
7.0 References
1. [Licensee] Licensee Amendment Request to adopt TSTF-513, [DATE].
2. Federal Register Notice, Notice of Availability published on
[DATE] ([ ] FR [ ]).
3. TSTF Traveler-513, Revision 2, ``Revise PWR Operability
Requirements and Actions for RCS Leakage Instrumentation''.
[FR Doc. E9-24407 Filed 10-8-09; 8:45 am]
BILLING CODE 7590-01-P