ML19255J326
| ML19255J326 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 10/24/2019 |
| From: | Victor Cusumano NRC/NRR/DSS/STSB |
| To: | |
| Honcharik M, NRR/DSS, 301-415-1774 | |
| Shared Package | |
| ML19253A044 | List: |
| References | |
| EPID L-2019-PMP-0178, TSTF-541, Rev. 2 | |
| Download: ML19255J326 (18) | |
Text
Enclosure 2 General Directions: This model safety evaluation (SE) provides the format and content to be 1
used when preparing the plant-specific SE of a license amendment request to adopt TSTF-541, 2
Revision 2. The bolded bracketed information shows text that should be filled in for the specific 3
amendment; individual licensees would furnish site-specific nomenclature or values for these 4
bracketed items. The italicized wording provides guidance on what should be included in each 5
section. The italicized wording should not be included in the SE.
6 7
DRAFT MODEL SAFETY EVALUATION 8
BY THE OFFICE OF NUCLEAR REACTOR REGULATION 9
TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 10 TSTF-541, REVISION 2 11 ADD EXCEPTIONS TO SURVEILLANCE REQUIREMENTS FOR VALVES AND DAMPERS 12 LOCKED IN THE ACTUATED POSITION 13 USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 14 (EPID L-20XX-LLA-XXXX) 15 16 17
1.0 INTRODUCTION
18 19 By application dated [enter date] (Agencywide Documents Access and Management System 20 (ADAMS) Accession No. [MLXXXXXXXXX]), [as supplemented by letter(s) dated [enter 21 date(s))), [name of licensee] (the licensee) submitted a license amendment request (LAR) for 22
[name of facility or facilities (abbreviated name(s)), applicable unit(s)].
23 24 The amendment would revise certain Surveillance Requirements (SRs) in the Technical 25 Specifications (TSs) by adding an exception to the SR for automatic valves or dampers that are 26 locked, sealed, or otherwise secured in the actuated position.
27 28 The proposed amendment is based on Technical Specifications Task Force (TSTF) traveler 29 TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers 30 Locked in the Actuated Position, dated August 28, 2019 (ADAMS Accession 31 No. ML19240A315). The U.S. Nuclear Regulatory Commission (NRC or the Commission) 32 approved TSTF-541, Revision 2, by letter dated [enter date (ADAMS Accession 33 No. ML19XXXXXXX)]. The NRC staffs safety evaluation (SE) of the traveler is included with 34 the NRC staffs approval letter.
35 36
[The licensee has proposed variations from the TS changes described in traveler 37 TSTF-541, Revision 2. The variations are described in Section [2.2.1] of this SE and 38 evaluated in Section [3.1].]
39 40
[The supplemental letter(s) dated [enter date(s)], provided additional information that 41 clarified the application, did not expand the scope of the application as originally 42 noticed, and did not change the NRC staffs original proposed no significant hazards 1
consideration determination as published in the Federal Register on [enter date] (cite FR 2
reference).]
3 4
2.0 REGULATORY EVALUATION
5 6
2.1 System Descriptions 7
8
{NOTE: For B&W plant designs, use these paragraphs.}
9 10 The [spray additive system] is a subsystem of the [containment spray] system that assists in 11 reducing the iodine fission product inventory in the containment atmosphere resulting from a 12 design-basis accident (DBA). In the event of an accident such as a loss-of-coolant accident 13 (LOCA), the [spray additive system] will be automatically actuated upon a high containment 14 pressure signal by the [engineered safety features actuation system (ESFAS)]. The 15 purpose of SR [3.6.7.4] is to verify that each automatic valve in the [spray additive system]
16 flow path actuates to its correct position upon receipt of an actual or simulated actuation signal.
17 18 The [emergency ventilation system (EVS)] filters air from the area of the active emergency 19 core cooling system (ECCS) components during the recirculation phase of a LOCA. Ductwork, 20 valves or dampers, and instrumentation also form part of the system. During emergency 21 operations, the [EVS] dampers are realigned, and fans are started to begin filtration. Upon 22 receipt of the actuation signal(s), normal air discharges from the negative pressure area are 23 isolated, and the stream of ventilation air discharges through the system filter trains. The 24 prefilters remove any large particles in the air, and any entrained water droplets present, to 25 prevent excessive loading of the high-efficiency particulate air (HEPA) filters and charcoal 26 adsorbers. The purpose of SR [3.7.12.3] is to verify proper actuation of all train components, 27 including dampers, on an actual or simulated actuation signal. The purpose of SR [3.7.12.5] is 28 to ensure that the system is functioning properly by operating the [EVS] filter bypass damper.
29 30 The [fuel storage pool ventilation system (FSPVS)] provides negative pressure in the fuel 31 storage area, and filters airborne radioactive particulates from the area of the fuel pool following 32 a fuel handling accident. The [FSPVS] consists of portions of the normal [fuel handling area 33 ventilation system (FHAVS)], the station [EVS], ductwork bypasses, and dampers. The 34 portion of the normal [FHAVS] used by the [FSPVS] consists of ducting between the spent fuel 35 pool and the normal [FHAVS] exhaust fans or dampers, and redundant radiation detectors 36 installed close to the suction end of the [FHAVS] exhaust fan ducting. The purpose of 37 SR [3.7.13.3] is to verify proper actuation of all train components, including dampers, on an 38 actual or simulated actuation signal. The purpose of SR [3.7.13.5] is to ensure that the system 39 is functioning properly by operating the [FSPVS] filter bypass damper.
40 41 The [control room emergency ventilation system (CREVS)] provides a protected 42 environment from which occupants can control the unit following an uncontrolled release of 43 radioactivity, hazardous chemicals, or smoke. The purpose of SR [3.7.10.3] is to verify that 44 each train/subsystem starts and operates on an actual or simulated actuation signal.
45 46
{NOTE: For Westinghouse plant designs, use these paragraphs.}
47 48 The [control room emergency filtration system (CREFS)] provides a protected environment 49 from which occupants can control the unit following an uncontrolled release of radioactivity, 50 hazardous chemicals, or smoke. The purpose of SR [3.7.10.3] is to verify that each 1
train/subsystem starts and operates on an actual or simulated actuation signal.
2 3
The [shield building air cleanup system (SBACS)] is required to ensure that radioactive 4
materials that leak from the primary containment into the shield building (secondary 5
containment) following a design-basis accident (DBA) are filtered and adsorbed prior to 6
exhausting to the environment. The containment has a secondary containment called the shield 7
building, which is a concrete structure that surrounds the steel primary containment vessel.
8 Between the containment vessel and the shield building inner wall is an annular space that 9
collects any containment leakage that may occur following a loss-of-coolant accident (LOCA).
10 The [SBACS] establishes a negative pressure in the annulus between the shield building and 11 the steel containment vessel. Filters in the system then control the release of radioactive 12 contaminants to the environment. The [SBACS] consists of two separate and redundant trains.
13 Each train includes a heater, cooling coils, a prefilter, moisture separators, a high-efficiency 14 particulate air (HEPA) filter, an activated charcoal adsorber section for removal of radioiodines, 15 and a fan. Ductwork, valves and/or dampers, and instrumentation also form part of the system.
16 The system initiates and maintains a negative air pressure in the shield building by means of 17 filtered exhaust ventilation of the shield building following receipt of a safety injection signal.
18 The purpose of SR [3.6.13.3] is to verify proper actuation of all train components, including 19 dampers, on an actual or simulated actuation signal. The purpose of SR [3.6.13.4] is to ensure 20 that the system is functioning properly by operating the filter bypass damper.
21 22 The [iodine cleanup system (ICS)] is provided to reduce the concentration of fission products 23 released to the containment atmosphere following a postulated accident. The [ICS] would 24 function together with the [containment spray and cooling systems] following a DBA to 25 reduce the potential release of radioactive material, principally iodine, from the containment to 26 the environment. The [ICS] consists of two 100-percent capacity, separate, independent, and 27 redundant trains. Each train includes a heater, cooling coils, a prefilter, a demister, a HEPA 28 filter, an activated charcoal adsorber section for removal of radioiodines, and a fan. Ductwork, 29 valves and/or dampers, and instrumentation also form part of the system. The system initiates 30 filtered recirculation of the containment atmosphere following receipt of a safety injection signal.
31 The purpose of SR [3.6.11.3] is to verify proper actuation of all train components, including 32 dampers, on an actual or simulated actuation signal. The purpose of SR [3.6.11.4] is to ensure 33 that the system is functioning properly by operating the [ICS] filter bypass damper.
34 35 The [emergency core cooling system pump room exhaust air cleanup system (ECCS 36 PREACS)], in conjunction with other normally operating systems, also provides environmental 37 control of temperature and humidity in the ECCS pump room area and the lower reaches of the 38 auxiliary building. Ductwork, valves or dampers, and instrumentation also form part of the 39 system, as well as demisters functioning to reduce the relative humidity of the air stream.
40 During emergency operations, the [ECCS PREACS] dampers are realigned, and fans are 41 started to begin filtration. Upon receipt of the actuating [engineered safety feature actuation 42 system (ESFAS)] signal(s), normal air discharges from the ECCS pump room isolate, and the 43 stream of ventilation air discharges through the system filter trains. The prefilters or demisters 44 remove any large particles in the air, and any entrained water droplets present, to prevent 45 excessive loading of the HEPA filters and charcoal adsorbers. The purpose of SR [3.7.12.3] is 46 to verify proper actuation of all train components, including dampers, on an actual or simulated 47 actuation signal. The purpose of SR [3.7.12.5] is to ensure that the system is functioning 48 properly by operating the [ECCS PREACS] filter bypass damper.
49 50 The [fuel building air cleanup system (FBACS)] filters airborne radioactive particulates from 1
the area of the fuel pool following a fuel handling accident or LOCA. The [FBACS], in 2
conjunction with other normally operating systems, also provides environmental control of 3
temperature and humidity in the fuel pool area. The FBACS consists of two independent and 4
redundant trains. Each train consists of a heater, a prefilter or demister, a HEPA filter, an 5
activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a 6
fan. Ductwork, valves or dampers, and instrumentation also form part of the system, as well as 7
demisters, functioning to reduce the relative humidity of the airstream. The system initiates 8
filtered ventilation of the fuel handling building following receipt of a high-radiation signal. The 9
[FBACS] is a standby system, parts of which may also be operated during normal plant 10 operations. Upon receipt of the actuating signal, normal air discharges from the building, the 11 fuel handling building is isolated, and the stream of ventilation air discharges through the system 12 filter trains. The purpose of SR [3.7.13.3] is to verify proper actuation of all train components, 13 including dampers, on an actual or simulated actuation signal. The purpose of SR [3.7.13.5] is 14 to ensure that the system is functioning properly by operating the [FBACS] filter bypass 15 damper.
16 17 The [penetration room exhaust air cleanup system (PREACS)] filters air from the 18 penetration area between containment and the auxiliary building. The [PREACS] consists of 19 two independent and redundant trains. Each train consists of a heater, a prefilter or demister, a 20 HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally 21 iodines), and a fan. Ductwork, valves or dampers, and instrumentation, as well as demisters, 22 functioning to reduce the relative humidity of the air stream, also form part of the system. The 23
[PREACS] is a standby system, parts of which may also operate during normal unit operations.
24 Upon receipt of the actuating signal(s), the [PREACS] dampers are realigned and fans are 25 started to initiate filtration. The purpose of SR [3.7.14.3] is to verify proper actuation of all train 26 components, including dampers, on an actual or simulated actuation signal. The purpose of 27 SR [3.7.14.5] is to ensure that the system is functioning properly by operating the [PREACS]
28 filter bypass damper.
29 30
{NOTE: For CE plant designs, use these paragraphs.}
31 32 The [control room emergency air cleanup system (CREACS)] provides a protected 33 environment from which occupants can control the unit following an uncontrolled release of 34 radioactivity, hazardous chemicals, or smoke. The purpose of SR [3.7.11.3] is to verify that 35 each train/subsystem starts and operates on an actual or simulated actuation signal.
36 37 The [shield building exhaust air cleanup system (SBEACS)] is required to ensure that 38 radioactive materials that leak from the primary containment into the shield building (secondary 39 containment) following a design-basis accident (DBA) are filtered and adsorbed prior to 40 exhausting to the environment. The containment has a secondary containment called the shield 41 building, which is a concrete structure that surrounds the steel primary containment vessel.
42 Between the containment vessel and the shield building inner wall is an annular space that 43 collects any containment leakage that may occur following a loss-of-coolant accident (LOCA).
44 The [SBEACS] establishes a negative pressure in the annulus between the shield building and 45 the steel containment vessel. Filters in the system then control the release of radioactive 46 contaminants to the environment. The [SBEACS] consists of two separate and redundant 47 trains. Each train includes a heater, cooling coils, a prefilter, moisture separators, a 48 high-efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal 49 of radioiodines, and a fan. Ductwork, valves and/or dampers, and instrumentation also form 50 part of the system. The system initiates and maintains a negative air pressure in the shield 1
building by means of filtered exhaust ventilation of the shield building following receipt of a 2
safety injection signal. The purpose of SR [3.6.8.3] is to verify proper actuation of all train 3
components, including dampers, on an actual or simulated actuation signal. The purpose of 4
SR [3.6.8.4] is to ensure that the system is functioning properly by operating the filter bypass 5
6 7
The [iodine cleanup system (ICS)] is provided to reduce the concentration of fission products 8
released to the containment atmosphere following a postulated accident. The [ICS] would 9
function together with the [containment spray and cooling systems] following a DBA to 10 reduce the potential release of radioactive material, principally iodine, from the containment to 11 the environment. The [ICS] consists of two 100-percent capacity, separate, independent, and 12 redundant trains. Each train includes a heater, cooling coils, a prefilter, a demister, a HEPA 13 filter, an activated charcoal adsorber section for removal of radioiodines, and a fan. Ductwork, 14 valves and/or dampers, and instrumentation also form part of the system. The system initiates 15 filtered recirculation of the containment atmosphere following receipt of a containment isolation 16 actuation signal. The purpose of SR [3.6.10.3] is to verify proper actuation of all train 17 components, including dampers, on an actual or simulated actuation signal. The purpose of 18 SR [3.6.10.4] is to ensure that the system is functioning properly by operating the [ICS] filter 19 bypass damper.
20 21 The [emergency core cooling system pump room exhaust air cleanup system (ECCS 22 PREACS)], in conjunction with other normally operating systems, also provides environmental 23 control of temperature and humidity in the ECCS pump room area and the lower reaches of the 24 auxiliary building. Ductwork, valves or dampers, and instrumentation also form part of the 25 system, as well as demisters functioning to reduce the relative humidity of the air stream.
26 During emergency operations, the [ECCS PREACS] dampers are realigned, and fans are 27 started to begin filtration. Upon receipt of the actuating engineered safety features actuation 28 system (ESFAS) signal(s), normal air discharges from the ECCS pump room isolate, and the 29 stream of ventilation air discharges through the system filter trains. The prefilters or demisters 30 remove any large particles in the air, and any entrained water droplets present, to prevent 31 excessive loading of the HEPA filters and charcoal adsorbers. The purpose of SR [3.7.13.3] is 32 to verify proper actuation of all train components, including dampers, on an actual or simulated 33 actuation signal. The purpose of SR [3.7.13.5] is to ensure that the system is functioning 34 properly by operating the [ECCS PREACS] filter bypass damper.
35 36 The [fuel building air cleanup system (FBACS)] filters airborne radioactive particulates from 37 the area of the fuel pool following a fuel handling accident or LOCA. The [FBACS], in 38 conjunction with other normally operating systems, also provides environmental control of 39 temperature and humidity in the fuel pool area. [FBACS] consists of two independent and 40 redundant trains. Each train consists of a heater, a prefilter or demister, a HEPA filter, an 41 activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a 42 fan. Ductwork, valves or dampers, and instrumentation also form part of the system, as well as 43 demisters, functioning to reduce the relative humidity of the airstream. The system initiates 44 filtered ventilation of the fuel handling building following receipt of a high-radiation signal. The 45
[FBACS] is a standby system, parts of which may also be operated during normal plant 46 operations. Upon receipt of the actuating signal, normal air discharges from the building, the 47 fuel handling building is isolated, and the stream of ventilation air discharges through the system 48 filter trains. The purpose of SR [3.7.14.3] is to verify proper actuation of all train components, 49 including dampers, on an actual or simulated actuation signal. The purpose of SR [3.7.14.5] is 50 to ensure that the system is functioning properly by operating the [FBACS] filter bypass 1
2 3
The [penetration room exhaust air cleanup system (PREACS)] filters air from the 4
penetration area between containment and the auxiliary building. The [PREACS] consists of 5
two independent and redundant trains. Each train consists of a heater, a prefilter or demister, a 6
HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally 7
iodines), and a fan. Ductwork, valves or dampers, and instrumentation, as well as demisters, 8
functioning to reduce the relative humidity of the air stream, also form part of the system. The 9
[PREACS] is a standby system, parts of which may also operate during normal unit operations.
10 Upon receipt of the actuating signal(s), the [PREACS] dampers are realigned and fans are 11 started to initiate filtration. The purpose of SR [3.7.15.3] is to verify proper actuation of all train 12 components, including dampers, on an actual or simulated actuation signal. The purpose of 13 SR [3.7.15.5] is to ensure that the system is functioning properly by operating the [PREACS]
14 filter bypass damper.
15 16 The [essential chilled water (ECW)] system provides a heat sink for the removal of process 17 and operating heat from selected safety-related air handling systems during a DBA or transient.
18 The [ECW] system is a closed-loop system consisting of two independent trains. Each 19 100-percent capacity train includes a heat exchanger, surge tank, pump, chemical addition tank, 20 piping, valves, controls, and instrumentation. An independent 100-percent capacity chilled 21 water refrigeration unit cools each train. The [ECW] system is actuated on a [safety injection 22 actuation signal (SIAS)] and supplies chilled water to the heating, ventilation, and air 23 conditioning units in engineered safety feature equipment areas (e.g., the main control room, 24 electrical equipment room, and safety injection pump area). The purpose of SR [3.7.10.2] is to 25 verify proper automatic operation of the [ECW] system components and that the [ECW] pumps 26 will start in the event of any accident or transient that generates an [SIAS]. This SR also 27 ensures that each automatic valve in the flow paths actuates to its correct position on an actual 28 or simulated [SIAS].
29 30
{NOTE: For GE BWR/4 plant designs, use these paragraphs.}
31 32 The [main control room environmental control (MCREC)] provides a protected environment 33 from which occupants can control the unit following an uncontrolled release of radioactivity, 34 hazardous chemicals, or smoke. The purpose of SR [3.7.4.3] is to verify that each 35 train/subsystem starts and operates on an actual or simulated actuation signal.
36 37 The emergency core cooling system (ECCS) is designed to limit the release of radioactive 38 materials to the environment following a loss-of-coolant accident (LOCA) and consists of the 39 high pressure coolant injection system, the core spray system, the low pressure coolant 40 injection mode of the residual heat removal (RHR) system, and the automatic depressurization 41 system. The purpose of SR [3.5.1.10] is to verify the automatic initiation logic of high pressure 42 coolant injection, core spray, and low pressure coolant injection will cause the systems or 43 subsystems to operate as designed, including actuation of the system throughout its emergency 44 operating sequence, automatic pump startup, and actuation of all automatic valves to their 45 required positions on receipt of an actual or simulated actuation signal.
46 47 The function of the reactor core isolation cooling (RCIC) system is to respond to transient 48 events by providing makeup coolant to the reactor. The purpose of SR [3.5.3.5] is to verify the 49 system operates as designed, including actuation of the system throughout its emergency 50 operating sequence; that is, automatic pump startup and actuation of all automatic valves to 1
their required positions on receipt of an actual or simulated actuation signal.
2 3
The [plant service water (PSW) system] and ultimate heat sink are designed to provide 4
cooling water for the removal of heat from equipment, such as the diesel generators, RHR pump 5
coolers and heat exchangers, and room coolers for ECCS equipment, required for a safe 6
reactor shutdown following a design-basis accident (DBA) or transient. The [PSW] system also 7
provides cooling to unit components, as required, during normal shutdown and reactor isolation 8
modes. During a DBA, the equipment required only for normal operation is isolated and cooling 9
is directed to only safety-related equipment. The purpose of SR [3.7.2.6] is to verify the 10 systems will automatically switch to the position to provide cooling water exclusively to 11 safety-related equipment during an accident.
12 13 The function of the standby gas treatment (SGT) system is to ensure that radioactive materials 14 that leak from the primary containment into the secondary containment following a DBA are 15 filtered and adsorbed prior to exhausting to the environment. The purpose of SR [3.6.4.3.3] is 16 to verify that each SGT subsystem starts on receipt of an actual or simulated initiation signal.
17 The purpose of SR [3.6.4.3.4] is to verify that the filter cooler bypass damper can be opened 18 and the fan started. This ensures that the ventilation mode of SGT system operation is 19 available.
20 21
{NOTE: For GE BWR/6 plant designs, use these paragraphs.}
22 23 The [control room fresh air (CRFA)] system provides a protected environment from which 24 occupants can control the unit following an uncontrolled release of radioactivity, hazardous 25 chemicals, or smoke. The purpose of SR [3.7.3.3] is to verify that each train/subsystem starts 26 and operates on an actual or simulated actuation signal.
27 28 The emergency core cooling system (ECCS) is designed to limit the release of radioactive 29 materials to the environment following a loss-of-coolant accident (LOCA) and consists of the 30 high pressure core spray (HPCS) system, the low pressure core spray (LPCS) system, the low 31 pressure coolant injection (LPCI) mode of the residual heat removal (RHR) system, and the 32 automatic depressurization system. The purpose of SR [3.5.1.5] is to verify the automatic 33 initiation logic of HPCS, LPCS, and LPCI will cause the systems or subsystems to operate as 34 designed, including actuation of the system throughout its emergency operating sequence, 35 automatic pump startup, and actuation of all automatic valves to their required positions on 36 receipt of an actual or simulated actuation signal.
37 38 The function of the reactor core isolation cooling (RCIC) system is to respond to transient 39 events by providing makeup coolant to the reactor. The purpose of SR [3.5.3.5] is to verify the 40 system operates as designed, including actuation of the system throughout its emergency 41 operating sequence; that is, automatic pump startup and actuation of all automatic valves to 42 their required positions on receipt of an actual or simulated actuation signal.
43 44 The [standby service water (SSW) system] and ultimate heat sink are designed to provide 45 cooling water for the removal of heat from equipment, such as the diesel generators, RHR pump 46 coolers and heat exchangers, and room coolers for ECCS equipment, required for a safe 47 reactor shutdown following a design-basis accident (DBA) or transient. The [SSW] system also 48 provides cooling to unit components, as required, during normal shutdown and reactor isolation 49 modes. During a DBA, the equipment required only for normal operation is isolated and cooling 50 is directed to only safety-related equipment. The purpose of SR [3.7.1.6] is to verify the 1
systems will automatically switch to the position to provide cooling water exclusively to 2
safety-related equipment during an accident.
3 4
The RHR containment spray system is designed to mitigate the effects of primary containment 5
bypass leakage and low-energy line breaks. The purpose of SR [3.6.1.7.3] is to verify that each 6
RHR containment spray subsystem automatic valve actuates to its correct position upon receipt 7
of an actual or simulated automatic actuation signal.
8 9
The function of the standby gas treatment (SGT) system is to ensure that radioactive materials 10 that leak from the primary containment into the secondary containment following a DBA are 11 filtered and adsorbed prior to exhausting to the environment. The purpose of SR [3.6.4.3.3] is 12 to verify that each SGT subsystem starts on receipt of an actual or simulated initiation signal.
13 The purpose of SR [3.6.4.3.4] is to verify that the filter cooler bypass damper can be opened 14 and the fan started. This ensures that the ventilation mode of SGT System operation is 15 available.
16 17 The [high pressure core spray service water system (HPCS SWS)] provides cooling water 18 for the removal of heat from components of the [Division 3] HPCS system. The purpose of 19 SR [3.7.2.3] is to verify that the automatic valves of the HPCS SWS will automatically switch to 20 the safety or emergency position to provide cooling water exclusively to the safety-related 21 equipment on an actual or simulated initiation signal.
22 23 2.2 Description of Proposed Changes 24 25 The licensee proposed to revise certain SRs by adding exceptions to the SR for automatic 26 valves or dampers that are locked, sealed, or otherwise secured in the actuated position, 27 consistent with the changes described in TSTF-541, Revision 2. The following list denotes the 28 proposed changes to the SRs. The proposed new text containing the exception is shown in 29 italics.
30 31
{NOTE: For B&W plant designs, use this list.}
32 33 SR [3.6.7.4] Verify each spray additive automatic valve in the flow path actuates 34 to the correct position on an actual or simulated actuation signal, except for 35 valves that are locked, sealed, or otherwise secured in the actuated position.
36 37 SR [3.7.10.3] Verify [each CREVS train actuates] [or the control room 38 isolates] on an actual or simulated actuation signal, except for dampers and 39 valves that are locked, sealed, or otherwise secured in the actuated position.
40 41 SR [3.7.12.3] Verify each [EVS] train actuates on an actual or simulated 42 actuation signal, except for dampers and valves that are locked, sealed, or 43 otherwise secured in the actuated position.
44 45 SR [3.7.12.5] Verify each [EVS] filter cooling bypass damper can be opened, 46 except for dampers that are locked, sealed, or otherwise secured in the open 47 position.
48 49 SR [3.7.13.3] Verify each [FSPVS] train actuates on an actual or simulated 1
actuation signal, except for dampers and valves that are locked, sealed, or 2
otherwise secured in the actuated position.
3 4
SR [3.7.13.5] Verify each [FSPVS] filter bypass damper can be opened, except 5
for dampers that are locked, sealed, or otherwise secured in the open position.
6 7
{NOTE: For Westinghouse plant designs, use this list.}
8 9
SR [3.6.11.3] Verify each [ICS] train actuates on an actual or simulated 10 actuation signal, except for dampers and valves that are locked, sealed, or 11 otherwise secured in the actuated position.
12 13 SR [3.6.11.4] Verify each [ICS] filter bypass damper can be opened, except for 14 dampers that are locked, sealed, or otherwise secured in the open position.
15 16 SR [3.6.13.3] Verify each [SBACS] train actuates on an actual or simulated 17 actuation signal, except for dampers and valves that are locked, sealed, or 18 otherwise secured in the actuated position.
19 20 SR [3.6.13.4] Verify each [SBACS] filter bypass damper can be opened, except 21 for dampers that are locked, sealed, or otherwise secured in the open position.
22 23 SR [3.7.10.3] Verify each [CREFS] train actuates on an actual or simulated 24 actuation signal, except for dampers and valves that are locked, sealed, or 25 otherwise secured in the actuated position.
26 27 SR [3.7.12.3] Verify each ECCS [PREACS] train actuates on an actual or 28 simulated actuation signal, except for dampers and valves that are locked, 29 sealed, or otherwise secured in the actuated position.
30 31 SR [3.7.12.5] Verify each ECCS [PREACS] filter bypass damper can be closed, 32 except for dampers that are locked, sealed, or otherwise secured in the closed 33 position.
34 35 SR [3.7.13.3] Verify each [FBACS] train actuates on an actual or simulated 36 actuation signal, except for dampers and valves that are locked, sealed, or 37 otherwise secured in the actuated position.
38 39 SR [3.7.13.5] Verify each [FBACS] filter bypass damper can be closed, except 40 for dampers that are locked, sealed, or otherwise secured in the closed position.
41 42 SR [3.7.14.3] Verify each [PREACS] train actuates on an actual or simulated 43 actuation signal, except for dampers and valves that are locked, sealed, or 44 otherwise secured in the actuated position.
45 46 SR [3.7.14.5] Verify each [PREACS] filter bypass damper can be closed, except 47 for dampers that are locked, sealed, or otherwise secured in the closed position.
48 49
{NOTE: For CE plant designs, use this list.}
1 2
SR [3.6.8.3] Verify each [SBEACS] train actuates on an actual or simulated 3
actuation signal, except for dampers and valves that are locked, sealed, or 4
otherwise secured in the actuated position.
5 6
SR [3.6.8.4] Verify each [SBEACS] filter bypass damper can be opened, except 7
for dampers that are locked, sealed, or otherwise secured in the open position.
8 9
SR [3.6.10.3] Verify each [ICS] train actuates on an actual or simulated 10 actuation signal, except for dampers and valves that are locked, sealed, or 11 otherwise secured in the actuated position.
12 13 SR [3.6.10.4] Verify each [ICS] filter bypass damper can be opened, except for 14 dampers that are locked, sealed, or otherwise secured in the open position.
15 16 SR [3.7.10.2] Verify the proper actuation of each [ECW] System component on 17 an actual or simulated actuation signal, except for valves that are locked, sealed, 18 or otherwise secured in the actuated position.
19 20 SR [3.7.11.3] Verify each [CREACS] train actuates on an actual or simulated 21 actuation signal, except for dampers and valves that are locked, sealed, or 22 otherwise secured in the actuated position.
23 24 SR [3.7.13.3] Verify each ECCS [PREACS] train actuates on an actual or 25 simulated actuation signal, except for dampers and valves that are locked, 26 sealed, or otherwise secured in the actuated position.
27 28 SR [3.7.13.5] Verify each ECCS [PREACS] filter bypass damper can be 29 opened, except for dampers that are locked, sealed, or otherwise secured in the 30 open position.
31 32 SR [3.7.14.3] Verify each [FBACS] train actuates on an actual or simulated 33 actuation signal, except for dampers and valves that are locked, sealed, or 34 otherwise secured in the actuated position.
35 36 SR [3.7.14.5] Verify each [FBACS] filter bypass damper can be opened, except 37 for dampers that are locked, sealed, or otherwise secured in the open position.
38 39 SR [3.7.15.3] Verify each [PREACS] train actuates on an actual or simulated 40 actuation signal, except for dampers and valves that are locked, sealed, or 41 otherwise secured in the actuated position.
42 43 SR [3.7.15.5] Verify each [PREACS] filter bypass damper can be opened, 44 except for dampers that are locked, sealed, or otherwise secured in the open 45 position.
46 47
{NOTE: For GE BWR/4 plant designs, use this list.}
1 2
SR [3.5.1.10] Verify each ECCS injection/spray subsystem actuates on an 3
actual or simulated automatic initiation signal, except for valves that are locked, 4
sealed, or otherwise secured in the actuated position.
5 6
SR [3.5.3.5] Verify the RCIC System actuates on an actual or simulated 7
automatic initiation signal, except for valves that are locked, sealed, or otherwise 8
secured in the actuated position.
9 10 SR [3.6.4.3.3] Verify each SGT subsystem actuates on an actual or simulated 11 initiation signal, except for dampers that are locked, sealed, or otherwise secured 12 in the actuated position.
13 14 SR [3.6.4.3.4] Verify each SGT filter cooler bypass damper can be opened and 15 the fan started, except for dampers that are locked, sealed, or otherwise secured 16 in the open position.
17 18 SR [3.7.2.6] Verify each [PSW] subsystem actuates on an actual or simulated 19 initiation signal, except for valves that are locked, sealed, or otherwise secured in 20 the actuated position.
21 22 SR [3.7.4.3] Verify each [MCREC] subsystem actuates on an actual or 23 simulated initiation signal, except for dampers and valves that are locked, sealed, 24 or otherwise secured in the actuated position.
25 26
{NOTE: For GE BWR/6 plant designs, use this list.}
27 28 SR [3.5.1.5] Verify each ECCS injection/spray subsystem actuates on an actual 29 or simulated automatic initiation signal, except for valves that are locked, sealed, 30 or otherwise secured in the actuated position.
31 32 SR [3.5.3.5] Verify the RCIC System actuates on an actual or simulated 33 automatic initiation signal, except for valves that are locked, sealed, or otherwise 34 secured in the actuated position.
35 36 SR [3.6.1.7.3] Verify each RHR containment spray subsystem automatic valve 37 in the flow path actuates to its correct position on an actual or simulated 38 automatic initiation signal, except for valves that are locked, sealed, or otherwise 39 secured in the actuated position.
40 41 SR [3.6.4.3.3] Verify each SGT subsystem actuates on an actual or simulated 42 initiation signal, except for dampers that are locked, sealed, or otherwise secured 43 in the actuated position.
44 45 SR [3.6.4.3.4] Verify each SGT filter cooler bypass damper can be opened and 46 the fan started, except for dampers that are locked, sealed, or otherwise secured 47 in the open position.
48 49 SR [3.7.1.6] Verify each [SSW] subsystem actuates on an actual or simulated 1
initiation signal, except for valves that are locked, sealed, or otherwise secured in 2
the actuated position.
3 4
SR [3.7.2.3] Verify the [HPCS SWS] actuates on an actual or simulated initiation 5
signal, except for valves that are locked, sealed, or otherwise secured in the 6
actuated position.
7 8
SR [3.7.3.3] Verify each [CRFA] subsystem actuates on an actual or simulated 9
initiation signal, except for dampers and valves that are locked, sealed, or 10 otherwise secured in the actuated position.
11 12 The licensee also provided changes to the TS Bases for information only in [Enclosure 3].
13 Where the reason for each particular SR is described, the following text would be added:
14 15 The SR excludes automatic dampers and valves that are locked, sealed, or 16 otherwise secured in the actuated position. The SR does not apply to dampers 17 or valves that are locked, sealed, or otherwise secured in the actuated position 18 since the affected dampers or valves were verified to be in the actuated position 19 prior to being locked, sealed, or otherwise secured. Placing an automatic valve 20 or damper in a locked, sealed, or otherwise secured position requires an 21 assessment of the operability of the system or any supported systems, including 22 whether it is necessary for the valve or damper to be repositioned to the 23 non-actuated position to support the accident analysis. Restoration of an 24 automatic valve or damper to the non-actuated position requires verification that 25 the SR has been met within its required Frequency.
26 27
[The licensee also proposed changes to the TS Bases that would correct errors in the 28 descriptions of the reasons for SR ((3.7.12.5], SR [3.7.13.5], SR [3.7.14.5], and 29 SR 3.7.15.5)). The descriptions erroneously state that operability is verified if the damper 30 can be closed. The description should state operability is verified if the damper can be 31 opened.]
32 33 2.2.1 Variations from TSTF-541, Revision 2 34 35
{NOTE: Technical reviewers and/or the project manager are to assess the adequacy of any 36 variations from or exceptions to the approved traveler and document their acceptability. Use the 37 paragraph below if applicable.}
38 39 The licensee proposed the following variations from the TS changes described in TSTF-541, 40 Revision 2, or the applicable parts of the NRC staffs SE of TSTF-541, Revision 2. The licensee 41 stated that these variations do not affect the applicability of TSTF-541, Revision 2, or the NRC 42 staffs SE to the proposed LAR. [Describe variations.]
43 44 2.3 Applicable Regulatory Requirements and Guidance 45 46 Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for 47 amendment of license, construction permit, or early site permit, requires that whenever a 48 licensee desires to amend the license, application for an amendment must be filed with the 49 Commission fully describing the changes desired, and following as far as applicable, the form 1
prescribed for original applications.
2 3
Under 10 CFR 50.92(a), determinations on whether to grant an applied-for license amendment 4
are guided by the considerations that govern the issuance of initial licenses or construction 5
permits to the extent applicable and appropriate. Both the common standards for licenses and 6
construction permits in 10 CFR 50.40(a), and those specifically for issuance of operating 7
licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the 8
activities at issue will not endanger the health and safety of the public.
9 10 The regulation under 10 CFR 50.36, Technical specifications, establishes the regulatory 11 requirements related to the content of TSs. Section 50.36(a)(1) requires an application for an 12 operating license to include proposed TSs. A summary statement of the bases or reasons for 13 such specifications, other than those covering administrative controls, must also be included in 14 the application, but shall not become part of the TSs.
15 16 The regulation under 10 CFR 50.36(b) requires that:
17 18 Each license authorizing operation of a utilization facility will include 19 technical specifications. The technical specifications will be derived from the 20 analyses and evaluation included in the safety analysis report, and amendments 21 thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; 22 technical information]. The Commission may include such additional technical 23 specifications as the Commission finds appropriate.
24 25 The categories of items required to be in the TS are listed in 10 CFR 50.36(c). In accordance 26 with 10 CFR 50.36(c)(2), limiting conditions for operation (LCOs) are the lowest functional 27 capability or performance levels of equipment required for safe operation of the facility. When 28 LCOs are not met, the licensee must shut down the reactor or follow any remedial action 29 permitted by the TSs until the condition can be met.
30 31 SRs are defined in 10 CFR 50.36(c)(3) as requirements relating to test, calibration, or 32 inspection to assure that the necessary quality of systems and components is maintained, that 33 facility operation will be within safety limits, and that the limiting conditions for operation will be 34 met.
35 36 The regulation under 10 CFR 50.36(c)(5) requires TS to include administrative controls, which 37 are the provisions relating to organization and management, procedures, recordkeeping, 38 review and audit, and reporting necessary to assure operation of the facility in a safe manner.
39 40 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing 41 Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, 42 establishes quality assurance requirements for the operation of nuclear power plant 43 safety-related structures, systems, and components (SSCs).
44 45 NRC Regulatory Guide (RG) 1.33, Revision 2, Quality Assurance Program Requirements 46 (Operation), with Appendix A, Typical Procedures for Pressurized Water Reactors and Boiling 47 Water Reactors, dated February 1978 (ADAMS Accession No. ML003739995), describes a 48 method acceptable to the NRC staff for complying with the Commissions regulations with 49 regard to overall quality assurance program requirements for the operation phase of nuclear 50 power plants. Section 8.b of RG 1.33, Appendix A, states that implementing procedures are 1
required for each surveillance test, inspection, or calibration listed in the technical 2
specifications. Section 9.e of RG 1.33, Appendix A, states that General procedures for the 3
control of maintenance, repair, replacement, and modification work should be prepared before 4
reactor operation is begun. Section 9.e.1 states that the procedures should include information 5
such as methods for obtaining permission and clearance for operation personnel to work and for 6
logging such work.
7 8
TS [5.4.1.a] in the Administrative Controls section of the [PLANT] TS requires that written 9
procedures shall be established, implemented, and maintained covering the applicable 10 procedures recommended in RG 1.33, Revision 2, Appendix A, February 1978.
11 12 TS [5.5.11/5.5.8], Ventilation Filter Testing Program in the Administrative Controls section of 13 the [PLANT] TS contains requirements to identify any filter degradation and ensures the ability 14 of the filters to perform in a manner consistent with the licensing basis for the facility.
15 16 The NRC staffs guidance for the review of TS is in Chapter 16.0, Revision 3, Technical 17 Specifications, dated March 2010 (ADAMS Accession No. ML100351425) of NUREG-0800, 18 Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power 19 Plants: LWR [Light-Water Reactor] Edition (SRP). As described therein, as part of the 20 regulatory standardization effort, the NRC staff has prepared Standard Technical Specifications 21 (STS) for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes 22 consideration of whether the proposed changes are consistent with the applicable reference 23 STS (i.e., the current STS), as modified by NRC-approved travelers. In addition, the guidance 24 states that comparing the change to previous STS can help clarify the TS intent.
25 26 Section 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at 27 nuclear power plants, requires licensees to monitor the performance or condition of SSCs, 28 against licensee-established goals, in a manner sufficient to provide reasonable assurance that 29 these SSCs, as defined in paragraph (b) of this section, are capable of fulfilling their intended 30 functions.
31 32 The regulation under 10 CFR 50.65(a)(4) states:
33 34 Before performing maintenance activities (including but not limited to 35 surveillance, post-maintenance testing, and corrective and preventive 36 maintenance), the licensee shall assess and manage the increase in risk that 37 may result from the proposed maintenance activities. The scope of the 38 assessment may be limited to structures, systems, and components that a 39 risk-informed evaluation process has shown to be significant to public health and 40 safety.
41 42 The regulation under 10 CFR 50.65(b) states:
43 44 The scope of the monitoring program specified in paragraph (a)(1) of this section 45 shall include safety related and nonsafety related structures, systems, and 46 components, as follows:
47 48 (1) Safety-related structures, systems and components that are relied upon to 49 remain functional during and following design basis events to ensure the integrity 50 of the reactor coolant pressure boundary, the capability to shut down the reactor 1
and maintain it in a safe shutdown condition, or the capability to prevent or 2
mitigate the consequences of accidents that could result in potential offsite 3
exposure comparable to the guidelines in [10 CFR] 50.34(a)(1),
4
[10 CFR] 50.67(b)(2), or [10 CFR] 100.11 of this chapter, as applicable.
5 6
(2) Nonsafety related structures, systems, or components:
7 8
(i) That are relied upon to mitigate accidents or transients or are used in plant 9
emergency operating procedures (EOPs); or 10 11 (ii) Whose failure could prevent safety-related structures, systems, and 12 components from fulfilling their safety-related function; or 13 14 (iii) Whose failure could cause a reactor scram or actuation of a safety-related 15 system.
16 17 The most recent revision of NRC staff guidance for the format and content of the [PLANT] TS is 18 in 19
{NOTE: Choose applicable STS}
20
[U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Babcock and 21 Wilcox Plants, NUREG-1430, Volume 1, Specifications, and Volume 2, Bases, 22 Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12100A177 and ML12100A178, 23 respectively).
24 25 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse 26 Plants, NUREG-1431, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, 27 dated April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively).
28 29 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Combustion 30 Engineering Plants, NUREG-1432, Volume 1, Specifications, and Volume 2, Bases, 31 Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12102A165 and ML12102A169, 32 respectively).
33 34 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General 35 Electric BWR/4 Plants NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, 36 Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193, 37 respectively).
38 39 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General 40 Electric BWR/6 Plants NUREG-1434, Volume 1, Specifications, and Volume 2, Bases, 41 Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12104A195 and ML12104A196, 42 respectively).]
43 44
3.0 TECHNICAL EVALUATION
45 46 The proposed amendment is based on the NRC-approved TSTF-541, Revision 2. The NRC 47 staffs evaluation of the proposed amendment relies upon the NRC staffs previous approval of 48 TSTF-541, Revision 2. The regulatory framework the NRC staff used to determine the 49 acceptability of the proposed changes consist of the requirements and guidance listed in 50 Section 2.3 of this SE. The NRC staff reviewed the proposed TS changes to determine whether 1
they meet the standards in 10 CFR 50.36. The NRC staff also used the SRP to determine 2
whether the proposed TS changes would clarify the intent of the TS.
3 4
The NRC staff determined that when the exception is used the radiological consequences for 5
the accidents previously evaluated are not changed since the system is still capable of 6
performing the specified safety function assumed in the accident analyses and the associated 7
TS actions are followed if the system cannot perform its specified safety function. Additionally, 8
the licensee is required to perform filter testing in accordance with the Ventilation Filter Testing 9
Program as stated in the accompanying TSs SRs, as these SRs are not affected by this 10 proposed change. The Ventilation Filter Testing Program in TS [5.5.11/5.5.8] would identify any 11 filter degradation and it ensures the ability of the filters to perform in a manner consistent with 12 the licensing basis for the facility.
13 14 In the [PLANT] TS, SRs generally follow a format in which text states that certain SSCs or 15 systems (subsystems, trains, etc.) of components must be verified to be able to actuate or 16 function. Each verification must be performed at a given frequency. The rules governing SRs 17 are explicitly stated in the TS in SR 3.0.1 through SR 3.0.4.
18 19 For SRs lacking an explicit exception, the sentence Failure to meet a Surveillance, whether 20 such failure is experienced during the performance of the Surveillance or between 21 performances of the Surveillance, shall be failure to meet the LCO, in SR 3.0.1 requires that 22 when an SR is not met, the LCO is not met. Per the [PLANT] TS usage rules, when an LCO is 23 not met, Required Actions must be met within specified Completion Times. Traveler TSTF-541, 24 Revision 2, was approved to provide an acceptable method in the STS to avoid unnecessary 25 entry into Conditions and Required Actions.
26 27 While SR 3.0.1 through SR 3.0.4 are explicit with respect to when SRs are to be met and 28 performed, the text of the individual SRs does not contain more detail than a system name or 29 component name. Details of how the licensee will implement SRs are contained in 30 licensee-controlled procedures.
31 32 The procedures for how the licensee will implement SRs are discussed in Section 8.b of 33 Appendix A to RG 1.33, Revision 2, which is a requirement of TS [5.4]. The procedures for 34 general maintenance and equipment work clearances and logging discussed in Section 9.e of 35 Appendix A to RG 1.33, Revision 2, are also requirements of TS [5.4]. Since SR procedures 36 along with maintenance, equipment work clearance, and logging procedures are 37 licensee-controlled documents, changes to the procedure details must be done in accordance 38 with 10 CFR 50.59. If the change would require NRC approval, 10 CFR 50.59 would require the 39 licensee to submit an amendment request to the NRC per 10 CFR 50.90. SSCs with SRs are 40 scoped into the requirements of 10 CFR 50.65 and 10 CFR 50.65(a)(4) contains the 41 requirement to assess and manage the risk of maintenance. Therefore, the licensee must 42 further evaluate the effect of any maintenance on SSCs for which the exception is employed.
43 Given the requirements of 10 CFR 50.59 and 10 CFR 50.65, the NRC staff has reasonable 44 assurance that the licensee will assess the impact of using the exception in the SR for the SSCs 45 and systems involved. If the licensee fails to make the proper assessments, enforcement 46 actions related to the stated regulations could be taken.
47 48 Since 10 CFR 50.59 and 10 CFR 50.65 require a licensee to evaluate and document a change, 49 the exception is acceptable because there is reasonable assurance that placing the component 50 in a given position will not inadvertently impact the operability of required SSCs. The NRC staff 1
determined that there is reasonable assurance that the change will not have inadvertent effects 2
on system OPERABILITY or SSC quality.
3 4
The licensees LAR contains the following statements:
5 6
While the proposed exceptions permit automatic valves and dampers that are 7
locked, sealed, or otherwise secured in the actuated position to be excluded from 8
the SR in order to consider the SR met, the proposed changes will not permit a 9
system that is made inoperable by locking, sealing, or otherwise securing an 10 automatic valve or damper in the actuated position to be considered operable.
11 As stated in the [SR 3.0.1] Bases, Nothing in this Specification, however, is to 12 be construed as implying that systems or components are OPERABLE when: a.
13 The systems or components are known to be inoperable, although still meeting 14 the SRs.
15 16
[LICENSEE] acknowledges that under the proposed change, the affected valves 17 and dampers may be excluded from the SR when locked, sealed or otherwise 18 secured in the actuated position. However, if the safety analysis assumes 19 movement from the actuated position following an event, or the system is 20 rendered inoperable by locking, sealing, or otherwise securing the valve or 21 damper in the actuated position, then the system cannot perform its specified 22 safety function and is inoperable regardless of whether the SR is met.
23 24
[LICENSEE] acknowledges for components for which the SR allowance can be 25 utilized, the SR must be verified to have been met within its required Frequency 26 after removing the valve or damper from the locked, sealed or otherwise secured 27 status. If the SR exception is utilized to not test the actuation of a valve or 28 damper and the specified Frequency of the SR is exceeded without testing the 29 component, the SR must be performed on the component when it is returned to 30 service in order to meet the SR.
31 32 Given the statements provided on the docket to adopt TSTF-541, Revision 2, the NRC staff 33 determined that there is reasonable assurance that the change will not inadvertently affect the 34 clarity of [PLANTS] licensing basis.
35 36 The NRC staff determined that the [PLANT] TS changes, as amended by TSTF-541, 37 Revision 2, will continue to provide an acceptable way to meet 10 CFR 50.36(c)(3) because the 38 revised SRs will continue to provide assurance that the necessary quality of systems and 39 components is maintained and that the LCOs will be met.
40 41
[3.1 Variations]
42 43
{Note: If the licensee identifies variations in Section 2.2 of the LAR, other than differences in the 44 numbering, titles, and nomenclature in the TS, they should be evaluated in this section. More 45 extensive differences may exceed the scope of what is allowable in CLIIP applications. If the 46 variations are related to different numbering, titles, or nomenclature, use the paragraph below.}
47 48 As discussed in Section 2.2.1 of this SE, the licensee proposed variations from TSTF-541, 49 Revision 2, related to the use of different numbering, titles, and nomenclature. For example, 50
[insert example here]. The NRC staff reviewed these variations and finds them acceptable as 1
the differences do not affect the applicability of traveler TSTF-541 to the [PLANT] TSs.
2 3
4.0 STATE CONSULTATION
4 5
{This section is to be prepared by the plant project manager.}
6 7
In accordance with the Commissions regulations, the [Name of State] State official was notified 8
of the proposed issuance of the amendment(s) on [date]. The State official had [no]
9 comments. [If comments were provided, they should be addressed here.]
10 11
5.0 ENVIRONMENTAL CONSIDERATION
12 13
{This section is to be prepared by the plant project manager in accordance with current 14 procedures.}
15 16
6.0 CONCLUSION
17 18
{This section is to be prepared by the plant project manager.}
19 20 The Commission has concluded, based on the considerations discussed above, that: (1) there 21 is reasonable assurance that the health and safety of the public will not be endangered by 22 operation in the proposed manner, (2) there is reasonable assurance that such activities will be 23 conducted in compliance with the Commissions regulations, and (3) the issuance of the 24 amendment(s) will not be inimical to the common defense and security or to the health and 25 safety of the public.
26 27
7.0 REFERENCES
28 29
{Optional section to be prepared by the plant project manager and primary reviewers. If 30 document is publicly available, the ADAMS Accession No. should be listed.}
31 32
{NOTE: These are the principal contributors for the model SE of the traveler. Replace these 33 names with those who prepared the plant-specific SE. Since this is a CLIIP traveler, typically 34 only the STSB reviewer, Matthew Hamm, would be a contributor to the plant-specific SE.}
35 36 Principal Contributors: Matthew Hamm, NRR/DSS/STSB 37 Kristy Bucholtz, NRR/DSS 38 Robert Beaton, NRR/DSS 39 40 Date:
41