ML23292A351

Request for Additional Information Traveler Tstf-596, Rev 0, Expand the Applicability of the Surveillance Frequency Control Program

ML23292A351
Person / Time
Site:	Technical Specifications Task Force
Issue date:	10/19/2023
From:	Michelle Honcharik Office of Nuclear Reactor Regulation
To:	Technical Specifications Task Force
References
EPID L-2023-PMP-0002
Download: ML23292A351 (10)

Text

October 19, 2023 Technical Specifications Task Force 11921 Rockville Pike, Suite 100 Rockville, MD 20852

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RE: TRAVELER TSTF-596, REVISION 0, "EXPAND THE APPLICABILITY OF THE SURVEILLANCE FREQUENCY CONTROL PROGRAM" (EPID: L-2023-PMP-0002)

Dear Members of the Technical Specifications Task Force:

By letter dated May 12, 2023 (Agencywide Documents Access and Management System (Accession No. ML23132A139), you submitted a request to the U.S. Nuclear Regulatory Commission (NRC) to incorporate Traveler Technical Specifications Task Force-596, Revision 0, "Expand the Applicability of the Surveillance Frequency Control Program (SFCP),

into the standard technical specifications.

Upon review of the information provided, the NRC staff has determined that additional information is needed to complete the review. Mr. Brian Mann, Vice President of Industry Programs, EXCEL Services Corporation, agreed that the NRC staff will receive your response to the enclosed request for additional information questions within 90 calendar days of the date of this letter.

The review schedule that was provided in the acceptance letter dated August 10, 2023 (ADAMS ML23205A214), has not changed.

MILESTONE SCHEDULE DATE Issue Draft Safety Evaluation July 5, 2024 Issue Final Safety Evaluation November 4, 2024 If you have any questions, please contact me at (301) 415-1774 or via email to Michelle.Honcharik@nrc.gov.

Sincerely,

/RA/

Michelle C. Honcharik, Senior Project Manager Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation Project No. 753 cc: See next page cc:

Technical Specifications Task Force c/o EXCEL Services Corporation 11921 Rockville Pike, Suite 100 Rockville, MD 20852 Attention: Brian D. Mann Email: brian.mann@excelservices.com Drew Richards STP Nuclear Operating Company 12090 FM 521 Mail Code: N5016 Wadsworth, TX 77483 Email: amrichards@stpegs.com Kevin Lueshen Constellation Energy Generation 4300 Winfield Road Warrenville IL 60555 Email: kevin.lueshen@constellation.com Jordan L. Vaughan Duke Energy EC07C / P.O. Box 1006 Charlotte, NC 28202 Email: jordan.vaughan@duke-energy.com Phil H. Lashley Energy Harbor 168 E. Market St.

Akron, OH 44308 Email: phlashley@energyharbor.com Wesley Sparkman Southern Nuclear Operating Company 3535 Colonnade Parkway / Bin N-226-EC Birmingham, AL 35242 Email: wasparkm@southernco.com

• via email NRR-106 OFFICE NRR/DSS/STSB NRR/DSS/STSB: ABC NAME MHoncharik MJardaneh DATE 10/19/2023 9/18/2023

REQUEST FOR ADDITIONAL INFORMATION TECHNICAL SPECIFICATIONS TASK FORCE TSTF-596, REVISION 0, EXPAND THE APPLICABILITY OF THE SURVEILLANCE FREQUENCY CONTROL PROGRAM (SFCP)

(EPID L-2023-PMP-0002)

On May 12, 2023, the Technical Specifications Task Force (TSTF) submitted TSTF-596, Revision 0, Expand the Applicability of the Surveillance Frequency Control Program (SFCP),

(ADAMS Accession No. ML23132A139) for review by the U.S. Nuclear Regulatory Commission (NRC) staff.

The TSTF states that TSTF-596 proposes to expand the applicability of the SFCP at nuclear power plants to include other periodic testing frequencies in Technical Specifications (TS)

Section 5.5, Programs and Manuals. The TSTF indicates that the proposed change also revises the SFCP to encompass additional regulatory mechanisms that may be used to control surveillance frequencies, such as Title 10 of the Code of Federal Regulations (10 CFR),

Section 50.55a, Codes and standards, and 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors. The proposed change revises Surveillance Requirements (SRs) that reference the Inservice Testing (IST)

Program to instead reference the SFCP. The proposed change affects the Standard Technical Specifications (STS) in NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, and NUREG-1434.

The STSB staff has the following questions/comments about the technical and regulatory basis for the changes proposed in TSTF-596:

1)

Section 3.2 provides the technical basis for allowing the movement of Inservice Testing Program (IST) surveillance frequencies to the SFCP. In part, the justification relies on the NEI 04-10 process. However, NEI 04-10 assumes that any surveillance frequency included in the SFCP is eligible to have its frequency revised in accordance with the NEI 04-10 process. It does not include a step to identify which frequencies are eligible and none of the steps in the process require identification prohibitive regulatory requirements. NEI 04-10 was not previously relied on to do this, because the identification of ineligible surveillances was originally made in the TS themselves.

Accordingly, since TSTF-596 adds surveillances to the SFCP that are ineligible for the NEI 04-10 process, care must be taken to ensure that frequencies that are not eligible are clearly identified so that they do not get inadvertently entered into the NEI 04-10 process. Section 3.2, Movement of Inservice Testing Program Based Frequencies to the SFCP, states:

The reviews performed under the SFCP following NEI 04-10 will identify that the Frequency is based on a regulatory requirement.

NEI 04-10, Step 7, "Identify Qualitative Considerations to be Addressed,"

discusses test intervals specified in applicable industry codes and standards and requires any deviations from Frequencies specified in applicable industry codes and standards currently committed to in the plant licensing basis be considered. Before changing the Frequency, the appropriate change process must be followed. [Emphasis added]

Step 7 of NEI 04-10 is inadequate as a guard against applying the NEI 04-10 process to IST required surveillances because it generally applies to a variety of considerations and only addresses applicable industry codes to which the licensee has committed (and therefore can be changed via Step 2 of the NEI 04-10 process). There is no mention of consideration of prohibitive regulatory requirements in Step 7 or any step in the NEI 04-10 process. Step 7 provides no guidance on codes and standards required by regulation, and it allows the frequency required by a commitment to a code or standard to be changed.

Similarly, Section 3.2 also discusses the licensees list of controlled frequencies as part of its technical basis. Specifically, Section 3.2 states:

The revised Frequency is documented in the SFCP. The SFCP must contain a list of the frequencies controlled by the program, including tests that implement the requirements of 10 CFR 50.55a(f). Where appropriate, those entries in the list can consist of a reference to the licensee's program that implements 10 CFR 50.55a(f). [Emphasis added]

It is unclear as to why it would be optional for the licensee to identify surveillances that must be performed in accordance with 10 CFR 50.55a(f) in the list of controlled frequencies. Accordingly, based on the above, please revise this discussion in Section 3.2 to address the following:

a) Revise the discussion on the list of controlled surveillances to require that the list identify those surveillances/frequencies that are required by 10 CFR 50.55a(f).

b) Clarify that Bases statements must clearly identify frequencies that are subject to 10 CFR 50.55a(f) that would be controlled in accordance with TS 5.5.19.b.1 (for pressurized water reactors (PWRs)) or TS 5.5.16.a.1 (for BWRs), as applicable.

The list of controlled frequencies and the appropriate Bases statements are necessary to provide an adequate technical basis for allowing IST frequencies to be added to the SFCP. NEI 04-10 by itself is insufficient (although the staff recognizes that Step 7 of the 04-10 process could provide a backup the Tech Spec Bases and the list of controlled frequencies).

2)

The traveler moves all references to a test being conducted in accordance with the IST to the Bases. Accordingly, the technical basis in Section 3.2 should discuss what controls exist that make this acceptable. Specifically, this is acceptable because the Bases are incorporated by reference into the final safety analysis report (FSAR), and therefore, any changes to the Bases would be subject to 10 CFR 50.59.

3)

Section 3.3 describes the technical basis for the allowance for alternative treatment under 10 CFR 50.69. Since the alternative treatment can only be applied to TS SSCs that have been categorized as Risk-Informed Safety Class (RISC) RISC-3, why isnt the 10 CFR 50.69 allowance proposed for inclusion in the SFCP stated as applying only to RISC-3 SSCs similar to what was approved for Limerick?

4)

Section 3.7 of the traveler states, In addition, other TS Bases reference the IST Program. Those references were reviewed and removed if not needed, or revised to refer to 10 CFR 50.55a(f) to be consistent with the changes to the SFCP. However, these deleted references typically provide clarity to the Bases. For example, NUREG-1430, Volume 2, SRs 3.5.2.5 and 3.5.2.6 states that The actuation logic is tested as part of the engineered safety features actuation systems (ESFAS) testing, and equipment performance is monitored as part of the INSERVICE TESTING PROGRAM.

The traveler proposes to delete the second half of the sentence and retain the first half.

However, the sentence provides more clarity as a whole than it does with the second part deleted. It would be clearer if the reference to the IST Program were simply replaced with a reference to the regulation as is done throughout the traveler. What was the basis for removing clarifying statements that reference the IST Program and not replacing them with a reference to 10 CFR 50.55a(f)?

5)

Section 3.5 of the traveler states:

The requirements of the American Society of Mechanical Engineers (ASME) Code are applicable whether or not the IST Program is referenced in the body of the Surveillance, and a reference to the IST Program in the Surveillance does not impose or relieve any requirements, except as discussed regarding 10 CFR 50.69, below.

This statement is true as far as the IST Program goes, but for inservice tests that are also required as TS surveillances, the NRC staff believes this statement needs clarification. Referencing the IST test in the TS incorporates the IST requirement into TS as a surveillance requirement, which means the TS usage rules apply (e.g., failure to meet the surveillance is failure to meet the limiting condition for operation (LCO)). Not all IST tests are surveillances. The traveler should make it clear that the proposed changes for removing the in accordance with the INSERVICE TESTING PROGRAM from the surveillance and relying on a Bases statement does not change that the required inservice test is a TS surveillance requirement. In addition, the surveillance must still be performed in accordance with the IST Program as stated in the Bases. This includes requirements for conducting the test, such as those contained in the ASME Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code:

Section IST (ASME OM Code), Mandatory Appendix I, Inservice Testing of Pressure Relief Devices in Water-Cooled Reactor Nuclear Power Plants, Section I-4000, Test Methods. Section 3.5 in TSTF-596 states: Replacing the phrase "in accordance with the INSERVICE TESTING PROGRAM, with the specific acceptance criteria does not change the testing requirement. This is only true if the test is still conducted in accordance with the IST Program. Please clarify the discussion in Section 3.5 accordingly.

6)

The Regulatory Evaluation Section should discuss 10 CFR 50.36(c)(3) because the subject of the traveler involves SRs.

7)

The Traveler deletes surveillance frequencies that are specified as in accordance with the INSERVICE TEST PROGRAM and replaces it with In accordance with the Surveillance Frequency Control Program. A new line is added to the Bases of each affected specification stating that the Surveillance frequency is based on the requirements of 10 CFR 50.55a(f) and is controlled under the Surveillance Frequency Control Program. [Emphasis added]. In some cases, other language is used. For example, in NUREG-1433, Volume 2, SRs 3.5.1.7 and 3.5.1.8, the Bases are marked up to state that the surveillance frequency is consistent with 10 CFR 50.55a(f).

Accordingly, the NRC staff has the following comments:

a. Is based on implies a flexibility for IST surveillances that is not provided in the SFCP. It is also inconsistent with the requirement that is stated in the current TS SRs. Since this traveler is not intended to make any changes to IST related SRs in TS, please revise the Bases language to state in accordance with the requirements of 10 CFR 50.55a(f) or provide the technical basis for stating that it is based on the requirements of 10 CFR 50.55a(f). In general, if the surveillance frequency was originally in accordance with the INSERVICE TESTING PROGRAM in the technical specification surveillance, it should remain in accordance with the regulatory requirement when it is described in the Bases. It should not be changed to based on or consistent with.

b. The traveler allows the relocation of IST surveillance frequencies to the SFCP, but it does not place them under licensee control. If a component is classified as RISC-3 by the licensee that has received a license amendment to implement 10 CFR 50.69, the NRC regulations specify treatment requirements in 10 CFR 50.69(d) including testing and inspection for that component. In that situation, the TS surveillance requirement would continue to apply, but the licensee can determine a test interval that provides reasonable confidence that the component will continue to be capable of performing its safety function in accordance with 10 CFR 50.69. Since the changes proposed by the traveler do not give licensees control over IST testing frequencies, and to avoid confusion, the Bases should specifically reference that the surveillance frequencies are controlled in accordance with TS 5.5.19.b.1 of the SFCP (for PWRs) or TS 5.5.16.a.1 of the SFCP (for BWRs), as applicable.

8)

Some Bases state that the SR is required by or performed in accordance with the ASME Code (NUREG-1430, SR3.5.2.4), and the surveillance frequencies are stated as being based on 10 CFR 50.55a(f). The difference in language (i.e., ASME Code versus 10 CFR 50.55a(f)) implies they are two different requirements when they are not. Please standardize the language to refer to the regulation or provide the basis for citing the requirements differently. Additional examples include:

a.

For NUREGs-1430 through -1432, Volume 2, LCO 3.7.1, the traveler proposes to revise the Bases for the LCO to state that The OPERABILITY of the main steam stop valve (MSSVs) is determined by periodic surveillance testing in accordance with the ASME Code. [Emphasis added]. The words ASME Code replace INSERVICE TEST PROGRAM. Similarly, SR 3.7.1.1 is revised to state that the test is performed in accordance with the ASME Code in lieu of in accordance with the INSERVICE TESTING PROGRAM. Please revise to state that the test is conducted in accordance with 10 CFR 50.55a(f) or provide a technical basis for referring to the code.

b. In NUREG-1431 and -1432, Volume 2, SR 3.7.2.1, please the replace INSERVICE TESTING PROGRAM with 10 CFR 50.55a(f) in lieu of ASME Code.

9)

In NUREGs-1430 through -1432, SR 3.5.2.4 contains a sentence stating, The ASME Code provides the activities and frequencies necessary to satisfy the requirements. The traveler proposes to delete the words and frequencies. However, this statement remains true despite moving the surveillance frequency to the SFCP unless regulatory approval for a different frequency is obtained. Please provide the technical basis for striking the words. Clarity can be provided as indicated above by stating that IST surveillance frequencies are controlled in accordance with TS 5.5.19.b.1 of the SFCP (for PWRs) or TS 5.5.16.a.1 of the SFCP (for BWRs), as applicable. This comment also applies to SR 3.4.10.1 in NUREG-1432, Volume 2.

10)

For NUREGs-1430 and -1431, Volume 2, SR 3.7.3.1, NUREG-1433, Volume 2, SRs 3.6.1.3.6 and 3.6.4.2.2, and NUREG-1434, Volume 2, SRs 3.6.1.3.5, 3.6.4.2.2, and 3.6.5.3.4, the traveler proposes to delete the sentence stating, This SR also verifies the valve closure time is in accordance with the INSERVICE TESTING PROGRAM. Please provide a technical basis for deleting the sentence. The NRC staff notes that this sentence is retained in NUREG-1432, SR 3.7.3.1.

11)

For NUREGs-1430 through-1432, Volume 2, SR 3.7.5.2, the traveler proposes to revise the sentence stating, Performance of inservice testing as discussed in the ASME Code (Ref. 3) and the INSERVICE TESTING PROGRAM, satisfies this requirement to state that Performance of this testing is discussed in the ASME Code (Ref. 3). These two statements are not equivalent. Please provide the technical basis for the change or retain the original statement and revise it to replace INSERVICE TESTING PROGRAM with 10 CFR 50.55a(f).

12)

For NUREGs-1430 through -1432, Volume 2, the traveler proposes to revise SR 3.6.3.5 to indicate that the frequency is in accordance with 10 CFR 50.55a(f). However, the Bases do not state that the test is conducted in accordance with 10 CFR 50.55a(f) (or in accordance with the ASME Code) even though SR 3.9.3.2 (or SR 3.9.4.2 in NUREG-1431) specifically states SR 3.6.3.5 demonstrates that the isolation time of each valve is in accordance with the INSERVICE TESTING PROGRAM requirements.

This is inconsistent with other SRs that are conducted in accordance with the IST Program. Please update the language to be consistent or provide the technical basis for not citing the regulatory requirement for conducting the test in SR 3.6.3.5. In addition, please provide the technical basis for deleting the words INSERVICE TESTING PROGRAM in the above referenced statement in the Bases for SR 3.9.3.2.

a.

Similar to the Request for Additional Information (RAI) above, NUREG-1432, SR 3.6.7.4 states that the surveillance frequency is based on 10 CFR 50.55a(f) but does not indicate that the surveillance is performed in accordance with 10 CFR 50.55a(f) (or the ASME Code). Please revise to state that the surveillance is performed in accordance with 10 CFR 50.55a(f) or provide the technical basis for not making this change.

b.

Additional examples are NUREG-1433, Volume 2, SR 3.4.5.1, and NUREG-1434, Volume 2, SR 3.4.6.1. Please revise to state that the surveillance is performed in accordance with 10 CFR 50.55a(f) or provide the technical basis for not making this change.

13)

In NUREG-1431, Volume 2, the markup for the Bases for SR 3.4.12.4 proposes to delete the part of the surveillance that states that demonstrating that the residual heat removal (RHR) suction relief valves are operable includes testing it in accordance with the INSERVICE TESTING PROGRAM. In addition, the traveler proposes to delete the sentence stating, The ASME Code (Ref. 8), test per INSERVICE TESTING PROGRAM verifies OPERABILITY by proving proper relief valve mechanical motion and by measuring and, if required, adjusting the lift setpoint. Reference 8 is also proposed to be deleted. Similarly, the traveler proposes to modify the Bases for SR 3.4.12.7 by deleting the text that states that the SR is performed in accordance with the IST and refers to SR 3.4.12.4 for a description of the IST Program requirements. Please provide the technical basis for these proposed changes.

14)

NUREG-1430 and NUREG-1432, Volume 2, SR 3.4.14.1, states [The [18 month] Frequency is consistent with 10 CFR 50.55a(g) (Ref. 8). This appears to be an error previously introduced into the Bases, as a(g) refers to the Inservice Inspection Program, not the INSERVICE TESTING PROGRAM. It appears the correct reference should be 10 CFR 50.55a(f) unless both the Inservice Inspection Program and the INSERVICE TEST PROGRAM apply to this surveillance. The original wording in the Bases states in accordance with 10 CFR 50.55a(g) and the INSERVICE TESTING PROGRAM. [Emphasis added] Please revise traveler to correct or provide the basis for citing 10 CFR 50.55a(g). The NRC staff notes that the traveler does make this correction for NUREG-1431.

15)

For NUREG-1433, Volume 2, SR 3.5.1.6, the traveler proposes to revise the sentence that states, Verification during reactor startup prior to reaching > 25%

RTP is an exception to the normal INSERVICE TESTING PROGRAM generic valve cycling Frequency, by deleting the words INSERVICE TESTING PROGRAM. Deletion of the IST reference makes the sentence confusing as to what the normal generic valve cycling Frequency is. Please provide the technical basis for this proposed change.

16)

NUREG-1433, Volume 2, SR 3.6.1.7.2, originally stated that the frequency was based upon the INSERVICE TESTING PROGRAM requirements and is proposed to be revised to be consistent with the ASME Code. SR 3.6.1.8.2, however, also indicates the frequency was based on the IST Program but is marked to delete the discussion of the IST Program being part of the basis for the frequency. Similarly, SR 3.6.3.1.1 also deletes the reference to the SR frequency being consistent with the IST Program. In another example, NUREG-1434, Volume 2, SR 3.5.1.2, deletes information stating that the frequency was derived from the IST Program while SR 3.5.1.4 retains a statement that the frequency is consistent with 10 CFR 50.55a(f). There are other examples, such as in NUREG-1431 and -1432, Volume 2, SR 3.6.9.1. What is the reason for different treatment of the frequency information in these SRs?

17)

In public meetings, the TSTF has noted that the incorporation of surveillances that are part of the IST Program has been performed inconsistently in the STS. As such, TSTF-596 presents an opportunity to address the consistency issues. Accordingly, the NRC staff has the following suggestion:

The references to testing conducted in accordance with the IST Program should be made consistent throughout the STS. The changes being made to remove references to the IST Program are being revised to reference the regulation implementing regulation for the IST Program, 10 CFR 50.55a(f). However, existing references in the Bases describing how the test is performed typically reference the ASME Code. New references to how the test is conducted are also referencing the ASME Code. For consistency, all references to the IST Program and testing conducted in accordance with the IST Program should be updated to reference the regulatory requirement (10 CFR 50.55a(f)). In addition, the language for stating that a surveillance is conducted in accordance the IST is inconsistent. In some cases, the Bases state that the test is conducted in accordance with the ASME Code, while other places the language varies (e.g., the test is consistent with the ASME Code). The proposed changes are adding to the inconsistency instead of eliminating them. The traveler should be utilized to fix the inconsistent language used for describing surveillances conducted in accordance with 10 CFR 50.55a(f).

The EMIB staff requests that the TSTF provide the following information to support the review of TSTF-596:

1)

Section 1 in TSTF-596 on page 1 states that the proposed change revises the SFCP to encompass additional regulatory mechanisms that may be used to control Surveillance Frequencies. At the outset of the document, TSTF-596 should be clarified to specify that the SFCP does not control the IST Program requirements in the ASME OM Code as incorporated by reference in 10 CFR 50.55a. Under 10 CFR 50.55a, the IST Program requirements can only be modified where a licensee has submitted a request for relief from those requirements in accordance with 10 CFR 50.55a(f)(5) or has submitted a request for an alternative to those requirements under 10 CFR 50.55a(z),

and the NRC staff has granted the requested relief or authorized the requested alternative.

2)

Section 2.1 in TSTF-596 on page 2 references NRC Regulatory Issue Summary (RIS) 2012-10, NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests, which clarified that the delay period allowed in the TS does not apply to testing under 10 CFR 50.55a(f) not associated with TS. ASME prepared Code Case OMN-20, Inservice Test Frequency, to allow grace periods for IST test intervals required by the ASME OM Code as incorporated by reference in 10 CFR 50.55a. The NRC initially accepted Code Case OMN-20 directly in 10 CFR 50.55a, and later moved its acceptance into Regulatory Guide 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, which is incorporated by reference in 10 CFR 50.55a. Since then, ASME has incorporated the grace periods for IST test intervals allowed in Code Case OMN-20 into recent editions of the ASME OM Code. TSTF-596 should clarify the process for applying grace periods for IST test intervals allowed by the ASME OM Code as incorporated by reference in 10 CFR 50.55a.

3)

Section 3.4 in TSTF-596 on page 9 discusses the allowance for alternative treatment for licensees that have received a license amendment to implement 10 CFR 50.69. A licensee implementing 10 CFR 50.69 may replace the test methods and intervals specified in the IST Program required by 10 CFR 50.55a(f) for RISC-3 (low safety significant safety-related) components with alternate test methods and intervals in accordance with the requirements specified in 10 CFR 50.69(d)(2). TSTF-596 should clarify that the licensee must have a technical justification for the test or inspection methods and intervals applied to RISC-3 components under its 10 CFR 50.69 program to provide reasonable confidence that the RISC-3 components will be capable of performing their design-basis safety functions.

4)

Where the IST Program is relied on to meet applicable SRs, TSTF-596 should specify that the individual SRs must be reviewed to ensure that the ASME OM Code requirements will satisfy the intent of each SR. For example, pump flow requirements specified in an SR or the frequency of valve stroke-time testing specified in an SR might not match the requirements in the ASME OM Code as incorporated by reference in 10 CFR 50.55a.