ML20248H537
| ML20248H537 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 10/09/2020 |
| From: | Victor Cusumano NRC/NRR/DSS/STSB |
| To: | Technical Specifications Task Force |
| Honcharik, M., NRR/DSS, 301-415-1774 | |
| Shared Package | |
| ML20266G291 | List: |
| References | |
| Download: ML20248H537 (9) | |
Text
Enclosure General Directions: This model SE provides the format for a safety evaluation (SE) of LARs to adopt CLIIP TSTF-582. The bolded bracketed information shows text that should be filled in for the specific amendment. The italicized wording provides guidance on what should be included in each section.
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX XX]
AND AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX XX]
[NAME OF LICENSEE]
[NAME OF FACILITY]
DOCKET NOS. 50-[XXX] AND 50-[XXX]
Application (i.e., initial and supplements)
Safety Evaluation Date
[Date], [ADAMS Accession No.]
[Date]
Principal Contributors to Safety Evaluation Tarico Sweat
1.0 PROPOSED CHANGE
S
[Name of licensee] (the licensee) requested changes to the technical specifications (TSs) for
[name of facility] by license amendment request (LAR, application). In its application, the licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP). The proposed changes would revise the TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force (TSTF) Traveler TSTF-582, Revision 0, RPV WIC Enhancements (TSTF-582) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19240A260), and the associated NRC staff safety evaluation (SE) of TSTF-582 (ADAMS Accession No. ML20219A333).
The boiling-water reactor (BWR) RPV design includes multiple penetrations located below the top of active fuel (TAF). These penetrations provide entry for control rods, recirculation flow, reactor water cleanup (RWCU), and shutdown cooling. Since these penetrations are below the TAF, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling. The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release. Drain Time is the time it would take for the water inventory in and above the RPV to drain to the TAF.
1.1 Proposed TS Changes to Adopt TSTF-582 In accordance with NRC staff-approved TSTF-582, the licensee proposed changes that would revise the TSs related to RPV WIC to incorporate operating experience and to correct errors and omissions that the licensee incorporated into the [name of facility] TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (ADAMS Accession No. ML16074A448). Specifically, the licensee proposed the following changes to adopt TSTF-582:
{NOTE: Delete items on this list that are not applicable to the LAR. Some licensees may have already adopted some of these changes as variations in their LARs to adopt TSTF-582 or in other post-TSTF-582 LARs.}
The Drain Time definition in TS 1.1 would be revised to move the examples of common mode failure mechanisms to the Bases and delete seismic events.
In TS 1.1, Drain Time definition, the exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are that are locked, sealed, or otherwise secured would be revised to apply the exception for manual or automatic valves that are closed and administratively controlled.
The Actions of TS 3.3.5.2 would be revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.
TS 3.3.5.2, Required Action B.2 requires calculating Drain Time with a Completion Time of immediately. The Required Action would be renumbered as A.2.2 and revised to state, Initiate action to calculate Drain Time.
Use this if the plant design has additional isolation instrumentation functions based on low RPV water level that could be credited when calculating Drain Time. [The [name of facility] design contains additional isolation instrumentation functions based on low RPV water level that could be credited when calculating Drain Time. Those functions would be added to the required functions in TS 3.3.5.2.]
Use this for plant TSs that are based upon the BWR/6 STS (NUREG-1434). [TS 3.3.6.1, Primary Containment Isolation Instrumentation, Required Action J.2 would be deleted. This action is no longer applicable after adoption of TSTF-542.]
Use this for plant TSs that are based upon the BWR/6 STS (NUREG-1434). [TS 3.5.1 Actions Note, the first use of the acronym HPCS would be defined and the definition would be removed from Condition B.]
In TS 3.5.2, the first use of the acronym SGT would be defined in Required Action C.3 and the acronym SGT would be used in Required Action D.4.
TS 3.5.2 and TS 3.3.5.2 would be revised to eliminate the requirement for a manual emergency core cooling system (ECCS) initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start. TS 3.5.2 Surveillance Requirements (SRs) related to manual initiation using the ECCS signal (such as verifying automatic alignment of valves on an initiation signal) would be eliminated. Related to this change, the TS 3.3.5.2 functions, Surveillance Requirements, and Actions that only support manual initiation using an ECCS signal (including interlocks and minimum flow instruments) would be eliminated.
Use this if the plant shares secondary containment structures between unites. ((Name of facility, Units X and X] share secondary containment structures between units.
The TS 3.5.2 Actions would be revised to recognize that an operable secondary containment and operable secondary containment isolation valves satisfy the Required Actions.]
Use this for plant TSs that are based upon the BWR/4 STS (NUREG-1433). [A redundant definition of LPCI in SR 3.5.2.2 would be eliminated.]
Surveillance Requirement (SR) 3.5.2.6, that requires operating the required ECCS injection/spray subsystem for at least 10 minutes through the recirculation line, would be modified by the addition of two notes. The first Note would replace the existing SR that the ECCS subsystem be run through the recirculation line with a Note that states that operation may be through the test return line. The second Note would permit crediting normal operation of the low-pressure ECCS subsystem for performance of the SR.
Use this for plant TSs that are based upon the BWR/4 STS (NUREG-1433). [The Applicability of TS 3.6.1.3, Primary Containment Isolation Valves (PCIVs), would be revised to delete the phrase, When associated instrumentation is required to be OPERABLE per Limiting Condition for Operation (LCO) 3.3.6.1, Primary Containment Isolation Instrumentation. This would make TS 3.6.1.3 only applicable in Modes 1, 2, and 3. Following adoption of TSTF-542, no functions in LCO 3.3.6.1 are applicable outside of Modes 1, 2, or 3. The Actions and SRs of TS 3.6.1.3 would be revised to reflect this change.]
TS 3.8.2, AC [Alternating Current] Sources - Shutdown, SR 3.8.2.1, would be revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and 5. TSTF-542 eliminated the automatic ECCS initiation in Modes 4 and 5.
The Applicability of LCO 3.3.8.1 would be revised to remove the specified condition When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown.
1.2 Additional Proposed TS Changes
{NOTE: Use this section if variations are proposed. Add additional subsections if needed.
Variations discussed below in Sections 1.2.1 and 1.2.2 are expected and do not warrant removal from the CLIIP and do not require any additional technical branches to be on the review.}
{NOTE: After Traveler TSTF-582 was approved, the Technical Specifications Task Force identified additional TS changes needed to reflect that TS 3.8.2 should not require automatic start and loading of a diesel generator within [12] seconds on an ECCS initiation signal or a loss of offsite power signal. The TSTF submitted TSTF-583-T, TSTF-582 Diesel Generator Variation (ADAMS Accession No. ML20248H330), to document these additional TS changes.}
1.2.1 Proposed TS Changes to Adopt TSTF-583-T The licensee proposed to make the following changes in accordance with TSTF-583-T, TSTF-582 Diesel Generator Variation (ADAMS Accession No. ML20248H330):
TS 3.3.8.1, Loss of Power (LOP) Instrumentation, would be revised to delete When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown. from the Applicability.
SR 3.8.2.1 would be revised to add SR 3.8.1.7, SR 3.8.1.15, and SR 3.8.2.18 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1. The format of SR 3.8.2.1 would also be restructured to list the SRs that are still applicable, instead of listing the SRs that are not applicable.
1.2.2 Editorial Variations
{NOTE: Use this section if the plant has different numbering or modify accordingly for other editorial changes made.}
The licensee noted that [name of facility] TSs have different numbering than standard technical specifications (STSs) for the RPV WIC related TS.
2.0 REGULATORY EVALUATION
The regulation at 10 CFR 50.36(c)(2) requires that TSs include limiting conditions for operation (LCOs). Per 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation also requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.
The regulation at 10 CFR 50.36(c)(3) requires that TSs include items in the category of SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.
The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the [insert applicable NUREG]1, as modified by NRC-approved travelers.
Traveler TSTF-582 revised the STSs related to RPV WIC to incorporate operating experience and to correct editorial errors in TSTF-542, Revision 2, Reactor Pressure Vessel Water 1 {NOTE: Choose the appropriate NUREG reference from those that follow:} U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric, BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193, respectively). U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric BWR/6 Plants, NUREG-1434, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A195 and ML12104A196, respectively).
Inventory Control (ADAMS Accession No. ML16074A448). The NRC approved TSTF-542, Revision 2, on December 20, 2016 (ADAMS Package Accession No. ML16343B066). The NRC staff approved TSTF-582 under the CLIIP in its letter dated August 13, 2020 (ADAMS Accession No. ML20219A333). The TSTF-582 SE states that a licensee may adopt the STS changes approved in TSTF-582, if the licensee has already adopted the STS changes approved in TSTF-542.
3.0 TECHNICAL EVALUATION
3.1 Proposed TS Changes to Adopt TSTF-582 The NRC staff compared the licensees proposed TS changes in Section 1.1 of this SE against the changes approved in TSTF-582. In accordance with the SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-582 are applicable to [name of facility]
TSs because the [name of facility] is a [insert BWR design: BWR/4, BWR/6, etc.] and the NRC staff approved the TSTF-582 changes for [insert BWR design] designs. The licensee meets the TSTF-582 SE provision for adoption of TSTF-582 since the licensee adopted Traveler TSTF-542 on [amendment date and Accession No.] Therefore, the NRC staff concludes that the licensees proposed changes to the [name of facility] TSs in Section 1.1 of this SE are acceptable in that they are consistent with TSTF-582 and the terms for use stated in the NRC staffs SE of TSTF-582.
{NOTE: In the next two paragraphs delete any TS, LCO, and SR numbers that are not applicable to the LAR. Some licensees may have already adopted some of these changes as variations in their LARs to adopt TSTF-582 or in other post-TSTF-582 LARs.}
The NRC staff finds that proposed changes to the TS 1.1 definition and LCOs [3.3.5.2, 3.3.6.1, 3.5.2, and 3.6.1.3] correctly specify the lowest functional capability or performance levels of equipment required for safe operation of the facility in accordance with 10 CFR 50.36(c)(2)(i).
Also, the NRC staff finds that proposed changes to the Actions of LCOs [3.3.5.2A, 3.3.5.2B, 3.3.6.1, 3.5.2, and 3.6.13] are adequate remedial actions to be taken until each LCO can be met provide protection to the health and safety of the public, thereby satisfying 10 CFR 50.36(c)(2)(i).
The NRC staff finds that the proposed revisions to the SRs in TS [3.3.5.2, 3.5.2, 3.6.1.3, and 3.8.2] continue to provide requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met in accordance with 10 CFR 50.36(c)(3).
Thus, the proposed changes continue to meet the requirements of 10 CFR 50.36(c)(2)(i) and 10 CFR 50.36(c)(3) as discussed in Section 3.0 of the NRC staffs SE of TSTF-582.
3.2 Additional Proposed TS Changes
{NOTE: Use this section if variations are proposed. Add additional subsections if needed.
Variations discussed below in Sections 3.2.1 and 3.2.2 to are expected and do not warrant removal from the CLIIP.}
3.2.1 Proposed TS Changes to Adopt TSTF-583-T Refer to Section 1.2.1 of this SE for proposed changes.
3.2.1.1 TS 3.3.8.1, Applicability The licensee stated that TS 3.8.2 does not require automatic start and loading of a diesel generator (DG) within [12] seconds on an ECCS initiation signal or a loss of offsite power signal. Currently, TS 3.3.8.1, Loss of Power (LOP) Instrumentation, is applicable in Modes 1, 2, and 3, and when the associated DG is required to be operable by TS 3.8.2. The NRC staff confirmed that TS 3.8.2 no longer requires automatic start and loading of a DG on an LOP signal. The NRC staff finds it acceptable to revise the Applicability of LCO 3.3.8.1 by deleting When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown, because the LOP instrumentation that generates the LOP signal does not need to be operable when the DG is required to be operable by TS 3.8.2. Therefore, the NRC staff concludes that the LCO applicability changes will continue to provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility and, therefore, meet the LCO requirements of 10 CFR 50.36(c)(2).
3.2.1.2 SR 3.8.2.1 LCO 3.8.2, AC Sources - Shutdown, requires one offsite circuit and one DG capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8, Distribution Systems-Shutdown, to be operable in shutdown conditions. The existing SR 3.8.2.1 lists the TS 3.8.1 SRs that are applicable in shutdown conditions with some exceptions.
TS SR 3.8.1.7 and SR 3.8.1.15 require that the DG starts from standby or hot conditions, respectively, and achieve required voltage and frequency within [12] seconds and required steady state voltage and frequency ranges. The [12]-second start requirement associated with the DG automatic start supports the assumptions in the design basis loss-of-coolant accident analysis. The NRC staff confirmed that [12]-second timing is not required during a manual DG start to respond to a draining event, which has a minimum Drain Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. In addition, SR 3.8.1.2, which requires the DG to start from standby conditions and achieve the required steady state voltage and frequency ranges, is applicable under SR 3.8.2. The NRC staff finds that the SR 3.8.1.7 and SR 3.8.1.15 testing for the DGs capability to achieve required steady state voltage and frequency ranges will be performed in SR 3.8.1.2 since SR 3.8.1.2 provides the test for this DG capability. Therefore, the NRC staff finds it acceptable to add SR 3.8.1.7 and SR 3.8.1.15 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.
{NOTE: SR 3.8.1.18 is plant-specific, and the wording also varies by plant. Revise the variation description as necessary to reflect the plant-specific wording.}
TS SR 3.8.1.18 states, [Verify interval between each sequenced load block is within
+/- [10% of design interval] [for each load sequencer timer)). This SR verifies the
[10] percent load sequence time interval tolerance between each sequenced load block when loads are sequentially connected to the engineered safety features (ESF) bus by [an automatic sequencer] [relay logic schemes that perform a function equivalent to a load sequencer]
while the DG is tied to the ESF bus. TS 3.5.2 requires manual starting of the equipment for water injection to respond to a draining event so that the DG will be manually loaded during a draining event. No other postulated events require automatic loading of the DG during shutdown conditions. The NRC staff confirmed that with respect to SR 3.8.18, the [load sequencer][relay logic schemes that perform a function equivalent to a load sequencer]
are used for the automatic loading of the DG and are not used during a manual loading of the DG. Therefore, the NRC staff finds it acceptable to add SR 3.8.1.18 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.
Additionally, the licensee proposed to recast SR 3.8.2.1 from a listing of exceptions (i.e., a list of TS 3.8.1 SRs that do not need to be performed) to a listing the SRs that need to be performed to demonstrate the operability of the offsite and onsite AC power sources during shutdown conditions. The NRC staff confirmed that the list of SRs that need to be performed during shutdown conditions are correctly listed in SR 3.8.2.1. The NRC staff finds that the proposed revision of SR 3.8.2.1 is acceptable because it is an editorial clarification and does not substantively change TS requirements.
The NRC staff finds that the proposed changes to revise SR 3.8.2.1 are acceptable because the remaining applicable SRs will continue to demonstrate the operability of the required AC power sources and, as such, ensure the availability of the AC power required to operate the plant in a safe manner and mitigate postulated events during shutdown conditions. Therefore, the NRC staff finds the proposed changes to SR 3.8.2.1 are acceptable because the changes continue to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the associated LCO will continue to be met in accordance with 10 CFR 50.36(c)(3).
3.2.2 Editorial
{NOTE: Use this section if the plant has different numbering or modify accordingly for other editorial changes made.}
The licensee noted that [name of facility] TSs have different numbering than STS for the RPV WIC related TS. The NRC staff finds that the different TS numbering changes are acceptable because they are editorial clarifications and do not substantively change TS requirements.
Finally, the NRC staff reviewed the proposed TS changes for technical clarity and consistency with the existing requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with Chapter 16.0 of the SRP and are therefore acceptable.
4.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Enclosure [x]
NOTICES AND ENVIRONMENTAL FINDINGS RELATED TO AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX XX]
AND AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX XX]
[NAME OF LICENSEE]
[NAME OF FACILITY]
DOCKET NOS. 50 [XXX] AND 50 [XXX]
Application (i.e., initial and supplements)
Safety Evaluation Date
[Date], [ADAMS Accession No.]
[Date]
1.0 INTRODUCTION
The PM should prepare this required section.
[Name of licensee] (the licensee) requested changes to the technical specifications (TSs) for
[name of facility] by license amendment request (LAR, application). In its application, the licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP). The proposed changes would revise the TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force (TSTF) Traveler TSTF-582, Revision 0, RPV WIC Enhancements, (henceforth TSTF-582) (ADAMS Accession No. ML19240A260) and the associated NRC staff safety evaluation (SE) of TSTF-582 (ADAMS Accession No. ML20219A333).
2.0 STATE CONSULTATION
The PM should prepare this required section.
In accordance with the Commission's regulations, the [Name of State] State official was notified of the proposed issuance of the amendment on [insert date]. The State official had [no]
comments. [If comments were provided, they should be addressed here].
3.0 ENVIRONMENTAL CONSIDERATION
The PM should prepare this required section.
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding [enter Federal Register citation (XX FR XXXX) and date].
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.