ML20311A664
| ML20311A664 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 12/21/2020 |
| From: | Victor Cusumano NRC/NRR/DSS/STSB |
| To: | Technical Specifications Task Force |
| Honcharik,M., NRR/DSS, 301-415-1774 | |
| Shared Package | |
| ML20353A074 | List: |
| References | |
| EPID L-2019-PMP-0181 | |
| Download: ML20311A664 (7) | |
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5 6 General Directions: This model SE provides the format for a safety evaluation (SE) of LARs to 7 adopt traveler TSTF-554 using the CLIIP. The bolded bracketed information shows text that 8 should be filled in for the specific amendment. The italicized wording provides guidance on 9 what should be included in each section.
10 DRAFT MODEL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO TSTF-554 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
- Ravinder Grover 11 12
1.0 PROPOSED CHANGE
S 13 14 [Name of licensee] (the licensee) requested changes to the technical specifications (TSs) for 15 [name of facility] by license amendment request (LAR, application). In its application, the 16 licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) 17 process the proposed amendment under the Consolidated Line Item Improvement Process 18 (CLIIP). The proposed changes would revise the TSs related to reactor coolant system (RCS) 19 operational leakage and the definition of the term LEAKAGE based on Technical 20 Specifications Task Force (TSTF) Traveler TSTF-554, Revision 1, Revise Reactor Coolant 21 Leakage Requirements, (TSTF-554) (Agencywide Documents Access and Management 22 System (ADAMS) Accession No. ML20016A233), and the associated NRC staff safety 23 evaluation (SE) of TSTF-554 (ADAMS Accession No. ML20322A024).
24 25 Components that contain or transport the coolant to or from the reactor core make up the RCS.
26 Materials can degrade as a result of the complex interaction of the materials, the stresses they 27 encounter, and through operational wear or mechanical deterioration during normal and upset 28 operating environments. Such material degradation could lead to leakage of reactor coolant 29 into containment buildings.
30 31 RCS leakage falls under two main categories - identified leakage and unidentified leakage.
32 Identifying the sources of leakage is necessary for prompt identification of potentially adverse Enclosure
1 conditions, assessment of safety significance of the leakage, and quick corrective action. A 2 limited amount of leakage from the reactor coolant pressure boundary (RCPB) directly into the 3 containment/drywell atmosphere is expected as the RCS and other connected systems cannot 4 be made 100 percent leak tight. This leakage is detected, located, and isolated from the 5 containment atmosphere so as to not interfere with measurement of unexpected RCS leakage 6 detection.
7 8 The safety significance of RCS leakage varies widely depending on its source, rate, and 9 duration. Therefore, detecting and monitoring RCS leakage into the containment area is 10 necessary. Separation of identified leakage from unidentified leakage provides quantitative 11 information to the operators, allowing them to take corrective action should leakage occur that is 12 detrimental to the safety of the unit and the public.
13 14 1.1 Proposed TS Changes to Adopt TSTF-554 15 16 In accordance with NRC staff-approved TSTF-554, the licensee proposed changes that would 17 revise the TSs related to RCS operational leakage and the definition of the term LEAKAGE.
18 Specifically, the licensee proposed the following changes to adopt TSTF-554:
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- The TS 1.1 identified LEAKAGE definition a.2 would be revised to remove the exclusion 21 of pressure boundary leakage from identified leakage by deleting either and the phrase 22 not to be pressure boundary LEAKAGE.
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- The TS 1.1 pressure boundary LEAKAGE definition [c] would be revised to delete the 24 word "nonisolable." The sentence, "LEAKAGE past seals, packing, and gaskets is not 25 pressure boundary LEAKAGE," would be relocated from the STS Bases and added to 26 the definition.
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- Additionally, the LEAKAGE definition would be revised by other editorial and punctuation 28 changes to reflect the deletion and listed definitions.
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- The ACTIONS section of STS [3.4.13] RCS Operational LEAKAGE, would be revised 30 to add a new Condition A to isolate the pressure boundary leakage within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
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- Existing Condition B would be revised to be applicable should any Action of 32 LCO [3.4.13] not be met by deleting of Condition A [or B].
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- Use this for plant TSs that are based upon the STS in NUREGs-1430, -1431, -1432, 34 or -2194: [Existing Conditions A and B would be renumbered as Conditions B and 35 C to reflect the new Condition A. The existing Condition B would be revised to 36 delete the condition for when pressure boundary leakage exists because pressure 37 boundary leakage would be addressed by the new Condition A. Finally, the 38 Required Actions associated with existing Conditions A and B would be 39 renumbered accordingly.]
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41 [Existing Conditions A, B, and C would be renumbered to reflect the new 42 Condition A. The existing Condition C would be revised to delete to the condition 43 for when pressure boundary leakage exists because pressure boundary leakage 44 would be addressed by the new Condition A. The Required Actions Associated 45 with existing Conditions A and B would be renumbered accordingly.]
46 1.2 Additional Proposed TS Changes 47 48 {NOTE: Use this section if variations are proposed. Add additional subsections if needed.
49 Editorial variations discussed below in Section 1.2.1 do not warrant removal from the CLIIP and 50 do not require any additional technical branches to be on the review.}
1 2 1.2.1 Editorial Variations 3
4 {NOTE: Use this section if the plant has different numbering/nomenclature or modify 5 accordingly for other editorial changes made.}
6 7 The licensee noted that [name of facility] TSs have different numbering [and nomenclature]
8 than standard technical specifications (STSs).
9 10
2.0 REGULATORY EVALUATION
11 12 The regulation at 10 CFR 50.36(c)(2) requires that TSs include limiting conditions for operation 13 (LCOs). Per 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance 14 levels of equipment required for safe operation of the facility. The regulation also requires that 15 when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow 16 any remedial action permitted by the TSs until the condition can be met. The regulation at 10 17 CFR 50.2 defines RCPB as all those pressure-containing components of boiling and 18 pressurized water-cooled nuclear power reactors, such as pressure vessels, piping, pumps, and 19 valves Regulatory Guide (RG) 1.45, Revision 1, Guidance on Monitoring and Responding 20 to Reactor Coolant System Leakage, dated May 2008 (ADAMS Accession No. ML073200271),
21 Section B, Discussion Leakage Separation, provides information related to separation 22 between identified and unidentified leakage.
23 24 The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of 25 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for 26 Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ADAMS 27 Accession No. ML100351425). As described therein, as part of the regulatory standardization 28 effort, the NRC staff has prepared STSs for each of the LWR nuclear designs. Accordingly, the 29 NRC staffs review includes consideration of whether the proposed changes are consistent with 30 the [insert applicable NUREG from list in footnote]1, as modified by NRC-approved travelers.
1 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Babcock and Wilcox Plants, NUREG 1430, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, dated April 2012 (ADAMS Accession Nos.
ML12100A177 and ML12100A178, respectively).
U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse Plants, NUREG 1431, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, dated April 2012 (ADAMS Accession Nos.
ML12100A222 and ML12100A228, respectively).
U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Combustion Engineering Plants, NUREG 1432, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, dated April 2012 (ADAMS Accession Nos.
ML12102A165 and ML12102A169, respectively).
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, dated 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, dated April 2012 (ADAMS Accession Nos.
ML12104A195 and ML12104A196, respectively).
U.S. Nuclear Regulatory Commission, "Standard Technical Specifications, Westinghouse Advanced Passive 1000 (AP1000) Plants," NUREG 2194, Volume 1 Specifications, and Volume 2, Bases, Revision 0, dated April 2016 (ADAMS Accession Nos. ML16110A277 and ML16110A369, respectively).
1 Traveler TSTF-554 revised the STSs related to RCS operational leakage and the definition of 2 the term LEAKAGE. The NRC approved TSTF-554, under the CLIIP on December 18, 2020 3 (ADAMS Package Accession No. ML20324A083).
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3.0 TECHNICAL EVALUATION
6 7 3.1 Proposed TS Changes to Adopt TSTF-554 8
9 The NRC staff compared the licensees proposed TS changes in Section 1.1 of this SE against 10 the changes approved in TSTF-554. In accordance with the SRP Chapter 16.0, the NRC staff 11 determined that the STS changes approved in TSTF-554 are applicable to [name of facility]
12 TSs because the [name of facility] is a [insert plant design] and the NRC staff approved the 13 TSTF-554 changes for [insert plant design] designs. The NRC finds that the licensees 14 proposed changes to the [name of facility] TSs in Section 1.1 of this SE are consistent with 15 those found acceptable in TSTF-554.
16 17 In the SE of TSTF-554, the NRC staff concluded that TSTF-554 changes to STS 1.1 definition 18 of LEAKAGE and to STS [3.4.13], the LCO addressing conditions and required actions when 19 reactor coolant system pressure boundary leakage exists, are acceptable. The NRC staff found 20 that removing the term nonisolable provides a clearer definition of pressure boundary leakage 21 and that the source of the leakage is not relevant to this capability provided that separate, 22 appropriate limits on pressure boundary leakage have been established. Therefore, the 23 proposed change to the definition of identified leakage was acceptable as it did not conflict with 24 10 CFR 50.2 and was consistent with RG 1.45. The NRC staff further found that proposed new 25 Condition A on boundary pressure leakage, including its associated Required Action A.1 and 26 Completion Time, acceptable because the LCO revisions continue to specify the lowest 27 functionable capability of equipment, identify remedial actions and require shutdown of the 28 reactor if the remedial actions cannot be met.
29 30 The NRC staff finds that proposed changes to the TS 1.1 definition clarify what constitutes 31 pressure boundary leakage and the source of leakage does not matter if the TSs have separate 32 limits on pressure boundary leakage and LCO [3.4.13] correctly specify the lowest functional 33 capability or performance levels of equipment required for safe operation of the facility. Also, 34 the NRC staff finds that proposed changes to the Actions of LCO [3.4.13] are adequate 35 remedial actions to be taken until each LCO can be met provide protection to the health and 36 safety of the public. Thus, the proposed changes continue to meet the requirements of 37 10 CFR 50.36(c)(2)(i) as discussed in Section 3.0 of the NRC staffs SE of TSTF-554.
38 39 3.2 Additional Proposed TS Changes 40 41 {NOTE: Use this section if variations are proposed. Add additional subsections if needed.}
42 43 3.2.1 Editorial 44 45 {NOTE: Use this section if the plant has different numbering/nomenclature or modify 46 accordingly for other editorial changes made.}
47 48 The licensee noted that [name of facility] TSs have different numbering [and nomenclature]
49 than STS. The NRC staff finds that the different TS numbering [and nomenclature] changes 50 are acceptable because they do not substantively alter TS requirements.
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1 Finally, the NRC staff reviewed the proposed TS changes for technical clarity and consistency 2 with the existing requirements for customary terminology and formatting. The NRC staff finds 3 that the proposed changes are consistent with Chapter 16.0 of the SRP and are therefore 4 acceptable.
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4.0 CONCLUSION
7 8 The Commission has concluded, based on the considerations discussed above, that: (1) there 9 is reasonable assurance that the health and safety of the public will not be endangered by 10 operation in the proposed manner, (2) there is reasonable assurance that such activities will be 11 conducted in compliance with the Commission's regulations, and (3) the issuance of the 12 amendment will not be inimical to the common defense and security or to the health and safety 13 of the public.
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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 RCS operational leakage and the definition of the term LEAKAGE based on Technical Specifications Task Force (TSTF)
Traveler TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements, (TSTF-554)
(Agencywide Documents Access and Management System (ADAMS) Accession No. ML20016A233), and the associated NRC staff safety evaluation (SE) of TSTF-554 (ADAMS Accession No. ML20322A024).
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. 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 Enclosure [x]
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.