ML22075A172

NRC Staff High Level Comments Rev 1 of Draft Traveler TSTF-585, Provide an Alternative to the LCO 3.0.3 One-Hour Preparation Time

ML22075A172
Person / Time
Site:	Technical Specifications Task Force
Issue date:	03/31/2022
From:	NRC/NRR/DSS/STSB
To:
Honcharik M
References
Download: ML22075A172 (1)

Text

NRC Staff High Level Comments Revision 1 of Draft Traveler TSTF-585, Provide an Alternative to the LCO [Limiting Condition for Operation] 3.0.3 One-Hour Preparation Time March 2022 Without a clear understanding of the specific details of processes, tools, guidance, requirements, and timing to perform the risk assessment and mitigative measures, the NRC staff may be unable to accept or approve Revision 1 of draft traveler TSTF-585, Provide an Alternative to the LCO 3.0.3 One-Hour Preparation Time (Agencywide Documents Access and Management System Accession No. ML21337A109).

Overarching programmatic issues:

• Describe how the requirements for implementation of the proposal (some specifics of which are questioned below) will be documented in each plants licensing basis and controlled by each licensee. The NRC staff strongly believes that a TS program in Section 5 may be appropriate for this.

• The TSTF stated that NUMARC 93-01 will be used as guidance for performing the risk assessment. NUMARC 93-01 was not developed for such a purpose. Describe how the guidance contained in NUMARC 93-01 is appropriate for this purpose.

Specific issues:

• Define no net increase in risk and explain how it will be calculated. Please explain where quantitative and qualitative analyses would be appropriate and why.

• Define the methodology for calculating the risk improvement associated with mitigative measures including how the change in risk is determined.

• Provide the qualification requirements for personnel and tools used to perform the risk analysis.

• Describe how the risk analysis will be documented and monitored through the extended period.

• Describe the timing required for the risk analysis and risk management actions including whether LCO 3.0.3.b can be entered after LCO 3.0.3.a is entered for a given condition. If LCO 3.0.3.b can be entered after LCO 3.0.3.a, can power be increased before exiting LCO 3.0.3?

• Describe the basis for the determination that one hour is a reasonable time to prepare for an orderly shutdown, perform maintenance activities to determine the cause of the failure that resulted in the LCO 3.0.3 entry or perform repairs to allow exit of LCO 3.0.3, perform a risk assessment, complete mitigative measures, and take other actions that may be required to ensure plant safety. Consideration of human factors is important.

• State the licensees staff positions responsible for each aspect of the tasks required.

• Describe how extent of condition will be determined.

• Describe how the risk assessment will differ if extent of condition is not determined.

Exclusions:

• Consider a list of requirements that cannot be changed without prior NRC approval. There are some conditions for which it may not be appropriate to consider extended shutdown time if LCO 3.0.3 is entered. The NRC staff has not finalized criteria yet nor have specific LCOs been identified for inclusion or exclusion.

Additionally, the TSTF has not addressed other specific issues that the staff previously identified.