ML23012A284
| ML23012A284 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 03/13/2023 |
| From: | Victor Cusumano NRC/NRR/DSS/STSB |
| To: | Technical Specifications Task Force |
| Shared Package | |
| ML23012A280 | List: |
| References | |
| EPID L-2022-PMP-0002 | |
| Download: ML23012A284 (8) | |
Text
Enclosure 2 1
2 3
4 5
General Directions: This model SE provides the format for an SE of LARs to adopt traveler 6
TSTF-584. TSTF-584 was approved as part of the CLIIP. This model SE can also be used as a 7
template for LARs adopting TSTF-584 that have significant variations and are not using the 8
CLIIP. The [bolded bracketed] information shows text that should be filled in for the specific 9
amendment. The italicized wording provides guidance on what should be included in each 10 section.
11 12 DRAFT MODEL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO TSTF-584, ELIMINATE AUTOMATIC RWCU SYSTEM ISOLATION ON SLC SYSTEM INITIATION 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]
13
1.0 PROPOSED CHANGE
S 14 15
[Name of licensee] (the licensee) requested changes to the technical specifications (TSs) for 16
[name of facility] by license amendment request (LAR, application). In its application, the 17 licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) 18 process the proposed amendment under the Consolidated Line Item Improvement Process 19 (CLIIP). The proposed changes would revise the primary containment isolation instrumentation 20 TS based on Technical Specifications Task Force (TSTF) Traveler TSTF-584, Revision 0, 21 Eliminate Automatic RWCU [reactor water cleanup] System Isolation on SLC [standby liquid 22 control] Initiation (TSTF-584) (Agencywide Documents Access and Management System 23 (ADAMS) Accession No. ML22054A292), and the associated NRC staff safety evaluation (SE) 24 of TSTF-584 ([accession number only to be inserted when final SE is issued]).
25 26 TS 3.3.6.1, "Primary Containment Isolation Instrumentation," would be revised to remove the 27 requirement that the RWCU system automatically isolate on manual initiation of the SLC 28 system. The SLC system is manually actuated in response to an anticipated transient without 29 scram (ATWS) event.
30 31 Reactor Water Cleanup System 1
2 The following automatic signals to the RWCU system supply and/or return isolation valves 3
indicate that the RWCU piping or components have been breached:
4 5
Low reactor vessel water level; 6
RWCU system high differential flow; 7
Main steam tunnel penetration area temperature high; and 8
RWCU heat exchanger/pump/filter demineralizer unit area high temperature.
9 10 The TSs require the above functions to be operable. The automatic closure of the supply and/or 11 return isolation valves, coupled with the dual check valves in each RWCU system return line 12 isolates the RWCU system from the reactor coolant pressure boundary.
13 The automatic signal for RWCU system isolation on SLC system initiation that is proposed to be 14 removed is not used to indicate any breach of RWCU piping or components.
15 16 Standby Liquid Control System 17 18 During an ATWS event, the SLC system would bring the reactor from full power to a subcritical 19 condition without crediting the control rods. The SLC system injects a quantity of borated water 20 into the reactor core that adds negative reactivity sufficient to compensate for all of the various 21 positive reactivity effects that could occur during shutdown. {NOTE: Insert the following if 22 applicable:} [In addition to its use for ATWS mitigation, [name of facility] credits manual 23 actuation of the SLC system following a loss of coolant accident (LOCA) to control 24 primary containment acidity.]
25 26 1.1 Proposed TS Changes to Adopt TSTF-584 27 28 In accordance with the NRC staff-approved TSTF-584 under the CLIIP on [date and accession 29 number to be inserted with final SE is issued], the licensee proposed changes that would 30 revise TS 3.3.6.1, "Primary Containment Isolation Instrumentation for [name of facility].
31 Specifically, the licensee proposed the following changes to adopt TSTF-584:
32 33
{NOTE: If the plant TSs are based on NUREG-1433, use this option:}
34 35 Technical Change:
36 37 Table 3.3.6.1-1, Function 5.d, "Reactor Water Cleanup (RWCU) System Isolation - SLC 38 System Initiation," is deleted.
39 40 Editorial changes needed for consistency:
41 42 Table 3.3.6.1-1, Function 5.e, "Reactor Vessel Water Level - Low Low, Level 2," is 43 renumbered as Function 5.d.
44 Table 3.3.6.1-1, Function 5.f, "Manual Initiation," is renumbered as Function 5.e.
45 Table 3.3.6.1-1, Footnote (b), if present, is only referenced from Function 5.d, and is 46 deleted.
47 Table 3.3.6.1-1, Function 6.b, reference to Action J is revised to reference Action I.
48 TS 3.3.6.1, Action I, which is only referenced in Function 5.d, is deleted.
49 TS 3.3.6.1, Action J is renumbered as Action I.
1 2
{NOTE: If the plant TS are based on NUREG-1434 use this option:}
3 4
Technical Change:
5 6
Table 3.3.6.1-1, Function 4.l, "Reactor Water Cleanup (RWCU) System Isolation - Standby 7
Liquid Control System Initiation," is deleted.
8 9
Editorial changes needed for consistency:
10 11 Table 3.3.6.1-1, Function 4.m, "Manual Initiation," is renumbered as Function 4.l.
12 Table 3.3.6.1-1, Function 5.c, reference to Action J is revised to reference Action I.
13 TS 3.3.6.1, Action I, which is only referenced in Function 4.l, is deleted.
14 TS 3.3.6.1, Action J, is renumbered Action I.
15 TS 3.3.6.1, Action K, is renumbered Action J.
16 17 1.2 Additional Proposed TS Changes 18 19
{NOTE: Use this section if variations are proposed. Add additional subsections if needed.
20 Editorial variations discussed below in section 1.2.1 do not warrant removal from the CLIIP and 21 do not require any additional technical branches to be on the review. Variations discussed in 22 section 1.2.2, may remove the LAR from the CLIIP and may require additional technical review 23 depending on the significance of the variations.}
24 25 In addition to the changes proposed consistent with the traveler discussed in section 1.1, the 26 licensee proposed the variation[s] below.
27 28 1.2.1 Editorial Variations 29 30
{NOTE: Use this section if the plant has different numbering/nomenclature or modify accordingly 31 for other editorial changes made.}
32 33 The licensee noted that [name of facility] TSs have different numbering [and nomenclature]
34 than standard technical specifications (STSs).
35 36 1.2.2 Other Variations 37 38
{NOTE: Use this section if the plant has variations other than editorial variations discussed in 39 section 1.2.1.}
40 41
2.0 REGULATORY EVALUATION
42 43 The categories of items required to be in the TSs are listed in Title 10 of the Code of Federal 44 Regulations (10 CFR) 50.36(c). The regulation at 10 CFR 50.36(c)(2) requires that TSs include 45 limiting conditions for operations (LCOs). Per 10 CFR 50.36(c)(2)(i), LCOs are the lowest 46 functional capability or performance levels of equipment required for safe operation of the 47 facility. The regulation also requires that when an LCO of a nuclear reactor is not met, the 48 licensee shall shut down the reactor or follow any remedial action permitted by the TS until the 49 condition can be met.
50 1
The regulation at 10 CFR 50.62(b) defines an ATWS as an anticipated operational occurrence 2
as defined in appendix A of this part followed by the failure of the reactor trip portion of the 3
protection system specified in General Design Criterion 20 of appendix A of this part.
4 10 CFR Part 50 Appendix A, applicable General Design Criteria (GDCs) are as follows:
5 GDC 20 - Protection system functions. The protection system shall be designed (1) to 6
initiate automatically the operation of appropriate systems including the reactivity control 7
systems, to assure that specified acceptable fuel design limits are not exceeded as a 8
result of anticipated operational occurrences and (2) to sense accident conditions and to 9
initiate the operation of systems and components important to safety.
10 GDC 26 - Reactivity control system redundancy and capability. Two independent 11 reactivity control systems of different design principles shall be provided. One of the 12 systems shall use control rods, preferably including a positive means for inserting the 13 rods, and shall be capable of reliably controlling reactivity changes to assure that under 14 conditions of normal operation, including anticipated operational occurrences, and with 15 appropriate margin for malfunctions such as stuck rods, specified acceptable fuel design 16 limits are not exceeded. The second reactivity control system shall be capable of reliably 17 controlling the rate of reactivity changes resulting from planned, normal power changes 18 (including xenon burnout) to assure acceptable fuel design limits are not exceeded. One 19 of the systems shall be capable of holding the reactor core subcritical under cold 20 conditions.
21 The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of 22 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for 23 Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ML100351425).
24 As described therein, the NRC staff has prepared STSs for each of the LWR nuclear designs.
25 Accordingly, the NRC staffs review includes consideration of whether the proposed changes 26 are consistent with the [insert applicable NUREG from list in footnote]1, as modified by 27 NRC-approved travelers. The NRC staff-approved TSTF-584, under the CLIIP on [date and 28 accession number to be inserted when final SE is issued].
29 30
3.0 TECHNICAL EVALUATION
31 32 3.1 Proposed TS Changes to Adopt TSTF-584 33 34 The NRC staff compared the licensees proposed TS changes in section 1.1 of this SE against 35 the changes approved in TSTF-584. In accordance with the SRP chapter 16.0, the NRC staff 36 determined that the STS changes approved in TSTF-584 are applicable because [name of 37 facility] is a boiling-water reactor (BWR) design plant and the NRC staff approved the 38 TSTF-584 changes for BWR designs. The NRC staff finds that the licensees proposed changes 39 1 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric Plants, BWR/4, NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, Revision 5.0, September 2021 (ML21272A357 and ML21272A358, respectively).
U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric Plants, BWR/6, NUREG-1434, Volume 1, Specifications, and Volume 2, Bases,, Revision 5.0, September 2021 (ML21271A582 and ML21271A596, respectively).
to the [name of facility] TSs in section 1.1 of this SE are consistent with those found 1
acceptable in TSTF-584.
2 3
In the NRC SE of TSTF-584, the NRC staff concluded that the proposal to eliminate automatic 4
isolation of the RWCU system on the initiation of the SLC system by deleting table 3.3.6.1-1, 5
Function [5.d OR 4.l] is acceptable because the specified acceptable fuel design limits will not 6
be affected during an ATWS event. Therefore, 10 CFR 50.62(b) will continue to be met.
7 Additionally, 10 CFR 50.36(c)(2)(i) will continue to be met because TS 3.3.6.1 continues to 8
provide remedial actions and shuts down the reactor if the remedial actions cannot be met.
9 Thus, the proposed changes continue to meet the requirements of 10 CFR 50.62(b) and 10 10 CFR 50.36(c)(2)(i) as discussed in section 3.0 of the NRC staffs SE of TSTF-584.
11 12 3.2 Additional Proposed TS Changes 13 14
{NOTE: Use this section if variations are proposed. Add additional subsections if needed.
15 Variations evaluated in section 3.2.2 may remove the LAR from the CLIIP and may require 16 additional technical review depending on the significance of the variations. Additionally, the 17 variations may require additional regulations/guidance being included in the Regulatory 18 Evaluation Section.}
19 20 3.2.1 Editorial Variations 21 22
{NOTE: Use this section if the plant has different numbering/nomenclature or modify accordingly 23 for other editorial changes made.}
24 25 The licensee proposed renumbering and deletion of Functions and Actions in TS 3.3.6.1, which 26 are described above in section 2.2. These changes are acceptable because they are 27 conforming changes resulting from the deletion of table 3.3.6.1-1, Function [5.d OR 4.l], and do 28 not alter the way the TSs are implemented. Furthermore, the NRC staff finds this change is 29 acceptable since it is editorial and provides the correct numbering sequence.
30 31 The licensee noted that [name of facility] TSs have different numbering [and nomenclature]
32 than STS. The NRC staff finds that the different TS numbering [and nomenclature] changes 33 are acceptable because they do not substantively alter TS requirements.
34 35 3.2.2 Other Variations 36 37
{NOTE: Use this section if the plant has variations other than editorial changes discussed in 38 section 3.2.1.}
39 40 3.3 TS Change Consistency 41 42 The NRC staff reviewed the proposed TS changes for technical clarity and consistency with the 43 existing requirements for customary terminology and formatting. The NRC staff finds that the 44 proposed changes are consistent with chapter 16.0 of the SRP and are therefore acceptable.
45 46
4.0 CONCLUSION
47 48 The Commission has concluded, based on the considerations discussed above, that: (1) there 49 is reasonable assurance that the health and safety of the public will not be endangered by 50 operation in the proposed manner, (2) there is reasonable assurance that such activities will be 51 conducted in compliance with the Commission's regulations, and (3) the issuance of the 1
amendment will not be inimical to the common defense and security or to the health and safety 2
of the public.
3 4
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
{NOTE: The PM should prepare this 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 primary containment isolation instrumentation TS based on Technical Specifications Task Force (TSTF) Traveler TSTF-584, Revision 0, Eliminate Automatic RWCU [reactor water cleanup] System Isolation on SLC [standby liquid control] Initiation (TSTF-584) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22054A292), and the associated NRC staff safety evaluation (SE) of TSTF-584 ([ADAMS accession no. only to be inserted when final SE is issued]).
2.0 STATE CONSULTATION
{NOTE: The PM should prepare this 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 and modify language of section 3.0 below per SE Template for Power Reactors].
3.0 ENVIRONMENTAL CONSIDERATION
{NOTE: 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 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 amendment.