Text

Draft TSTF-591, Revise Risk Informed Completion Time (RICT) Program
	ML21316A237
Person / Time
Site:	Technical Specifications Task Force
Issue date:	11/11/2021
From:	; Office of Nuclear Reactor Regulation, Technical Specifications Task Force
To:	;
	Honcharik M
References
	TSTF-591
	Download: ML21316A237 (41)
	v • d • e

DRAFT PWROG-12, Rev. 0 TSTF-591, Rev. 0 Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler Revise Risk Informed Completion Time (RICT) Program NUREGs Affected: 1430 1431 1432 1433 1434 2194 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement: Improvement NRC Fee Status: Not Exempt Benefit: Prevents Unnecessary Actions Changes Marked on ISTS Rev 5.0 PWROG RISD & PA (if applicable): PA-LSC-1922 See attached.

Revision History OG Revision 0 Revision Status: Active Revision Proposed by: TSTF Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 07-Oct-21 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 22-Oct-21 TSTF Review Information TSTF Received Date: 26-Oct-21 Date Distributed for Review 26-Oct-21 TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 11-Nov-21 NRC Review Information NRC Received Date: 11-Nov-21 Affected Technical Specifications 5.5.20 Risk Informed Completion Time Program NUREG(s)- 1430 1431 1432 Only 11-Nov-21 Copyright(C) 2021, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

DRAFT PWROG-12, Rev. 0 TSTF-591, Rev. 0 5.6.8 Risk Informed Completion Time (RICT) Program Upgrade NUREG(s)- 1430 1431 1432 Only Report 5.5.17 Risk Informed Completion Time Program NUREG(s)- 1433 1434 Only 5.6.6 Risk Informed Completion Time (RICT) Program Upgrade NUREG(s)- 1433 Only Report 5.6.7 Risk Informed Completion Time (RICT) Program Upgrade NUREG(s)- 1434 Only Report 11-Nov-21 Copyright(C) 2021, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

DRAFT TSTF-591, Rev. 0

1.

SUMMARY

DESCRIPTION The proposed change revises the Technical Specifications (TS) Section 5.5 Program, "Risk Informed Completion Time Program," to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of the use of newly developed probabilistic risk assessment (PRA) methods to calculate a Risk Informed Completion Time (RICT). The proposed change affects the Standard Technical Specifications (STS) in NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, and NUREG-14341.

2. DETAILED DESCRIPTION 2.1. Current Technical Specifications Requirements The Risk Informed Completion Time Program (RICT Program) was added by TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b,"

(Agencywide Documents Access and Management System (ADAMS) Accession No. ML18183A493), which was approved by the Nuclear Regulatory Commission (NRC) on November 21, 2018 (ADAMS Accession No. ML18269A041).

Paragraph e of the RICT Program, states:

The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2.

Methods to assess the risk from extending the Completion Times must be PRA methods used to support this license amendment, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

2.2. Reason for the Proposed Change Prior to the approval of TSTF-505, Revision 2, the NRC and the industry agreed that some terms used in Paragraph e of the RICT Program, such as, "approaches," "methods," and "approved by NRC for generic use," were not well defined. As a result, the TS requirements were unclear regarding when prior NRC approval would be needed in order to use a new or different method or approach. However, many licensees were anxious to submit license amendment requests (LARs) based on TSTF-505, Revision 2, and the industry and NRC agreed that the NRC should 1

NUREG-1430 provides the STS for Babcock & Wilcox plant designs.

NUREG-1431 provides the STS for Westinghouse plant designs.

NUREG-1432 provides the STS for Combustion Engineering plant designs.

NUREG-1433 provides the STS for BWR/4 plant designs, but is also representative of the BWR/2, BWR/3, and, in this case, BWR/5 design.

NUREG-1434 provides the STS for BWR/6 plant designs, and is representative, in some cases, of the BWR/5 plant design.

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DRAFT TSTF-591, Rev. 0 approve Revision 2 and the industry and NRC would continue to work on clarification of Paragraph e.

The industry and NRC held a series of public meetings and teleconferences in 2019, 2020, and 2021 discussing changes to Paragraph e. In late 2020, the NRC determined that the revised language should reference RG 1.200, Revision 3, which was under development. RG 1.200, Revision 3, was issued in December 2020. In January 2021 the industry proposed wording for Paragraph e that referenced RG 1.200, Revision 3.

In April 2021 the NRC proposed a different TS reference to RG 1.200, Revision 3. The industry responded in May 2021. A teleconference was held with the NRC on June 3, 2021, and the NRC suggested that the industry submit a TSTF traveler with the proposed revisions to the RICT Program and the associated reporting requirement in order to facilitate closure of the issue.

2.3. Description of the Proposed Change The RICT Program is Specification 5.5.20 in NUREG-1430, NUREG-1431, and NUREG-1432, Revision 5, and Specification 5.5.17 in NUREG-1433 and NUREG-1434, Revision 5.

Paragraph e of the RICT Program is replaced with the following:

e. A RICT must be calculated using the following PRA and non-PRA approaches approved by the NRC: [list specific PRA and non-PRA approaches used for fire and seismic analysis (e.g., Fire PRA and Seismic Margins Analysis)]. Changes to these PRA and non-PRA approaches require prior NRC approval.

New paragraphs f and g are added that state:

f. The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, "Acceptability of Probabilistic Risk Assessment Results for Risk- Informed Activities."

g. A report shall be submitted in accordance with Specification 5.6.[X] before a newly developed method is used to calculate a RICT.

A new reporting requirement is added to TS Section 5.6, "Reporting Requirements." The new report is Specification 5.6.8 in NUREG-1430, NUREG-1431, and NUREG-1432; Specification 5.6.6 in NUREG-1433; and Specification 5.6.7 in NUREG-1434. It states:

5.6.[8] Risk Informed Completion Time (RICT) Program Upgrade Report A report describing newly developed methods and their implementation must be submitted following a probabilistic risk assessment (PRA) upgrade associated with newly developed methods prior to using those methods to calculate a RICT. The report shall include:

a. The PRA models upgraded to include newly developed methods; Page 2

DRAFT TSTF-591, Rev. 0

b. A description of the acceptability of the newly developed methods consistent with Section 5.2 of PWROG-19027-NP, Revision 2, "Newly Developed Method Requirements and Peer Review;"

c. Any open findings from the peer-review of the implementation of the newly developed methods and how those findings were closed or demonstrated to not have a significant impact on the RICT calculation; and

d. All changes to key assumptions related to newly developed methods or their implementation.

Both the RICT Program and the RICT Program Upgrade Report are bracketed in the Standard Technical Specifications (STS), indicating that the specifications only apply to licensees that have adopted TSTF-505 by license amendment.

A model application is attached. The model may be used by licensees desiring to adopt the traveler following NRC approval.

3. TECHNICAL EVALUATION 3.1. Change From Referencing RG 1.200, Revision 2, To Revision 3 The primary change in this traveler is to replace a requirement to maintain and upgrade the PRA in accordance with RG 1.200, Revision 2, with a reference to RG 1.200, Revision 3.

RG 1.200, Revision 3, was issued in December 2020 and addresses new industry guidance and issues identified since Revision 2 was issued. Specifically, Revision 3:

Endorses, with staff exceptions and clarifications, the requirements in ASME/ANS RA-S Case 1, "Case for ASME/ANS RA-Sb-2013 Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment of Nuclear Power Plant Applications," dated November 22, 2017;

Endorses Nuclear Energy Institute (NEI) 17-07, Revision 2, "Performance of PRA Peer Reviews Using the ASME/ANS PRA Standard," issued August 2019;

Endorses the following portions of the Pressurized Water Reactor Owners Group (PWROG) report, PWROG-19027-NP, Revision 2, "Newly Developed Method Requirements and Peer Review," issued July 2020:

o Requirements for the peer review of newly developed methods; o Process for determining whether a change to a PRA is classified as PRA maintenance or a PRA upgrade; o Definitions related to newly developed methods, PRA maintenance, and PRA upgrade.

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DRAFT TSTF-591, Rev. 0

Enhances guidance related to key assumptions and sources of uncertainty;

Provides a glossary of key terms; and

Provides a list of hazards to be considered in the development and use of PRA.

A significant improvement in RG 1.200, Revision 3, is the inclusion of guidance that enables peer-reviewers to evaluate newly developed methods. NEI 17-07, Revision 2, discusses peer review of PRA upgrades that include newly develop methods.

These changes permit licensees to revise their PRA models used to calculate a RICT to incorporate most newly developed methods in accordance with the requirements of the ASME/ANS PRA Standard without prior NRC approval, while giving the NRC oversight capability. The documents endorsed in RG 1.200, Rev. 3, provide clear definitions of what constitutes a PRA method and what is a newly developed method (i.e., a method that has been developed separately from a state-of-practice method or that involves a fundamental change to a state-of-practice model). The proposed TS requirements ensure that changes to the PRA models used in the RICT program, including changes involving newly-developed methods, are properly evaluated. To provide the NRC with oversight, a required report will be submitted to the NRC when a newly developed method is used in the RICT Program.

3.2. RICT Program Changes The current RICT Program, Paragraph e, begins by stating, "The risk assessment approaches and methods shall be acceptable to the NRC." It also states, "Methods to assess the risk from extending the Completion Times must be PRA methods used to support this license amendment, and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval." These sentences are replaced because the phrases, "risk assessment approaches and methods," "this license amendment," and "outside these approval boundaries," are undefined or unclear when used within a plant's TS.

The proposed Paragraph e states, "A RICT must be calculated using the following PRA and non-PRA approaches approved by the NRC: [list specific PRA and non-PRA approaches used for fire and seismic analysis (e.g., Fire PRA and Seismic Margins Analysis)]. Changes to these PRA and non-PRA approaches require prior NRC approval." The proposed requirement clearly states the types of changes that require prior NRC approval. For example, if a licensee's TSTF-505 submittal described a Seismic Margins Analysis used to calculate a RICT and the licensee desires to use a seismic PRA, prior NRC approval is required. The proposed TS encompass the current Paragraph e requirements that the PRA approaches and methods must be acceptable to the NRC, that they must be those used to support the TSTF-505 license amendment, and that prior NRC approval is needed to change those approaches and methods.

The Paragraph e phrase, "other methods approved by the NRC for generic use" is deleted. There is no established regulatory process for the NRC to approve a PRA method for generic use.

The current RICT Program, Paragraph e, states, "The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified Page 4

DRAFT TSTF-591, Rev. 0 in Regulatory Guide 1.200, Revision 2." It is replaced a new Paragraph f which states, "The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3,

'Acceptability of Probabilistic Risk Assessment Results for Risk- Informed Activities'." The reference to the "as-built, as-operated, and maintained plant," is unnecessary because it is incorporated in RG 1.200, Revision 3. RG 1.200, Revision 3, Staff Regulatory Position C.1, states, "The base PRA serves as the foundational representation of the as-built and as-operated plant necessary to support an application." The term "maintained" does not appear in RG 1.200, Rev. 3, in this context and is not necessary because "maintained" is encompassed within "as-operated." The proposed change refers to the regulatory positions in RG. 1200, Revision 3.

RG 1.200, Revision 3, contains other information that does not convey the regulatory positions, which are only contained in Section C of the RG.

Separating the proposed Paragraph f from Paragraph e conveys meaning. The proposed Paragraph e describes when prior NRC approval is required. The proposed Paragraph f describes PRA model maintenance and upgrade in accordance with RG 1.200, Rev. 3, which does not typically require prior NRC approval.

As described in Section 3.1, Revision 3 of RG 1.200 discusses the use of newly developed methods. If a licensee uses a newly developed method in the RICT Program, a report is required to be submitted to the NRC. Paragraph g requires the report and references a new reporting requirement in Section 5.6, of the TS.

3.3. Addition of a TS Reporting Requirement The proposed change adds a new reporting requirement to Section 5.6 of the TS titled the, "Risk Informed Completion Time (RICT) Program Upgrade Report." The report is required to be submitted by the Section 5.5 RICT Program if a newly developed method is to be used. The details of the reporting requirement are in Section 5.6.

The proposed report must be submitted following a PRA upgrade associated with a newly developed method prior to using that method to calculate a RICT.

The proposed report must include:

The PRA models upgraded to include newly developed methods;

A description of the acceptability of the newly developed methods consistent with Section 5.2 of PWROG-19027-NP, Revision 2, "Newly Developed Method Requirements and Peer Review;"

Any open findings from the peer-review of the implementation of the newly developed methods and how those findings were closed or demonstrated to not have a significant impact on the RICT calculation; and

All changes to key assumptions related to newly developed methods or their implementation.

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DRAFT TSTF-591, Rev. 0 In accordance with Title 10 of the Code of Federal Regulations, Part 50.4, all reports from a licensee to the Nuclear Regulatory Commission must be sent to the Document Control Desk using the specified address.

3.4. Comparison to NRC-Proposed Wording In April 2021 the NRC provided proposed TS wording referencing RG 1.200, Revision 3, for industry comment. Attachment A provides a comparison of the NRC's proposal to the proposed traveler.

4. REGULATORY EVALUATION The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The Commission may include such additional technical specifications as the Commission finds appropriate.

Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate.

Section IV, "The Commission Policy," of the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58FR39132), dated July 22, 1993, states in part that improved STS have been developed and will be maintained for each NSSS owners group. The Commission Policy encourages licensees to use the improved STS as the basis for plant-specific Technical Specifications." The industry's proposal of travelers and the NRC's approval of travelers is the method used to maintain the improved STS as described in the Commission's Policy. Following NRC approval, licensees adopt travelers into their plant-specific technical specifications following the requirements of 10 CFR 50.90. Therefore, the traveler process facilitates the Commission's policy while satisfying the requirements of the applicable regulations.

The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls. The proposed traveler does not affect the Bases and, therefore, does not affect compliance with 10 CFR 50.36(a)(1).

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, Page 6

DRAFT TSTF-591, Rev. 0 (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

5. REFERENCES

1. TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b," July 2, 2018, NRC ADAMS Accession No. ML18183A493.

2. Final Revised Model Safety Evaluation of Traveler TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b," November 21, 2018, ADAMS Accession No. ML18269A041.

3. Regulatory Guide 1.200, Revision 3, "Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities," December 2020.

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DRAFT TSTF-591, Rev. 0 Model Application

DRAFT TSTF-591, Rev. 0

[DATE] 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOCKET NO.PLANT NAME

[50]-[xxx]

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-591, "Revise Risk Informed Completion Time (RICT)

Program" Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].

[LICENSEE] requests adoption of TSTF-591, "Revise Risk Informed Completion Time (RICT)

Program," which is an approved change to the Standard Technical Specifications (STS), into the

[PLANT NAME, UNIT NOS] TS. TSTF-591 revises the Technical Specifications (TS) Section 5.5 Program, "Risk Informed Completion Time Program," to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. Attachment 2 provides revised (clean) TS pages. The proposed change does not affect the TS Bases.

[LICENSEE] requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within [90] days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated [STATE] Official.

[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.

Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]

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DRAFT TSTF-591, Rev. 0 If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Enclosure:

Description and Assessment Attachments: 1. Proposed Technical Specification Changes (Mark-Up)

2. Revised Technical Specification Pages

[The attachments are to be provided by the licensee and are not included in the model application.]

cc: NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact Page 2

DRAFT TSTF-591, Rev. 0 ENCLOSURE DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

[LICENSEE] requests adoption of TSTF-591, "Revise Risk Informed Completion Time (RICT)

Program," which is an approved change to the Standard Technical Specifications (STS), into the

[PLANT NAME, UNIT NOS] TS. TSTF-591 revises the Technical Specifications (TS) Section 5.5 Program, "Risk Informed Completion Time Program," to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of the use of newly developed PRA methods to calculate a RICT.

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation

[LICENSEE] has reviewed the safety evaluation for TSTF-591 provided to the Technical Specifications Task Force in a letter dated [DATE]. This review included the NRC staffs evaluation, as well as the information provided in TSTF-591. [LICENSEE] has concluded that the justifications presented in TSTF-591 and the safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS.

2.2 Variations

[LICENSEE is not proposing any variations from the TS changes described in TSTF-591 or the applicable parts of the NRC staffs safety evaluation.] [LICENSEE is proposing the following variations from the TS changes described in TSTF-591 or the applicable parts of the NRC staffs safety evaluation:]

[The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-591 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-591 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-591 to the [PLANT] TS.]

[The [PLANT] TS contain requirements that differ from the STS on which TSTF-591 was based but are encompassed in the TSTF-591 justification. [Describe differences and why TSTF-591 is still applicable.]

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

[LICENSEE] requests adoption of TSTF-591, "Revise Risk Informed Completion Time (RICT)

Program," which is an approved change to the Standard Technical Specifications (STS), into the

[PLANT NAME, UNIT NOS] Technical Specifications (TS). TSTF-591 revises the Technical Page 3

DRAFT TSTF-591, Rev. 0 Specifications (TS) Section 5.5 Program, "Risk Informed Completion Time Program," to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of the use of newly developed probabilistic risk assessment (PRA) methods to calculate a RICT.

[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change changes the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed PRA method is used.

The proposed change does not involve a significant increase in the probability of an accident previously evaluated because the change involves no change to the plant or its modes of operation. The proposed change does not increase the consequences of an accident because the design-basis mitigation function of the affected systems is not changed and the consequences of an accident during the extended Risk Informed Completion Time are no different from those during the existing Completion Time. The submittal of information-only reports has no effect on the initiators or consequences of any accidents previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change changes the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed PRA method is used.

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

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

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DRAFT TSTF-591, Rev. 0

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

Response: No The proposed change changes the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed PRA method is used.

The proposed change supports the extension of Completion Times provided risk is assessed and managed in accordance with the NRC-approved RICT Program. The proposed change does not alter any design basis or safety limits. The proposed change affects the standard used to maintain the PRA models used in the RICT Program by changing from one NRC-approved standard to a later NRC-approved version and requiring submittal of an information-only report. The RICT Program will continue to assure that adequate margins of safety are maintained.

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

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

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions 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.

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

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DRAFT TSTF-591, Rev. 0 Appendix A Comparison of NRC April 2021 Proposed TS Wording to the Traveler Proposed Wording Page A-1

DRAFT TSTF-591, Rev. 0 NRC 4/20/21 Proposal TSTF-591 Proposal Discussion 5.5.X 5.5.X

e. A RICT must be calculated e. A RICT must be calculated

In the NRC proposal, there using [list specific using the following PRA is no explicit requirement approaches used (e.g., and non-PRA approaches for NRC prior approval. It's internal events probabilistic approved by the NRC: [list implied that a license risk assessment (PRA), fire specific PRA and non-PRA amendment is required if PRA, addition of bounding approaches used for fire the parenthetical TS seismic risk to RICT and seismic analysis (e.g., description is changed.

calculations, etc.)] based on Fire PRA and Seismic

In the NRC proposal, the the as-built, as-operated, Margins Analysis)]. internal events model must and as-maintained plant. Changes to these PRA and be described. It's not clear non-PRA approaches how that would be done.

require prior NRC

In the NRC proposal, the approval. first sentence states on how a RICT is calculated and also discusses maintenance (as-build, as-operated, as-maintained plant), which is confusing.

PRA models used to f. The PRA models used to

Reg Guide 1.200, Rev. 3, calculate a RICT shall be calculate a RICT shall be only has 4 regulatory maintained and upgraded in maintained and upgraded in positions (C.1 - C.4).

accordance with processes accordance with the Therefore, stating described in Regulatory processes endorsed in the Regulatory Positions C.1-Positions C.1, C.2, C.3, and regulatory positions of C.4 is unnecessary.

C.4 in Regulatory Guide Regulatory Guide 1.200, (RG) 1.200, Revision 3, Revision 3, "Acceptability "Acceptability of of Probabilistic Risk Probabilistic Risk Assessment Results for Assessment Results for Risk- Informed Activities."

Risk- Informed Activities."

f. Use of any newly

The details in the NRC's developed methods, as proposal Paragraph f defined in RG 1.200, duplicate requirements in Revision 3, must meet all RG 1.200, regulatory applicable review positions C.1 through C.4.

requirements in Tables 1- This is unnecessary and 7.2-2 through 1-7.2-7 of repetitive. As a result, there Pressurized-Water Reactor is no need to specifically Owners Group (PWROG)- discuss the review 19027-NP, Revision 2, requirements for newly "Newly Developed Method developed methods in the Page A-2

DRAFT TSTF-591, Rev. 0 NRC 4/20/21 Proposal TSTF-591 Proposal Discussion Requirements and Peer TS. The correspondence Review," in accordance between the NRC's with the process in NEI 17- Paragraph f and RG 1.200, 07, Revision 2, Rev. 3, is detailed below.

"Performance of PRA Peer

Regulatory Position Reviews Using the C.2.2.2.1 states that NEI ASME/ANS PRA 17-07, Rev. 2, is endorsed Standard." The peer review for peer review of a PRA report described in Section upgrade (which includes 9.1 of NEI 17-07, Revision newly developed methods).

2 for both the acceptability

Regulatory Position and implementation of the C.2.2.2.2 states "An newly developed method acceptable set of must be available to the requirements against which NRC for oversight and the adequacy of a newly inspection activities. developed method can be assessed is provided in PWROG-19027-NP, Revision 2."

PWROG-19027-NP, Revision 2, states, "The generic expectation is that newly developed methods satisfy the set of requirements discussed in this section," which includes Table 1-7.2-2 through 1-7.2-7.

Regulatory position C.2.2.2.2 recognizes that Section 5.2 of PWROG-19027-NP states that the peer review report must be publicly available.

g. A summary report g. A report shall be submitted

The term "summary" is describing the newly in accordance with confusing.

developed method and its Specification 5.6.[X] before

Revised to include the implementation must be a newly developed method restriction on use until after submitted in accordance is used to calculate a RICT. the report is submitted to with Section 5.6.x . avoid it being missed.

Page A-3

DRAFT TSTF-591, Rev. 0 NRC 4/20/21 Proposal TSTF-591 Proposal Discussion 5.6.X 5.6.X A summary report describing A report describing newly

The term "summary" is the newly developed method developed methods and their confusing.

and its implementation shall implementation must be

The first three paragraphs of be submitted to the NRC submitted following a the NRC proposal appear to following a PRA upgrade probabilistic risk assessment be redundant to each other unless it has already been (PRA) upgrade associated and to the proposed submitted to the NRC by a with newly developed paragraph "g".

licensee. methods prior to using those

A "newly developed methods to calculate a RICT. method" that has been A summary report shall also submitted by a licensee no be submitted if the licensee longer satisfies the uses an already submitted definition of a "newly newly developed method with developed method" and a exceptions, deviations, or report is not required. If a clarifications from the licensee takes an exception precedent. or deviation from the already submitted method, A summary report describing it is a "newly developed a newly developed method method." Therefore, it is and its implementation must not required to be stated in be submitted following a PRA the TS.

upgrade associated with a newly developed method prior

The proposed schedules for to using that method in the submitting a report, before RICT program or within 60 use in the RICT program or days after completing the within 60 days after the focused peer review, focused peer review, whichever date occurs sooner.

whichever is sooner, have The summary report shall different purposes (before describe the scope of the use of the method versus upgrade and shall include: The report shall include: submittal of a "for

a. The PRA models information" report). The

a. The PRA models upgraded upgraded, and the RICT program is not to include newly developed newly developed affected by a new method methods; method used; that is not used to calculate

b. A description of the

b. A description of the a RICT, so the report timing acceptability of the newly acceptability of the should be based on that developed methods newly developed purpose.

consistent with Section 5.2 method consistent with of PWROG-19027-NP, Section 5.2 of Revision 2, "Newly Page A-4

DRAFT TSTF-591, Rev. 0 NRC 4/20/21 Proposal TSTF-591 Proposal Discussion PWROG-19027-NP, Developed Method Revision 2, "Newly Requirements and Peer Developed Method Review;"

Requirements and Peer Review;"

c. All open finding c. Any open findings from the

Item c is revised to refer to and how those peer-review of the the impact on the RICT findings from the implementation of the calculation, not the PRA.

newly developed newly developed methods Only impacts on the RICT method and how those findings calculation are relevant to implementation were closed or the report.

and how those demonstrated to not have a findings were significant impact on the

Footnotes are not used in 1

resolved or RICT calculation; and the Administrative demonstrated not to Controls. Item c was have a significant changed from "resolved" to impact on the PRA; "closed" to address the issue and in the footnote.

d. All changes to key d. All changes to key assumptions related assumptions related to to the newly newly developed methods developed method or their implementation.

or its implementation.

Footnote 1: For PRA peer reviews, the terms "resolving a finding" and "closing a finding" have different meanings. A peer review finding may only be "closed" using a process endorsed by the NRC. All NDM related findings shall be "closed" prior to the use of that NDM in a RICT program.

Page A-5

DRAFT TSTF-591, Rev. 0 Technical Specifications Changes

No changes on this page. TSTF-591, Rev. 0 DRAFT Included for information only.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 Risk Informed Completion Time Program (continued)

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

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

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

c. When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

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

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

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

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

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

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

Babcock & Wilcox STS 5.5-24 Rev. 5.0

TSTF-591, Rev. 0 DRAFT Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 Risk Informed Completion Time Program (continued)

e. The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods used to support this license amendment, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval. ]

e. A RICT must be calculated using the following PRA and non-PRA approaches approved by the NRC: [list specific PRA and non-PRA approaches used for fire and seismic analysis (e.g., Fire PRA and Seismic Margins Analysis)]. Changes to these PRA and non-PRA approaches require prior NRC approval.

f. The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, "Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities."

g. A report shall be submitted in accordance with Specification 5.6.[X]

before a newly developed method is used to calculate a RICT. ]

[ 5.5.21 Spent Fuel Storage Rack Neutron Absorber Monitoring Program This Program provides controls for monitoring the condition of the neutron absorber used in the spent fuel pool storage racks to verify the Boron-10 areal density is consistent with the assumptions in the spent fuel pool criticality analysis. The program shall be in accordance with NEI 16-03-A, "Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools," Revision 0, May 2017 [, with the following exceptions:

1. . . . ].]

Babcock & Wilcox STS 5.5-25 Rev. 5.0

TSTF-591, Rev. 0 DRAFT Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.7 Steam Generator Tube Inspection Report (continued)

2. The location, orientation (if linear), measured size (if available), and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported;

3. A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment;

4. The number of tubes plugged [or repaired] during the inspection outage; and

[5. The repair methods utilized and the number of tubes repaired by each repair method.]

d. An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results;

e. The number and percentage of tubes plugged [or repaired] to date, and the effective plugging percentage in each SG;

f. The results of any SG secondary side inspections; and

[g. Insert any plant-specific reporting requirements, if applicable.]

5.6.8 Risk Informed Completion Time (RICT) Program Upgrade Report A report describing newly developed methods and their implementation must be submitted following a probabilistic risk assessment (PRA) upgrade associated with newly developed methods prior to using those methods to calculate a RICT. The report shall include:

a. The PRA models upgraded to include newly developed methods;

b. A description of the acceptability of the newly developed methods consistent with Section 5.2 of PWROG-19027-NP, Revision 2, "Newly Developed Method Requirements and Peer Review;"

c. Any open findings from the peer-review of the implementation of the newly developed methods and how those findings were closed or demonstrated to not have a significant impact on the RICT calculation; and Babcock & Wilcox STS 5.6-5 Rev. 5.0

TSTF-591, Rev. 0 DRAFT Reporting Requirements 5.6

d. All changes to key assumptions related to newly developed methods or their implementation.

Babcock & Wilcox STS 5.6-6 Rev. 5.0

No changes on this page. TSTF-591, Rev. 0 DRAFT Included for information only.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 Risk Informed Completion Time Program (continued)

a. The RICT may not exceed 30 days;