ML25027A421

Entergy Operations, Inc. - Application to Revise Technical Specifications to Adopt TSTF-591, Revised Risk Informed Completion Time (RICT) Program

ML25027A421
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	01/27/2025
From:	Couture P Entergy Operations
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
CNRO2024-00022
Download: ML25027A421 (1)

Text

Phil Couture Senior Manager Fleet Regulatory Assurance 601-368-5102

Entergy Operations, Inc. 1340 Echelon Parkway, Jackson, MS 39213 CNRO2024-00022 10 CFR 50.90 January 27, 2025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Application to Revise Technical Specifications to Adopt TSTF-591, "Revise Risk Informed Completion Time (RICT) Program" Arkansas Nuclear One, Unit 1 and 2 NRC Docket No. 50-313 and 50-368 Renewed Facility Operating License No. DPR-51 and NPF-6 River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 Pursuant to 10 CFR 50.90, Entergy Operations Inc. (Entergy), is submitting a request for an amendment to the Technical Specifications (TS) for Arkansas Nuclear One Units 1 and 2 (ANO-1/2), River Bend Station Unit 1 (RBS), Grand Gulf Nuclear Station Unit 1 (GGNS), and Waterford Steam Electric Station Unit 3 (WSES).

Entergy requests adoption of TSTF-591, "Revise Risk Informed Completion Time (RICT)

Program," which is an approved change to the TS, into the ANO-1/2, RBS, GGNS, and WSES TS. TSTF-591 revises the TS Section 5.5 Program, "Risk Informed Completion Time Program,"

to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of newly developed methods used to calculate a RICT. Administrative numbering differences exist between the plant specific TS and the STS Section numbers listed above.

The enclosure provides a description and assessment of the proposed changes. Attachments 1 through 5 provide the existing TS pages for ANO1, ANO2, GGNS, RBS, WSES marked to show the proposed changes. The proposed change does not affect the TS Bases.

Entergy requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 90 days.

CNRO2024-00022 Page 2 of 3 There are no regulatory commitments made in this application. Furthermore, this application contains no changes to each sites Probabilistic Risk Analysis (PRA) models that would be considered a Newly Developed Method (NDM), in accordance with the Pressurized Water Reactor Owners Group (PWROG), PWROG-19027-NP, Revision 2, Newly Developed Method Requirement and Peer Review, (Reference 1) as endorsed in Regulatory Guide 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, (Reference 2).

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State Officials for Arkansas, Mississippi, and Louisiana.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 27, 2025.

Should you have any questions or require additional information please contact me at 601-368-5102.

Respectfully, Phil Couture PC/dlw

Enclosure:

Evaluation of the Proposed Change Attachments to

Enclosure:

1.

ANO Technical Specification Pages Markups

2.

ANO Technical Specification Pages Markups

3.

GGNS - Technical Specification Pages Markups

4.

RBS

- Technical Specification Pages Markups

5.

WSES - Technical Specification Pages Markups

6.

ANO Technical Specification Pages Retyped

7.

ANO Technical Specification Pages Retyped

8.

GGNS - Technical Specification Pages Retyped Digitally signed by Philip Couture DN: cn=Philip Couture, c=US, o=Entergy, ou=Regulatory Assurance, email=pcoutur@entergy.com Date: 2025.01.27 14:56:28 -06'00' Philip Couture

CNRO2024-00022 Page 3 of 3

9.

RBS - Technical Specification Pages Retyped

10. WSES - Technical Specification Pages Retyped

References:

1. PWROG Topical Report, PWROG-19027, Revision 2, Newly Developed Method Requirements and Peer Review, (ML20213C660) dated July 2020.

2. Regulatory Guide 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, dated December 30, 2022.

cc:

NRC Region IV Regional Administrator NRC Senior Resident Inspector - ANO NRC Senior Resident Inspector - GGNS NRC Senior Resident Inspector - RBS NRC Senior Resident Inspector - WSES NRC Project Manager - ANO NRC Project Manager - GGNS NRC Project Manager - RBS NRC Project Manager - WSES NRC Project Manager - Fleet Designated State Official - Arkansas Designated State Official - Louisiana Designated State Official - Mississippi

Enclosure CNRO2024-00022 Evaluation of the Proposed Change

CNRO2024-00022 Enclosure Page 1 of 7 TABLE OF CONTENTS

1.0 DESCRIPTION

................................................................................................................... 2

2.0 ASSESSMENT

................................................................................................................... 2 2.1 Applicability of Safety Evaluation.................................................................................... 2 2.2 Variations........................................................................................................................ 2 2.2.1 ANO-1 Variations.................................................................................................... 2 2.2.2 ANO-2 Variations.................................................................................................... 3 2.2.3 GGNS Variations..................................................................................................... 3 2.2.4 RBS Variations........................................................................................................ 3 2.2.5 WSES Variations..................................................................................................... 3

3.0 REGULATORY ANALYSIS

................................................................................................ 4 3.1 No Significant hazard consideration............................................................................... 4 3.2 Conclusion...................................................................................................................... 5

4.0 ENVIRONMENTAL CONSIDERATION

............................................................................. 6

5.0 REFERENCES

................................................................................................................... 6 6.0 ATTACHMENTS................................................................................................................ 6

CNRO2024-00022 Enclosure Page 2 of 7 EVALUATION OF THE PROPOSED CHANGE

1.0 DESCRIPTION

Entergy Operations Inc. (Entergy) requests adoption of TSTF-591, "Revise Risk Informed Completion Time (RICT) Program," which is an approved change to the Standard Technical Specifications (STS), into the Arkansas Nuclear One Units 1 and 2 (ANO-1/2), River Bend Station Unit 1 (RBS), Grand Gulf Nuclear Station Unit 1 (GGNS), and Waterford Steam Electric Station Unit 3 (WSES) Technical Specifications (TS). TSTF-591 revises the TS Section 5.5 Program, "Risk Informed Completion Time Program," to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of newly developed methods used to calculate a RICT.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation Entergy has reviewed the safety evaluation for TSTF-591 provided to the Technical Specifications Task Force (TSTF) in a letter dated September 21, 2023 (Reference 1). This review included the NRC staffs evaluation, as well as the information provided in TSTF-591.

Entergy has concluded that the justifications presented in TSTF-591 and the safety evaluation prepared by the NRC staff are applicable to ANO-1/2, RBS, GGNS, and WSES and justify this amendment for the incorporation of the changes to the ANO-1/2, RBS, GGNS, and WSES TS.

The ANO2 and WSES TSs are based on NUREG-0212, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors," (Reference 2). As such, the TS numbering generally differs from that of the current STS, and the actual TS wording may also differ. ANO2 and WSES have implemented TSTFs Travelers based on NUREG-1432 STS (Reference 3) in the past by adapting the wording from the TSTF Traveler to the current TS format and verifying that it continues to meet the intent of the applicable TSTF Traveler NRC safety evaluation Report (SER). The same has been done for TSTF-591.

This application contains no changes to each sites Probabilistic Risk Analysis (PRA) models that would be considered a Newly Developed Method, in accordance with the Pressurized Water Reactor Owners Group (PWROG) topical report, PWROG-19027-NP, Revision 2, Newly Developed Method Requirements and Peer Review, issued July 2020 (Reference 4), as endorsed in RG 1.200 Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, Revision 3 (Reference 5).

2.2 Variations 2.2.1 ANO-1 Variations The ANO-1 TS utilize different numbering than the STS on which TSTF-591 was based.

Specifically, the Risk Informed Completion Time Program is contained in TS 5.5.18 rather than 5.5.20 as shown in the TSTF-591 SER. These differences are administrative and do not affect the applicability of TSTF-591 to the ANO-1 TS.

CNRO2024-00022 Enclosure Page 3 of 7 2.2.2 ANO-2 Variations ANO-2 TS utilize different numbering than the STS on which TSTF-591 was based.

Specifically, the Risk Informed Completion Time Program is contained in TS 6.5.20 rather than 5.5.20 as shown in the TSTF-591 SER. Additionally, the new RICT Program Report is created using TS 6.6.9 rather than TS 5.6.8 as shown in the TSTF-591 SER. The differences for the proposed change are administrative and do not affect the applicability of TSTF-591 to the ANO-2 TS.

2.2.3 GGNS Variations GGNS TS utilize different numbering than the STS on which TSTF-591 was based. Specifically, the Risk Informed Completion Time Program is contained in TS 5.5.14 rather than 5.5.17 as shown in the TSTF-591 SER. Additionally, the new RICT Program Report is created using TS 5.6.8 rather than TS 5.6.7 as shown in the TSTF-591 SER. The differences for the proposed change are administrative and do not affect the applicability of TSTF-591 to the GGNS TS.

2.2.4 RBS Variations RBS TS utilize different numbering than the STS on which TSTF-591 was based. Specifically, the Risk Informed Completion Time Program is contained in TS 5.5.16 rather than 5.5.17 as shown in the TSTF-591 SER. Additionally, the new RICT Program Report is created using TS 5.6.6 rather than TS 5.6.7 as shown in the TSTF-591 SER. The differences for the proposed change are administrative and do not affect the applicability of TSTF-591 to the RBS TS.

2.2.5 WSES Variations WSES TS utilize different numbering than the STS on which TSTF-591 was based. Specifically, the Risk Informed Completion Time Program is contained in TS 6.5.19 rather than 5.5.20 as shown in the TSTF-591 SER. Additionally, the new RICT Program Report is created using TS 6.9.3 rather than TS 5.6.8 as shown in the TSTF-591 SER. The differences for the proposed change are administrative and do not affect the applicability of TSTF-591 to the WSES TS.

CNRO2024-00022 Enclosure Page 4 of 7

3.0 REGULATORY ANALYSIS

3.1 No Significant hazard consideration Entergy Operations Inc. (Entergy) requests adoption of TSTF-591, "Revise Risk Informed Completion Time (RICT) Program," which is an approved change to the Standard Technical Specifications (STS), into the Arkansas Nuclear One Units 1 and 2 (ANO-1/2), River Bend Station Unit 1 (RBS), Grand Gulf Nuclear Station Unit 1 (GGNS), and Waterford Steam Electric Station Unit 3 (WSES) Technical Specifications (TS). TSTF-591 revises the TS Section 5.5 Program, "Risk Informed Completion Time Program," to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, "Reporting Requirements," to inform the NRC of newly developed methods used to calculate a RICT. Administrative numbering differences exist between the plant specific TS and the STS Section numbers listed above.

Entergy has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change updates the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed method is used.

The proposed change does not involve a significant increase in the probability of an accident previously evaluated because the change involves no change to the plant or its modes of operation. The proposed change does not increase the consequences of an accident because the design-basis mitigation function of the affected systems is not changed and the consequences of an accident during the extended Risk Informed Completion Time are no different from those during the existing Completion Time. The submittal of information-only reports has no effect on the initiators or consequences of any accidents previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change updates the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3.

A new report is added to inform the NRC when a newly developed method is used. The proposed change does not change a design function or method of operation of the plant.

CNRO2024-00022 Enclosure Page 5 of 7 The proposed change does not involve a physical alteration of the plant (no new or different kind of equipment will be installed).

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change updates the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed method is used.

The proposed change supports the extension of Completion Times provided risk is assessed and managed in accordance with the NRC-approved RICT Program. The proposed change does not alter any design basis or safety limits. The proposed change affects the standard used to maintain the PRA models used in the RICT Program by changing from one NRC-approved standard to a later NRC-approved version and requiring submittal of an information-only report. The RICT Program will continue to assure that adequate margins of safety are maintained.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions 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.

CNRO2024-00022 Enclosure Page 6 of 7

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

5.0 REFERENCES

1. US NRC letter to the Technical Specifications Task Force, "Final Safety Evaluation of Technical Specifications Task Force Traveler TSTF-591, Revision 0, Revise Risk-Informed Completion Time (RICT) Program," ML23262B230, dated September 21, 2023.

2. NUREG-0212, Revision 3, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors," dated December 1981.

3. NUREG-1432, Revision 5.0, "Standard Technical specifications, Combustion Engineering Plants," ML21258A421, dated September 2021.

4. PWROG Topical Report, PWROG-19027, Revision 2, Newly Developed Method Requirements and Peer Review, (ML20213C660) dated July 2020.

5. Regulatory Guide 1.200, Revision 3, Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities, dated December 30, 2022.

6.0 ATTACHMENTS

1.

ANO-1

- Technical Specification Pages Markups

2.

ANO-2

- Technical Specification Pages Markups

3.

GGNS

- Technical Specification Pages Markups

4.

RBS

- Technical Specification Pages Markups

5.

WSES

- Technical Specification Pages Markups

6.

ANO Technical Specification Pages Retyped

7.

ANO Technical Specification Pages Retyped

CNRO2024-00022 Enclosure Page 7 of 7

8.

GGNS - Technical Specification Pages Retyped

9.

RBS - Technical Specification Pages Retyped

10. WSES - Technical Specification Pages Retyped

Enclosure, Attachment 1 CNRO2024-00022 ANO Technical Specification Pages Markups (4 Pages Follows)

Programs and Manuals 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals 5.5.17 5.5.18 ANO-1 Metamic Coupon Sampling Program A coupon surveillance program will be implemented to maintain surveillance of the Metamic absorber material under the radiation, chemical, and thermal environment of the SFP. The purpose of the program is to establish the following:

• Coupons will be examined on a two year basis for the first three intervals with the first coupon retrieved for inspection being on or before February 2009 and thereafter at increasing intervals over the service life of the inserts.

• Measurements to be performed at each inspection will be as follows:

A)

Physical observations of the surface appearance to detect pitting, swelling or other degradation, B)

Length, width, and thickness measurements to monitor for bulging and swelling C) Weight and density to monitor for material loss, and D)

Neutron attenuation to confirm the B-10 concentration or destructive chemical testing to determine the boron content.

• The provisions of SR 3.0.2 are applicable to the Metamic Coupon Sampling Program.

• The provisions of SR 3.0.3 are not applicable to the Metamic Coupon Sampling Program.

Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a.

The RICT may not exceed 30 days;

b.

A RICT may only be utilized in MODE 1 and 2; 5.0-20 Amendment No. ~.~.2W,281 For information only. No change is made to this page. Included for information to show the appropriate numbering.

Programs and Manuals 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals ANO-1

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e.

The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

5.0-20a Amendment No. 281

e. A RICT calculation must include the following hazard groups: internal flood and internal events using a PRA model, internal fires using a PRA model, seismic hazards using penalty factors, and configuration specific extreme winds and tornado hazards using penalty factors. 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 5.6.8 before a newly developed method is used to calculate a RICT.

Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 Reporting Requirements 5.6.6 5.6.7 Reactor Building Inspection Report Any degradation exceeding the acceptance criteria of the containment structure detected during the tests required by the Containment Inspection Program shall undergo an engineering evaluation within 60 days of the completion of the inspection surveillance. The results of the engineering evaluation shall be reported to the NRC within an additional 30 days of the time the evaluation is completed. The report shall include the cause of the condition that does not meet the acceptance criteria, the applicability of the conditions to the other unit, the acceptability of the concrete containment without repair of the item, whether or not repair or replacement is required and, if required, the extent, method, and completion date of necessary repairs, and the extent, nature, and frequency of additional examinations.

Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.9, "Steam Generator (SG) Program." The report shall include:

a.

The scope of inspections performed on each SG;

b.

The nondestructive examination techniques utilized for tubes with increased degradation susceptibility;

c.

For each degradation mechanism found:

1.

The nondestructive examination techniques utilized;

2.

The location, orientation (if linear), measured size (if available), and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported;

3.

A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and

4.

The number of tubes plugged during the inspection outage.

d.

An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results; ANO-1 5.0-23 Amendment No. 24-a,',',250,258,273 For information only. No change is made to this page. Included for information to show the appropriate numbering.

AN0-1 Reporting Requirements 5.6

e.

The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG; and

f.

The results of any SG secondary side inspections.

5.0-23a Amendment No. 273 5.6.8 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.

Enclosure, Attachment 2 CNRO2024-00022 ANO Technical Specification Pages Markups (2 Pages Follows)

6.5.20 Risk Informed Completion Time Program (continued)

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e.

The risk assessment approaches and methods shall be acceptable to the NRC.

The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

ARKANSAS - UNIT 2 6-18c Amendment No. 333

e. A RICT calculation must include the following hazard groups: internal flood and internal events using a PRA model, internal fires using a PRA model, seismic hazards using penalty factors, and configuration specific extreme winds and tornado hazards using penalty factors. 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 6.6.9 before a newly developed method is used to calculate a RICT.

ADMINISTRATIVE CONTROLS 6.6.8 Specific Activity The results of specific activity analysis in which the primary coolant exceeded the limits of Specification 3.4.8. The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2) Results of the last isotopic analysis for radioiodine performed prior to exceeding the limit, results of analysis while limit was exceeded the results of one analysis after the radioiodine activity was reduced to less than limit. Each result should include date and time of sampling and the radioiodine concentrations; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) Graph of the 1-131 concentration and one other radioiodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primarycoolant exceeded the radioiodine limit.

ARKANSAS - UNIT 2 6-22a Amendment No. 326 6.6.9 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

Enclosure, Attachment 3 CNRO2024-00022 GGNS - Technical Specification Pages Markups (3 Pages Follows)

5.5 Programs and Manuals Programs and Manuals 5.5 5.5.13 Control Room Envelope Habitability Program (continued)

1.

Plant maintenance activities such as modifications, rework, and preventive maintenance tasks on components that could affect the CRE shall be controlled under fleet, plant and system specific procedures to ensure that the CRE boundary is not degraded by such activities.

2.

Testing of CRFA system sealing areas shall be performed following maintenance activities (rework and preventative) and periodically to ensure that the areas of negative pressures do not leak bypassing emergency filtration system components.

3.

Fire damper inspection procedures that require opening of duct panels and doors shall ensure that upon restoration no leakage path exists.

4.

The remainder of ducting components such as plenum access doors, duct access doors (rectangular and round), flex connections (ventglass, etc), plugs, and patches will be maintained per paragraph b.

5.

An assessment of the CRE Boundary will be conducted at a frequency in accordance with the Surveillance Frequency Control Program. The results of assessing items 1 through 4 shall be trended and used as part of the assessment of the CRE boundary as indicated in paragraph c.

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by testing described in paragraph c. The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of DBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.14 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a.

The RICT may not exceed 30 days;

b.

A RICT may only be utilized in MODES 1 and 2; GRAND GULF 5.0-16b Amendment No. 178, 219, 227, 234 For information only. No change is made to this page. Included for information to show the appropriate numbering.

5.5 Programs and Manuals Programs and Manuals 5.5 5.5.14 Risk Informed Completion Time Program (continued)

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,

not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the functions(s) performed by the inoperable SSCs.

e.

The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program in Amendment No. 234, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

GRAND GULF 5.0-16c Amendment No. 234

e. A RICT calculation must include the following hazard groups: internal flood and internal events using a PRA model, internal fires using a PRA model, and seismic hazards using penalty factors. 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 5.6.8 before a newly developed method is used to calculate a RICT.

Reporting Requirements 5.6 GRAND GULF 5.0-21a Amendment No. 191, 205 5.6 Reporting Requirements 5.6.6 Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)

a.

RCS pressure and temperature limits for heatup, cooldown, low temperature operation, criticality, and hydrostatic testing as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:

i)

Limiting Conditions for Operations Section 3.4.11, RCS Pressure and Temperature (P/T) Limits ii)

Surveillance Requirements Section 3.4.11, RCS Pressure and Temperature (P/T) Limits

b.

The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following document:

i)

NEDC-33178P-A, GE Hitachi Nuclear Energy Methodology for Development of Reactor Pressure Vessel Temperature Curves Revision 1, June 2009

c.

The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

5.6.7 Oscillation Power Range Monitor (OPRM) Report When an OPRM report is required by CONDITION J of LCO 3.3.1.1, RPS Instrumentation, it shall be submitted within the following 90 days.

The report shall outline the preplanned means to provide backup stability protection, the cause of the inoperability, and the plans and schedule for restoring the required instrumentation channels to OPERABLE status.

5.6.8 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.

Enclosure, Attachment 4 CNRO2024-00022 RBS

- Technical Specification Pages Markups (3 Pages Follows)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.14 5.5.15 5.5.16 RIVER BEND Control Room Envelope Habitability Program (continued)

d.

Measurement, at designated locations, of the CRE pressure relative to all external areas adjacent to the CRE boundary during the pressurization mode of operation by one subsystem of the CRFA System, operating at the flow rate required by the VFTP, at a Frequency in accordance with the Surveillance Frequency Control Program. The results shall be trended and used as part of the CRE boundary assessment specified in 5.5.14.c (ii).

e.

The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences. Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f.

The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

Spent Fuel Storage Rack Neutron Absorber Monitoring Program This program provides controls for monitoring the condition of the neutron absorber inserts used in the high density storage racks in the spent fuel storage facility in the Fuel Building to verify the Boron-10 areal density is consistent with the assumptions in the spent fuel pool criticality analysis. The program shall be in accordance with NEI 16-03-A, "Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools," Revision 0, May 2017.

Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a.

The RICT may not exceed 30 days;

b.

A RICT may only be utilized in MODES 1 and 2; (continued) 5.0-16b Amendment No. 196, 201, 213 I For information only. No change is made to this page. Included for information to show the appropriate numbering.

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.16 RIVER BEND Risk Informed Completion Time Program (continued)

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,

not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the functions(s) performed by the inoperable SSCs.

e.

The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program in Amendment No. 213, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

5.0-16c Amendment No. 213 I

e. A RICT calculation must include the following hazard groups: internal flood and internal events using a PRA model, internal fires using a PRA model, and seismic hazards using penalty factors. 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 5.6.6 before a newly developed method is used to calculate a RICT.

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

RIVER BEND

24)

NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel (GESTAR-11)".

25)

NEDC-33383P, "GEXL97 Correlation Applicable to ATRIUM-10 Fuel," Global Nuclear Fuel.

c.

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SOM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRG.

5.0-19 Amendment No. 81 96 99 100 105 106 -22, 166 5.6.6 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.

Enclosure, Attachment 5 CNRO2024-00022 WSES - Technical Specification Pages Markups (2 Pages Follows)

ADMINISTRATIVE CONTROLS 6.5.19 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a.

The RICT may not exceed 30 days;

b.

A RICT may only be utilized in MODES 1 and 2;

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e.

The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

WATERFORD - UNIT 3 6-10 AMENDMENT NO. a43; 270

e. A RICT calculation must include the following hazard groups:

internal flood and internal events using a PRA model, internal fires using a PRA model, and seismic hazards using penalty factors.

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 6.9.3 before a newly developed method is used to calculate a RICT.

ADMINISTRATIVE CONTROLS CORE OPERA TING LIMITS REPORT COLR (Continued) 6.9.1.11.2 The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown margin, and transient and accident analysis limits) of the safety analysis are met.

6.9.1.11.3 The CORE OPERATING LIMITS REPORT, including any mid-cycle revisions or supplements thereto, shall be provided upon issuance, for each reload cycle, to the NRC.

SPECIAL REPORTS 6.9.2 Special reports shall be submitted in accordance with 1 O CFR 50.4 within the time period specified for each report.

6.10 Not Used WATERFORD - UNIT 3 6-20b AMENDMENT NO. 200, 2-14 226 Risk Informed Completion Time (RICT) Program Upgrade Report 6.9.3 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.

Enclosure, Attachment 6 CNRO2024-00022 ANO Technical Specification Pages Retyped (2 Pages Follows)

Programs and Manuals 5.5 ANO-1 5.0-20a Amendment No. 281 ADMINISTRATIVE CONTROLS 5.5 Programs and Manuals

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e.

A RICT calculation must include the following hazard groups: internal flood and internal events using a PRA model, internal fires using a PRA model, seismic hazards using penalty factors, and configuration specific extreme winds and tornado hazards using penalty factors. 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 off Probabilistic Risk Assessment Results for Risk-Informed Activities."

g.

A report shall be submitted in accordance with Specification 5.6.8 before a newly developed method is used to calculate a RICT.

Programs and Manuals 5.5 ANO-1 5.0-23a Amendment No. 273

e.

The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG; and

f.

The results of any SG secondary side inspections.

5.6.8 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.

Enclosure, Attachment 7 CNRO2024-00022 ANO Technical Specification Pages Retyped (2 Page Follows)

ARKANSAS - UNIT 2 6-18c Amendment No. 333 6.5.20 Risk Informed Completion Time Program (continued)

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e.

A RICT calculation must include the following hazard groups: internal flood and internal events using a PRA model, internal fires using a PRA model, seismic hazards using penalty factors, and configuration specific extreme winds and tornado hazards using penalty factors. 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 6.6.9 before a newly developed method is used to calculate a RICT.

ARKANSAS - UNIT 2 6-22a Amendment No. 326 ADMINISTRATIVE CONTROLS 6.6.8 Specific Activity The results of specific activity analysis in which the primary coolant exceeded the limits of Specification 3.4.8. The following information shall be included: (1) Reactor power history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (2) Results of the last isotopic analysis for radioiodine performed prior to exceeding the limit, results of analysis while limit was exceeded the results of one analysis after the radioiodine activity was reduced to less than limit. Each result should include date and time of sampling and the radioiodine concentrations; (3) Clean-up system flow history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in which the limit was exceeded; (4) Graph of the I-131 concentration and one other radioiodine isotope concentration in microcuries per gram as a function of time for the duration of the specific activity above the steady-state level; and (5) The time duration when the specific activity of the primarycoolant exceeded the radioiodine limit.

6.6.9 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

Enclosure, Attachment 8 CNRO2024-00022 GGNS - Technical Specification Pages Retyped (3 Pages Follows)

Programs and Manuals 5.5 GRAND GULF 5.0-16c Amendment No. 234 5.5 Programs and Manuals 5.5.14 Risk Informed Completion Time Program (continued)

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,

not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the functions(s) performed by the inoperable SSCs.

e.

A RICT calculation must include the following hazard groups: internal flood and internal events using a PRA model, internal fires using a PRA model, and seismic hazards using penalty factors. 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 5.6.8 before a newly developed method is used to calculate a RICT.

Reporting Requirements 5.6 GRAND GULF 5.0-21a Amendment No. 191, 205 5.6 Reporting Requirements 5.6.6 Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)

a.

RCS pressure and temperature limits for heatup, cooldown, low temperature operation, criticality, and hydrostatic testing as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:

i)

Limiting Conditions for Operations Section 3.4.11, RCS Pressure and Temperature (P/T) Limits ii)

Surveillance Requirements Section 3.4.11, RCS Pressure and Temperature (P/T) Limits

b.

The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following document:

i)

NEDC-33178P-A, GE Hitachi Nuclear Energy Methodology for Development of Reactor Pressure Vessel Temperature Curves Revision 1, June 2009

c.

The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

5.6.7 Oscillation Power Range Monitor (OPRM) Report When an OPRM report is required by CONDITION J of LCO 3.3.1.1, RPS Instrumentation, it shall be submitted within the following 90 days. The report shall outline the preplanned means to provide backup stability protection, the cause of the inoperability, and the plans and schedule for restoring the required instrumentation channels to OPERABLE status.

5.6.8 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 coonsistent 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

Reporting Requirements 5.6 GRAND GULF 5.0-21b Amendment No.

5.6 Reporting Requirements 5.6.8 Risk Informed Completion Time (RICT) Program Upgrade Report (continued)

d.

All changes to key assumptions related to newly developed methods or their implementation.

Enclosure, Attachment 9 CNRO2024-00022 RBS - Technical Specification Pages Retyped (2 Pages Follows)

Program Manuals 5.5

RIVER BEND 5.0-16c Amendment No. 213 5.5 Programs and Manuals 5.5.16 Risk Informed Completion Time Program (continued)

c. When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,

not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the functions(s) performed by the inoperable SSCs.

e.

A RICT calculation must include the following hazard groups: internal flood and internaal events using a PRA model, internal fires using a PRA model, and seismic hazards using penalty factors. 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 5.6.6 before a newly developed method is used to calculate a RICT.

Reporting Requirements 5.6

RIVER BEND 5.0-19 Amendment No. 81 96 99 100 105 105 122, 166

5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

24)

NEDE-24011-P-A, General Electric Standard Application for Reactor Fuel (GESTAR-II).

25)

NEDC-33383P, GEXL97 Correlation Applicable to ATRIUM-10 Fuel, Global Nuclear Fuel.

c.

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.6 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.

Enclosure, Attachment 10 CNRO2024-00022 WSES - Technical Specification Pages Retyped (3 Page Follows)

Waterford - UNIT 3 6-10 Amendment No. 218, 270 ADMINISTRATIVE CONTROLS 6.5.19 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a.

The RICT may not exceed 30 days;

b.

A RICT may only be utilized in MODES 1 and 2;

c.

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3. Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2. Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e.

A RICT calculation must include the following hazard groups: internal flood and internal events using a PRA model, internal fires using a PRA model, seismic hazards using penalty factors. 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."

Waterford - UNIT 3 6-10a Amendment No.

ADMINISTRATIVE CONTROLS 6.5.19 Risk Informed Completion Time Program (Continued)

g.

A report shall be submitted in accordance with Specification 6.9.3 before a newly developed method is used to calculate a RICT.

Waterford - UNIT 3 6-20b Amendment No. 200, 214, 226 ADMINISTRATIVE CONTROLS CORE OPERATING LIMITS REPORT COLR (Continued) 6.9.1.11.2 The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown margin, and transient and accident analysis limits) of the safety analysis are met.

6.9.1.11.3 The CORE OPERATING LIMITS REPORT, including any mid-cycle revisions or supplements thereto, shall be provided upon issuance, for each reload cycle, to the NRC.

SPECIAL REPORTS 6.9.2 Special reports shall be submitted in accordance with 10 CFR 50.4 within the time period specified for each report.

Risk Informed Completion Time (RICT) Program Upgrade Report 6.9.3 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.

6.10 Not Used