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TSTF-505 Near Term Revised Draft - Change Tracking Copy for 09/12/2017 Teleconference
	ML17258A126
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Site:	Technical Specifications Task Force
Issue date:	09/12/2017
From:	; Technical Specifications Task Force
To:	; Office of Nuclear Reactor Regulation
	Honcharik M, 301-415-1774, DSS/STSB
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TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY DATE DRAFT TSTF-17-01 REVISION 13 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Response to NRC Questions on TSTF-505-A, "Provide Risk-Informed Extended Completion Times"

Reference:

Letter from T. McGinty and A. Boland (NRC) to Technical Specifications Task Force (TSTF), "Issues with Technical Specifications Task Force Traveler TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b'," dated November 15, 2016 In the referenced letter, the NRC raised concerns with approved TSTF traveler, TSTF-505-A, Revision 1, "Provide Risk-Informed Extended Completion Times." The NRC published in the Federal Register a notice of availability for the Model Safety Evaluation (SE) for plant-specific adoption of TSTF traveler TSTF-505, Revision 1, on March 15, 2012. Currently, six several licensees have License Amendment Requests (LARs) under NRC review to adopt risk-informed Completion Times.

On December 13, 2016, the TSTF and the Nuclear Energy Institute (NEI) met with the NRC to discuss the NRC's concerns. Most of the NRC concerns were related to proposed Technical Specifications (TS) Actions related to all trains of a TS required system being inoperable (i.e.,

loss of function). The industry proposed the following short-term and long-term actions to resolve the NRC concerns:

1. The industry will pursue development of a companion traveler for TSTF-505-A that addresses the NRC issues with Actions related to inoperability of all trains of a TS required systema loss of function. Following approval, plants that have adopted TSTF-505-A without these Actions related to a loss of function could submit a LAR to adopt the companion traveler. Following NRC approval of the companion traveler, plants that have not adopted TSTF-505-A can adopt TSTF-505-A and the companion traveler in a single LAR.

2. TSTF-505-A allows licensees to choose which Action changes are included in their LAR.

The TSTF will recommend to the industry that until the companion traveler is approved by the NRC, licensees submitting LARs to adopt TSTF-505 follow the guidance in the attachments to this letter. Actions related to the inoperability of all trains of a TS required system should not be included in LARs submitted prior to approval of the companion 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation

TSTF-17-01 DATE traveler. not include Action changes related to a loss of function. Omitting these Actions and incorporating the other changes recommended in the attachments to this letter should allow timely approval of LARs and provide the majority of the benefit of TSTF-505.

Attachment 1 contains a list of the Actions revised by TSTF-505-A that should be omitted in LARs submitted prior to approval of the companion traveler. Attachment 1 also includes , as well as conforming changes to the TSTF-505-A Section 1.3 TS example and the TS Section 5.5 Administrative Controls program. Attachment 2 contains a list of Actions revised by TSTF-505-A that have conditions on their inclusion in a plant-specific LAR. Attachment 3 contains a revised Mode Application for requesting adoption of TSTF-505-A.

3. The proposed actions only apply to future submittals. The licensees with LARs currently under NRC review will decide how to proceed.

The TSTF has been informed by Southern Nuclear Operating Company that the Vogtle LAR will proceed with limited Risk Informed Completion Times for loss-of-function conditions. The TSTF encourages the NRC to expeditiously complete the Vogtle LAR review, as it will provide valuable insight regarding loss-of-function Actions.

The NRC had questions on other aspects of TSTF-505 not related to loss of function. Those questions are addressed in Attachment 2.

The TSTF requests that the NRC rescind the suspension of the approval of TSTF-505-A, Revision 1, and accept LARs to adopt TSTF-505-A that follow the recommendations in the attachments to this letter. do not include proposed Actions with risk-informed Completion Times related to loss of function, as described in Attachment 1. Following NRC approval of a TSTF traveler that addresses Actions with a risk-informed Completion Time related to loss of function, LARs should be accepted for review that propose to adopt TSTF-505 and the companion traveler.

Should you have any questions, please do not hesitate to contact us.

James R. Morris (PWROG/W) Lisa L. Williams (BWROG)

Otto W. Gustafson (PWROG/CE) Jordan Vaughan (PWROG/B&W)

Jason P. Redd (APOG)

Enclosure

TSTF-17-01 DATE cc: Mirella Gavrilas, Director of the Division of Safety Systems Anne T. Boland, Director of the Division of Operating Reactor Licensing Jennifer Whitman, Acting Chief of the Technical Specifications Branch Michelle Honcharik, Technical Specifications Branch

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to TSTF-505 Markup to NUREG-1430, Babcock and Wilcox STS Specification Specification Title Notes 1.3 Completion Times See attached recommended changes Action 3.3.1.C RPS Instrumentation LOF. Do not include Action 3.3.2.A Reactor Protection System (RPS) Manual Reactor Do not include.

Trip Action 3.3.5.B ESFAS Instrumentation LOF. Do not include Action 3.3.6.B ESFAS Manual Initiation LOF. Do not include Action 3.3.11.D EFIC System Instrumentation LOF. Do not include Action 3.3.13.B EFIC Logic LOF. Do not include Action 3.3.14.B EFIC-EFW- Vector Valve Logic LOF. Do not include Action 3.4.10.A Pressurizer Safety Valves Do not include.

Action 3.4.14.C RCS Pressure Isolation Valve (PIV) Leakage Do not include.

Action 3.5.1.A CFTs Do not include Action 3.5.1.B CFTs Do not include Action 3.5.1.C CFTs LOF. Do not include Action 3.5.2.C ECCS - Operating LOF. Do not include Action 3.5.3.B ECCS - Shutdown Do not include.

Action 3.5.4.A BWST Do not include Action 3.5.4.B BWST Do not include Action 3.6.3.B Containment Isolation Valves Do not include Action 3.6.3.D Containment Isolation Valves Do not include Action 3.6.6.F Containment Spray and Cooling Systems LOF. Do not include Action 3.7.2.C MSIVs LOF. Do not include Action 3.7.4.B AVVs Do not include.

Action 3.7.5.C EFW System LOF. Do not include Action 3.7.6.A CST Do not include.

Page 1

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to TSTF-505 Markup to NUREG-1430, Babcock and Wilcox STS Specification Specification Title Notes Action 3.7.8.B SWS LOF. Do not include Action 3.7.9.C UHS LOF. Do not include Action 3.7.11.B CREVS LOF. Do not include Action 3.8.1.E AC Sources - Operating Do not include Action 3.8.1.G AC Sources - Operating LOF. Do not include Action 3.8.4.A.1 DC Sources - Operating Do not include. Required Action outside the scope of TSTF-505.

Action 3.8.4.D DC Sources - Operating LOF. Do not include Action 3.8.7.B Inverters - Operating LOF. Do not include Action 3.8.9.D Distribution Systems - Operating LOF. Do not include 5.5.18 Risk Informed Completion Time Program See attached recommended changes Page 2

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1431, Westinghouse STS Specification Specification Title Notes 1.3 Completion Times See attached recommended changes Action 3.3.1.C RTS Instrumentation LOF. Do not include Action 3.3.1.E RTS Instrumentation LOF. Do not include Action 3.3.1.G RTS Instrumentation LOF. Do not include Action 3.3.1.I RTS Instrumentation LOF. Do not include Action 3.3.1.Q RTS Instrumentation LOF. Do not include Action 3.3.1.S RTS Instrumentation Do not include Action 3.3.1.T RTS Instrumentation LOF. Do not include Action 3.3.1.V RTS Instrumentation Do not include Action 3.3.1.W RTS Instrumentation LOF. Do not include Action 3.3.1.Z RTS Instrumentation LOF. Do not include Action 3.3.1.CC RTS Instrumentation LOF. Do not include Action 3.3.1.EE RTS Instrumentation LOF. Do not include Action 3.3.1.JJ RTS Instrumentation LOF. Do not include Action 3.3.2.C ESFAS Instrumentation LOF. Do not include Action 3.3.2.E ESFAS Instrumentation LOF. Do not include Action 3.3.2.G ESFAS Instrumentation LOF. Do not include Action 3.3.2.I ESFAS Instrumentation LOF. Do not include Action 3.3.2.K ESFAS Instrumentation LOF. Do not include Action 3.3.2.M ESFAS Instrumentation LOF. Do not include Action 3.3.2.O ESFAS Instrumentation LOF. Do not include Action 3.3.2.Q ESFAS Instrumentation LOF. Do not include Action 3.3.2.S ESFAS Instrumentation LOF. Do not include Action 3.3.2.U ESFAS Instrumentation LOF. Do not include Page 3

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1431, Westinghouse STS Specification Specification Title Notes Action 3.3.2.V ESFAS Instrumentation Do not include. Required Action outside the scope of TSTF-505.

Action 3.3.9.B BDPS LOF. Do not include Action 3.4.9.C Pressurizer LOF. Do not include.

Action 3.4.10.A Pressurizer Safety Valves Do not include.

Action 3.4.11.E Pressurizer Power Operated Relief Valves Do not include.

(PORVs)

Action 3.4.11.F Pressurizer Power Operated Relief Valves Do not include.

(PORVs)

Action 3.4.14.C RCS Pressure Isolation Valve (PIV) Leakage Do not include.

Action 3.5.1.A Accumulators Do not include.

Action 3.5.1.B Accumulators Do not include.

Action 3.5.1.C Accumulators LOF. Do not include.

Action 3.5.2.B ECCS - Operating LOF. Do not include.

Action 3.5.3.B ECCS - Shutdown Do not include.

Action 3.5.4.A RWST Do not include.

Action 3.5.4.B RWST Do not include.

Action 3.5.6.A Boron Injection Tank Do not include.

Action 3.6.3.B Containment Isolation Valves Do not include.

Action 3.6.3.C Containment Isolation Valves Do not include.

Action 3.6.3.D Containment Isolation Valves Do not include.

Action 3.6.3.E Containment Isolation Valves Do not include.

Action 3.6.6A.E Containment Spray and Cooling Systems LOF. Do not include.

(Atmospheric and Dual)

Action 3.6.6B.G Containment Spray and Cooling Systems LOF. Do not include.

(Atmospheric and Dual)

Action 3.6.6C.B Containment Spray System (Ice Condenser) LOF. Do not include.

Action 3.6.6D.B QS System (Subatmospheric) LOF. Do not include.

Action 3.6.6E.F RS System (Subatmospheric) LOF. Do not include.

Page 4

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1431, Westinghouse STS Specification Specification Title Notes Action 3.6.9.B Hydrogen Mixing System Do not include.

Action 3.6.10.C HIS (Ice Condenser) LOF. Do not include.

Action 3.6.14.B ARS (Ice Condenser) LOF. Do not include.

Action 3.6.15.A Ice Bed Do not include.

Action 3.6.17.A Divider Barrier Integrity (Ice Condenser) Do not include.

Action 3.6.17.B Divider Barrier Integrity (Ice Condenser) Do not include.

Action 3.6.18.A Containment Recirculation Drains (Ice Condenser) LOF. Do not include.

Action 3.6.18.B Containment Recirculation Drains (Ice Condenser) LOF. Do not include.

Action 3.7.2.C MSIVs LOF. Do not include.

Action 3.7.5.C AFW System LOF. Do not include.

Action 3.7.6.A Condensate Storage Tank Do not include.

Action 3.7.7.B CCW System LOF. Do not include.

Action 3.7.8.B SWS LOF. Do not include.

Action 3.7.9.C UHS LOF. Do not include.

Action 3.7.11.B CREATCS LOF. Do not include.

Action 3.8.1.E AC Sources - Operating Do not include Action 3.8.1.G AC Sources - Operating LOF. Do not include Action 3.8.4.A.1 DC Sources - Operating Do not include. Required Action outside the scope of TSTF-505.

Action 3.8.4.D DC Sources - Operating LOF. Do not include Action 3.8.7.B Inverters - Operating LOF. Do not include Action 3.8.9.D Distribution Systems - Operating LOF. Do not include 5.5.18 Risk Informed Completion Time Program See attached Recommended Changes Page 5

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1432, Combustion Engineering STS Specification Specification Title Notes 1.3 Completion Times See attached recommended changes Action 3.3.4.B ESFAS Instrumentation (Analog) LOF. Do not include.

Action 3.3.5.B ESFAS Logic and Manual Trip (Analog) LOF. Do not include.

Action 3.3.5.E ESFAS Logic and Manual Trip (Analog) LOF. Do not include.

Action 3.3.6.A ESFAS Logic and Manual Trip (Digital) Do not include.

Action 3.3.6.E ESFAS Logic and Manual Trip (Digital) LOF. Do not include.

Action 3.4.9.C Pressurizer LOF. Do not include.

Action 3.4.10.A Pressurizer Safety Valves Do not include.

Action 3.4.11.E Pressurizer Power Operated Relief Valves Do not include.

(PORVs)

Action 3.4.11.F Pressurizer Power Operated Relief Valves Do not include.

(PORVs)

Action 3.4.14.C RCS Pressure Isolation Valve (PIV) Leakage Do not include.

Action 3.5.1.A SITs Do not include.

Action 3.5.1.B SITs Do not include.

Action 3.5.1.C SITs LOF. Do not include.

Action 3.5.2.C ECCS - Operating LOF. Do not include.

Action 3.5.3.A ECCS - Shutdown Do not include.

Action 3.5.4.A RWT Do not include.

Action 3.5.4.B RWT Do not include.

Action 3.6.3.C Containment Isolation Valves Do not include.

Action 3.6.3.E Containment Isolation Valves Do not include.

Action 3.6.3.F Containment Isolation Valves Do not include.

Action 3.6.6A.F Containment Spray and Cooling Systems LOF. Do not include.

(Atmospheric and Dual)

Action 3.6.6B.F Containment Spray and Cooling Systems LOF. Do not include.

(Atmospheric and Dual)

Action 3.6.9.B Hydrogen Mixing System Do not include.

Page 6

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1432, Combustion Engineering STS Specification Specification Title Notes Action 3.7.2.C MSIVs LOF. Do not include.

Action 3.7.4.B Atmospheric Dump Valves Do not include.

Action 3.7.5.C AFW System LOF. Do not include.

Action 3.7.6.A Condensate Storage Tank Do not include.

Action 3.7.7.B CCW System LOF. Do not include.

Action 3.7.8.B SWS LOF. Do not include.

Action 3.7.9.C UHS LOF. Do not include.

Action 3.7.10.B ECW LOF. Do not include.

Action 3.7.12.B CREATCS LOF. Do not include.

Action 3.8.1.E AC Sources - Operating Do not include.

Action 3.8.1.G AC Sources - Operating LOF. Do not include Action 3.8.4.A.1 DC Sources - Operating Do not include. Required Action outside the scope of TSTF-505.

Action 3.8.4.D DC Sources - Operating LOF. Do not include Action 3.8.7.B Inverters - Operating LOF. Do not include Action 3.8.9.D Distribution Systems - Operating LOF. Do not include 5.5.18 Risk Informed Completion Time Program See attached recommended changes Page 7

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1433, BWR/4 STS Specification Specification Title Notes 1.3 Completion Times See attached recommended changes Action 3.1.7.A SLC System Do not include.

Action 3.1.7.C SLC System Do not include.

Action 3.3.1.1.C Reactor Protection System (RPS) Instrumentation Do not include.

Action 3.3.4.1.B End of Cycle Recirculation Pump Trip (EOC-RPT) Do not include.

Instrumentation Action 3.3.4.2.B Anticipated Transient Without Scram Do not include.

Recirculation Pump Trip (ATWS-RPT)

Instrumentation Action 3.3.4.2.C Anticipated Transient Without Scram Do not include.

Recirculation Pump Trip (ATWS-RPT)

Action 3.3.5.2.C Reactor Core Isolation Cooling (RCIC) System Do not include.

Instrumentation Action 3.3.6.1.B Primary Containment Isolation Instrumentation Do not include.

Action 3.3.6.3.C LLS Instrumentation Do not include.

Action 3.3.6.3.D LLS Instrumentation LOF. Do not include.

Action 3.4.3.B S/RVs LOF. Do not include.

Action 3.5.1.G ECCS - Operating LOF. Do not include.

Action 3.5.1.I ECCS - Operating LOF. Do not include.

Action 3.6.1.3.B PCIVs Do not include. Required Action outside the scope of TSTF-505.

Action 3.6.1.3.C PCIVs Do not include. Required Action outside the scope of TSTF-505.

Action 3.6.2.3.B Residual Heat Removal (RHR) Suppression Pool Do not include.

Cooling Action 3.6.2.4.B Residual Heat Removal (RHR) Suppression Pool Do not include.

Spray Action 3.6.3.3.B Containment Atmosphere Dilution (CAD) System Do not include.

Action 3.7.1.D Residual Heat Removal Service Water (RHRSW) Do not include.

System Action 3.7.2.F [PSW] System and [UHS] LOF. Do not include.

Action 3.7.5.B [Control Room AC] System LOF. Do not include.

Action 3.8.1.E AC Sources - Operating Do not include Page 8

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1433, BWR/4 STS Specification Specification Title Notes Action 3.8.1.G AC Sources - Operating LOF. Do not include Action 3.8.4.A.1 DC Sources - Operating Do not include. Required Action outside the scope of TSTF-505.

Action 3.8.4.D DC Sources - Operating LOF. Do not include Action 3.8.7.B Inverters - Operating LOF. Do not include Action 3.8.9.D Distribution Systems - Operating LOF. Do not include 5.5.15 Risk Informed Completion Time Program See attached recommended changes Page 9

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1434, BWR/6 STS Specification Specification Title Notes 1.3 Completion Times See attached recommended changes Action 3.1.7.A SLC System Do not include.

Action 3.1.7.C SLC System Do not include.

Action 3.3.1.1.C Reactor Protection System (RPS) Instrumentation Do not include.

Action 3.3.4.1.B End of Cycle Recirculation Pump Trip (EOC-RPT) Do not include.

Instrumentation Action 3.3.4.2.B Anticipated Transient Without Scram Do not include.

Recirculation Pump Trip (ATWS-RPT)

Instrumentation Action 3.3.4.2.C Anticipated Transient Without Scram Do not include.

Recirculation Pump Trip (ATWS-RPT)

Instrumentation Action 3.3.5.2.C Reactor Core Isolation Cooling (RCIC) System Do not include.

Instrumentation Action 3.3.6.1.B Primary Containment Isolation Instrumentation Do not include.

Action 3.3.6.4.B Suppression Pool Makeup (SPMU) System Do not include.

Instrumentation Action 3.3.6.4.C Suppression Pool Makeup (SPMU) System Do not include.

Instrumentation Action 3.3.6.5.B Relief and LLS Instrumentation LOF. Do not include.

Action 3.4.4.B S/RVs LOF. Do not include.

Action 3.5.1.G ECCS - Operating LOF. Do not include.

Action 3.5.1.I ECCS - Operating LOF. Do not include.

Action 3.5.1.J ECCS - Operating LOF. Do not include.

Action 3.5.1.K ECCS - Operating LOF. Do not include.

Action 3.5.1.L ECCS - Operating LOF. Do not include.

Action 3.6.1.3.B Primary Containment Isolation Valves (PCIVs) Do not include.

Action 3.6.1.3.C Primary Containment Isolation Valves (PCIVs) Do not include.

Action 3.6.1.3.D Primary Containment Isolation Valves (PCIVs) Do not include.

Action 3.6.1.7.B Residual Heat Removal (RHR) Containment Spray Do not include.

System Action 3.6.2.3.B Residual Heat Removal (RHR) Suppression Pool Do not include.

Cooling Page 10

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function TSTF-505 Markup to NUREG-1434, BWR/6 STS Specification Specification Title Notes Action 3.6.2.4.A SPMU System Do not include.

Action 3.6.2.4.B SPMU System Do not include.

Action 3.6.2.4.D SPMU System LOF. Do not include.

Action 3.6.3.1.B Drywell Cooling System Fans Do not include.

Action 3.6.3.2.B Drywell Purge System Do not include.

Action 3.6.5.1.A Drywell Do not include.

Action 3.6.5.3.B Drywell Isolation Valve[s] Do not include.

Action 3.6.5.6.D Drywell Vacuum Relief System Do not include.

Action 3.6.5.6.E Drywell Vacuum Relief System Do not include.

Action 3.6.5.6.F Drywell Vacuum Relief System LOF. Do not include.

Action 3.7.1.D [SSW] System and [UHS] LOF. Do not include.

Action 3.7.4.B [Control Room AC] System LOF. Do not include.

Action 3.8.1.E AC Sources - Operating Do not include Action 3.8.1.G AC Sources - Operating LOF. Do not include Action 3.8.4.A.1 DC Sources - Operating Do not include. Required Action outside the scope of TSTF-505.

Action 3.8.4.D DC Sources - Operating LOF. Do not include Action 3.8.7.B Inverters - Operating LOF. Do not include Action 3.8.9.D Distribution Systems - Operating LOF. Do not include 5.5.15 Risk Informed Completion Time Program See attached recommended changes Page 11

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function Recommended Changes to the Section 1.3 Example in TSTF-505

Reviewer's Note ------------------------------------------

Example 1.3-8 is only applicable to plants that have adopted the Risk Informed Completion Time Program.

[ EXAMPLE 1.3-8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem A.1 Restore subsystem 7 days inoperable. to OPERABLE status. OR In accordance with the Risk Informed Completion Time Program B. --- NOTE ------ B.1 Restore subsystems 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Not applicable to OPERABLE when second status. OR subsystem intentionally In accordance with the made Risk Informed inoperable. Completion Time

Program Two subsystems inoperable.

BC.Required BC.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated AND Completion Time not met. BC.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Page 12

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests TSTF-505 Recommended Changes to Exclude Provisions Related to Loss of Function Recommended Changes to the Section 1.3 Example in TSTF-505 When a subsystem is declared inoperable, Condition A is entered. The 7 day Completion Time may be applied as discussed in Example 1.3-2. However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time. The RICT cannot exceed 30 days. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition BC must also be entered.

If a second subsystem is declared inoperable, Condition B may also be entered. The Condition is modified by a Note stating it is not applicable if the second subsystem is intentionally made inoperable. The Required Actions of Condition B are not intended for voluntary removal of redundant subsystems from service. The Required Action is only applicable if one subsystem is inoperable for any reason and the second subsystem is found to be inoperable, or if both subsystems are found to be inoperable at the same time. If Condition B is applicable, at least one subsystem must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or Condition C must also be entered. The licensee may be able to apply a RICT to extend the Completion Time beyond 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months if the requirements of the Risk Informed Completion Time Program are met. If two subsystems are inoperable and Condition B is not applicable (i.e., the second subsystem was intentionally made inoperable), LCO 3.0.3 is entered as there is no applicable Condition.

The Risk Informed Completion Time Program requires recalculation of the RICT to reflect changing plant conditions. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

If the 7 day Completion Time clock of Condition A or the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time clock of Condition B have has expired and subsequent changes in plant condition result in exiting the applicability of the Risk Informed Completion Time Program without restoring the inoperable subsystem to OPERABLE status, Condition BC is also entered and the Completion Time clocks for Required Actions BC.1 and BC.2 start.

If the RICT expires or is recalculated to be less than the elapsed time since the Condition was entered and the inoperable subsystem has not been restored to OPERABLE status, Condition BC is also entered and the Completion Time clocks for Required Actions BC.1 and BC.2 start. If the inoperable subsystems are restored to OPERABLE status after Condition BC is entered, Conditions A, B, and BC are exited, and therefore, the Required Actions of Condition BC may be terminated. ]

Page 13

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific Amendment Requests Recommended Changes to the Risk Informed Completion Time Program

[ 5.5.18 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a. The RICT may not exceed 30 days;

REVIEWER'S NOTE ----------------------------------

The Risk Informed Completion Time is only applicable in MODES supported by the Licensees PRA. Licensee's applying the RICT Program to MODES other than Modes 1 and 2 must demonstrate that they have the capability to calculate a RICT in those MODES or that the risk indicated by their MODE 1 and 2 PRA model is bounding with respect to the lower MODE conditions.

b. A RICT may only be utilized in MODE 1, 2 [, and 3, and MODE 4 while relying on steam generators for heat removal];

c. When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, change within the scope of the Risk Informed Completion Time Program must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3. Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.

d. Use of a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e. Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE if one or more of the trains are considered "PRA functional" as defined in Section 2.3.1 of NEI 06-09.]

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Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific Amendment Requests Recommended Changes to the Risk Informed Completion Time Program

d. If the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1. Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2. Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e. [This paragraph will describe when prior NRC approval is needed for changes to the methodology used to calculate a RICT. The wording for this provision is currently under discussion between the NRC and the industry.]

Discussion of Recommended Changes to the Risk Informed Completion Time Program

1. The reference to NEI 06-09 is revised to refer to the approved version, NEI 06-09-A, Revision 0.

2. Paragraphs d. and e. of TSTF-505 are deleted. These paragraphs discuss determining a RICT when all trains of a system are inoperable and are not applicable to the near-term submittals that are the subject of this letter.

3. The NRC questioned the difference between the TSTF-505 Risk Informed Completion Time (RICT) Program in paragraph 5.5.c and the NEI 06-09 Configuration Risk Management Program (CRMP). The traveler justification stated that the TS Section 5.5 RICT Program was the same as the NEI 06-09 CRMP; however, users of the TS may not have TSTF-505 available, which may lead to confusion when applying NEI 06-09 in accordance with the TS 5.5 RICT Program. The program was revised to clarify the application of the requirements.

4. A new paragraph d. is added addressing common cause failure considerations.

5. A new paragraph e. is added. The NRC's Safety Evaluation for NEI 06-09 stated:

As part of its review and approval of a licensees application requesting to implement the RMTS, the NRC staff intends to impose a license condition that will explicitly address the scope of the PRA and non-PRA methods approved by the NRC staff for use in the plant-specific RMTS program. If a licensee wishes to change its methods, and the change is outside the bounds of the license condition, the licensee will need NRC approval, via a license amendment, of the implementation of the new method in its RMTS program. The focus of the NRC staffs review and approval will be on the Page 15

Attachment 1 Recommended Variations from TSTF-505-A in Near-Term Plant-Specific Amendment Requests Recommended Changes to the Risk Informed Completion Time Program technical adequacy of the methodology and analyses relied upon for the RMTS application.

There is no legal difference between a license condition and a Technical Specification and it is less error prone to put all requirements related to calculation of a RICT in the same location.

Therefore, in lieu of a license condition, the restriction is added as paragraph e. of the program.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Specification LCO Requirements and Condition Condition on Use 3.3.2.A LCO: The Reactor Protection System (RPS) Licensee must justify Manual Reactor Trip Function shall be that this is not a OPERABLE. condition in which all Condition: Manual Reactor Trip Function required trains or inoperable. subsystems of a TS required system are inoperable[BM1].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Specification LCO Requirements and Condition Condition on Use 3.3.8.B LCO: Three channels of loss of voltage Function Licensee must justify and three channels of degraded voltage Function that two or more EDG LOPS instrumentation per EDG shall be channels per EDG OPERABLE. inoperable is not a Condition: One or more Functions with two or condition in which all more channels per EDG inoperable. required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative would be to limit the TS Condition to when the minimum number of channels needed to perform the function are operable (assuming no additional failures).

See Note 1 at the end of Attachment 2.The Required Actions and Completion Times would be the same and would provide the option to calculate a RICT. Either a new condition would be created that applies when less than the minimum number of channels are operable or, depending on the construction of the TS, LCO 3.0.3 would apply. The licensee would need to justify that the function can still be performed in the revised Action.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Specification LCO Requirements and Condition Condition on Use 3.3.12.B LCO: Two manual initiation switches per Licensee must justify actuation channel for each of the following that one or both emergency feedwater initiation and control (EFIC) channels inoperable is Functions shall be OPERABLE: not a condition in

a. Steam generator (SG) A Main Feedwater (MFW) which all required Isolation, trains or subsystems of

b. SG B MFW Isolation, a TS required system

c. SG A Main Steam Line Isolation, are inoperable or

d. SG B Main Steam Line Isolation, and modify the Action to

e. Emergency Feedwater Actuation. not apply a RICT when Condition: One or more EFIC Function(s) with all required trains or one or both manual initiation switches inoperable in subsystems are both actuation channels. inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of Attachment 2.

3.4.9.C LCO: The pressurizer shall be OPERABLE. Pressurizer is typically Condition: Capacity of pressurizer heaters not modeled in the

[capable of being powered by emergency power PRA. Licensee must supply] less than limit. justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Specification LCO Requirements and Condition Condition on Use 3.4.10.A LCO: Two pressurizer safety valves shall be The Applicable Safety OPERABLE with lift settings > [2475] psig and < Analysis section of the

[2525] psig. Bases states that the Condition: One pressurizer safety valve accident analysis inoperable. assumes both PSVs actuate to mitigate an overpressure event.

Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR.

Licensee must also explain how the PSVs are modeled in the PRA[BM2].

3.4.14.C LCO: RCS Pressure Isolation Valve (PIV) Licensee must justify Leakage that applying a RICT to Condition: Decay Heat Removal (DHR) System the action to isolate the autoclosure interlock function inoperable. affected penetration is equivalent to isolating a Containment Isolation Valve and is acceptable[BM3]

3.5.1.B LCO: Two CFTs shall be OPERABLE The Applicable Safety Condition: One CFT inoperable for reasons other Analysis Bases states than to boron concentration not within limits. that both CFTs are required to function in the event of a large break LOCA or the ECCS acceptance criteria may be violated. Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR[BM4].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Specification LCO Requirements and Condition Condition on Use 3.5.2.B LCO: Two ECCS trains shall be OPERABLE. Licensee must justify Condition: One or more [ECCS] trains inoperable that one or more ECCS for reasons other than one LPI subsystem trains inoperable is not inoperable. a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. Acceptable justification is TS Condition requiring 100% flow equivalent to a single ECCS train.

3.6.2.C LCO: [Two] containment air lock[s] shall be Licensee must justify OPERABLE. Condition: One or more that an inoperable containment air locks inoperable for reasons other containment air lock is than an inoperable door or inoperable interlock not a condition in mechanism. which all required trains or subsystems of a TS required system are inoperable. An acceptable argument may be that a note in TS 3.6.2 requires the condition to be assessed in accordance with TS 3.6.1, Containment Integrity, and any loss of function would require an immediate plant shutdown under that TS.

3.5.3.B LCO: One ECCS train shall be OPERABLE. Licensee must justify Condition: Required ECCS HPI subsystem that it is not a condition inoperable in Mode 4. in which all required trains or subsystems of a TS required system are inoperable[BM5].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Specification LCO Requirements and Condition Condition on Use 3.5.4.B LCO: The BWST shall be OPERABLE. Licensee must justify Condition: BWST inoperable for other than boron that it is not a condition concentration or water temperature not within in which all required limits. trains or subsystems of a TS required system are inoperable[BM6].

3.6.2.C LCO: [Two] containment air lock[s] shall be Licensee must justify OPERABLE. Condition: One or more that an inoperable containment air locks inoperable for reasons other containment air lock is than an inoperable door or inoperable interlock not a condition in mechanism. which all required trains or subsystems of a TS required system are inoperable[BM7].

3.6.3.B LCO: Each containment isolation valve shall be Licensee must justify OPERABLE. that two or more Condition: One or more penetration flow paths inoperable containment with two [or more] containment isolation valves isolation valves on a inoperable [for reasons other than purge valve penetration with two leakage not within limit]. valves is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM8].

3.6.3.D LCO: Each containment isolation valve shall be Licensee must justify OPERABLE. that inoperable Condition: One or more penetration flow paths containment purge with one or more containment purge valves not valves is not a within purge valve leakage limits. condition in which all required trains or subsystems of a TS required system are inoperable[BM9].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Specification LCO Requirements and Condition Condition on Use 3.6.6 LCO: Containment Spray and Cooling Systems Licensee must justify Condition A: One containment spray train the ability to calculate a inoperable RICT for the condition, Condition C: One [required] containment cooling including how the train inoperable. system is modeled in Condition D: One containment spray train and one the PRA, whether all

[required] containment cooling train inoperable. functions of the system Condition E: Two [required] containment cooling are modeled, and, if a trains inoperable. surrogate is used, why that modeling is conservative.

3.7.4.B LCO: [Two] Atmospheric Vent Valves (AW) Licensee must justify

[lines per steam generator] shall be OPERABLE. that two or more Condition: Two or more required AVV lines inoperable ADVs is not inoperable a condition in which all required trains or subsystems of a TS required system are inoperable[BM10].

3.7.6.A LCO: The [two] Condensate Storage Tanks (CST) Licensee must justify shall be OPERABLE. that this is not a Condition: [Two] CSTs inoperable condition in which all required trains or subsystems of a TS required system are inoperable[BM11].

3.8.1.E Two [required] DGs inoperable Licensee must justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM12].

3.8.4.A LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One [or two] battery charger[s] on one condition in which all subsystem inoperable. required trains or subsystems of a TS required system are inoperable.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1430, Babcock and Wilcox STS Specification LCO Requirements and Condition Condition on Use 3.8.4.B LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One [or two] batter[y][ies on one condition in which all subsystem] inoperable. required trains or subsystems of a TS required system are inoperable.

3.8.4.C LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One DC electrical power subsystem condition in which all inoperable for reasons other than Condition A [or required trains or B]. subsystems of a TS required system are inoperable.

3.8.7.A LCO: The required Train A and Train B inverters Licensee must justify shall be OPERABLE. that this is not a Condition: One [required] inverter inoperable. condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.9.A LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more AC electrical power required trains or distribution subsystems inoperable. subsystems of a TS required system are inoperable.

3.8.9.B LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more AC vital buses required trains or inoperable. subsystems of a TS required system are inoperable.

3.8.9.C LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more DC electrical power required trains or distribution subsystems inoperable. subsystems of a TS required system are inoperable.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.3.1.F LCO: The RTS instrumentation for each Function Licensee must justify in Table 3.3.1-1 shall be OPERABLE. that the condition does Condition: One Power Range Neutron Flux - High not represent the channel inoperable. inability to perform the safety function assumed in the FSAR given the loss of spacial distribution of the remaining Power Range detectors. The justification can include that the Actions require periodic monitoring of spacial power distribution and imposition of compensatory limits and reduced power.

3.3.1.S LCO: The RTS instrumentation for each Function This function is a in Table 3.3.1-1 shall be OPERABLE. single channel per Condition: One Reactor Coolant Pump Breaker RCP. Licensee must Position (Single Loop) channel inoperable. justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable. Adequate justification may be that the RCP Breaker Position trip is an anticipatory trip, and the low flow trip is credited in the analysis[BM13].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.3.1.V LCO: The RTS instrumentation for each Function This function is a in Table 3.3.1-1 shall be OPERABLE. single channel per Condition: One Reactor Coolant Breaker Position RCP. Licensee must (Two Loops) channel justify that this is not a condition in which all required trains or subsystems of a TS required system are inoperable. Adequate justification may be that the RCP Breaker Position trip is an anticipatory trip, and the low flow trip is credited in the analysis[BM14].

3.3.1.DD LCO: The RTS instrumentation for each Function There are two RTB in Table 3.3.1-1 shall be OPERABLE. trains and either can Condition: One RTB train inoperable. perform the function.

Unclear why loss of one would be considered a potential LOF.The licensee must include information regarding how the TSTF-411 conditions and limitations will be implemented (or similar conditions if TSTF-411 has not been adopted), including discussion of ATWS Mitigation System Actuation (AMSAC),

and why those actions are sufficient, including a discussion of defense in depth.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.3.5.B LCO: [Three] channels per bus of the loss of Licensee must justify voltage Function and [three] channels per bus of the that two or more degraded voltage Function shall be OPERABLE. channels per bus Condition: One or more Functions with two or inoperable is not a more channels per bus inoperable. condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of Attachment 2.

3.3.9.A LCO: Boron Dilution Protection System (BDPS) BDPS is typically not Condition: One train inoperable (applicable to modeled in the PRA.

MODES [2,] 3, 4, and 5.) Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.4.9.B LCO: The pressurizer shall be OPERABLE Pressurizer is typically Condition: One [required] group of pressurizer not modeled in the heaters inoperable. PRA. Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative..

3.4.10.A LCO: [Three] pressurizer safety valves shall be The Applicable Safety OPERABLE with lift settings > [2460] psig and < Analysis section of the

[2510] psig. Bases states that the Condition: One pressurizer safety inoperable accident analysis assumes all PSVs actuate to mitigate an overpressure event.

Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR.

Licensee must also explain how the PSVs are modeled in the PRA[BM15].

3.4.11.E LCO: Each PORV and associated block valve Licensee must justify shall be OPERABLE. that all PORVs Condition: Two [three] PORVs inoperable and inoperable and not capable of being manually cycled. incapable of being cycled is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM16].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.4.11.F LCO: Each PORV and associated block valve Licensee must justify shall be OPERABLE. that all block valves Condition: Two [three] block valves inoperable. inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM17].

3.5.1.B LCO: [Four] ECCS accumulators shall be The Applicable Safety OPERABLE. Analysis Bases state Condition: One accumulator inoperable for that three accumulators reasons other than boron concentration. are required to inject to meet the ECCS acceptance criteria and the contents of one accumulator are assumed lost through the break. Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR[BM18].

3.5.2.A LCO: Two ECCS trains shall be OPERABLE. Licensee must justify Condition: One or more [ECCS] trains inoperable. that one or more ECCS trains inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable. Acceptable justification is TS Condition requiring 100% flow equivalent to a single ECCS train.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.6.2.C LCO: [Two] containment air lock[s] shall be Licensee must justify OPERABLE. Condition: One or more that an inoperable containment air locks inoperable for reasons other containment air lock is than an inoperable door or inoperable interlock not a condition in mechanism. which all required trains or subsystems of a TS required system are inoperable. An acceptable argument may be that a note in TS 3.6.2 requires the condition to be assessed in accordance with TS 3.6.1, Containment Integrity, and any loss of function would require an immediate plant shutdown under that TS.

3.5.3.B LCO: One ECCS train shall be OPERABLE. Licensee must justify Condition: Required ECCS [high head subsystem] that it is not a condition in operable. (Mode 4). in which all required trains or subsystems of a TS required system are inoperable[BM19].

3.5.4.B LCO: The Refueling Water Storage Tank (RWST) Licensee must justify shall be OPERABLE. that it is not a condition Condition: RWST inoperable for reasons other in which all required than boron concentration or temperature trains or subsystems of a TS required system are inoperable[BM20].

3.5.6.A LCO: The Boron Injection Tank (BIT) shall be Licensee must justify OPERABLE. that it is not a condition Condition: BIT inoperable in which all required trains or subsystems of a TS required system are inoperable. If included, licensee must justify how the BIT is modeled in the PRA as it does not typically affect CDF or LERF[BM21].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.6.2.C LCO: [Two] containment air lock[s] shall be Licensee must justify OPERABLE. that an inoperable Condition: One or more containment air locks containment air locks is inoperable for reasons other than an inoperable not a condition in door or inoperable interlock. which all required trains or subsystems of a TS required system are inoperable[BM22].

3.6.3.B LCO: Each containment isolation valve shall be Licensee must justify OPERABLE. that both inoperable Condition: One or more penetration flow paths containment isolation with two [or more] containment isolation valves valves on a penetration inoperable [for reasons other than shield building is not a condition in bypass leakage and containment purge valves not which all required within leakage limit)) trains or subsystems of a TS required system are inoperable[BM23].

3.6.3.C LCO: Each containment isolation valve shall be Licensee must justify OPERABLE. that inoperable Condition: One or more penetration flow paths containment isolation with one containment isolation valve inoperable valve on a penetration (for penetrations with only one isolation valve). is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM24].

3.6.3.D LCO: Each containment isolation valve shall be Licensee must justify OPERABLE. that leakage in excess Condition: [One or more shield building bypass of the limit is not a leakage [or purge valve leakage] not within limit]. condition in which all required trains or subsystems of a TS required system are inoperable[BM25].

3.6.3.E LCO: Each containment isolation valve shall be Licensee must justify OPERABLE. that excessive leakage Condition: [One or more penetration flow paths is not a condition in with one or more containment purge valves not which all required within leakage limits.] trains or subsystems of a TS required system are inoperable[BM26].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.6.6A LCO: Containment Spray and Cooling Systems Licensee must justify (Atmospheric and Dual) (Credit taken for iodine the ability to calculate a removal by the Containment Spray System) RICT for the condition, Condition A: One containment spray train including how the inoperable. system is modeled in Condition C: One [required] containment cooling the PRA, whether all train inoperable. functions of the system Condition D: Two [required] containment cooling are modeled, and, if a trains inoperable. surrogate is used, why that modeling is conservative.

3.6.6B LCO: Containment Spray and Cooling Systems Licensee must justify (Atmospheric and Dual (Credit not taken for iodine the ability to calculate a removal by the Containment Spray System) RICT for the condition, Condition A: One containment spray train including how the inoperable. system is modeled in Condition B: One [required] containment cooling the PRA, whether all train inoperable. functions of the system Condition C: Two containment spray trains are modeled, and, if a inoperable. surrogate is used, why Condition D: One containment spray train and one that modeling is

[required] containment cooling train inoperable. conservative.

Condition E: Two [required] containment cooling trains inoperable.

3.6.6C.A LCO: Containment Spray System (Ice Condenser) Licensee must justify Condition: One containment spray train the ability to calculate a inoperable. RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.6.6D.A LCO: Quench Spray (QS) System Licensee must justify (Subatmospheric) the ability to calculate a Condition: One QS train inoperable RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.6.6E LCO: Recirculation Spray (RS) System Licensee must justify (Subatmospheric) the ability to calculate a Condition A: One RS subsystem inoperable. RICT for the condition, Condition B: Two RS subsystems inoperable in including how the one train. system is modeled in Condition C: Two inside RS subsystems the PRA, whether all inoperable functions of the system Condition D: Two outside RS subsystems are modeled, and, if a inoperable. surrogate is used, why Condition E: Casing cooling tank inoperable. that modeling is conservative.

3.6.16.A LCO: The ice condenser inlet doors, intermediate Licensee must justify deck doors, and top deck [doors] shall be that one or more OPERABLE and closed. inoperable doors is not Condition: One or more ice condenser doors a condition in which all physically restrained from opening required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all doors inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of Attachment 2.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.6.17.A LCO: Divider barrier integrity shall be Licensee must justify maintained. that one or more Condition: One or more personnel access doors or inoperable doors or equipment hatches open or inoperable, except for hatches is not a entry and exit. condition in which all required trains or subsystems of a TS required system are inoperable[BM27].

3.6.17.B LCO: Divider barrier integrity shall be Licensee must justify maintained. that it is not a condition Condition: Divider barrier seal inoperable in which all required trains or subsystems of a TS required system are inoperable[BM28].

3.7.4.B LOC: [Three] Atmospheric Dump Valves (ADV) Licensee must justify lines shall be OPERABLE. that two or more Condition: Two or more required ADV lines inoperable ADVs is not inoperable a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of Attachment 2.

3.7.6.A LOC: The Condensate Storage Tank (CST) shall Licensee must justify be OPERABLE. that this is not a Condition: CST inoperable condition in which all required trains or subsystems of a TS required system are inoperable[BM29].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.8.1.E LCO: The following AC electrical sources shall be Licensee must justify OPERABLE: that this is not a Condition: Two [required] DGs inoperable. condition in which all required trains or subsystems of a TS required system are inoperable[BM30].

3.8.4.A LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One [or two] battery charger[s] on one condition in which all subsystem inoperable. required trains or subsystems of a TS required system are inoperable.

3.8.4.B LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One [or two] batter[y][ies on one condition in which all subsystem] inoperable. required trains or subsystems of a TS required system are inoperable.

3.8.4.C LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One DC electrical power subsystem condition in which all inoperable for reasons other than Condition A [or required trains or B]. subsystems of a TS required system are inoperable.

3.8.7.A LCO: The required Train A and Train B inverters Licensee must justify shall be OPERABLE. that this is not a Condition: One [required] inverter inoperable. condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.9.A LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more AC electrical power required trains or distribution subsystems inoperable. subsystems of a TS required system are inoperable.

Page 35

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1431, Westinghouse STS Specification LCO Requirements and Condition Condition on Use 3.8.9.B LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more AC vital buses required trains or inoperable. subsystems of a TS required system are inoperable.

3.8.9.C LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more DC electrical power required trains or distribution subsystems inoperable. subsystems of a TS required system are inoperable.

Page 36

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Specification LCO Requirements and Condition Condition on Use 3.3.6.C LCO: [Four] channels of Loss of Voltage Function Licensee must justify (analog) and [four] channels of Degraded Voltage Function that more than two auto-initiation instrumentation per DG shall be channels per bus OPERABLE. inoperable is not a Condition: One or more Functions with more than condition in which all two channels inoperable. required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of Attachment 2.

3.4.9.B LCO: The pressurizer shall be OPERABLE Pressurizer is typically Condition: One [required] group of pressurizer not modeled in the heaters inoperable. PRA. Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

Page 37

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Specification LCO Requirements and Condition Condition on Use 3.4.10.A LCO: [Two] pressurizer safety valves shall be The Applicable Safety OPERABLE with lift settings > [2475] psia and < Analysis section of the

[2525] psia. Bases states that the Condition: One pressurizer safety valve accident analysis inoperable assumes all PSVs actuate to mitigate an overpressure event.

Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR.

Licensee must also explain how the PSVs are modeled in the PRA[BM31].

3.4.11.E LCO: Each Power Operated Relief Valve (PORV) Licensee must justify and associated block valve shall be OPERABLE that all PORVs Condition: Two PORVs inoperable and incapable inoperable and of being manually cycled. incapable of being cycled is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM32].

3.4.11.F LCO: Each PORV and associated block valve Licensee must justify shall be OPERABLE that all block valves Condition: Two block valves inoperable inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM33].

3.4.14.C LCO: Leakage from each reactor coolant system Licensee must justify (RCS) pressure isolation valve (PIV) shall be that applying a RICT to within limits. the action to isolate the Condition: Shutdown Cooling System autoclosure affected penetration is interlock function inoperable. equivalent to isolating a Containment Isolation Valve and is acceptable[BM34]

Page 38

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Specification LCO Requirements and Condition Condition on Use 3.5.1.B LCO: [Four] Safety Injection Tanks (SIT) shall be The Applicable Safety OPERABLE. Analysis Bases state Condition: One SIT inoperable that three SITs are required to inject to meet the ECCS acceptance criteria and the contents of one SIT are assumed lost through the break.

Licensee must justify that the condition does not represent the inability to perform the safety function assumed in the FSAR[BM35].

3.5.2.D LCO: Two ECCS trains shall be OPERABLE. Licensee must justify Condition: Less than 100% of the ECCS flow that one or more ECCS equivalent to a single OPERABLE train available. trains inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable. Acceptable justification is TS Condition requiring 100% flow equivalent to a single ECCS train.

Page 39

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Specification LCO Requirements and Condition Condition on Use 3.6.2.C LCO: [Two] containment air lock[s] shall be Licensee must justify OPERABLE. Condition: One or more that an inoperable containment air locks inoperable for reasons other containment air lock is than an inoperable door or inoperable interlock not a condition in mechanism. which all required trains or subsystems of a TS required system are inoperable. An acceptable argument may be that a note in TS 3.6.2 requires the condition to be assessed in accordance with TS 3.6.1, Containment Integrity, and any loss of function would require an immediate plant shutdown under that TS.

3.5.3.A LCO: One high pressure safety injection (HPSI) Licensee must justify train shall be OPERABLE. that it is not a condition Condition: Required HPCI train inoperable (Mode in which all required

4) trains or subsystems of a TS required system are inoperable[BM36].

3.5.4.A LCO: The Refueling Water Tank (RWT) shall be Licensee must justify OPERABLE. that it is not a condition Condition: RWT inoperable due to boron in which all required concentration or borated water temperature not trains or subsystems of within limits. a TS required system are inoperable[BM37].

3.5.4.B LCO: The Refueling Water Tank (RWT) shall be Licensee must justify OPERABLE. that it is not a condition Condition: RWT inoperable other than Condition in which all required A (above). trains or subsystems of a TS required system are inoperable[BM38].

Page 40

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Specification LCO Requirements and Condition Condition on Use 3.6.2.C LCO: [Two] containment air lock[s] shall be Licensee must justify OPERABLE. that an inoperable Condition: One or more containment air locks containment air lock is inoperable for reasons other than an inoperable not a condition in door or inoperable interlock which all required trains or subsystems of a TS required system are inoperable[BM39].

3.6.3.B LCO: Each containment isolation valve shall be Licensee must justify OPERABLE. that all inoperable Condition: One or more penetration flow paths containment isolation with two [or more] containment isolation valves valves on a penetration inoperable [for reasons other than leakage limits is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM40].

3.6.3.C LCO: Each containment isolation valve shall be Licensee must justify OPERABLE. that an inoperable Condition: One or more penetration flow paths containment isolation with one containment isolation valve inoperable. valve on a penetration is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM41].

3.6.3.D LCO: Each containment isolation valve shall be Licensee must justify OPERABLE. that purge valve Condition: One or more secondary containment leakage is not a bypass leakage [or purge valve leakage] not within condition in which all limit. required trains or subsystems of a TS required system are inoperable[BM42].

3.6.3.E LCO: Each containment isolation valve shall be Licensee must justify OPERABLE. that purge valve Condition: One or more penetration flow paths leakage is not a with one or more containment purge valves not condition in which all within purge valve leakage limits. required trains or subsystems of a TS required system are inoperable[BM43].

Page 41

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Specification LCO Requirements and Condition Condition on Use 3.6.6A LCO: Containment Spray and Cooling Systems Licensee must justify (Atmospheric and Dual) (Credit taken for iodine the ability to calculate a removal by the Containment Spray System) RICT for the condition, Condition A: One containment spray train including how the inoperable. system is modeled in Condition C: One containment cooling train the PRA, whether all inoperable. functions of the system Condition D: One containment spray and one are modeled, and, if a containment cooling train inoperable. surrogate is used, why Condition E: Two containment cooling trains that modeling is inoperable. conservative.

3.6.6B LCO: Containment Spray and Cooling Systems Licensee must justify (Atmospheric and Dual) (Credit not taken for the ability to calculate a iodine removal by the Containment Spray System) RICT for the condition, Condition A: One containment spray train including how the inoperable. system is modeled in Condition B: One containment cooling train the PRA, whether all inoperable. functions of the system Condition C: Two containment spray trains are modeled, and, if a inoperable. surrogate is used, why Condition D: One containment spray train and one that modeling is containment cooling train inoperable. conservative.

Condition E: Two containment cooling trains inoperable.

3.7.4.B LCO: [Two] Atmospheric Dump Valve (ADV) Licensee must justify lines shall be OPERABLE. Condition: Two or that two or more more [required] ADV lines inoperable. inoperable ADVs is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM44].

3.7.6.A LCO: The Condensate Storage Tank (CST) shall Licensee must justify be OPERABLE. that this is not a Condition: CST inoperable condition in which all required trains or subsystems of a TS required system are inoperable[BM45].

Page 42

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Specification LCO Requirements and Condition Condition on Use 3.8.1.E LCO: The following AC electrical sources shall be Licensee must justify OPERABLE: that this is not a Condition: Two DGs inoperable condition in which all required trains or subsystems of a TS required system are inoperable[BM46].

3.8.4.A LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One [or two] battery charger[s] on one condition in which all subsystem inoperable. required trains or subsystems of a TS required system are inoperable.

3.8.4.B LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One [or two] batter[y][ies on one condition in which all subsystem] inoperable. required trains or subsystems of a TS required system are inoperable.

3.8.4.C LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One DC electrical power subsystem condition in which all inoperable for reasons other than Condition A [or required trains or B]. subsystems of a TS required system are inoperable.

3.8.7.A LCO: The required Train A and Train B inverters Licensee must justify shall be OPERABLE. that this is not a Condition: One [required] inverter inoperable. condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.9.A LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more AC electrical power required trains or distribution subsystems inoperable. subsystems of a TS required system are inoperable.

Page 43

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1432, Combustion Engineering STS Specification LCO Requirements and Condition Condition on Use 3.8.9.B LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more AC vital buses required trains or inoperable. subsystems of a TS required system are inoperable.

3.8.9.C LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more DC electrical power required trains or distribution subsystems inoperable. subsystems of a TS required system are inoperable.

Page 44

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1433, BWR/4 STS Specification LCO Requirements and Condition Condition on Use 3.3.1.1.C LCO: The RPS instrumentation for each Function Licensee must justify in Table 3.3.1.1-1 shall be OPERABLE. that this is not a Condition: One or more Functions with RPS trip condition in which all capability not maintained. required trains or subsystems of a TS required system are inoperable[BM47].

3.3.1.2.A LCO: The SRM instrumentation in Table 3.3.1.2-1 Licensee must justify shall be OPERABLE. that one or more Condition: One or more required SRMs inoperable SRMs is not inoperable in MODE 2 with intermediate range a condition in which all monitors (IRMs) on Range 2 or below required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time. See Note 1 at the end of Attachment 2.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

Page 45

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1433, BWR/4 STS Specification LCO Requirements and Condition Condition on Use 3.3.2.2.B LCO: [Three] channels of feedwater and main Licensee must justify turbine high water level trip instrumentation shall that two or more be OPERABLE. inoperable trip Condition: Two or more feedwater and main channels is not a turbine high water level trip channels inoperable. condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of Attachment 2.

Page 46

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1433, BWR/4 STS Specification LCO Requirements and Condition Condition on Use 3.3.4.1.A LCO: End of Cycle Recirculation Pump Trip Licensee must justify (EOC-RPT) Instrumentation that one or more Condition: One or more required channels inoperable EOC-RPT inoperable. channels is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. See Note 1 at the end of Attachment 2.

Licensee must justify the ability to calculate a RICT given that EOC-RPT channels are not typically modeled in the PRA. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.

Page 47

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1433, BWR/4 STS Specification LCO Requirements and Condition Condition on Use 3.3.4.1.B LCO: a. Two channels per trip system for each Licensee must justify EOC-RPT instrumentation Function listed below that one or more shall be OPERABLE inoperable EOC-RPT Condition: One or more Functions with EOC-RPT channels is not a trip capability not maintained. condition in which all AND required trains or

[MCPR limit for inoperable EOC-RPT not made subsystems of a TS applicable.] required system are inoperable. Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative[BM48].

3.3.4.2.B LCO: Two channels per trip system for each Licensee must justify ATWS-RPT instrumentation Function listed below that this is not a shall be OPERABLE condition in which all Condition: One Function with ATWS-RPT trip required trains or capability not maintained. subsystems of a TS required system are inoperable. Licensee must justify the ability to calculate a RICT given that ATWS-RPT channels are not typically modeled in the PRA[BM49].

Page 48

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1433, BWR/4 STS Specification LCO Requirements and Condition Condition on Use 3.3.4.2.C LCO: Two channels per trip system for each Licensee must justify ATWS-RPT instrumentation Function listed below that this is not a shall be OPERABLE condition in which all Condition: Both Functions with ATWS-RPT trip required trains or capability not maintained. subsystems of a TS required system are inoperable. Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative[BM50].

3.3.5.2.C LCO: The RCIC System instrumentation for each Licensee must justify Function in Table 3.3.5.2-1 shall be OPERABLE. that inoperability of Condition: As required by Required Action A.1 this single channel and referenced in Table 3.3.5.2-1. function is not a (i.e., One or more channels inoperable: condition in which all

- Reactor Vessel Water - High, Level 8 required trains or

- [Manual Initiation]) subsystems of a TS required system are inoperable[BM51].

3.3.6.1.B LCO: The primary containment isolation Licensee must justify instrumentation for each Function in Table 3.3.6.1- that this is not a 1 shall be OPERABLE. condition in which all Condition: One or more automatic Functions with required trains or isolation capability not maintained. subsystems of a TS required system are inoperable[BM52].

Page 49

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1433, BWR/4 STS Specification LCO Requirements and Condition Condition on Use 3.3.6.3.A LCO: Low-Low Set (LLS) Instrumentation Licensee must justify Condition: One LLS valve inoperable due to the ability to calculate a inoperable channel(s). RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.3.6.3.C LCO: The LLS valve instrumentation for each Licensee must justify Function in Table 3.3.6.3-1 shall be OPERABLE. that this is not a Condition: ---NOTE--- condition in which all Separate Condition entry is allowed for each required trains or S/RV.-------- subsystems of a TS One or more S/RVs with two Function 3 channels required system are inoperable. inoperable. Licensee must justify the ability to calculate a RICT for this inoperability[BM53].

3.3.8.1.A LCO: The LOP instrumentation for each Function Licensee must justify in Table 3.3.8.1-1 shall be OPERABLE. that one or more Condition: One or more channels inoperable. channels inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.See Note 1 at the end of Attachment 2.

Page 50

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1433, BWR/4 STS Specification LCO Requirements and Condition Condition on Use 3.6.1.2.C LCO: The primary containment air lock shall be Licensee must justify OPERABLE. that an inoperable Condition: Primary containment air lock airlock is not a inoperable for reasons other than an inoperable condition in which all door or inoperable interlock required trains or subsystems of a TS required system are inoperable[BM54].

3.6.1.3.B LCO: Each PCIV, except reactor building-to- Licensee must justify suppression chamber vacuum breakers, shall be that all inoperable OPERABLE. PCIVs in a flow path is Condition: One or more penetration flow paths not a condition in with two [or more] PCIVs inoperable for reasons which all required other than {leak rate} trains or subsystems of a TS required system are inoperable[BM55].

3.6.1.3.C LCO: Each PCIV, except reactor building-to- Licensee must justify suppression chamber vacuum breakers, shall be that inoperability of the OPERABLE. single PCIV in a flow Condition: One or more penetration flow paths path is not a condition with one inoperable isolation valve (for in which all required penetrations with only one valve) trains or subsystems of a TS required system are inoperable[BM56].

3.6.1.2.C LCO: The primary containment air lock shall be Licensee must justify OPERABLE. Condition: Primary containment air that an inoperable lock inoperable for reasons other than Condition A containment air lock is or B. not a condition in which all required trains or subsystems of a TS required system are inoperable. An acceptable argument may be that a note in TS 3.6.1.2 requires the condition to be assessed in accordance with TS 3.6.1.1, Primary Containment, and any loss of function would require an immediate plant shutdown under that TS.

Page 51

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1433, BWR/4 STS Specification LCO Requirements and Condition Condition on Use 3.6.1.3.E LCO: Each PCIV, except reactor building-to- Licensee must justify suppression chamber vacuum breakers, shall be that PCIV leakage in OPERABLE. excess of the limits is Condition: One or more penetration flow paths not a condition in with one or more containment purge valves not which all required within purge valve leakage limits. trains or subsystems of a TS required system are inoperable.

Licensee must justify the ability to calculate a RICT for this inoperability.

3.6.1.7.D LCO: Each reactor building-to-suppression Licensee must justify chamber vacuum breaker shall be OPERABLE. that one or more Condition: Two or more lines with one or more inoperable vacuum reactor building -to-suppression chamber vacuum breakers on two or breakers inoperable for opening. more lines is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. See Note 1 at the end of Attachment 2.

Page 52

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1433, BWR/4 STS Specification LCO Requirements and Condition Condition on Use 3.7.7.A LCO: The Main Turbine Bypass System shall be Licensee must justify OPERABLE. the ability to calculate a OR RICT for the condition, The following limits are made applicable: including how the

[ a. LCO 3.2.1, "AVERAGE PLANAR LINEAR system is modeled in HEAT GENERATION RATE (APLHGR)," limits the PRA, whether all for an inoperable Main Turbine Bypass System, as functions of the system specified in the [COLR]; and ] are modeled, and, if a

[ b. LCO 3.2.2, "MINIMUM CRITICAL POWER surrogate is used, why RATIO (MCPR)," limits for an inoperable Main that modeling is Turbine Bypass System, as specified in the conservative.

[COLR]. ]

Condition: [Requirements of the LCO not met or Main Turbine Bypass System inoperable].

3.8.1.E LCO: The following AC electrical power sources Licensee must justify shall be OPERABLE : that this is not a Condition: Two [or three] required DGs condition in which all inoperable required trains or subsystems of a TS required system are inoperable[BM57].

3.8.4.A LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One [or two] battery charger[s] on one condition in which all subsystem inoperable. required trains or subsystems of a TS required system are inoperable.

3.8.4.B LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One [or two] batter[y][ies on one condition in which all subsystem] inoperable. required trains or subsystems of a TS required system are inoperable.

3.8.4.C LCO: The Train A and Train B DC electrical Licensee must justify power subsystems shall be OPERABLE. that this is not a Condition: One DC electrical power subsystem condition in which all inoperable for reasons other than Condition A [or required trains or B]. subsystems of a TS required system are inoperable.

Page 53

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1433, BWR/4 STS Specification LCO Requirements and Condition Condition on Use 3.8.7.A LCO: The required Train A and Train B inverters Licensee must justify shall be OPERABLE. that this is not a Condition: One [required] inverter inoperable. condition in which all required trains or subsystems of a TS required system are inoperable.

3.8.9.A LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more AC electrical power required trains or distribution subsystems inoperable. subsystems of a TS required system are inoperable.

3.8.9.B LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more AC vital buses required trains or inoperable. subsystems of a TS required system are inoperable.

3.8.9.C LCO: Train A and Train B AC, DC, and AC vital Licensee must justify bus electrical power distribution subsystems shall that this is not a be OPERABLE. condition in which all Condition: One or more DC electrical power required trains or distribution subsystems inoperable. subsystems of a TS required system are inoperable.

Page 54

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1434, BWR/6 STS Specification LCO Requirements and Condition Condition on Use 3.3.1.1.C LCO: The RPS instrumentation for each Function Licensee must justify in Table 3.3.1.1-1 shall be OPERABLE. that this is not a Condition: One or more Functions with RPS trip condition in which all capability not maintained. required trains or subsystems of a TS required system are inoperable[BM58].

3.3.1.2.A LCO: The SRM instrumentation in Table 3.3.1.2-1 Licensee must justify shall be OPERABLE. that one or more Condition: One or more required SRMs inoperable SRMs is not inoperable in MODE 2 with intermediate range a condition in which all monitors (IRMs) on Range 2 or below. required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. See Note 1 at the end of Attachment 2.

Licensee must justify the ability to calculate a RICT given that SRMs are not typically modeled in the PRA.

An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.

Page 55

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1434, BWR/6 STS Specification LCO Requirements and Condition Condition on Use 3.3.4.1.A LCO: End of Cycle Recirculation Pump Trip Licensee must justify (EOC-RPT) Instrumentation that one or more Condition: One or more required channels inoperable channels is inoperable. not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. See Note 1 at the end of Attachment 2. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

Page 56

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1434, BWR/6 STS Specification LCO Requirements and Condition Condition on Use 3.3.4.1.B LCO: a. Two channels per trip system for each Licensee must justify EOC-RPT instrumentation Function listed below that one or more shall be OPERABLE: inoperable EOC-RPT

1. Turbine Stop Valve (TSV) - Closure and 2. channels is not a Turbine Control Valve (TCV) Fast Closure, Trip condition in which all Oil Pressure -Low. [ OR required trains or

b. LCO 3.2.2, "MINIMUM CRITICAL POWER subsystems of a TS RATIO (MCPR)," limits for inoperable EOC-RPT required system are as specified in the COLR are made applicable.] inoperable. Licensee Condition: One or more Functions with EOC-RPT must justify the ability trip capability not maintained. to calculate a RICT for AND the condition, including

[MCPR limit for inoperable EOC-RPT not made how the system is applicable.] modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative[BM59].

3.3.4.2.B LCO: Two channels per trip system for each Licensee must justify ATWS-RPT instrumentation Function listed below that this is not a shall be OPERABLE: condition in which all

a. Reactor Vessel Water Level - Low Low, Level 2 required trains or and subsystems of a TS

b. Reactor Steam Dome Pressure - High. required system are Condition: One Function with ATWS-RPT trip inoperable. Licensee capability not maintained. must justify the ability to calculate a RICT given that ATWS-RPT channels are not typically modeled in the PRA[BM60].

Page 57

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1434, BWR/6 STS Specification LCO Requirements and Condition Condition on Use 3.3.4.2.C LCO: Two channels per trip system for each Licensee must justify ATWS-RPT instrumentation Function listed below that this is not a shall be OPERABLE: condition in which all

a. Reactor Vessel Water Level - Low Low, Level 2 required trains or and subsystems of a TS

b. Reactor Steam Dome Pressure - High. required system are Condition: Both Functions with ATWS-RPT trip inoperable. Licensee capability not maintained. must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative[BM61].

3.3.5.2.C LCO: The RCIC System instrumentation for each Licensee must justify Function in Table 3.3.5.2-1 shall be OPERABLE. that inoperability of Condition: As required by Required Action A.1 this single channel and referenced in Table 3.3.5.2-1. function is not a (i.e., One or more channels inoperable: condition in which all

- Reactor Vessel Water Level - High, Level 8 required trains or

- [Manual Initiation) subsystems of a TS required system are inoperable[BM62].

3.3.6.1.B LCO: The primary containment isolation Licensee must justify instrumentation for each Function in Table 3.3.6.1- that this is not a 1 shall be OPERABLE. condition in which all Condition: One or more automatic Functions with required trains or isolation capability not maintained. subsystems of a TS required system are inoperable[BM63].

3.3.6.4.B LCO: The SPMU System instrumentation for each Licensee must justify Function in Table 3.3.6.4-1 shall be OPERABLE. that this condition, Condition: As required by Required Action A.1 which can include all and referenced in Table 3.3.6.4-1.B.1. channels in a function inoperable, is not a Condition in which all required trains or subsystems of a TS required system are inoperable[BM64].

Page 58

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1434, BWR/6 STS Specification LCO Requirements and Condition Condition on Use 3.3.6.5.A LCO: Relief and Low-Low Set (LLS) Licensee must justify Instrumentation the ability to calculate a Condition: One trip system inoperable. RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.3.8.1.A LCO: The LOP instrumentation for each Function Licensee must justify in Table 3.3.8.1-1 shall be OPERABLE. that one or more Condition: One or more channels inoperable. channels inoperable is not a condition in which all required trains or subsystems of a TS required system are inoperable or modify the Action to not apply a RICT when all required trains or subsystems are inoperable. An acceptable alternative may be to create a separate condition for all channels inoperable that does not apply a Risk Informed Completion Time. See Note 1 at the end of Attachment 2.

3.6.1.3.B LCO: Each PCIV shall be OPERABLE. Licensee must justify Condition: One or more penetration flow paths that both inoperable with two [or more] PCIVs inoperable for reasons PCIVs in a flow path is other than {leak rate} not a condition in which all required trains or subsystems of a TS required system are inoperable[BM65].

Page 59

Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1434, BWR/6 STS Specification LCO Requirements and Condition Condition on Use 3.6.1.3.C LCO: Each PCIV shall be OPERABLE. Licensee must justify Condition: One or more penetration flow paths that inoperability of the with one inoperable isolation valve (for single PCIV in a flow penetrations with only one valve) path is not a condition in which all required trains or subsystems of a TS required system are inoperable[BM66].

3.6.1.3.D LCO: Each PCIV shall be OPERABLE. Licensee must justify Condition: [One or more [secondary containment that PCIV leakage in bypass leakage rate,] [MSIV leakage rate,] [purge excess of the limits is valve leakage rate,] [hydrostatically tested line not a condition in leakage rate,] [or] [EFCV leakage rate] not within which all required limit. trains or subsystems of a TS required system are inoperable.

Licensee must justify the ability to calculate a RICT for this inoperability[BM67].

3.6.1.2.C LCO: The primary containment air lock shall be Licensee must justify OPERABLE. Condition: Primary containment air that an inoperable lock inoperable for reasons other than Condition A containment air lock is or B. not a condition in which all required trains or subsystems of a TS required system are inoperable. An acceptable argument may be that a note in TS 3.6.1.2 requires the condition to be assessed in accordance with TS 3.6.1.1, Primary Containment, and any loss of function would require an immediate plant shutdown under that TS.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1434, BWR/6 STS Specification LCO Requirements and Condition Condition on Use 3.6.1.3.E LCO: Each PCIV shall be OPERABLE. Licensee must justify Condition: One or more penetration flow paths that PCIV leakage in with one or more containment purge valves not excess of the limits is within purge valve leakage limits. not a condition in which all required trains or subsystems of a TS required system are inoperable.

Licensee must justify the ability to calculate a RICT for the condition, including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.6.1.7.A LCO: Residual Heat Removal (RHR) Containment Licensee must justify Spray System the ability to calculate a Condition: One RHR containment spray RICT for the condition, subsystem inoperable. including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.6.2.4.A LCO: Two Suppression Pool Makeup (SPMU) Licensee must justify System subsystems shall be OPERABLE. that this condition, Condition: Upper containment pool water level which affects both not within limit. SPMU subsystems, is not a Condition in which all required trains or subsystems of a TS required system are inoperable.

Licensee must justify the ability to calculate a RICT for this inoperability[BM68].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1434, BWR/6 STS Specification LCO Requirements and Condition Condition on Use 3.6.2.4.B LCO: Two SPMU subsystems shall be Licensee must justify OPERABLE. that this condition, Condition: Upper containment pool water which affects both temperature not within limit. SPMU subsystems, is not a Condition in which all required trains or subsystems of a TS required system are inoperable.

Licensee must justify the ability to calculate a RICT for this inoperability[BM69].

3.6.5.3.B LCO: Each drywell isolation valve [,except for Licensee must justify Drywell Vacuum Relief System valves,] shall be that both inoperable OPERABLE. valves in a flow path is Condition: One or more penetration flow paths not a condition in with two drywell isolation valves inoperable. which all required trains or subsystems of a TS required system are inoperable[BM70].

3.6.5.6.D LCO: [Two] drywell post-LOCA and [two] Licensee must justify drywell purge vacuum relief subsystems shall be that this is not a OPERABLE. condition in which all Condition: [Two] drywell purge vacuum relief required trains or subsystems inoperable for reasons other than subsystems of a TS vacuum relief subsystem not closed. required system are inoperable[BM71].

3.6.5.6.E LCO: [Two] drywell post-LOCA and [two] Licensee must justify drywell purge vacuum relief subsystems shall be that this is not a OPERABLE. condition in which all Condition: [Two] drywell post-LOCA vacuum required trains or relief subsystems inoperable for reasons other than subsystems of a TS Condition A. required system are AND inoperable[BM72].

One drywell purge vacuum relief subsystem inoperable for reasons other than Condition A.

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests NUREG-1434, BWR/6 STS Specification LCO Requirements and Condition Condition on Use 3.7.4.A LCO: Two [control room AC] subsystems shall be Licensee must justify OPERABLE. the ability to calculate a Condition: One [control room AC] subsystem RICT for the condition, inoperable. including how the system is modeled in the PRA, whether all functions of the system are modeled, and, if a surrogate is used, why that modeling is conservative.

3.7.6.A LCO: The Main Turbine Bypass System shall be Licensee must justify OPERABLE. the ability to calculate a OR RICT for the condition, The following limits are made applicable: including how the

[ a. LCO 3.2.1, "AVERAGE PLANAR LINEAR system is modeled in HEAT GENERATION RATE (APLHGR)," limits the PRA, whether all for an inoperable Main Turbine Bypass System, as functions of the system specified in the [COLR] and ] are modeled, and, if a

[ b. LCO 3.2.2, "MINIMUM CRITICAL POWER surrogate is used, why RATIO (MCPR)," limits for an inoperable Main that modeling is Turbine Bypass System, as specified in the conservative.

[COLR]. ]

Condition: [Requirements of the LCO not met or Main Turbine Bypass System inoperable].

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Attachment 2 Conditional Variations from TSTF-505-A in Near-Term Plant-Specific License Amendment Requests Note 1 Some Conditions are applicable when an unspecified number of subsystems or instrument channels are inoperable, typically written as "One or more" or "Two or more". These conditions currently apply when all subsystems or channels required to be operable to perform a function are inoperable, and application of a RICT in this situation is prohibited in the near-term TSTF-505 submittals.

To address this, it is recommended that the following modification to TSTF-505 be made to the Required Actions indicated in the Attachment 2 tables for Completion Times potentially applicable when all required subsystems or channels are inoperable.

The typical Completion Time is modified by TSTF-505 to state:

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (i.e., the existing Completion Time)

OR In accordance with the Risk Informed Completion Time Program It is recommended that the second Completion Time be modified with a Note, as shown below:

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (i.e., the existing Completion Time)

OR

NOTE-------------

Not applicable when

[all/four/both] required channels are inoperable.

In accordance with the Risk Informed Completion Time Program The bracketed number of channels will depend on the specification. This approach retains the existing requirements and limits the use of a RICT to conditions in which the function can still be performed.

The licensee must justify that the required function can still be performed absent an additional failure when a RICT is applied.

Alternatively, the licensee may modify the Condition to only apply when at least one subsystem or channel is operable, but this approach may require creating a new Condition or modifying an existing condition to retain the current requirements, or accepting a more restrictive requirement (such a LCO 3.0.3 entry).

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Attachment 3 Response to Additional NRC Questions on TSTF-505 At the December 13, 2016, public meeting, the NRC asked for more information on the inclusion of a Risk Informed Completion Time (RICT) provision for Required Actions that do not require restoration of the system to Operable status.

Response

At a September 8, 2010, public meeting between the NRC and the TSTF to discuss TSTF-505, the NRC raised concerns with including changes in TSTF-505 that were not in the South Texas Project (STP) lead plant submittal scope of applying a RICT to Required Actions that either 1) require restoring the inoperable system to operable status, 2) require placing an instrument channel in trip, or 3) require isolating a containment isolation valve. As a result, Revision 1 of TSTF-505 removed changes that did not fall into these categories.

In a Request for Additional Information (RAI) on TSTF-505 dated July 27, 2010, the NRC questioned the calculation of a RICT for placing a channel in trip or bypass. The TSTF agreed to remove changes applying a RICT to placing a channel in bypass, and justified applying a RICT for placing a channel in trip. The RAI response stated:

The TSTF believes that the TSTF-505 option to calculate a RICT for placing channels in trip should be retained. The NRC has reviewed and approved risk-based Topical Reports that change the Completion Time for placing a channel in trip, such as WCAP-14333, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times,"

approved July 15, 1998. A licensee could choose to model these actions and calculate a RICT for placing a channel in trip.

The NRC approved TSTF-505 with provisions to calculate a RICT for Required Actions that require placing a channel in trip.

2. At the December 13, 2016, public meeting, the NRC asked for an explanation of the difference between the TSTF-505 RICT program and the NEI 06-09 Configuration Risk Management Program.

Response

The TSTF-505 justification, Section 2.0, "Proposed Change," states:

There is a new Chapter 5 Program entitled, "Risk Informed Completion Time Program" which is invoked when utilizing a RICT. In NEI 06-09 this program is called the Configuration Risk Management Program. That title is not used in the Traveler because some licensees already have a Chapter 5 program of that name serving a different purpose and the proposed name is more descriptive of the purpose of the new program.

Therefore, the TSTF-505 Risk Informed Completion Time program is the same as the NEI 06-09 Configuration Risk Management Program.

Page 1

Attachment 3 Response to Additional NRC Questions on TSTF-505

3. At the December 13, 2016, public meeting, the NRC asked for a more detailed discussion regarding treatment of common cause failure term adjustments when calculating a RICT.

Response

The NEI 06-09 and the associated safety evaluation state that common cause must be considered for emergent failures and require consideration and implementation of Risk Management Actions (RMAs) to address the risk of potential common cause failures as identified by the extent of condition evaluation.

The last paragraph of section 2.3.1 of NEI 06-09 states:

15. Operability determinations should follow regulatory guidance established in Part 9900 of the NRC Inspection Manual [9]. RMAT and RICT calculations performed for emergent conditions shall be performed assuming that all equipment not declared inoperable during the operability determination process are functional. However, the station shall establish appropriate RMAs based on an assessment of the potential for increased risks due to common cause failure of similar equipment. (Note that if there is not evidence for increased potential for common cause failures, no RMAs are required).

The safety evaluation for NEI 06-09, in the section titled "emergent failures," states:

Emergent Failures. During the time when an RICT is in effect and risk is being assessed and managed, it is possible that emergent failures of SSCs may occur, and these must be assessed to determine the impact on the RICT. If a failed component is one of two or more redundant components in separate trains of a system, then there is potential for a common cause failure mechanism. Licensees must continue to assess the remaining redundant components to determine there is reasonable assurance of their continued operability, and this is not changed by implementation of the RMTS. If a licensee concludes that the redundant components remain operable, then these components are functional for purposes of the RICT. However, the licensee is required to consider and implement additional risk management actions (RMAs), due to the potential for increased risks from common cause failure of similar equipment. The staff interprets TR NEI 06-09, Revision 0, as requiring consideration of such RMAs whenever the redundant components are considered to remain operable, but the licensee has not completed the extent of condition evaluations, and additionally, as required by a follow-up prompt operability determination. (emphasis added)

NEI 06-09 includes the following guidance on consideration of common cause failures:

3.3.6 Common Cause Failure Consideration Common cause failures are required to be considered for all RICT assessments. For all RICT assessments of planned configurations, the treatment of common cause failures in the quantitative CRM Tools may be performed by considering only the removal of the planned equipment and not adjusting common cause failure terms. For RICT assessments involving unplanned or emergent conditions, the potential for common cause failure is Page 2

Attachment 3 Response to Additional NRC Questions on TSTF-505 considered during the operability determination process. This assessment is more accurately described as an "extent of condition" assessment. Licensed operators recognize that an emergent condition identified on a Technical Specifications component may have the potential to affect a redundant component or similar components. In addition to a determination of operability on the affected component, the operator should make a judgment with regard to whether the operability of similar or redundant components might be affected. In accordance with the operability determination guidance in Part 9900 of the NRC Inspection Manual (provided in Regulatory Information Summary 2005-20), the determination of operability should be done promptly, commensurate with the safety significance of the affected component. If a common condition affects the operability of multiple components (e.g., that more than one common cause group functional train is affected), action should be taken via the Technical Specifications. Based on the information available, the licensed operator is often able to make an immediate determination that there is reasonable assurance that redundant or similar components are not affected. Using judgment with regard to the specific condition, the operator may direct that similar or redundant components be inspected for evidence of the degradation. For conditions where the operator has less information, assistance from other organizations, such as Station Engineering, is typically requested. These support organizations continue to perform the evaluation promptly, as described above. The guidance contained in Part 9900 of the Inspection Manual is used as well as conservative decision-making for extent of condition evaluations. The components are considered functional in the PRA unless the operability evaluation determines otherwise.

While quantitative changes to the PRA are not required, the PRA should be used as appropriate to provide insights for the qualitative treatment of potential common cause failures and RMAs that may be applied for the affected configuration. Such information may be used in prioritizing the repair, ensuring proper resource application, and taking other compensatory measures as deemed prudent by station management."

NRC Regulatory Guide 1.177, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," addresses common cause failure treatment for risk-informed changes to Technical Specifications. Appendix A, Section 1.3.1.1, discusses quantitative adjustment of the common cause failure probabilities based on the cause of the equipment unavailability. Section 2.3 of the Regulatory Guide states that Appendix A outlines issues associated with Tier 1. Tier 1 is an assessment of the risk impact of a proposed change that is submitted to the NRC as part of a license amendment request. This is contrasted with Tier 3, which is a contemporaneous configuration risk management risk assessment performed by the licensee while the equipment is out of service.

As noted in NEI 06-09, Section 1.1, and throughout the document, the assessment and management of configuration-specific risk is within the context of a configuration risk management program, and the RICT is required to be re-calculated for any configuration changes. Since common cause failure quantitative adjustments are explicitly excluded from Tier 3 methods in Regulatory Guide 1.177 and since the RICT calculations are configuration risk Page 3

Attachment 3 Response to Additional NRC Questions on TSTF-505 assessments associated with Tier 3 assessments, these quantitative adjustments are not applicable to calculating a RICT.

Therefore, the RICT process explicitly addresses common cause failure and mitigates the associated risk by development and implementation of RMAs specifically targeted toward common cause failure, consistent with regulatory guidance.

4. At the December 13, 2016, public meeting, the NRC asked for a discussion regarding the differences between the Risk Informed Completion Time Program and the 10 CFR 50.65 Maintenance Rule program.

Response

Most TS provide a Completion Time during which the LCO may not be met to permit a licensee to perform required testing, maintenance, or repair activities. Normally, upon expiration of the Completion Time, the requirement to shut down the reactor or follow remedial action is imposed. NEI 06-09 provides a means for the licensee to extend the Completion Time and thereby delay reactor shutdown or remedial actions, if risk is assessed and managed within specified limits and programmatic requirements established by the TS. The regulatory requirements for the content of LCOs will continue to be met, since only the Completion Time is changed. The specific functional capabilities or performance levels of equipment required by the safety analyses are unchanged, and the remedial actions, including the requirement to shut down the reactor, are also unchanged; only the specific time limits for initiating actions are extended by the methodology documented in NE1 06-09.

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 structures, systems and components (SSCs) against licensee-established goals in a manner sufficient to provide a reasonable assurance that these SSCs are capable of fulfilling their intended functions. In addition, 10 CFR 50.65(a)(4) requires the assessment and management of the increase in risk that may result from a proposed maintenance activity. The methodology in NE1 06-09 uses processes that are complementary to the requirements of 10 CFR 50.65(a)(4).

Both processes recognize that plant risk is increased when equipment is out of service. Both processes take actions commensurate with the risk due to the specific configuration. If a system is addressed in the Technical Specifications any work performed under the Maintenance Rule program is performed within the constraints of the TS completion time. The RICT program allows the completion time available to perform work to potentially be adjusted within the constraints of the program and plant configuration. Thus, the two programs are interrelated and implementation of the RICT program builds on the existing Maintenance Rule configuration control process.

5. At the December 13, 2016, public meeting, the NRC questioned applying a RICT to existing TS Actions that appeared to be a loss of function. In particular, the staff questioned calculating a RICT for the existing Actions for two inoperable emergency diesel generators and two inoperable offsite circuits.

Page 4

Attachment 3 Response to Additional NRC Questions on TSTF-505

Response

The ISTS defines "operable/operability" as:

A system, subsystem, train, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

(emphasis added)

In order to be operable, a system must have either normal electrical power (offsite circuits) or emergency electrical power (emergency diesel generators). Losing one power source does not render the supported systems inoperable. TS 3.8.1, "AC Sources - Operating," contains requirements on both the offsite circuits and the emergency diesel generators because either system can perform the safety function.

TS Administrative Controls Section 5.5, "Safety Function Determination Program," defines a loss of safety function. It states:

A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed.

Under this TS definition, a single offsite circuit or a single emergency diesel generator can perform the safety function. Therefore, the existing TS 3.8.1 Actions for two inoperable offsite circuits (Action C) or two inoperable diesel generators (Action E) do not represent a loss of safety function. This is consistent with the TS Bases. The Bases for Condition H, which is applicable when three or more required AC sources are inoperable, states, "Condition H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function" (emphasis added). In other words, a loss of safety function occurs when there is no operable offsite circuits or emergency diesel generators.

Therefore, a RICT can be calculated for two inoperable offsite circuits (Condition C) or two inoperable emergency diesel generators (Condition E) without considering PRA Functionality or a loss of function.

Page 5

Attachment 3 TSTF-505 Model Application Page PROPOSED MODEL APPLICATION FOR PLANT-SPECIFIC ADOPTION OF TSTF-505, REVISION 1, "PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF INITIATIVE 4B" U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

SUBJECT:

[PLANT]

DOCKET NO. 50-[XXX]

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT RISK INFORMED COMPLETION TIMES TSTF-505, REVISION 1, "PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF INITIATIVE 4B."

REFERENCE:

Letter from the TSTF to U.S. NRC, "Response to NRC Questions on TSTF-505, 'Provide Risk-Informed Extended Completion Times'," dated DATE 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.]

The proposed amendment would modify TS requirements to permit the use of Risk Informed Completion Times in accordance with TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b,." as modified by the [DATE] letter from the TSTF to the NRC (Reference). The availability of this TS improvement was announced in the Federal Register on March 15, 2012 [Date] (77[ ] FR 15399)[ ]).

Attachment 1 provides a description and assessment 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 changes.

Attachment 3 provides revised (clean) TS pages.

Attachment 4 provides existing TS Bases pages marked up to show the proposed changes.

[LICENSEE] requests approval of the proposed license amendment by [DATE], with the amendment being implemented [BY DATE OR WITHIN X DAYS].

Page In accordance with 10 CFR 50.91(a)(1), "Notice for Public Comment," the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission.

In accordance with 10 CFR 50.91(b)(1), "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 true and correct.

Executed on [date][Signature]

If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)

3. Revised Technical Specification Pages

4. Proposed Technical Specification Bases Changes (Mark-Up)

Enclosures:

1. List of Revised Required Actions to Corresponding PRA Functions

2. Information Supporting Consistency with Regulatory Guide 1.200, Revision 2.

3. Information Supporting Technical Adequacy of PRA Models Without PRA Standards Endorsed by Regulatory Guide 1.200, Revision 2.

4. Information Supporting Justification of Excluding Sources of Risk Not Addressed by the PRA Models.

5. Baseline CDF and LERF.

6. Justification of Application Of At-Power PRA Models to Shutdown Modes.

7. PRA Model Update Process.

8. Attributes of the CRMP Model.

9. Key Assumptions and Sources of Uncertainty.

10. Program Implementation

11. Monitoring Program

12. Risk Management Action Examples cc: NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact Page ATTACHMENT 1 DESCRIPTION AND ASSESSMENT OF THE PROPOSED CHANGE License Amendment Request for Adoption of TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b"

1.0 DESCRIPTION

The proposed amendment would modify the Technical Specification (TS) requirements related to Completion Times (CTs) for Required Actions to provide the option to calculate a longer, risk-informed CT (RICT). A new program, the Risk-Informed Completion Time Program, is added to TS Section 5 Administrative Controls.

The methodology for using the RICT Program is described in NEI 06-09-A, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS)

Guidelines," Revision 0, which was approved by the NRC on May 17, 2007. Adherence to NEI NEI 06-09-A is required by the RICT Program.

The proposed amendment is consistent with TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b,." as modified by the TSTF's [DATE] letter to the NRC, "Response to NRC Questions on TSTF-505, 'Provide Risk-Informed Extended Completion Times'." However, only those Required Actions described in Enclosure 1 are proposed to be changed, [which does not include all of the modified Required Actions in TSTF-505 and which includes some plant-specific Required Actions not included in TSTF-505].

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation

[LICENSEE] has reviewed the model safety evaluation dated [DATE] as part of the Federal Register Notice for Comment. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-505 and the safety evaluation for NEI 06-09, as well as the TSTF's [DATE] letter on TSTF-505. [As described in the subsequent paragraphs,][LICENSEE] has concluded that the technical basis presented in the TSTF-505 proposal, and the associated model safety evaluation prepared by the NRC staff, as modified by the TSTF letter on TSTF-505 are applicable to [PLANT, UNIT NOS.] and support incorporation of this amendment in the [PLANT] TS. ]

2.2 Verifications and Regulatory Commitments In accordance with Section 4.0, Limitations and Conditions, of the safety evaluation for NEI 06-09-A, the following is provided:

1. Enclosure 1 identifies each of the TS Required Actions to which the RICT Program will apply, with a comparison of the TS functions to the functions modeled in the probabilistic risk assessment (PRA) of the structures, systems and components (SSCs) subject to those actions.

2. Enclosure 2 provides a discussion of the results of peer reviews and self-assessments conducted for the plant-specific PRA models which support the RICT Program, as required by Regulatory Guide (RG) 1.200 Section 4.2.

3. [Enclosure 3 provides a description of all PRA models used to support the RICT Program for which Nuclear Regulatory Commission endorsed standards are not available.]

[Enclosure 3 is not applicable since each PRA model used for the RICT Program is addressed using a standard endorsed by the Nuclear Regulatory Commission.]

4. Enclosure 4 provides appropriate justification for excluding sources of risk not addressed by the PRA models.

5. Enclosure 5 provides the plant-specific baseline CDF and LERF to confirm that the potential risk increases allowed under the RICT Program are acceptable.

6. [Enclosure 6 provides appropriate plant-specific justification for using at power PRA models in shutdown modes to which the RICT Program applies (modes 3 [and 4]).]

[Enclosure 6 is not applicable since the RICT Program is not being applied to shutdown modes.]

7. Enclosure 7 provides a discussion of the licensees programs and procedures that assure the PRA models that support the RICT Program are maintained consistent with the as-built, as-operated plant.

8. Enclosure 8 provides a description of how the baseline PRA model, which calculates average annual risk, is evaluated and modified for use in the Configuration Risk Management Program (CRMP) to assess real-time configuration risk, and describes the scope of, and quality controls applied to, the CRMP

9. Enclosure 9 provides a discussion of how the key assumptions and sources of uncertainty in the PRA models were identified, and how their impact on the RICT Program was assessed and dispositioned.

10. Enclosure 10 provides a description of the implementing programs and procedures regarding the plant staff responsibilities for the RICT Program implementation, including risk management action (RMA) implementation.

Page

11. Enclosure 11 provides a description of the implementation and monitoring program as described in NEI 06-09, Section 2.3.2, Step 7.

12. Enclosure 12 provides a description of the process to identify and provide RMAs.

2.3 Optional Changes and Variations

[LICENSEE is not proposing any changes, variations, or deviations from the TS changes described in the TSTF-505, Revision 1, or the applicable parts of the NRC staffs model safety evaluation dated [DATE], except as described in the TSTF letter dated [DATE].] [LICENSEE is proposing the following changes or variations from the TS changes described in the TSTF-505, Revision 1, or the applicable parts of the NRC staffs model safety evaluation dated [DATE].

These options were recognized as acceptable changes or variations in TSTF-505 and the NRC staff's model safety evaluation.]

{NOTE: If a change or variation is not identified in TSTF-505, the NRC staff's model safety evaluation, or NEI 06-09 then provide the description and justification.}

[The [PLANT] TS utilize different [numbering][and][titles] than the Standard Technical Specifications on which TSTF-505 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles (including Required Actions and programs) and the TSTF-505 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-505 to the [PLANT] TS.]

3.0 REGULATORY SAFETY ANALYSIS 3.1 No Significant Hazards Consideration Determination

[LICENSEE] has evaluated the proposed change to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed change does not involve a significant hazards consideration.

[PLANT, UNIT NOS.] requests adoption of an approved change to the standard technical specifications (STS) and plant-specific technical specifications (TS), to modify the TS requirements related to Completion Times for Required Actions to provide the option to calculate a longer, risk-informed Completion Time. The allowance is described in a new program in Chapter 5, "Administrative Controls," entitled the "Risk-Informed Completion Time Program."

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?

Page Response: No.

The proposed change permits the extension of Completion Times provided the associated risk is assessed and managed in accordance with the NRC approved Risk-Informed Completion Time Program. The proposed change does not involve a significant increase in the probability of an accident previously evaluated because the change involves no change to the plant or its modes of operation. The proposed change does not increase the consequences of an accident because the design-basis mitigation function of the affected systems is not changed and the consequences of an accident during the extended Completion Time are no different from those during the existing Completion Time.

Therefore, the proposed change does 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 does not change the design, configuration, or method of operation of the plant. The proposed change does not involve a physical alteration of the plant (no new or different kind of equipment will be installed).

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change permit the extension of Completion Times provided risk is assessed and managed in accordance with the NRC approved Risk-Informed Completion Time Program. The proposed change implements a risk-informed configuration management program to assure that adequate margins of safety are maintained. Application of these new specifications and the configuration management program considers cumulative effects of multiple systems or components being out of service and does so more effectively than the current TS.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Page Based on the above, [LICENSEE] concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL CONSIDERATION

[LICENSEE] has reviewed the environmental evaluation included in the model safety evaluation published on [DATE] ([ ] FR [ ]) as part of the Notice of Availability. [LICENSEE] has concluded that the NRC staff 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, or 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 effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meet 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.

Page ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

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ATTACHMENT 3 REVISED TECHNICAL SPECIFICATION PAGES

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ATTACHMENT 4 PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP) PAGES

{provided by the licensee}

ENCLOSURE 1 LIST OF REVISED REQUIRED ACTIONS TO CORRESPONDING PRA FUNCTIONS

{NOTE: This enclosure provides confirmation that the PRA models include the necessary scope of structures, systems, and components (SSCs) and their functions to address each proposed application of the RICT Program to the TS Required Actions.

TS conditions with insufficient TS operable equipment to meet the specified safety function of the system, are not to be included in the application.

List each TS Required Action to which the RICT Program may be applied and, for each Required Action, describe the following:

The TS Required Action;

The corresponding SSC;

Each design basis function of the SSC;

How each design basis function is modeled in the PRA. If one of the design basis functions of an SSC or the SSC is not modeled in the PRA, describe any proposed surrogates and why the proposed surrogate adequately captures the configuration risk; and

The success criteria used in the PRA model compared to the licensing basis criteria. The success criteria should include both train-level and component/parameter level.

Note that the above description should be at the level of the TS condition/TS Required Action (not at the LCO level only). If the TS condition/ TS Required action covers multiple SSCs or multiple design basis functions, such as in the case ESFAS Instrumentation or Containment Sprays, describe each one individually.

The enclosure should also include clear definitions of any used terms, such as train, division, loop, "subsystem," etc.

The licensee lists each TS Required Action to which the RICT Program may be applied and, for each Required Action, describes the corresponding SSC and associated function modeled in the PRA. This is to include the applicable success criteria used in the PRA model compared to the licensing basis criteria, and if applicable a disposition of any differences which justifies use of the PRA success criteria when calculating RICTs. The calculated RICT is provided for the condition to which the RICT applies.

This enclosure should provide a description of PRA functionality for each associated specified safety function that corresponds to each proposed Required Action that is applicable when all trains of equipment are inoperable as discussed in Section 2.3.1.10 of NEI 06-09. For example, the number and identity of instrumentation and control channels (or functions) required to be PRA functional is highly dependent on the specific plant and associated equipment design.

The enclosure should provide a detailed system description of TS 3.8, "Electrical Power Systems," Required Actions if the loading scheme is not uniform (e.g., Train A and B have similar loading, except Train B supplies power to additional SSCs.) Also, provide

a description in Enclosure 12 of representative RMAs for non-uniform trains to demonstrate that the systems safety function is maintained with either train or subsystem operable.}

Page 10

ENCLOSURE 2 INFORMATION SUPPORTING CONSISTENCY WITH REGULATORY GUIDE 1.200, REVISION 2

{NOTE: This enclosure provides information supporting the licensee evaluation of the technical adequacy of the PRA models supporting the RICT Program based on peer reviews and self-assessments against the relevant PRA standards as endorsed in the current applicable revision of RG 1.200, including consideration of staff clarifications of the standards.

Per NEI 06-09 Rev. 0, capability category II of the standards is applicable; therefore, the licensee identifies those parts of the PRAs that conform to capability categories lower than II, and provides a disposition for the RICT Program. Consistent with RG 1.200 Section 4.2, the licensee identifies and provides a discussion of the resolution of any findings and observations from the peer reviews or self-assessments.

The licensee assessment must also address the clarifications and qualifications found in RG 1.200, either by a separate discussion provided by the licensee, or by confirmation that the peer reviews or self-assessments included consideration of the clarifications and qualifications of the current applicable RG 1.200 revision.

Licensees are strongly encouraged to apply the guidance in Appendix X, "Close out of Facts and Observations," of NEI 05-04, "Process for Performing Internal Events PRA Peer Reviews Using the ASME/ANS PRA Standard, Rev 3, November 2009," NEI 07-12, "Fire Probabilistic Risk Assessment Peer Review Process Guidelines, Rev 1, June 2010," and NEI 12-13, "External Hazards PRA Peer Review Process Guidelines, Rev 0, August 2012," to close PRA peer review findings, as this will make more efficient use of the NRC and industry resources needed to develop and review of the application. }

ENCLOSURE 3 INFORMATION SUPPORTING TECHNICAL ADEQUACY OF PRA MODELS WITHOUT PRA STANDARDS ENDORSED BY REGULATORY GUIDE 1.200, REVISION 2

{NOTE: This enclosure provides information supporting the licensee evaluation of the PRA models supporting the RICT Program for which the relevant PRA standards are not yet endorsed in the current applicable revision of RG 1.200.

RG 1.200 Rev. 2 endorses standards for internal and external events including internal floods and fires, seismic events, and other external hazards for full power conditions.

This scope includes the relevant hazard groups applicable to a RICT Program unless the program is to apply to lower modes of operation. In this case, shutdown and transition risk PRA models may apply but are not be covered by an endorsed standard.

If applicable, the licensee should provide a detailed description of these PRA models and the basis for its determination of their technical adequacy to support the RICT Program.}

ENCLOSURE 4 INFORMATION SUPPORTING JUSTIFICATION OF EXCLUDING SOURCES OF RISK NOT ADDRESSED BY THE PRA MODELS

{NOTE: This enclosure identifies and provides a justification for excluding sources of risk which are not in the scope of the PRA models applied to the RICT Program.

Exclusion of risk sources determined to be insignificant to the calculation of configuration specific risk, or the use of conservative or bounding analyses for the calculation of RICTs in lieu of realistic PRA models, are described. A qualitative treatment may be sufficient if the licensee demonstrates that those risk contributions would not affect decisions in a RICT Program. The use of conservative bounding calculations in a RICT Program may also be acceptable. However, when the risk associated with a particular hazard group would affect decisions, it is the Commissions policy that risk be assessed using a PRA that meets the staff-endorsed PRA standard.

External hazards screened out from inclusion in RICT calculations should be clearly identified as such, and should be done in a manner consistent with Part 6 of the ASME ANS PRA Standard. The justification should address baseline and configuration-specific considerations.

For external hazards that are not screened out from inclusion in RICT calculations, the licensee may propose a bounding approach to address the hazard. If the bounding approach involves assuming a uniform increase in baseline risk to address the hazard, the licensee will need to address potential RICT-specific impacts by doing one of the following:

Demonstrate in the LAR that this approach is bounding for all TS actions included in the LAR, or

Establish a procedure to evaluate the validity of the bounding approach when calculating an RICT that is not demonstrated to be bounded in the LAR, or

For RICTs not demonstrated to be bounded in the LAR, establish a procedure to qualitatively evaluate the impact of the specific external hazard for each RICT when calculated and apply risk management actions as appropriate. }

ENCLOSURE 5 BASELINE CDF AND LERF

{NOTE: This enclosure provides the plant-specific total CDF and total LERF to confirm that these are less than 10-4/year and 10-5/year, respectively. This assures that the potential risk increases allowed under the RICT Program are consistent with RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," Revision 2.

The licensee should provide the totals and the contributions from each hazard group (internal events, fires, floods, seismic, other external).

}

ENCLOSURE 6 JUSTIFICATION OF APPLICATION OF AT-POWER PRA MODELS TO SHUTDOWN MODES

{NOTE: This enclosure provides a justification for the use of existing PRA models during shutdown conditions if the RICT Program is applicable in these shutdown conditions.

The at-power PRA models may potentially be applied to lower modes of operation (hot standby for PWRs, and hot shutdown for PWRs and BWRs) for some Required Actions.

If the licensee is not proposing to use the RICT Program in these modes, then this information is not required and this Enclosure should be marked "Not applicable."

Otherwise, the licensee provides a detailed justification for those Required Actions proposed to apply the RICT Program in lower modes of operation using the at-power PRA models.}

ENCLOSURE 7 PRA MODEL UPDATE PROCESS

{NOTE: This enclosure describes how the PRA models used in the calculation of completion times is maintained consistent with the as-built, as-operated plant.

The licensee provides a discussion of its programs and procedures to assure the PRA models that support the RICT Program are maintained consistent with the as-built, as-operated plant. This should include a discussion of the timing of significant PRA model changes as described in NEI 06-09, Section 2.3.4, Step 7.}

ENCLOSURE 8 ATTRIBUTES OF THE CRMP MODEL

{NOTE: This enclosure describes how the baseline PRA model, which calculates average annual risk, is evaluated and modified for use in the Configuration Risk Management Program (CRMP) to assess real-time configuration risk, and describes the scope of, and quality controls applied to, the CRMP.

The licensee provides a description of the PRA models and CRMP used to support the RICT Program. The following specific attributes must also be addressed:

The baseline PRA models assess the average annual risk. However, some risk is not consistent throughout the year or the operating cycle, and the PRA models used for the CRMP need to properly assess the change in risk for the existing plant conditions. For example, success criteria may be different at core beginning of life compared to end of life, or at different times of the year for room cooling systems. The licensee describes these issues and how they are addressed in the CRMP.

The baseline PRA models may assume some configurations are not allowable, but these assumptions may not be applicable to a CRMP. The licensee describes these issues and how they are addressed in the CRMP.

The scope of SSCs within the CRMP is provided, along with confirmation that the CRMP tools can be readily applied for each TS Required Action within the scope of the Risk-Informed Completion Time Program. The licensee should also identify and justify SSCs that are not included in the CRMP that could provide accident mitigation functions.

The licensee describes how consistency of calculated results from the baseline PRA model and the CRMP are verified to assure the CRMP PRA models are consistent with the baseline model and updated when the baseline PRA model is updated.

The licensee describes the quality requirements applied to the CRMP PRA models.

The licensee describes the training and qualification programs applicable to personnel responsible for development and use of the CRMP.}

ENCLOSURE 9 KEY ASSUMPTIONS AND SOURCES OF UNCERTAINTY

{NOTE: This enclosure describes the key assumptions and sources of uncertainty in the PRA models, and how their impact on the RICT Program was assessed and dispositioned. Sensitivity analyses for various plant configuration cases under different assumptions should be provided to justify conclusions.}

ENCLOSURE 10 PROGRAM IMPLEMENTATION

{NOTE: This enclosure provides a description of the implementing programs and procedures regarding the plant staff responsibilities for the RICT Program implementation including training of plant personnel, and specifically discusses the decision process for risk management action (RMA) implementation during extended CTs.}

ENCLOSURE 11 MONITORING PROGRAM

{NOTE: This enclosure describes the monitoring program for cumulative risk impacts as described in NEI 06-09, Revision 0, Section 2.3.2, Step 7. This should include a description of how the calculations are made and what actions and thresholds are applied when corrective measures are necessary due to excessive risk increases.}

ENCLOSURE 12 RISK MANAGEMENT ACTION EXAMPLES

{NOTE: This enclosure describes the process for identification of RMAs applicable during extended CTs, and provides examples of RMAs.

Provide example RMAs for TS 3.8 Required Actions. These should be representative examples, such as a long and short RICTs. See the Plant Vogtle April 14, 2017 RAI response (ADAMS Accession No. ML17108A253) for an example.

If the TS-required electrical power loading scheme is not uniform (e.g., Train A and B have similar loading, except Train B supplies power to additional SSCs,) provide a description of representative RMAs for non-uniform trains to ensure that the systems safety function is maintained with either train or subsystem inoperable.}

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