ML23325A214

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Final Model SE of TSTF-591, Revise Risk Informed Completion Time (RICT) Program
ML23325A214
Person / Time
Site: Technical Specifications Task Force
Issue date: 12/18/2023
From:
NRC/NRR/DSS/STSB
To:
Technical Specifications Task Force
References
EPID L-2022-PMP-0003
Download: ML23325A214 (8)
v • d • e


Text

General Directions: This model SE provides the format for an SE of LARs to adopt traveler TSTF-591. TSTF-591 was approved as part of the CLIIP. This model SE can also be used as a template for LARs adopting TSTF-591 that have significant variations and are not using the CLIIP. The [bolded bracketed] information shows text that should be filled in for the specific amendment. The italicized wording provides guidance on what should be included in each section.

FINAL MODEL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO TSTF-591, REVISE RISK-INFORMED COMPLETION TIME (RICT) PROGRAM 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

  • [Staff Names]

1.0 PROPOSED CHANGE

S

[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 TS based on Technical Specifications Task Force (TSTF) Traveler TSTF-591, Revision 0, Revise Risk-Informed Completion Time (RICT)

Program (TSTF-591) (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML22081A224), and the associated NRC staff safety evaluation (SE) of Traveler TSTF-591 (ML23262B230).

The proposed changes would revise the TS 5.5.[20], Risk Informed Completion Time Program, by referencing RG 1.200, Revision 3, instead of Revision 2. The proposed changes

would also add a requirement in TS Section 5.6, Reporting Requirements, for the licensee to submit a report to the NRC before calculating a RICT using a newly developed method (NDM).

Description of Risk-Informed Completion Time Program The TS limiting conditions for operations (LCOs) are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO is not met, the licensee must shut down the reactor or follow any remedial or required action (e.g.,

testing, maintenance, or repair activity) permitted by the TSs until the condition can be met. The remedial actions (i.e., ACTIONS) associated with an LCO contain Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and completion times (CTs). The CTs are referred to as the front stops in the context of this SE. For certain Conditions, the TS require exiting the Mode of Applicability of an LCO (i.e., shutdown the reactor).

Topical Report NEI 06-09-A (ML12286A321) provides a methodology for extending existing CTs and thereby delay exiting the operational mode of applicability or taking Required Actions if risk is assessed and managed within the limits and programmatic requirements established by a RICT Program.

1.1 Proposed TS Changes to Adopt TSTF-591 TS 5.5.[20] Risk Informed Completion Time Program TS 5.5.[20], which describes the RICT program, is revised. Existing paragraph e would be replaced with the paragraph e below. Paragraphs f and g would be added.

e. A RICT calculation must include the following hazard groups: [list specific hazards and the associated PRA models or alternate means of assessing the hazard for each applicable hazard group approved by NRC. For example, internal flood and internal events PRA model, internal fire PRA model, and seismic penalty factor]. Changes to these means of assessing the hazard groups 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.

TS 5.6.[8], Risk Informed Completion Time Program Upgrade Report A new specification, TS 5.6.[8], would be added as follows:

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 and prior to the first use of 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 dispositioned; and
d. All changes to key assumptions related to newly developed methods or their implementation.

1.2 Additional Proposed TS Changes

{NOTE: Use this section if variations are proposed. Add additional subsections if needed.

Editorial variations discussed below in section 1.2.1 do not warrant removal from the CLIIP and do not require any additional technical branches to be on the review. Variations discussed in section 1.2.2, may remove the LAR from the CLIIP and may require additional technical review depending on the significance of the variations.}

In addition to the changes proposed consistent with the traveler discussed in section 1.1, the licensee proposed the variation[s] below.

1.2.1 Editorial Variations

{NOTE: Use this section if the plant has different numbering/nomenclature or modify accordingly for other editorial changes made.}

The licensee noted that [name of facility] TSs have different numbering [and nomenclature]

than standard technical specifications (STSs).

1.2.2 Other Variations

{NOTE: Use this section if the plant has variations other than editorial variations discussed in section 1.2.1.}

2.0 REGULATORY EVALUATION

2.1 Applicable Regulatory Requirements and Guidance The regulation under Title 10 of the Code of Federal Regulations (10 CFR) 50.36(b) requires that:

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.

The categories of items required to be in the TSs are listed in 10 CFR 50.36(c).

The regulation at 10 CFR 50.36(c)(5), states that administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

NRC Regulatory Guides (RGs) provide one way to ensure that the regulations continue to be met. The NRC staff considered during its review of the proposed changes, along with industry guidance endorsed by the NRC, the guidance in RG 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, December 2020 (ML20238B871).

  • NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light-water reactor] Edition (SRP):
  • Chapter 19, Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, dated June 2007 (ML071700658).
  • Chapter 16, Section 16.0, Technical Specifications, March 2010 (ML100351425).

The NRC staffs review includes consideration of whether the proposed changes are consistent with the [insert applicable NUREG from list in footnote]1.

  • Chapter 16, Section 16.1, Risk-Informed Decision Making: Technical Specifications, March 2007 (ML070380228).
  • NEI 06-09-A, Revision 0, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines (ML063390639), provides guidance for risk-informed TS. The NRC staff issued a final SE approving NEI 06-09 on May 17, 2007 (ML071200238).

1

  • NRC NUREG-1430, Standard Technical Specifications, Babcock and Wilcox Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21272A363 and ML21272A370, respectively).
  • NRC NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21259A155 and ML21259A159, respectively).
  • NRC NUREG-1432, Standard Technical Specifications, Combustion Engineering Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21258A421 and ML21258A424, respectively).
  • NRC NUREG-1433, Standard Technical Specifications, General Electric, BWR/4 Plants Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21272A357 and ML21272A358, respectively).
  • NRC NUREG-1434, Standard Technical Specifications, General Electric, BWR/6 Plants Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21271A582 and ML21271A596, respectively).
  • PWR Owners Group (PWROG) topical report PWROG-19027-NP, Revision 2, "Newly Developed Method Requirements and Peer Review," establishes the definitions, processes, and technical requirements necessary to implement newly developed methods, issued July 2020 (ML20213C660). RG 1.200, Revision 3, endorsed specified portions of PWROG-19027-NP.

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes to Adopt TSTF-591 The NRC staff compared the licensees proposed TS changes in section 1.1 of this SE against the changes approved in Traveler TSTF-591. The NRC staff finds that the licensees proposed changes to the [name of facility] TSs in section 1.1 of this SE are consistent with those found acceptable in TSTF-591.

In the final SE for Traveler TSTF-591, the NRC staff concluded that the TSTF-591 proposed changes to STS 5.5.20, Risk Informed Completion Time Program, and the proposed addition of STS 5.6.8, Risk Informed Completion Time (RICT) Program Upgrade Report, were acceptable. These modifications were acceptable because, as discussed in that SE, they continued to ensure the PRA models used to calculate a RICT are maintained and upgraded by the licensees appropriate use of endorsed guidance (i.e., the ASME/ANS PRA Standard requirements, and specific industry guidance that the NRC staff has determined are sufficient for determining the acceptability of PRA models and NDMs for use in the RICT program).

Furthermore, as discussed in the traveler SE, the addition of reporting requirements does not preclude any NRC staff oversight of PRA changes performed to ensure the PRA model(s) continue to be maintained and upgraded consistent with RG 1.200, Revision 3. Therefore, the NRC staff found that the proposed changes to the RICT Program and addition of the RICT Program Upgrade Report requirements were acceptable because they continued to meet the requirements of 10 CFR 50.36(c)(5) by providing administrative controls necessary to assure operation of the facility in a safe manner. For these same reasons, the NRC staff concludes that the corresponding proposed changes to the [name of facility] TSs in section 1.1 of this SE continue to meet the requirements of 10 CFR 50.36(c)(5).

3.2 Additional Proposed Changes

{NOTE: Use this section if variations are proposed. Add additional subsections if needed.

Variations evaluated in section 3.2.2 may remove the LAR from the CLIIP and may require additional technical review depending on the significance of the variations. Additionally, the variations may require additional regulations/guidance being included in the Regulatory Evaluation Section.}

In addition to the changes proposed consistent with the traveler discussed in sections 1.1 and 1.2, the licensee proposed the variation[s] below.

3.2.1 Variations That Do Not Affect the Applicability of the Traveler

{NOTE: Use this section if the plant has different numbering/nomenclature or modify accordingly for other changes described in section 1.2.1 of this SE.}

The LAR noted that the [name of facility] TSs have different numbering [and nomenclature]

than STS. The NRC staff finds that the different TS numbering [and nomenclature] changes proposed in the LAR are acceptable because they do not alter TS requirements.

3.2.2 Variations That Do Affect the Applicability of the Traveler

{NOTE: Use this section if the plant has variations other than changes discussed in section 3.2.1 of this SE.}

3.3 TS Change Consistency The NRC staff reviewed the proposed TS changes for technical clarity and consistency with the existing requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with chapter 16.0 of the SRP and are therefore acceptable.

4.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's 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.

Principle Contributors: Adrienne Brown Andrea Russell Edward Miller

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 TS based on Technical Specifications Task Force (TSTF) Traveler TSTF-591, Revision 0, Revise Risk-Informed Completion Time (RICT)

Program (TSTF-591) (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML22081A224), and the associated NRC staff safety evaluation (SE) of Traveler TSTF-591 (ML23262B230).

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 Title 10 of the Code of Federal Regulations (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.

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