ML17080A415
| ML17080A415 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 07/03/2017 |
| From: | Jennifer Whitman NRC/NRR/DSS/STSB |
| To: | |
| Honcharik M, NRR/DSS, 301-415-1774 | |
| Shared Package | |
| ML17080A409 | List: |
| References | |
| TAC MF5125 | |
| Download: ML17080A415 (10) | |
Text
ENCLOSURE 2 DRAFT MODEL SAFETY EVALUATION 1
BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2
TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 3
TSTF-551, REVISION 3, 4
REVISE SECONDARY CONTAINMENT SURVEILLANCE REQUIREMENTS 5
6
1.0 INTRODUCTION
7 8
By application dated [enter date], (Agencywide Documents Access and Management System 9
(ADAMS) Accession No. [MLXXXXXXXXX], [name of licensee] (the licensee) requested 10 changes to the technical specifications (TS) for [name of facility]. Specifically, the licensee 11 requested changes to the TSs to adopt Technical Specifications Task Force (TSTF) traveler, 12 TSTF-551, Revision 3, Revise Secondary Containment Surveillance Requirements, dated 13 October 3, 2016 (ADAMS Accession No. ML16277A226). The NRC approved the traveler on 14 Month, Day, 2017 (ADAMS Accession No. MLXXXX).
15 16 The proposed changes would allow the [secondary] containment vacuum limit to not be met 17 provided that the standby gas treatment (SGT) system remains capable of establishing the 18 required [secondary] containment vacuum within the [specified time] and revises the TS to 19 permit [secondary] containment access opening to be open to permit ingress and egress.
20 21
2.0 REGULATORY EVALUATION
22 23 2.1 SYSTEM DESCRIPTION 24 25 The [secondary] containment is a structure that encloses the primary containment, including 26 components that may contain primary system fluid. The safety function of the [secondary]
27 containment is to contain, dilute, and hold up fission products that may leak from primary 28 containment following a design basis accident (DBA) to ensure the control room operator and 29 offsite doses are within the regulatory limits. There is no redundant train or system that can 30 perform the [secondary] containment function should the [secondary] containment be 31 inoperable.
32 33 The [secondary] containment boundary is the combination of walls, floor, roof, ducting, doors, 34 hatches, penetrations and equipment that physically form the [secondary] containment.
35 Routinely used [secondary] containment access openings contain at least one inner and one 36 outer door in an airlock configuration. In some cases, [secondary] containment access 37 openings are shared such that there are multiple inner or outer doors. All [secondary]
38 containment access doors are normally kept closed, except when the access opening is being 39 used for entry and exit of personnel, equipment, or material.
40 41
[Secondary] containment operability is based on its ability to contain, dilute, and hold up fission 42 products that may leak from primary containment following a DBA. To prevent ground level 43 exfiltration of radioactive material while allowing the [secondary] containment to be designed 1
as a mostly conventional structure, the [secondary] containment requires support systems to 2
maintain the pressure at less than atmospheric pressure. During normal operation, non-safety 3
related systems are used to maintain the [secondary] containment at a slight negative pressure 4
to ensure any leakage is into the building and that any [secondary] containment atmosphere 5
exiting is via a pathway monitored for radioactive material. However, during normal operation it 6
is possible for the [secondary] containment vacuum to be momentarily less than the required 7
vacuum for a number of reasons, such as during wind gusts or swapping of the normal 8
ventilation subsystems.
9 10 During emergency conditions, the SGT system is designed to be capable of drawing down the 11
[secondary] containment to a required vacuum within a prescribed time and continue to 12 maintain the negative pressure as assumed in the accident analysis. For [name of facility], the 13 SGT must be able to establish the required vacuum within [insert time requirement]. The leak 14 tightness of the [secondary] containment together with the SGT system ensure that radioactive 15 material is either contained in the [secondary] containment or filtered through the SGT system 16 filter trains before being discharged to the outside environment via the elevated release point.
17 18 2.2 PROPOSED TECHNICAL SPECIFICATION CHANGES 19 20 The proposed changes would allow the [secondary] containment vacuum limit to not be met 21 provided the SGT system remains capable of establishing the required [secondary]
22 containment vacuum. The proposed changes would also allow for the temporary opening of the 23 inner and outer doors of [secondary] containment for the purpose of ingress and egress (i.e.,
24 normal opening and prompt closure of a door for transit).
25 26 2.2.1 Revision to Surveillance Requirement 3.6.4.1.1 27 28
[NOTE: This change is applicable to NUREGs-1433 and -1434.]
29 30 Surveillance requirement (SR) 3.6.4.1.1 requires verification that [secondary] containment 31 vacuum is [0.25] inch of vacuum water gauge. This SR would be modified by a note that 32 states:
33 34 Not required to be met for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if analysis demonstrates one 35 standby gas treatment (SGT) subsystem is capable of establishing 36 the required [secondary] containment vacuum.
37 38 2.2.2 Revision to Surveillance Requirement 3.6.4.1.3 39 40
[NOTE: This change is applicable to NUREG-1433 only.]
41 42 SR 3.6.4.1.3 requires verification that one [secondary] containment access door in each 43 access opening is closed. This SR would be modified by adding the following phrase to the end 44 of the SR statement, except when the access opening is being used for entry and exit.
45 46 2.2.3 Revision to Surveillance Requirement 3.6.4.1.4 47 48 An editorial change is made to SR 3.6.4.1.4 in which the words standby gas treatment are 1
replaced with the initialism SGT.
2 3
2.3 REGULATORY REQUIREMENTS AND GUIDANCE 4
5 The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) 6 requires an applicant for an operating license to include in the application proposed TS in 7
accordance with the requirements of 10 CFR 50.36. The applicant must include in the 8
application, a summary statement of the bases or reasons for such specifications, other than 9
those covering administrative controls. However, per 10 CFR 50.36(a)(1), these technical 10 specification bases shall not become part of the technical specifications.
11 12 Additionally, 10 CFR 50.36(b) requires:
13 14 Each license authorizing operation of a utilization facility will 15 include technical specifications. The technical specifications will 16 be derived from the analyses and evaluation included in the safety 17 analysis report, and amendments thereto, submitted pursuant to 18 10 CFR 50.34 [Contents of applications; technical information].
19 The Commission may include such additional technical 20 specifications as the Commission finds appropriate.
21 22 The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). As required 23 by 10 CFR 50.36(c)(2)(i), the TSs will include limiting conditions for operation (LCOs), which are 24 the lowest functional capability or performance levels of equipment required for safe operation 25 of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the 26 licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the 27 condition can be met.
28 29 The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of SRs, 30 which are requirements relating to test, calibration, or inspection to assure that the necessary 31 quality of systems and components is maintained, that facility operation will be within safety 32 limits, and that the LCOs will be met.
33 34 The NRC staffs guidance for review of TSs is in Chapter 16, Technical Specifications, of 35 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for 36 Nuclear Power Plants (SRP), dated March 2010 (ADAMS Accession No. ML100351425).
37 38 NUREG-0800, SRP Section 15.0.1, Radiological Consequence Analyses Using Alternative 39 Source Terms, Revision 0, dated July 2000 (ADAMS Accession No. ML003734190), provides 40 guidance to the NRC staff for the review of alternate source term (AST) amendment requests.
41 SRP 15.0.1 states that the NRC reviewer should evaluate the proposed change against the 42 guidance in Regulatory Guide (RG) 1.183, Alternative Radiological Source Terms for 43 Evaluating Design Basis Accidents at Nuclear Power Reactors, Revision 0, dated July 2000 44 (ADAMS Accession No. ML003716792).
45 46 RG 1.183 provides acceptable methodology for analyzing the radiological consequences of 47 several design basis accidents to show compliance with 10 CFR 50.67. RG 1.183 provides 48 guidance to licensees on acceptable application of AST (also known as the accident source 49 term) submittals, including acceptable radiological analysis assumptions for use in conjunction 1
with the accepted AST.
2 3
10 CFR 50.67, Accident source term, states that:
4 5
(i)
An individual located at any point on the boundary of the 6
exclusion area for any 2-hour period following the onset of 7
the postulated fission product release, would not receive a 8
radiation dose in excess of 0.25 Sv (25 rem) total effective 9
dose equivalent (TEDE),
10 (ii)
An individual located at any point on the outer boundary of 11 the low population zone, who is exposed to the radioactive 12 cloud resulting from the postulated fission product release 13 (during the entire period of its passage), would not receive 14 a radiation dose in excess of 0.25 Sv (25 rem) TEDE, and 15 (iii)
Adequate radiation protection is provided to permit access 16 to and occupancy of the control room under accident 17 conditions without personnel receiving radiation exposures 18 in excess of 0.05 Sv (5 rem) TEDE for the duration of the 19 accident.
20 21
3.0 TECHNICAL EVALUATION
22 23 The NRC staff evaluated the licensees application to determine if the proposed changes are 24 consistent with the guidance, regulations, and licensing information discussed in Section 2.3 of 25 this safety evaluation (SE). In determining whether an amendment to a license will be issued, 26 the Commission is guided by the considerations that govern the issuance of initial licenses to 27 the extent applicable and appropriate. In making its determination as to whether to amend the 28 license, the NRC staff considered those regulatory requirements that are automatically 29 conditions of the license through 10 CFR 50.54.
30 31 The regulation at 10 CFR 50.36(a)(1) states, in part: A summary statement of the bases or 32 reasons for such specifications shall also be included in the application, but shall not become 33 part of the technical specifications. Accordingly, along with the proposed TS changes, the 34 licensee also submitted TS Bases changes that correspond to the proposed STS changes for 35 information only.
36 37
3.1 PROPOSED CHANGE
TO SURVEILLANCE REQUIREMENT 3.6.4.1.1 38 39 A note is being added to SR 3.6.4.1.1. The note allows the SR to not be met for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if 40 an analysis demonstrates that one SGT subsystem is capable of establishing the required 41
[secondary] containment vacuum. During normal operation, conditions may occur that result in 42 SR 3.6.4.1.1 not being met for short durations. For example, wind gusts that lower external 43 pressure or loss of the normal ventilation system that maintains [secondary] containment 44 vacuum may affect [secondary] containment vacuum. These conditions may not be indicative 45 of degradations of the [secondary] containment boundary or of the ability of the SGT system to 46 perform its specified safety function.
47 48 The note provides an allowance for the licensee to confirm [secondary] containment operability 1
by confirming that one SGT subsystem is capable of performing its specified safety function.
2 This confirmation is necessary to apply the exception to meeting the SR acceptance criterion.
3 While the duration of these occurrences is anticipated to be very brief, the allowance is 4
permitted for a maximum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, [which is consistent with the time permitted for 5
[secondary] containment to be inoperable per [Condition A of LCO 3.6.4.1 or the corresponding 6
Condition for the plant-specific TS].
7 8
The NRC staff has evaluated the impact of this note on the licensees design basis radiological 9
consequence analyses to ensure that the proposed change will not result in an increase in the 10 dose consequences and that the resulting calculated doses remain within the design criteria 11 specified in 10 CFR 50.67 and the accident specific design criteria outlined in RG 1.183.
12 13 The proposed addition of the note to SR 3.6.4.1.1 does not change the TS requirement to meet 14 SR 3.6.4.1.4 and SR 3.6.4.1.5. SR 3.6.4.1.4 requires verification that the [secondary]
15 containment can be drawn down to [0.25] inch of vacuum water gauge in [120] seconds 16 using one SGT subsystem. SR 3.6.4.1.5 requires verification that the [secondary] containment 17 can be maintained [0.25] inch of vacuum water gauge for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> using one SGT subsystem at 18 a flow rate [4000] cubic feet per minute. In addition, TS LCO 3.6.4.3, Standby Gas Treatment 19 (SGT) System, must be met; otherwise the licensee shall shut down the reactor or follow any 20 remedial action permitted by TSs until the condition can be met.
21 22 As discussed above, [secondary] containment operability is based on its ability to contain, 23 dilute, and hold up fission products that may leak from primary containment following a DBA.
24 To prevent ground level exfiltration of radioactive material the [secondary] containment 25 pressure must be maintained at a pressure that is less than atmospheric pressure. The 26
[secondary] containment requires support systems to maintain the control volume pressure 27 less than atmospheric pressure. Following an accident, the SGT system ensures the 28
[secondary] containment pressure is less than the external atmospheric pressure. During 29 normal operation, non-safety related systems are used to maintain the [secondary]
30 containment at a negative pressure. However, during normal operation it is possible for the 31
[secondary] containment vacuum to be momentarily less than the required vacuum for a 32 number of reasons. These conditions may not be indicative of degradations of the [secondary]
33 containment boundary or of the ability of the SGT system to perform its specified safety 34 function. Since the licensee meets the requirements of SR 3.6.4.1.4, SR 3.6.4.1.5, meets the 35 LCO or is following the Actions of TS LCO 3.6.4.3, and the licensees analysis confirms 36
[secondary] containment operability by confirming that one SGT subsystem is capable of 37 performing its specified safety function, then there is reasonable assurance that the 38
[secondary] containment and SGT subsystem will maintain the vacuum requirements during a 39 DBA.
40 41 Therefore, the NRC staff has determined that: if the conditions do not affect (1) the ability to 42 maintain the [secondary] containment pressure during an accident, at a pressure that is less 43 than atmospheric, and (2) the time assumed in the accident analyses to draw down the 44
[secondary] containment pressure, then the [secondary] containment can perform its safety 45 function and may be considered TS operable. This is evident by being able to successfully 46 perform and meet SR 3.6.4.1.4 and SR 3.6.4.1.5. These SRs require the SGT system to 47 establish and maintain the required vacuum in the [secondary] containment as assumed in the 48 accident analyses.
49 1
Furthermore, because the specified safety functions of the [secondary] containment and SGT 2
subsystem can be performed in the time assumed in the licensees accident analysis, then the 3
fission products that bypass or leak from primary containment, or are released from the reactor 4
coolant pressure boundary components located in [secondary] containment prior to release to 5
the environment, will be contained and processed as assumed in the licensees design basis 6
radiological consequence dose analyses. The NRC staff finds that the proposed change does 7
not affect the current radiological consequence analyses and concludes that the proposed 8
change is acceptable with respect to the radiological consequences of DBAs.
9 10
3.2 PROPOSED CHANGE
TO SURVEILLANCE REQUIREMENT 3.6.4.1.3 11 12
[NOTE: The proposed change is not applicable if the radiological dose consequence analysis 13 assumes the [secondary] containment pressure is below atmospheric pressure prior to or 14 coincident with the time at which the accident or event occurs. Such an analysis assumption 15 would require a revised radiological dose consequence analysis considering the new release 16 point (the open [secondary] containment doors), with appropriate atmospheric dispersion 17 factors, and any other necessary revisions to the accident or event analysis.]
18 19 The NRC staff review was limited to the licensee's request to provide an allowance for the brief, 20 inadvertent, simultaneous opening of redundant [secondary] containment access doors during 21 normal entry and exit conditions. Planned activities that could result in the simultaneous 22 opening of redundant [secondary] containment access openings, such as maintenance of a 23
[secondary] containment personnel access door or movement of large equipment through the 24 openings that would take longer than the normal transit time, will be considered outside the 25 scope of the NRC staff's review.
26 27 The NRC staff reviewed the changes to SR 3.6.4.1.3. The NRC staff determined that the SR 28 continues to provide appropriate confirmation that [secondary] containment boundary doors 29 are properly positioned and capable of performing their function in preserving the [secondary]
30 containment boundary. The NRC staff determined that the SRs continue to appropriately verify 31 the operability of the [secondary] containment and provide assurance that the necessary 32 quality of systems and components are maintained in accordance with 10 CFR 50.36(c)(3).
33 34 Additionally, the NRC staff evaluated the impact of modifying the TS to allow [secondary]
35 containment access openings to be open for entry and exit on the licensees design basis 36 radiological consequence dose analyses to ensure that the modification will not result in an 37 increase in the radiation dose consequences and that the resulting calculated radiation doses 38 will remain within the design criteria specified in 10 CFR 50.67 and the accident specific design 39 criteria outlined in RG 1.183. The NRC staff review of these DBAs determined that there are 40 two DBAs that take credit for the [secondary] containment, and are possibly impacted by the 41 brief, inadvertent, simultaneous opening of both an inner and outer access door during normal 42 entry and exit conditions, the loss of coolant accident (LOCA) and the fuel handling accident 43 (FHA) in [secondary] containment.
44 45 3.2.1 LOCA 46 47 Following a LOCA, the [secondary] containment structure is maintained at a negative pressure 48 ensuring that leakage from primary containment to [secondary] containment can be collected 49 and filtered prior to release to the environment. The SGT system performs the function of 1
maintaining a negative pressure within the [secondary] containment, as well as collecting and 2
filtering the leakage from primary containment. The licensee credits the SGT system for 3
mitigation of the radiological releases from the [secondary] containment. In the LOCA 4
analysis, the [secondary] containment draw down analysis assumes that SGT system can 5
draw down the [secondary] containment within [5 minutes]. TS SR 3.6.4.1.4 requires one 6
SGT subsystem to draw down the [secondary] containment, to greater than or equal to [0.25]
7 inches of vacuum water gauge in a maximum allowable time of [120] seconds.
8 9
Conservatively, the DBA LOCA radiological consequence analysis in [Updated Final Safety 10 Analysis Report (UFSAR) Chapter 15] assumes that following the start of a DBA LOCA the 11
[secondary] containment pressure of [0.25] inches of vacuum water gauge is achieved at 12 approximately [10] minutes. The license assumes that releases into the [secondary]
13 containment prior to the [10]-minute draw down time leak directly to the environment as a 14 ground level release with no filtration. After the assumed [10]-minute draw down these releases 15 are filtered by the SGT system and released via the SGT system exhaust vent.
16 17 Based on this information, the NRC staff concludes that the licensees DBA LOCA analysis has 18 sufficient conservatism by assuming a draw down time of [10] minutes from the start of the DBA 19 LOCA. Margin exists to ensure that the [secondary] containment can be reestablished during 20 a brief, inadvertent, simultaneous opening of the inner and outer doors, and there is reasonable 21 assurance that a failure of a safety system needed to control the release of radioactive material 22 to the environment will not result. The brief, inadvertent, simultaneous opening of the 23
[secondary] containment access doors does not impact the design bases and will not result in 24 an increase in any on-site or off-site dose.
25 26 Based on the above discussion, the NRC staff finds that the licensees proposed change to the 27 TSs does not impact the licensees design basis LOCA radiological consequence analysis and 28 will not result in an increase in any onsite or offsite dose. Therefore, the NRC staff concludes that 29 this change is acceptable with respect to the radiological consequences of the DBAs.
30 31
[The licensee was approved for AST methodology and the radiological dose consequences 32 analyses for DBAs via license amendment[s] [insert license amendment number] for [name 33 of facility].] The NRC staff reviewed the impact of the proposed changes to [name of facility]
34 TS, on all DBAs currently analyzed in the [name of facility] Updated Final Safety Analysis 35 Report (UFSAR) that could have the potential for significant dose consequences. [Chapter 15]
36 of the [name of facility] UFSAR describes the DBAs and their radiological consequence 37 analysis results.]
38 39 3.2.2 FHA in [Secondary] Containment 40 41 During normal operation, non-safety related systems are used to maintain the [secondary]
42 containment at [0.25] inches of vacuum water gauge to ensure that any leakage is into the 43 building and that any [secondary] containment atmosphere exiting the building is via a 44 monitored pathway. The refuel floor, which is inside the [secondary] containment, is 45 maintained at a negative [0.25] inches of vacuum water gauge by normal operating ventilation 46 systems. The refueling floor exhaust ductwork in the [secondary] containment is equipped with 47 radiation monitors to detect a fuel handling accident. When a radiological release is sensed by 48 the radiation monitors, a [secondary] containment isolation signal is generated. This initiates 49 the SGT system and the normal ventilation system isolates. The radiation monitor is positioned 1
such that it will detect the release and send a closure signal to the [secondary] containment 2
isolation dampers.
3 4
Following a FHA, the [secondary] containment structure is maintained at a negative pressure 5
by the SGT system ensuring that fission products released from the spent fuel pool to 6
[secondary] containment can be collected and filtered prior to release to the environment. In 7
the FHA analysis, the [secondary] containment draw down analysis demonstrates that SGT 8
system can draw down the [secondary] containment within [5 minutes]. The licensee credits 9
the SGT system for mitigation of the radiological releases from the [secondary] containment.
10 TS SR 3.6.4.1.4 requires one SGT subsystem to draw down the [secondary] containment, to 11 greater than or equal to [0.25] inches of vacuum water gauge in a maximum allowable time of 12
[120] seconds.
13 14 Conservatively, the DBA FHA radiological consequence analysis in [UFSAR Chapter 15]
15 assumes that following the start of a DBA FHA the [secondary] containment pressure of 16
[0.25] inches of vacuum water gauge is achieved at approximately [10] minutes. The license 17 assumes that releases into the [secondary] containment prior to the [10]-minute draw down 18 time leak directly to the environment as a ground level release with no filtration. After the 19 assumed [10]-minute draw down these releases are filtered by the SGT system and released 20 via the SGT system exhaust vent.
21 22 Based on this information, the NRC staff concludes that the licensees DBA FHA analysis has 23 sufficient conservatism by assuming a draw down time of [10] minutes from the start of the DBA 24 FHA. Margin exists to ensure that the [secondary] containment can be reestablished during 25 brief, inadvertent, simultaneous opening of the inner and outer doors, and there is reasonable 26 assurance that a failure of a safety system needed to control the release of radioactive material 27 to the environment will not result. The brief, inadvertent, simultaneous opening of the 28
[secondary] containment access doors does not impact the design bases and will not result in 29 an increase in any on-site or off-site dose.
30 31 Based on the above discussion, the NRC staff finds that the licensees proposed change to the 32 TSs does not impact the licensees design basis FHA radiological consequence analysis and will 33 not result in an increase in any onsite or offsite dose. Therefore, the NRC staff concludes that this 34 change is acceptable with respect to the radiological consequences of the DBAs.
35 36 The NRC staff review was limited to the licensee's request to provide an allowance for the brief, 37 inadvertent, simultaneous opening of redundant [secondary] containment access doors during 38 normal entry and exit conditions. Planned activities that could result in the simultaneous 39 opening of redundant [secondary] containment access openings, such as maintenance of a 40
[secondary] containment personnel access door or movement of large equipment through the 41 openings that would take longer than the normal transit time, will be considered outside the 42 scope of the NRC staff's review.
43 44 3.2.3 Conclusion 45 46 As described above, the NRC staff reviewed the technical basis provided by the licensee to 47 assess the radiological impacts of the changes to the [secondary] containment in the licensees 48 TSs. The NRC staff finds that the licensee proposed change to SR 3.6.4.1.3 is consistent with 49 regulatory requirements and guidance identified in Section 2.3 of this SE. The NRC staff finds, 1
with reasonable assurance that the licensees change to the TSs will continue to comply with 2
these criteria and that that the licensee's estimates of the dose consequences of a design basis 3
LOCA and FHA will comply with the requirements of 10 CFR 50.67 and the accident specific 4
dose guidelines specified in RG 1.183. Therefore, the proposed changes are acceptable with 5
regard to the radiological consequences of the postulated DBAs.
6 7
3.3 PROPOSED CHANGE
TO SURVEILLANCE REQUIREMENT 3.6.4.1.4 8
9 The changes to SR 3.6.4.1.4 are editorial only and do not change any technical aspects of 10 SR 3.6.4.1.4. The NRC staff determined that the change is acceptable.
11 12 3.4
SUMMARY
13 14 The NRC staff reviewed the proposed changes and determined that changes to the TS meet the 15 standards for TS in 10 CFR 50.36(b). The proposed SRs assure that the necessary quality of 16 systems and components is maintained, that facility operation will be within safety limits, and 17 that the LCOs will be met, and satisfy 10 CFR 50.36(c)(3). Additionally, the changes to the TS 18 were reviewed for technical clarity and consistency with customary terminology and format in 19 accordance with SRP Chapter 16.
20 21 Additionally, the NRC staff has evaluated the impact of the proposed changes on the design 22 basis radiological consequence analyses against the regulatory requirements and guidance 23 identified in Section 2.3 of this SE. The NRC staff finds, with reasonable assurance that the 24 licensees change to the TSs will continue to comply with the requirements of 10 CFR 50.67 and 25 the guidelines specified in RG 1.183. Therefore, the proposed changes are acceptable with 26 regard to the radiological consequences of the postulated DBAs.
27 28
4.0 STATE CONSULTATION
29 30 In accordance with the Commission's regulations, the [Name of State] State official was notified 31 of the proposed issuance of the amendment on [enter date]. The State official had [no]
32 comments. [If comments were provided, they should be addressed here].
33 34
5.0 ENVIRONMENTAL CONSIDERATION
35 36
[Note: This section is to be prepared by the PM. As needed, the PM should coordinate with 37 NRRs Environmental Review and Projects Branch (RERP) to determine the need for an EA.
38 Specific guidance on preparing EAs and considering environmental issues is contained in NRR 39 Office Instruction LIC-203, Procedural Guidance for Preparing Categorical Exclusions, 40 Environmental Assessments, and Considering Environmental Issues.]
41 42 The amendment changes requirements with respect to the installation or use of facility 43 components located within the restricted area as defined in 10 CFR Part 20 and changes SRs.
44 The NRC staff has determined that the amendment involves no significant increase in the 45 amounts and no significant change in the types of any effluents that may be released offsite, 46 and that there is no significant increase in individual or cumulative occupational radiation 47 exposure. The Commission has previously issued a proposed finding that the amendment 48 involves no significant hazards consideration, and there has been no public comment on such 49 finding published in the Federal Register on [DATE (XX FR XXX)]. Accordingly, the 1
amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
2 Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment 3
need be prepared in connection with the issuance of the amendment.
4 5
6.0 CONCLUSION
6 7
The Commission has concluded, based on the considerations discussed above, that: (1) there 8
is reasonable assurance that the health and safety of the public will not be endangered by 9
operation in the proposed manner, (2) there is reasonable assurance that such activities will be 10 conducted in compliance with the Commission's regulations, and (3) the issuance of the 11 amendment will not be inimical to the common defense and security or to the health and safety 12 of the public 13 14 Principal Contributors:
Kristy Bucholtz, NRR/DRA/ARCB 15 Nageswara Karipineni, NRR/DSS/SBPB 16 Margaret Chernoff, NRR/DSS/STSB 17 18 Date:
19 20