ML24283A200
| ML24283A200 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 12/10/2024 |
| From: | Office of Nuclear Reactor Regulation |
| To: | Technical Specifications Task Force |
| References | |
| EPID L-2023-PMP-0002 | |
| Download: ML24283A200 (11) | |
Text
DRAFT SAFETY EVALUATION 1
BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2
TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 3
TSTF-596, REVISION 2, EXPAND THE APPLICABILITY OF THE SURVEILLANCE 4
FREQUENCY CONTROL PROGRAM (SFCP) 5 USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 6
(EPID: L-2023-PMP-0002) 7 8
1.0 INTRODUCTION
9 By letter dated October 8, 2024, (Agencywide Documents Access and Management System 10 (ADAMS) Accession No. ML24282B020), the Technical Specifications Task Force (TSTF) 11 submitted Traveler TSTF-596, Revision 2, "Expand the Applicability of the Surveillance 12 Frequency Control Program (SFCP)" (TSTF-596), to the U.S. Nuclear Regulatory Commission 13 (NRC). TSTF-596 proposed changes to the Standard Technical Specifications (STS) for all 14 operating reactor designs (except the AP-1000 design) under the Consolidated Line Item 15 Improvement Process (CLIIP). Upon approval, these changes would be incorporated into future 16 revisions of NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, and NUREG-1434.1 17 This STS change will be made available to licensees for adoption through the CLIIP.
18 19 The proposed changes would: 1) expand the applicability of the SFCP to include other periodic 20 testing frequencies in STS Section 5.5, "Programs and Manuals;" 2) revise the SFCP to 21 reference additional regulatory mechanisms that may be used to control surveillance 22 frequencies (i.e., Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a and 23 10 CFR 50.69); 3) revise Surveillance Requirements (SRs) that reference the Inservice Testing 24 (IST) Program to instead reference the SFCP or to describe the required test; and 4) correct 25 some editorial errors in the STS. In addition, the STS Bases would be revised to replace all 26 references to the IST Program with a reference to 10 CFR 50.55a, Codes and standards, 27 Paragraph (f), Preservice and inservice testing requirements, which is the regulation that 28 requires the IST requirements of the American Society of Mechanical Engineers (ASME) Boiler 29 and Pressure Vessel Code (BPV Code) and the ASME Operation and Maintenance [OM] of 30 Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) be met as incorporated by 31 reference in 10 CFR 50.55a.
32 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).
NUREG-1433 provides the STS for BWR/4 plant designs, but is also representative of the BWR/2, BWR/3, and, in this case, of the BWR/5 plant design.
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).
NUREG-1434 provides the STS for BWR/6 plant designs, but is also representative in some cases of the BWR/5 plant design.
1.1 Description of the SFCP 1
2 The SFCP is a program that controls the frequencies of technical specification (TS) SRs for 3
structures, systems, and components (SSCs). The SFCP uses a risk-informed process to allow 4
licensees to optimize the frequency of surveillance activities. The SFCP reduces the number of 5
surveillances performed which can reduce the risk of plant transients. The SFCP is part of the 6
STS Section 5, Administrative Controls. Changes to surveillance frequencies are made in 7
accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies."
8 9
1.2 Description of the Proposed Changes 10 11 1.2.1 Proposed Changes to the SFCP 12 13 Specifications 5.5.19 in NUREG-1430, NUREG-1431 and NUREG-1432, and 5.5.16 in 14 NUREG-1433 and NUREG-1434 are entitled, Surveillance Frequency Control Program.
15 TSTF-596 proposes that each would be revised as follows (new text shown in italics):
16 17 This program provides controls for Surveillance Frequencies and the frequencies 18 of other periodic testing required by these Technical Specifications (herein also 19 referred to as Surveillance Frequencies). The program shall ensure that 20 Surveillance Requirements and other required testing specified in these 21 Technical Specifications are performed at intervals sufficient to assure the 22 associated Limiting Conditions for Operation and other requirements are met.
23
- a.
The Surveillance Frequency Control Program shall contain a list of 24 Frequencies of those Surveillance Requirements for which the Frequency is 25 controlled by the program.
26
- b.
Changes to the Frequencies listed in the Surveillance Frequency Control 27 Program shall be made:
28
- 1.
In accordance with the requirements of 10 CFR 50.55a for testing 29 required by 10 CFR 50.55a(f);
30
- 2.
In accordance with the requirements of 10 CFR 50.69(d)(2) for testing 31 permitted under 10 CFR 50.69(b)(1)(v) in lieu of testing required by 32 10 CFR 50.55a(f);
33
- 3.
Otherwise, in accordance with NEI 04-10, "Risk-Informed Method for 34 Control of Surveillance Frequencies," Revision 1.
35
- c.
The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable 36 to Frequencies established in the Surveillance Frequency Control Program, 37 except:
38
- 1.
For testing required by 10 CFR 50.55a(f), Surveillance Requirement 39 3.0.2 is only applicable as permitted by that regulation; and 40
- 2.
Surveillance Requirement 3.0.3 is only applicable to other required 41 testing when invoked by a Chapter 5 Specification.
42 As discussed below, the inclusion of language related to 10 CFR 50.69 in this provision would 1
not permit licensees adopting this traveler to apply this alternative without a license amendment 2
to adopt 10 CFR 50.69.
3 4
1.2.2 Proposed Changes Related to the Inservice Testing Program 5
6 TSTF-596 proposes the following changes related to how the IST Program is referenced:
7 8
In STS 1.1, the definition of Inservice Testing Program would be removed.
9 All SR test frequencies that state in accordance with the Inservice Testing Program would 10 be revised to state in accordance with the Surveillance Frequency Control Program.
11 All SRs that reference the IST Program in the surveillance would be revised to replace the 12 reference with a description of the required test.
13 The STS Bases for each SR that is required by the IST Program would be revised to 14 indicate that it is to be performed in accordance with 10 CFR 50.55a(f), which is the 15 regulatory requirement for licensees to meet the IST requirements of the ASME BPV and 16 OM Codes.
17 The STS Bases for SR frequencies for surveillances that are required by the IST Program 18 would be revised to state, The Surveillance Frequency is controlled under the Surveillance 19 Frequency Control Program in accordance with the requirements of 10 CFR 50.55a(f).
20 21 1.2.3 Proposed Changes to Periodic Testing Requirements in Section 5.5 Programs 22 23 TSTF-596 proposes that the periodic testing frequencies required by four Section 5.5 programs 24 would be revised to reference the SFCP2. The specific revised testing frequencies are in the 25 following programs:
26 27 Primary Coolant Sources Outside Containment, 28 Ventilation Filter Testing Program (VFTP),
29 Diesel Oil Testing Program, and 30 Control Room Envelope (CRE) Habitability Program.
31 32 The periodic testing frequencies for these programs would be revised to state that they are 33 tested at a Frequency in accordance with the Surveillance Frequency Control Program.
34 35 2 The specific STS Sections affected by the proposed change to the Section 5.5 programs are:
NUREG-1430, NUREG-1431, NUREG-1432 5.5.2, "Primary Coolant Sources Outside Containment" 5.5.10, "Ventilation Filter Testing Program (VFTP)"
5.5.12, "Diesel Fuel Oil Testing Program" 5.5.17, "Control Room Envelope (CRE) Habitability Program" NUREG-1433, NUREG-1434 5.5.2, "Primary Coolant Sources Outside Containment" 5.5.7, "Ventilation Filter Testing Program (VFTP)"
5.5.9, "Diesel Fuel Oil Testing Program" 5.5.14, "Control Room Envelope (CRE) Habitability Program" 1.2.4 Editorial Corrections 1
2 The traveler also proposed to make two editorial corrections. The corrections are described and 3
evaluated in Section 3.6 of this safety evaluation.
4 5
2.0 REGULATORY EVALUATION
6 7
As described in the Commissions Final Policy Statement on Technical Specifications 8
Improvements for Nuclear Power Reactors (58 FR 39132, dated July 22, 1993), the NRC and 9
industry task groups for new STS recommended that the new STS include greater emphasis on 10 human factors principles to add clarity and understanding to the text of the STS, and provide 11 improvements to the STS Bases. The improved vendor-specific STS were developed and 12 issued by the NRC in September 1992.
13 14 The Commissions Final Policy Statement states that each Limiting Condition for Operation 15 (LCO), action, and SR should have supporting Bases, and the Bases should at a minimum 16 address certain questions and cite references to appropriate licensing documentation (e.g.,
17 FSAR, Topical Report) to support the Bases.
18 19 10 CFR 50.36(b) states:
20 21 Each license authorizing operation of a utilization facility will include 22 technical specifications. The technical specifications will be derived from the 23 analyses and evaluation included in the safety analysis report, and amendments 24 thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; 25 technical information"]. The Commission may include such additional technical 26 specifications as the Commission finds appropriate.
27 28 10 CFR 50.36(c) states that TS will include items in several categories, which include 29 Paragraph (3), "Surveillance requirements." It defines SRs as, "requirements relating to test, 30 calibration, or inspection to assure that the necessary quality of systems and components is 31 maintained, that facility operation will be within safety limits, and that the LCOs will be met."
32 33 10 CFR 50.55a, Paragraph (f), requires licensees to meet the IST requirements of the ASME 34 BPV and OM Codes.
35 36 10 CFR 50.69, "Risk-informed categorization and treatment of structures, systems and 37 components for nuclear power reactors," provides alternative requirements for some SSCs in 38 lieu of the requirements of 10 CFR 50.55a(f). However, 10 CFR 50.69(b)(2) states, [a] licensee 39 voluntarily choosing to implement this section shall submit an application for license amendment 40 under § 50.90. 10 CFR 50.69(b)(3) states, The Commission will approve a licensee's 41 implementation of this section if it determines that the process for categorization of 42
[risk-informed safety classification (RISC)] RISC-1, RISC-2, RISC-3, and RISC-4 SSCs satisfies 43 the requirements of § 50.69(c) by issuing a license amendment approving the licensee's use of 44 this section. Therefore, a licensee may not implement the requirements of 10 CFR 50.69 45 without prior NRC approval.
46 47 The NRC staffs guidance for the review of TSs is in NUREG 0800, Standard Review Plan for 48 the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light-water reactor]
49 Edition (SRP), Chapter 16.0, Technical Specifications, Revision 3, dated March 2010 50 (ML100351425).
51
3.0 TECHNICAL EVALUATION
1 2
3.1 Changes to the SFCP in the STS 3
4 The traveler proposes expansion of the SFCP to include other STS periodic tests that had not 5
previously been included in the SFCP. Specifically, the proposed SFCP expansion would 6
include: 1) surveillance testing required by the IST Program; 2) surveillance testing in which an 7
alternative treatment has been applied in accordance with 10 CFR 50.69(b)(1)(v) in lieu of the 8
IST Program requirements; and 3) periodic testing that is required by the STS Section 5.5 9
programs for Primary Coolant Sources Outside Containment, VFTP, Diesel Fuel Oil Testing, and 10 CRE Habitability. To accomplish this, additional methodologies for the control of surveillance 11 frequencies are added to the SFCP to reference the applicable regulatory requirements for 12 implementing the IST Program and 10 CFR 50.69 alternative treatment.
13 14 As currently structured, the STS format creates potential confusion for SSCs with surveillances 15 that state that the surveillance frequency is [i]n accordance with the INSERVICE TESTING 16 PROGRAM. If a licensee that has an NRC-approved license amendment to implement 10 CFR 17 50.69 categorizes an SSC as RISC-3 and its TSs state that the surveillance frequency for that 18 SSC must be in accordance with the INSERVICE TESTING PROGRAM, there could be 19 confusion as to whether the licensee can apply the alternative treatment described in 10 CFR 20 50.69(d)(2) without a license amendment to change its TSs. The traveler proposes a TS 21 structure that will permit a licensee that has an NRC-approved 10 CFR 50.69 license 22 amendment to utilize the provisions of 10 CFR 50.69 as a basis for changing the frequency for 23 certain surveillance actions specified in the TSs without requiring a TS license amendment to 24 revise those frequencies.
25 26 The traveler proposes to describe all the possible surveillance frequency control processes 27 under the envelope of the SFCP, which then allows licensees to utilize the applicable process in 28 accordance with the NRC regulations and the plant-specific licensing basis. Specifically, the 29 traveler 1) revises the SR frequencies that reference the IST Program to reference the SFCP, 2) 30 revises the SFCP to include the applicable regulatory requirements for both IST Program testing 31 and 10 CFR 50.69 alternative treatment and 3) retains the existing surveillance frequency 32 control process for SR frequencies already covered under the SFCP. With this structure, the 33 traveler, if adopted by a licensee that has received a 10 CFR 50.69 license amendment, will 34 permit the licensee to use the alternative treatment requirements as a basis for changing the 35 frequencies of TS surveillance actions for SSCs that have been categorized as RISC-3 without 36 submitting a license amendment to change the frequencies specified in the TS. The traveler 37 would not, however, modify the required surveillance action specified in the TS. The NRC staffs 38 evaluation of these proposed changes is provided in Sections 3.2 through 3.6 below.
39 40 3.2 Technical Evaluation of Changes to Surveillances Required by the Inservice Testing 41 Program References (Paragraph b.1) 42 43 There are three ways the STS typically identify surveillance testing to be performed in 44 accordance with the IST Program:
45 46
- 1)
The TS SR and the associated Frequency both state that the SR is to be conducted in 47 accordance with the IST Program, 48
- 2)
Only the Surveillance Frequency states that the SR is to be performed in accordance 49 with the IST Program, or 50
- 3)
The Bases identify that the SR or associated Frequency should be performed in 1
accordance with the IST Program, the ASME Code, or the ASME OM Code.
2 3
The proposed changes in the traveler add the IST Program surveillances to the SFCP and 4
provide a consistent method of identifying IST Program surveillances in the STS by:
5 6
- 1)
The addition of new paragraph b.1 to the SFCP in Specification 5.5.19 in NUREG-1430, 7
NUREG-1431 and NUREG-1432, and 5.5.16 in NUREG-1433 and NUREG-1434 which 8
would state that changes to frequencies listed in the SFCP shall be made [i]n 9
accordance with the requirements of 10 CFR 50.55a for testing required by 10 CFR 10 50.55a(f).
11
- 2)
Removing all references to the IST Program in the STS SRs and replaces them with a 12 description of the test to be performed.
13
- 3)
Removing all references to the IST Program in SR frequencies and replaces them with a 14 statement saying that the frequency is [i]n accordance with the Surveillance Frequency 15 Control Program[.]
16
- 4)
Removing the definition of Inservice Testing Program in Section 1.1 of the STS.
17
- 5)
Revising the STS Bases for all SRs required by the IST Program to state that the SRs 18 are performed in accordance with 10 CFR 50.55a(f).
19
- 6)
Revising the STS Bases for the SR Frequency for each SR required by the IST Program 20 to state: The Surveillance Frequency is controlled under the Surveillance Frequency 21 Control Program in accordance with the requirements of 10 CFR 50.55a(f).
22 23 The NRC staff evaluated the proposed changes and found:
24 25 The definition of Inservice Testing Program in Section 1.1 of the STS states that The 26 INSERVICE TESTING PROGRAM is the licensee program that fulfills the requirements of 27 10 CFR 50.55a(f). Accordingly, there is no change in requirements by changing references 28 to the IST Program from in accordance with the Inservice Testing Program to in 29 accordance with 10 CFR 50.55a(f).
30 One of the methods previously found acceptable by the NRC staff that is currently used in 31 the STS for identifying surveillances that are required to be performed in accordance with 32 10 CFR 50.55a(f) is to state in the STS Bases that the SR must be performed in accordance 33 with the IST Program, the ASME Code, or the ASME OM Code. Revising the STS Bases for 34 all SRs required by the IST Program, ASME Code, or ASME OM Code to state that they are 35 required to be performed in accordance with 10 CFR 50.55a(f) provides consistency on how 36 the IST requirements are identified in the STS and improved clarity for those requirements 37 by citing the regulation in lieu of codes or code terminology. The technical requirements for 38 the performance of these surveillances are not modified in any way by this change.
39 The removal of references to the IST Program in the individual SRs and describing the 40 surveillance to be performed does not change the SR to be performed. In addition, the 41 surveillance will continue to be identified as being required by 10 CFR 50.55a(f) in the 42 associated STS Bases for each SR. Changing the STS Bases to state that the SRs are 43 performed in accordance with 10 CFR 50.55a(f) instead of the IST Program or ASME Code 44 does not change the SR requirement in any way.
45 The current IST Program SR Frequencies state that they are to be performed [i]n 46 accordance with the Inservice Testing Program. Accordingly, they can only be changed in 47 accordance 10 CFR 50.55a. The traveler proposes to modify the IST Program SR 48 Frequencies to state that they are to be performed in accordance with the SFCP. Since the 49 SFCP is also modified in the traveler to state that changes to the frequencies listed in the 1
SFCP shall be made [i]n accordance with the requirements of 10 CFR 50.55a for testing 2
required by 10 CFR 50.55a(f), there is no change to how the surveillance frequencies for 3
IST Program are controlled.
4 Specifying in the STS Bases which SRs are required to be performed in accordance with 5
10 CFR 50.55a(f) is acceptable because there are regulatory controls on these 6
requirements. Specifically, the Bases Control Program in Section 5.5 of the STS only allows 7
changes to the Bases to be made without prior NRC approval if they do not require a 8
change to the TSs or are allowed pursuant to the requirements of 10 CFR 50.59. In addition, 9
the regulation continues to require that the IST requirements specified in the ASME BPV or 10 OM Codes be met.
11 The requirements of 10 CFR 50.55a(f) will continue to be met because the IST requirements 12 that are also TS SRs will be clearly identified in the STS Bases for the appropriate SRs. In 13 addition, changes to the IST frequencies can only be made in accordance with 10 CFR 14 50.55a.
15 In that no technical changes are made to any of the IST-related SRs, 10 CFR 50.36(c)(3) 16 will continue to be met because the SRs will continue to assure that the necessary quality of 17 systems and components is maintained, that facility operation will be within safety limits, and 18 that the LCOs will be met.
19 Based on the above evaluation, the NRC staff concludes that that overall effect of these 20 changes is to restructure and clarify the SRs related to the IST Program. In addition, these 21 changes are administrative only since no technical requirements are changed for the IST 22 Program. Therefore, the NRC staff finds these changes to be acceptable.
23 24 3.3 Technical Evaluation of Changes to Surveillances to Which an Alternative Treatment Has 25 Been Applied in Accordance With 10 CFR 50.69(b)(1)(v) (Paragraph b.2) 26 27 Paragraph b of the SFCP in Specification 5.5.19 in NUREG-1430, NUREG-1431 and NUREG-28 1432, and 5.5.16 in NUREG-1433 and NUREG-1434 specifies the conditions under which 29 changes to surveillance frequencies may be made. The traveler proposes the addition of new 30 Paragraph b.2, which would state that changes to frequencies listed in the SFCP shall be made 31
[i]n accordance with the requirements of 10 CFR 50.69(d)(2) for testing permitted under 10 32 CFR 50.69(b)(1)(v) in lieu of testing required by 10 CFR 50.55a(f).
33 34 10 CFR 50.69 is an optional rule that allows a licensee to use an NRC-approved risk-informed 35 process to categorize SSCs into one of four RISC categories. For SSCs that are determined to 36 be safety-related SSCs that perform low safety significance functions (RISC-3), alternative 37 treatment provisions may be used in lieu of certain other regulatory requirements. As stated in 38 10 CFR 50.69(b)(2), [a] licensee voluntarily choosing to implement this section shall submit an 39 application for license amendment under § 50.90. 10 CFR 50.69(b)(3) states, 40 41 The Commission will approve a licensee's implementation of this section if it 42 determines that the process for categorization of RISC-1, RISC-2, RISC-3, and 43 RISC-4 SSCs satisfies the requirements of § 50.69(c) by issuing a license 44 amendment approving the licensee's use of this section.
45 46 Therefore, by regulation, a licensee may not implement the requirements of 10 CFR 50.69 47 without prior NRC approval. This approval is separate from the approval to adopt TSTF-596.
48 While TSTF-596 is structured to permit the use of 10 CFR 50.69 without requiring another TS 49 change upon adoption of 10 CFR 50.69, adoption of the traveler itself would not give licensees 1
approval to utilize 10 CFR 50.69. Therefore, the changes proposed for implementing 10 CFR 2
50.69 in the SFCP would not be applicable until the licensee had: 1) an approved license 3
amendment from the NRC to apply 10 CFR 50.69 and 2) applied alternative treatments in 4
accordance with the regulation. Furthermore, adoption of this traveler and the addition of 5
language to the TSs of a licensee that has not previously adopted 10 CFR 50.69 does not pre-6 determine the outcome of the NRC staffs review of the license amendment to adopt 10 CFR 7
50.69. A licensee seeking to adopt 10 CFR 50.69 is still responsible for submitting a license 8
amendment that meets the relevant requirements.
9 10 Consistent with the requirements of 10 CFR 50.69, Section 2.1 of TSTF-596 states, Licensees 11 that receive NRC approval to use 10 CFR 50.69 may apply a categorization process to 12 determine the Risk-Informed Safety Class (RISC) for structures, systems, or components 13 (SSCs). Similarly, Section 3.3 of TSTF-596 states, Licensees that have not been approved to 14 use 10 CFR 50.69 do not have Frequencies permitted under 10 CFR 50.69(b)(1)(v). Therefore, 15 that provision cannot be used until the licensee is approved to use 10 CFR 50.69. Based on 16 these statements, the NRC staff finds that TSTF-596 makes it clear that that proposed provision 17 in Paragraph b.2 of the SFCP cannot be used until the licensee has NRC approval to use 18 10 CFR 50.69, and that approval of TSTF-596 does not constitute approval for the licensee to 19 utilize the provisions of 10 CFR 50.69.
20 21 The purpose of adding Paragraph b.2 to the SFCP (in combination with the IST changes 22 discussed in Section 3.2 above) is to clarify that a licensee who has an approved license 23 amendment from the NRC to utilize the provisions of 10 CFR 50.69 may control a surveillance 24 frequency of a RISC-3 SSC that had previously been tested in accordance with the INSERVICE 25 TESTING PROGRAM, where the INSERICE TESTING PROGRM had previously been defined 26 as the program that fulfilled the requirements of 10 CFR 50.55a(f) without needing an additional 27 license amendment to revise its TSs. The proposed SFCP revision is structured to allow 28 licensees to apply the appropriate applicable methodology (consistent with their licensing basis) 29 for controlling the surveillance frequency.
30 31 The NRC staff reviewed the proposed addition of Paragraph b.2 to the SFCP. The staff found 32 that SSCs are subject to the alternative treatment requirements specified in 10 CFR 50.69(d)(2) 33 for the SCCs that a licensee categorized as RISC-3 in accordance with 10 CFR 50.69 and 34 chose to remove from the inservice testing or inservice inspection requirements of 10 CFR 35 50.55a(f) in accordance with 10 CFR 50.69(b)(1)(v). Where the NRC has approved a license 36 amendment to implement 10 CFR 50.69, the revised SFCP requires that RISC-3 SSCs continue 37 to meet the acceptance criteria specified in the applicable TS SR requirements. However, the 38 surveillance frequency could be determined as part of the alternative treatment developed in 39 accordance with 10 CFR 50.69. In other words, for a licensee that has received a 10 CFR 40 50.69 license amendment, the Surveillance Requirements in the TS for RISC-3 components 41 remain as written. However, the licensee can adjust the frequency of the Surveillance 42 Requirement based on its 10 CFR 50.69 program (rather than the 10 CFR 50.55a IST program 43 that 10 CFR 50.69 allows to be removed for RISC-3 components).
44 45 The proposed changes do not involve a change to any safety limits, limiting safety system 46 settings, limiting control settings, LCOs, design features, or administrative controls required by 47 10 CFR 50.36. Therefore, the proposed changes do not impact the initiators or assumptions of 48 analyzed events, nor do they impact mitigation of accidents or transient events. In addition, 49 10 CFR 50.36(c)(3) will continue to be met because the SRs will continue to assure that the 50 necessary quality of systems and components is maintained, that facility operation will be within 1
safety limits, and that the LCOs will be met.
2 3
Based on the above evaluation, the NRC staff concludes the proposed addition of 4
Paragraph b.2 to the SFCP in the STS is acceptable.
5 6
3.4 Technical Evaluation of Paragraph b.3 7
8 Paragraph b of the SFCP originally stated that all surveillance frequencies would be controlled 9
in accordance with NEI 04-10. The traveler proposes to add a new Paragraph b.3 specifying 10 that all surveillance frequencies not controlled in accordance with Paragraphs b.1 and b.2 of the 11 SFCP will be controlled in accordance with NEI 04-10. The addition of Paragraph b.3 ensures 12 that there is no change in the requirement for the existing SRs in the SFCP to be controlled in 13 accordance with NEI 04-10. Therefore, this change is acceptable.
14 15 3.5 Technical Evaluation of the Addition of Section 5 Periodic Test Programs to the SFCP 16 17 The NRCs approval (ML090900716) of TSTF-425, Revision 3, Relocate Surveillance 18 Frequencies to Licensee Control - RITSTF Initiative 5b, (ML090850642) established the SFCP 19 in the STS. The approved traveler TSTF-425 allowed all periodic surveillance frequencies to be 20 relocated to the SFCP and controlled using the methodology described in Nuclear Energy 21 Institute (NEI) 04-10, Risk-Informed Method for Control of Surveillance Frequencies, 22 Revision 1 (ML071360456), except for the following:
23 24 Frequencies that reference other approved programs for the specific interval (such as the 25 Inservice Testing Program);
26 Frequencies that are purely event-driven; 27 Frequencies that are event-driven, but have a time component for performing the 28 surveillance on a one-time basis once the event occurs; and 29 Frequencies that are related to specific conditions (e.g., battery degradation) or conditions 30 for the performance of a surveillance requirement (e.g., "drywell to suppression chamber 31 differential pressure decrease").
32 33 TSTF-596 also proposes to allow the frequencies for the periodic test requirements of the 34 Primary Coolant Sources Outside Containment, the Ventilation Filter Testing, the Diesel Oil 35 Testing, and the CRE Habitability programs to be relocated to the SFCP. These frequencies 36 would be controlled in accordance with NEI 04-10.
37 38 The NRC staff evaluated the proposed addition of the Primary Coolant Sources Outside 39 Containment, VFTP, Diesel Oil Testing Program, and CRE Habitability Program to the SFCP for 40 the identified Section 5.5 tests and determined that the SR frequencies do not meet any of the 41 exclusion criteria in the approved TSTF-425, the frequencies are fixed periodic frequencies, and 42 the proposed changes are consistent with the intent of TSTF-425. Based on this, the NRC staff 43 finds that relocation of these Section 5.5 testing frequencies to the SFCP is acceptable.
44 45 3.6 Other Changes to the SFCP and STS Bases 46 47 In the current STS, Paragraph c of the SFCP states that the provisions of SR 3.0.2 and 48 SR 3.0.3 apply to the frequencies controlled by the SFCP. This statement is not correct under 49 the proposed revision due to the addition of IST Program SRs and Section 5.5 periodic testing.
50 Accordingly, the traveler proposes to modify Paragraph c of the SFCP to add two exceptions.
1 The proposed exceptions are:
2 3
- 1. For testing required by 10 CFR 50.55a(f), Surveillance Requirement 3.0.2 is 4
only applicable as permitted by that regulation; and 5
- 2. Surveillance Requirement 3.0.3 is only applicable to other required testing 6
when invoked by a Chapter 5 Specification.
7 Both exceptions are consistent with current STS applicability for SR 3.0.2 and SR 3.0.3 as 8
stated in the STS Bases. Thus, neither exception changes existing requirements. Accordingly, 9
the NRC staff finds them to be acceptable.
10 11 The traveler also makes several minor wording changes to the STS Bases so that discussions 12 regarding IST Program SRs refer to 10 CFR 50.55a(f), instead of the IST Program or ASME 13 Code. The NRC staff reviewed these changes and found them to be editorial to provide 14 consistency and clarity of the Bases. Therefore, the NRC staff finds them to be acceptable.
15 16 3.7 Corrections of Errors in the STS 17 18 The traveler proposed the correction of following two errors found in the STS:
19 20 3.7.1 CRE Habitability Program 21 22 The traveler proposes to correct an error in the CRE Habitability Program. Specifically, a 23 sentence in Paragraph d currently states, "The results shall be trended and used as part of the 24
[18] month assessment of the CRE boundary." The traveler proposes to revise the sentence to 25 state the "periodic assessment" instead of the "[18] month assessment." The traveler states that 26 this corrects an error in TSTF-448, Revision 3, "Control Room Habitability," which added the 27 program to the STS.
28 29 The CRE Habitability Program in the STS requires that determining unfiltered air inleakage past 30 the CRE boundary and assessment of the CRE habitability shall be performed in accordance 31 with the methods and at the frequencies specified in accordance with Sections C.1 and C.2 of 32 Regulatory Guide (RG) 1.197, "Demonstrating Control Room Envelope Integrity at Nuclear 33 Power Reactors," Revision 0, May 2003 (ML031490664). Paragraph 1.5, Periodicity of 34 Section C.1 in RG 1.197 states, All CREs should be tested to establish the baseline value for 35 inleakage and tested thereafter on a performance-based periodic frequency consistent with 36 Figure 1. Per RG 1.197, Figure 1, the periodic assessment is performed between inleakage 37 tests, or every 6 years. Based on this, the NRC staff concludes that the proposed correction 38 properly states the requirements for the CRE Habitability Program as described in RG 1.197, 39 and is therefore, acceptable.
40 41 3.7.2 SR 3.4.14.1 Bases 42 43 The traveler proposes to correct the SR 3.4.14.1 Bases in NUREG-1430, NUREG-1431, and 44 NUREG-1432. The existing Bases incorrectly reference 10 CFR 50.55a(g), "Preservice and 45 inservice inspection requirements." The SR is part of the IST Program. Accordingly, the 46 reference is corrected to 10 CFR 50.55a(f), "Preservice and inservice testing requirements."
47 This change is administrative only and does not make any technical changes. Therefore, the 48 NRC staff finds the correction to be acceptable.
49 50
4.0 CONCLUSION
1 2
The NRC staff reviewed traveler TSTF-596, Revision 2, which proposed changes to 3
NUREGs-1430, -1431, -1432, -1433 and -1434. The NRC staff determined that the proposed 4
changes to the STS continue to meet 10 CFR 50.36. The proposed changes ensure that the 5
requirements of 10 CFR 50.55a(f), and 10 CFR 50.69 that are applicable to TS SRs would be 6
met. Additionally, the changes to the STS were reviewed and found to be technically clear and 7
consistent with customary terminology and format in accordance with NRC Standard Review 8
Plan (SRP) Chapter 16.0, Technical Specifications. The NRC staff reviewed the proposed 9
changes to the SRs and concluded that the modified SRs would continue to assure that the 10 necessary quality of systems and components is maintained that facility operation will be within 11 safety limits, and that the LCOs will be met, and the changes would continue to provide 12 reasonable assurance of adequate protection of the health and safety of the public. Therefore, 13 the NRC staff concludes that the TS changes proposed in TSTF-596 are acceptable.
14 15 Principal Contributors:
R. Elliott, NRR/DSS 16 T. Scarbrough, NRR/DEX 17 18 Date: December 10, 2024 19