ML17341A326

Draft Model Safety Evaluation of TSTF-567, Revision 1, Add Containment Sump TS to Address GSI-191 Issues.

ML17341A326
Person / Time
Site:	Technical Specifications Task Force
Issue date:	03/26/2018
From:	Office of Nuclear Reactor Regulation
To:
Honcharik M
Shared Package
ML17341A333	List: ML17341A326 ML17341A327 ML17341A329
References
CAC MF9568, EPID L-2017-PMP-0005
Download: ML17341A326 (13)

Text

1 General Directions: This Model SE provides the format and content to be used when preparing 2 the plant-specific SE of an LAR to adopt TSTF-567, Revision 1. The bolded bracketed 3 information shows text that should be filled in for the specific amendment; individual licensees 4 would furnish site-specific nomenclature or values for these bracketed items. The italicized 5 wording provides guidance on what should be included in each section and should not be 6 included in the SE.

7 DRAFT MODEL SAFETY EVALUATION 8 BY THE OFFICE OF NUCLEAR REACTOR REGULATION 9 TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 10 TSTF-567, REVISION 1 11 ADD CONTAINMENT SUMP TS TO ADDRESS GSI-191 ISSUES 12 USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 13 (CAC NO. MF9568, EPID L-2017-PMP-0005) 14 15 16

1.0 INTRODUCTION

17 18 By application dated [enter date], (Agencywide Documents Access and Management System 19 (ADAMS) Accession No. [MLXXXXXXXXX]), [as supplemented by letters dated, [enter 20 date(s))) [name of licensee] (the licensee) submitted a license amendment request (LAR) for 21 [name of facility (abbreviated name). applicable units].

22 23 The amendment would revise Limiting Condition for Operation (LCO) 3.5.2, ECCS [Emergency 24 Core Cooling System]-Operating, LCO 3.5.3, ECCS-Shutdown, and TS Section 5.5.15, 25 Safety Function Determination Program (SFDP). The proposed changes would also add a 26 new LCO, Containment Sump, to TS Section 3.6, Containment Systems. The proposed 27 changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-567, 28 Revision 1, Add Containment Sump TS to Address GSI [Generic Safety Issue]-191 Issues, 29 dated August 2, 2017 (ADAMS Accession No. ML17214A813). The U.S. Nuclear Regulatory 30 Commission (NRC or the Commission) issued a final safety evaluation (SE) approving 31 TSTF-567, Revision 1, on [Month, Day, Year] (ADAMS Accession No. [MLXXXXXXXXX]).

32 33 [The licensee has proposed several variations from the TS changes described in 34 TSTF-567. The variations are described in Section [2.2.5] of this SE and evaluated in 35 Section [X.X].]

36 37 [The supplemental letters dated [enter date(s)], provided additional information that 38 clarified the application, did not expand the scope of the application as originally 39 noticed, and did not change the NRC staffs original proposed no significant hazards 40 consideration determination as published in the Federal Register on [enter date] (cite FR 41 reference).]

42 Enclosure 2

1

2.0 REGULATORY EVALUATION

2 3 2.1 SYSTEM DESCRIPTION AND CHANGES TO THE TS 4

5 LCOs are the lowest functional capability or performance levels of equipment required for safe 6 operation of the facility. The actions associated with an LCO state conditions that typically 7 describe the ways in which the requirements of the LCO can fail to be met. Specified with each 8 stated condition are required action(s) and completion time(s).

9 10 2.1.1 LCO 3.5.2, ECCS-Operating 11 12 The function of the ECCS is to provide core cooling and negative reactivity to ensure the reactor 13 core is protected after any of the following accidents:

14 15 a. Loss-of-coolant accident (LOCA), coolant leakage greater than the capability of the 16 normal charging system, 17 18 b. Rod ejection accident, 19 20 c. Loss of secondary coolant accident, including uncontrolled steam release or loss of 21 feedwater, and 22 23 d. Steam generator tube rupture.

24 25 LCO 3.5.2 is applicable in Modes 1, 2, and 3 and requires that two independent ECCS trains be 26 operable to ensure that sufficient ECCS flow is available, assuming a single failure affecting 27 either train.

28 29 LCO 3.5.2 helps ensure the following acceptance criteria for ECCS, established by Title 10 of 30 the Code of Federal Regulations (10 CFR) 50.46, will be met following a LOCA:

31 32 a. Maximum fuel element cladding temperature is 2200 degrees Fahrenheit (°F),

33 34 b. Maximum cladding oxidation is 0.17 times the total cladding thickness before 35 oxidation, 36 37 c. Maximum hydrogen generation from a zirconium water reaction is 0.01 times the 38 hypothetical amount generated if all of the metal in the cladding cylinders surrounding 39 the fuel, excluding the cladding surrounding the plenum volume, were to react, 40 41 d. Core is maintained in a coolable geometry, and 42 43 e. Adequate long-term core cooling capability is maintained.

44 45 LCO 3.5.2 also limits the potential for a post-trip return to power following a main steam line 46 break event and ensures that containment temperature limits are met.

47

1 2.1.2 LCO 3.5.3, ECCS-Shutdown 2

3 LCO 3.5.3 is applicable in Mode 4 and requires one of the two independent (and redundant) 4 ECCS trains to be operable to ensure that sufficient ECCS flow is available to the core following 5 a design-basis accident.

6 7 2.1.3 TS Section 5.5.15, Safety Function Determination Program (SFDP) 8 9 Section 5.5.15 establishes the Safety Function Determination Program (SFDP) which 10 implements the requirements of LCO 3.0.6. The SFDP ensures loss of safety function is 11 detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation shall be 12 made to determine if loss of safety function exists. Additionally, other appropriate actions may 13 be taken as a result of the support system inoperability and corresponding exception to entering 14 supported system(s) condition(s) and required action(s).

15 16

2.2 PROPOSED CHANGE

S TO THE TECHNICAL SPECIFICATIONS 17 18 The proposed changes would revise LCO 3.5.2, ECCS-Operating, LCO 3.5.3, 19 ECCS-Shutdown, and Section 5.5.15, Safety Function Determination Program. The 20 proposed changes would also add a new TS LCO, Containment Sump to Section 3.6, 21 Containment Systems. The proposed changes are described below.

22 23 2.2.1 Proposed Changes to LCO 3.5.2, ECCS-Operating 24 25 LCO 3.5.2 currently contains Surveillance Requirement (SR) 3.5.2.[9], which requires the 26 following at a frequency [of 18 months][in accordance with the Surveillance Frequency 27 Control Program (SFCP)]:

28 29 Verify, by visual inspection, each ECCS train containment sump 30 suction inlet is not restricted by debris and suction inlet trash racks 31 and screens show no evidence of structural distress or abnormal 32 corrosion.

33 34 The licensee proposed to modify and move SR 3.5.2.[9] from LCO 3.5.2 and include it in the 35 new containment sump LCO.

36 37 This change is evaluated in Section 3.1 of this SE.

38 39 2.2.2 Proposed Changes to LCO 3.5.3, ECCS-Shutdown 40 41 LCO 3.5.3 currently contains SR 3.5.3.1 which refers to applicable SRs under LCO 3.5.2. One 42 of those referenced SRs is SR 3.5.2.[9], as described in Section 2.2.1 of this SE.

43 44 Because the licensee proposed to move SR 3.5.2.[9] from LCO 3.5.2 and include it in the new 45 containment sump LCO, the licensee also proposed to delete the reference to SR 3.5.2.[9] in 46 SR 3.5.3.1.

47 48 This change is evaluated in Section 3.2 of this SE.

49

1 2.2.3 Proposed Changes to TS Section 5.5.15, Safety Function Determination 2 Program (SFDP) 3 4 The licensee proposed to add the following sentence at the end of TS Section 5.5.15:

5 6 When a loss of safety function is caused by the inoperability of a 7 single Technical Specification support system, the appropriate 8 Conditions and Required Actions to enter are those of the support 9 system.

10 11 This change is evaluated in Section 3.3 of this SE.

12 13 2.2.4 Proposed Addition of a New Containment Sump LCO 14 15 The licensee proposed to add LCO 3.6.[8] requiring the containment sump to be operable 16 during Modes 1, 2, 3, and 4. Condition A specifies that if the containment sump is inoperable 17 due to containment accident generated and transported debris exceeding the analyzed limits, 18 Required Actions A.1, A.2, and A.3 require immediate initiation of action to mitigate containment 19 accident generated and transported debris, performing SR 3.4.13.1 once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 20 restoring the containment sump to operable status in 90 days, respectively. The SR 3.4.13.1 21 requires verification that the reactor coolant system (RCS) operational leakage is within limits by 22 performance of RCS water inventory balance.

23 24 Condition B specifies that if the containment sump is inoperable for reasons other than 25 Condition A, Required Action B.1 requires restoration of the containment sump to operable 26 status [within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s][in accordance with the Risk Informed Completion Time (RICT) 27 Program]. Required Action B.1 is modified by two notes which directs entering the applicable 28 conditions and required actions of LCO 3.5.2, ECCS-Operating, and LCO 3.5.3, 29 ECCS-Shutdown, for ECCS trains made inoperable by the containment sump and entering the 30 applicable conditions and required actions of LCO 3.6.6, Containment Spray and Cooling 31 Systems, for CSS trains made inoperable by the containment sump.

32 33 Condition C specifies that if required action and associated completion time (CT) under 34 Condition A and B are not met, Required Actions C.1 and C.2 require licensees to be in Mode 3 35 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, respectively.

36 37 The licensee proposed to expand and relocate an SR currently located in LCO 3.5.2. The new 38 SR requires the licensee to verify, by visual inspection, the containment sump does not show 39 structural damage, abnormal corrosion, or debris blockage [every 18 months][in accordance 40 with the SFCP].

41 42 {NOTE: If the plant has more than one containment sump, include the following paragraph :}

43 [Plant name]s containment sump design includes more than one containment sump. [Enter 44 additional details of the plants containment sump design and justification detailing why 45 the new proposed LCO is applicable.] The new containment sump LCO proposed is 46 applicable to plants that have more than one containment sump.

47 48 The licensee also proposed a conforming change to the TS Table of Contents to reflect the 49 addition of the new containment sump LCO.

50 51 This change is evaluated in Section 3.4 of this SE.

1 2 2.2.5 Variations from TSTF-567, Revision 1 3

4 {NOTE: Technical reviewers and/or project manager to discuss variations from the approved 5 traveler and whether they are acceptable. Choose the applicable paragraphs based on 6 information provided in the LAR.}

7 8 [The licensee is not proposing any variations from the TS changes described in 9 TSTF-567 or the applicable parts of the NRC staffs safety evaluation (SE) of TSTF-567.]

10 11 [The licensee is proposing the following variations from the TS changes described in 12 TSTF-567 or the applicable parts of the NRC staffs safety evaluation (SE) of TSTF-567.

13 These variations do not affect the applicability of TSTF-567 or the NRC staff's SE to the 14 proposed license amendment.]

15 16 [The [PLANT] TS utilize different [numbering][and][titles] than the Standard Technical 17 Specifications on which TSTF-567 was based. Specifically, [describe differences 18 between the plant-specific TS numbering and/or titles and the TSTF-567 numbering 19 and/or titles.] These differences are editorial and do not affect the applicability of 20 TSTF-567 to the [PLANT] TS.]

21 22 {NOTE: Use of a RICT for Required Action B.1, is a permissible variation, but requires 23 plant-specific review. Therefore, use of a RICT will remove the LAR from the CLIIP.}

24 [The licensee is proposing the use of a RICT Program for Required Action B.1.

25 Additional plant-specific technical information and justification, consistent with the 26 justification provided when adopting [TSTF-505 or the plant-specific RICT Program], was 27 provided in the submittal. This SE does not approve the use of the RICT Program. The 28 NRC staffs evaluation of the proposed RICT for Required Action B.1 is in Section 3.4 of 29 this SE.]

30 31 2.3 APPLICABLE REGULATORY REQUIREMENTS AND GUIDANCE 32 33 2.3.1 Technical Specifications 34 35 Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires each 36 applicant for a license authorizing operation of a utilization facility to include in the application 37 proposed TSs. A summary statement of the bases or reasons for such specifications 38 39 The regulation at 10 CFR 50.36(b) requires:

40 41 Each license authorizing operation of a utilization facility will 42 include technical specifications. The technical specifications will 43 be derived from the analyses and evaluation included in the safety 44 analysis report, and amendments thereto, submitted pursuant to 45 [10 CFR] 50.34 [Contents of applications; technical information].

46 The Commission may include such additional technical 47 specifications as the Commission finds appropriate.

48 49 The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). As required 50 by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability 51 or performance levels of equipment required for safe operation of the facility. Per

1 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut 2 down the reactor or follow any remedial action permitted by the TSs until the condition can be 3 met.

4 5 The regulation at 10 CFR 50.36(c)(3) requires TSs to include SRs, which are requirements 6 relating to test, calibration, or inspection to assure that the necessary quality of systems and 7 components is maintained, that facility operation will be within safety limits, and that the LCOs 8 will be met.

9 10 The regulation at 10 CFR 50.36(c)(5) requires TSs to include administrative controls, which are 11 the provisions relating to organization and management, procedures, recordkeeping, review and 12 audit, and reporting necessary to assure operation of the facility in a safe manner.

13 14 2.3.2 Guidance 15 16 The guidance that the NRC staff considered in its review of this LAR included the following:

17 18 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports 19 for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Chapter 16, Technical 20 Specifications, dated March 2010 (ADAMS Accession No. ML100351425), provides 21 guidance on review of TSs.

22 23 {NOTE: Choose applicable STS}

24 [U.S. Nuclear Regulatory Commission, Standard Technical Specifications, 25 Babcock and Wilcox Plants, NUREG-1430, Volume 1, Specifications, Revision 4.0, 26 dated April 2012 (ADAMS Accession No. ML12100A177).

27 28 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, 29 Westinghouse Plants, NUREG-1431, Volume 1, Specifications, Revision 4.0, dated 30 April 2012 (ADAMS Accession No. ML12100A222).

31 32 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, 33 Combustion Engineering Plants, NUREG-1432, Volume 1, Specifications, Revision 4.0, 34 dated April 2012 (ADAMS Accession No. ML12102A165).]

35 36

3.0 TECHNICAL EVALUATION

37 38

3.1 PROPOSED CHANGE

S TO LCO 3.5.2, ECCS-OPERATING 39 40 The licensee proposed to modify and move SR 3.5.2.[9] from LCO 3.5.2 to the new containment 41 sump LCO. Therefore, the licensee proposed deletion of SR 3.5.2.[9].

42 43 The new SR does not limit the visual inspection to the suction inlet, trash racks and screens as 44 currently required by the TSs, but instead requires inspection of the entire containment sump 45 system. The containment sump system consists of the containment drainage flow paths, any 46 design features upstream of the containment sump that are credited in the containment debris 47 analysis, the containment sump strainers (or screens), the pump suction trash racks, and the 48 inlet to the ECCS and CSS piping.

49 50 The NRC staff concludes the proposed change is acceptable since the existing requirements 51 are either unchanged or expanded and continue to ensure the containment sump is unrestricted

1 (i.e., unobstructed) and stays in proper operating condition. The proposed change meets the 2 requirements of 10 CFR 50.36(c)(3) because it provides SRs to assure the necessary quality of 3 systems and components are maintained, that facility operation will be within safety limits, and 4 that the LCOs will be met.

5 6

3.2 PROPOSED CHANGE

S TO LCO 3.5.3, ECCS-SHUTDOWN 7

8 The licensee proposed to delete the reference to SR 3.5.2.[9] in SR 3.5.3.1.

9 10 The NRC staff concludes the proposed change is acceptable since SR 3.5.2.[9] was modified 11 and relocated to the new containment sump LCO. The existing SR on the containment sump is 12 augmented (by requiring inspection of additional sump components) and moved to the new 13 specification, and a duplicative requirement to perform the SR in TS 3.5.3 is removed. The new 14 specification retains or expands the existing requirements on the containment sump and the 15 actions to be taken when the containment sump is inoperable with the exception of adding new 16 actions to be taken when the containment sump is inoperable due to containment accident 17 generated and transported debris exceeding the analyzed limits. The new action provides time 18 to evaluate and correct the condition instead of requiring an immediate plant shutdown. The 19 proposed change meets the requirements of 10 CFR 50.36(c)(3) because it provides SRs to 20 assure the necessary quality of systems and components are maintained, that facility operation 21 will be within safety limits, and that the LCOs will be met.

22 23

3.3 PROPOSED CHANGE

S TO SECTION 5.5.15, SAFETY FUNCTION 24 DETERMINATION PROGRAM (SFDP) 25 26 LCO 3.0.6 states:

27 28 When a supported system LCO is not met solely due to a support 29 system LCO not being met, the Conditions and Required Actions 30 associated with this supported system are not required to be 31 entered. Only the support system LCO ACTIONS are required to 32 be entered. This is an exception to LCO 3.0.2 for the supported 33 system. In this event, an evaluation shall be performed in 34 accordance with Specification 5.5.15, Safety Function 35 Determination Program (SFDP). If a loss of safety function is 36 determined to exist by this program, the appropriate Conditions 37 and Required Actions of the LCO in which the loss of safety 38 function exists are required to be entered.

39 40 When a support systems Required Action directs a supported 41 system to be declared inoperable or directs entry into Conditions 42 and Required Actions for a supported system, the applicable 43 Conditions and Required Actions shall be entered in accordance 44 with LCO 3.0.2.

45 46 When a loss of safety function is determined to exist, the SFDP requires entry into the 47 appropriate conditions and required actions of the LCO in which the loss of safety function 48 exists. Where a loss of function is solely due to a single TS support system (e.g., a single 49 containment sump train) the appropriate LCO is the LCO for that support system. When the 50 loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the 51 supported systems.

1 2 The licensee proposed to add the following statement to TS 5.5.12, [W]hen a loss of safety 3 function is caused by the inoperability of a single Technical Specification support system, the 4 appropriate Conditions and Required Actions to enter are those of the support system.

5 6 The NRC staff finds that the proposed addition to TS 5.5.12 clarifies the intent of the allowance 7 (not to enter the Conditions and Required Actions) provided by LCO 3.0.6 and the SFDP for 8 single-train support systems. The NRC staff concludes the proposed change is acceptable 9 since the actions for the support system LCO adequately address the inoperability of that 10 system. Therefore, as required by 10 CFR 50.36(c)(5), it continues to provide adequate 11 administrative controls to assure safe operation.

12 13 3.4 PROPOSED ADDITION OF CONTAINMENT SUMP LCO 14 15 3.4.1 Considerations of the LCO 16 17 The licensee proposed to add a new LCO to address operability requirements of the 18 containment sump. The numbering for this new LCO is LCO 3.6.[8].

19 20 The containment sump supports the post-accident operation of the ECCS and CSS. However, 21 only the current ECCS TS LCOs contain SRs related to the containment sump and the TS do 22 not specify required actions that specifically address an inoperable containment sump. If the 23 containment sump were found to be inoperable, as an ECCS and CSS support system, those 24 respective LCOs would not be met. In order to address concerns related with to containment 25 sump operability due to debris accumulation described in GSI-191, Assessment of Debris 26 Accumulation on Pressurized-Water Reactor Sump Performance, the licensee proposed to add 27 a new specification to address containment sump inoperability and create a condition for when 28 the sump is inoperable due to analyzed containment accident generated and transported debris.

29 30 Based on the above evaluation, the NRC staff determined that proposed LCO satisfies the 31 requirements of 10 CFR 50.36(c)(2)(i) because the LCO specifies the lowest functional 32 capability or performance levels of equipment required for safe operation of the facility. There is 33 reasonable assurance that the required actions to be taken when the LCO is not met can be 34 conducted without endangering the health and safety of the public.

35 36 3.4.2 Considerations of the Applicability 37 38 The new LCO requires the containment sump to be operable during Modes 1, 2, 3, and 4. The 39 ECCS and CSS LCOs currently in TS are applicable during Modes 1, 2, 3, and 4.

40 41 The NRC staff finds the proposed applicability is acceptable because the applicability is 42 consistent with the applicability of the ECCS and CSS LCOs, the containment sump supported 43 systems.

44 45 3.4.3 Considerations of Condition A 46 47 The licensee has analyzed the susceptibility of the ECCS and CSS to the adverse effects of 48 post-accident debris blockage and operation with debris-laden fluids. The licensee has 49 established [Final Safety Analysis Report] limits on the allowable quantities of containment 50 accident generated debris that could be transported to the containment sump based on its 51 current plant configuration. In the current TSs, if unanalyzed debris sources are discovered

1 inside containment, if errors are discovered in debris-related analyses, or if a previously 2 unevaluated phenomenon that can affect containment sump performance is discovered, the 3 containment sump, and the supported ECCS and CSS, may be inoperable and the TSs require 4 an immediate plant shutdown with no time provided to evaluate the condition.

5 6 In order to address this situation and to provide sufficient time to evaluate the condition, the 7 licensee proposed Condition A, which is applicable when the containment sump is inoperable 8 due to containment accident generated and transported debris exceeding the analyzed limits.

9 Under Condition A, the operability of the containment sump with respect to debris is based on a 10 quantity of debris evaluated and determined to be acceptable by the licensee. Emergent 11 nonconforming or degraded conditions affecting the quantity of analyzed debris shall be 12 evaluated using a deterministic process.

13 14 Under Condition A, Required Action A.1 mandates immediate action to be initiated to mitigate 15 the condition. In its submittal, the licensee provided the following examples of mitigating 16 actions:

17 18

• Removing the debris source from containment or preventing the 19 debris from being transported to the containment sump; 20 21

• Evaluating the debris source against the assumptions in the 22 analysis; 23 24

• Deferring maintenance that would affect availability of the affected 25 systems and other LOCA mitigating equipment; 26 27

• Deferring maintenance that would affect availability of primary 28 defense-in-depth systems, such as containment coolers; 29 30

• Briefing operators on LOCA debris management actions; or 31 32

• Applying an alternative method to establish new limits.

33 34 The NRC staff finds the proposed Required Action A.1 and its completion time (CT) are 35 acceptable because they place urgency on the appropriate actions that could mitigate or reduce 36 the impact of the identified conditions.

37 38 Concurrently, Required Action A.2 mandates SR 3.4.13.1, the RCS water inventory balance, to 39 be performed at an increased frequency of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. An unexpected increase in RCS 40 leakage could be indicative of an increased potential for an RCS pipe break, which could result 41 in debris being generated and transported to the containment sump.

42 43 The NRC staff finds the proposed Required Action A.2 and its CT are acceptable because the 44 more frequent monitoring allows operators to act in a timely fashion to minimize the potential for 45 an RCS pipe break while the containment sump is inoperable.

46 47 In addition, Required Action A.3 requires the inoperable containment sump to be restored to 48 operable status in 90 days.

49

1 The NRC staff finds the proposed Required Action A.3 and its CT are acceptable because they 2 provide a reasonable amount of time to diagnose, plan and possibly reduce the severity of, or 3 mitigate the unanalyzed debris condition and prevent a loss of ECCS and CSS safety function.

4 In addition, 90 days is adequate given the conservatisms in the analysis and the proposed 5 compensatory actions required to be implemented immediately by Required Action A.1. Also, 6 as discussed later in this SE section, the new SR will require visual inspection of the 7 containment sump system (including the containment drainage flow paths, any design features 8 upstream of the containment sump that are credited in the containment debris analysis, the 9 containment sump strainers, the pump suction trash racks, and the inlet to the ECCS and CSS 10 piping for evidence of structural degradation, potential for debris bypass, and presence of 11 corrosion or debris blockage) to ensure no loose debris is present and there is no evidence of 12 structural distress or abnormal corrosion.

13 14 {NOTE: If the plant has more than one containment sump, include the following paragraph, 15 ensuring the plant-specific containment sump design aligns with this justification and modifying 16 accordingly :}

17 [Specifically for Condition A, multiple containment sumps are considered part of a single 18 support system. The NRC staff finds this proposed change is acceptable since it is a 19 conservative assumption. The plant is designed so that one sump will remain operable 20 with the design-basis debris load. The second sump is assumed to be out of service due 21 to a single failure in the ECCS or CSS. The single sump in a plant with multiple sumps is 22 equivalent to the sump in a plant with only one sump because the multiple sumps are 23 considered to be part of a single support system. In any case where the single failure did 24 not occur, the second sump would be in service and provide significant additional 25 surface area for debris to collect, thus reducing the severity of the effects of the debris.

26 The second sump provides redundancy in these cases.]

27 28 3.4.4 Considerations of Condition B 29 30 Condition B specifies the required actions for when the containment sump is inoperable for 31 reasons other than containment accident generated and transported debris exceeding the 32 analyzed limits.

33 34 Required Action B.1 requires restoring the containment sump to operable status and is modified 35 by two notes. These two notes direct entry into the conditions and required actions for the 36 supported systems (ECCS and CSS). Since Required Action B.1 directs entry to the 37 corresponding ECCS and CSS LCOs, these notes retain the existing TS actions for ECCS or 38 CSS trains made inoperable by a containment sump inoperable for reasons other than 39 containment accident generated and transported debris exceeding the analyzed limits. The 40 proposed CT for Required Action B.1 is [72 hours or in accordance with the RICT Program].

41 42 {NOTE: If the licensee has a previously approved Risk-Informed Completion Time (RICT) 43 Program in TS Section 5.0, Administrative Controls, use this paragraph and revise the last 44 sentence of the following paragraph.}

45 [The licensee has an NRC-approved [adoption of TSTF-505, Provide Risk-Informed 46 Extended Completion Times - RITSTF Initiative 4B,][plant-specific RICT Program] and 47 has a Risk-Informed Completion Time (RICT) Program in TS Section 5.0, Administrative 48 Controls. Therefore, the licensee has proposed to calculate a RICT for Required 49 Action B.1. [Insert NRC staff technical evaluation of proposed use of a RICT.]

50

1 The NRC staff finds the proposed change is acceptable since it continues to provide remedial 2 actions for when the containment sump is inoperable for reasons other than Condition A and 3 ensures safe operation of the plant. In addition, the proposed CT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is acceptable 4 since it provides a reasonable time for repairs, and there is a low probability of an accident 5 occurring during this period necessitating the containment sump.

6 7 3.4.5 Considerations of Condition C 8

9 If operators are unable to restore the affected containment sump to operable status under 10 Condition A or B, Required Action C.1 requires the unit to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> followed by 11 Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, as required by Required Action C.2.

12 13 The NRC staff finds this proposed condition and its required actions are acceptable because the 14 condition is consistent with the STSs and requires the operators to place the unit in a condition 15 in which the LCO no longer applies. In addition, the proposed CTs allow a reasonable amount 16 of time to decrease from full power conditions to the required plant conditions in an orderly 17 manner and without challenging plant systems.

18 19 3.4.6 Considerations of the New SR 20 21 The licensee proposed a new SR in the new containment sump LCO. This SR was originally 22 located in LCO 3.5.2 and referred to in LCO 3.5.3. The numbering for this new SR is 23 SR 3.6.8.[1]. The frequency of the new SR is [18 months][as specified in the SFCP].

24 25 The proposed SR requires verification, by visual inspection, that the containment sump does not 26 show structural damage, abnormal corrosion, or debris blockage.

27 28 The new SR is stated in generic terms and expands the scope of the required visual inspection 29 to include the entire containment sump system. The entire containment sump system consists 30 of the containment drainage flow paths, the containment sump strainers (or screens), the pump 31 suction trash racks, and the inlet to the ECCS and CSS piping.

32 33 The NRC staff finds the proposed new SR is acceptable since it expands the scope of 34 inspection of the original SR. In addition, the proposed frequency is acceptable since it is the 35 same as that currently required by the TSs. Therefore, the NRC staff finds that, as required by 36 10 CFR 50.36(c)(3), the necessary quality of systems will be maintained in accordance with the 37 associated LCOs.

38 39 3.4.7 Considerations of Changes to Table of Contents 40 41 The licensee also proposed a conforming change to the Table of Contents to include the new 42 containment sump LCO. This conforming change is acceptable since it is an editorial change to 43 support the inclusion of the new containment sump TS LCO.

44 45 3.4.8 Conclusion Regarding Proposed Containment Sump LCO 46 47 The new containment sump LCO retains and expands the existing TS requirements with the 48 exception of the addition of Condition A. Condition A provides a condition for an inoperable 49 containment sump due to containment accident generated and transported debris exceeding the 50 analyzed limits.

51

1 The NRC staff reviewed the proposed changes against the regulations and concludes that the 2 changes continue to meet the requirements of 10 CFR 50.36(c)(2), 50.36(c)(3) and 50.36(c)(5),

3 for the reasons discussed above, and thus provide reasonable assurance that adoption of these 4 TSs will have the requisite requirements and controls to operate safely. Therefore, the NRC 5 staff concludes that the proposed TS changes are acceptable.

6 7 3.5 VARIATIONS 8

9 [Insert evaluation of any variations discussed in Section 2.2.5]

10 11

3.6 TECHNICAL EVALUATION

CONCLUSION 12 13 The NRC staff determined that the proposed changes meet the standards for TS in 14 10 CFR 50.36(b). The proposed changes to the SR assure that the necessary quality of 15 systems and components is maintained, that facility operation will be within safety limits, and 16 that the LCOs will be met, and satisfy 10 CFR 50.36(c)(3 17 18

4.0 STATE CONSULTATION

19 20 This section is to be prepared by the plant project manager.

21 22 In accordance with the Commission's regulations, the [Name of State] State official was notified 23 of the proposed issuance of the amendment(s) on [date]. The State official had [no] comments.

24 [If comments were provided, they should be addressed here.]

25 26

5.0 ENVIRONMENTAL CONSIDERATION

27 28 This section is to be prepared by the plant project manager in accordance with current 29 procedures.

30 31

6.0 CONCLUSION

32 33 This section is to be prepared by the plant project manager.

34 35 The Commission has concluded, based on the considerations discussed above, that: (1) there 36 is reasonable assurance that the health and safety of the public will not be endangered by 37 operation in the proposed manner, (2) there is reasonable assurance that such activities will be 38 conducted in compliance with the Commission's regulations, and (3) the issuance of the 39 amendment(s) will not be inimical to the common defense and security or to the health and 40 safety of the public.

1 2

7.0 REFERENCES

3 4 Optional section to be prepared by the PM and primary reviewers. If document is publicly 5 available, the ADAMS Accession No. should be listed.

6 7 {NOTE: These are the principal contributors for the model SE of the traveler. Replace these 8 names with those who prepared the plant-specific SE.}

9 Principal Contributors: C. Tilton, NRR/DSS 10 S. Smith, NRR/DSS 11 P. Klein, NRR/DMLR 12 M. Honcharik, NRR/DSS 13 14 Date: