Text

TSTF Comments on Draft Safety Evaluation for Traveler TSTF-567, Revision 1, Add Containment Sump TS to Address GSI-191 Issues.
	ML18106B172
Person / Time
Site:	Technical Specifications Task Force
Issue date:	04/16/2018
From:	Gullott D, Miksa J, Sparkman W, Vaughan J, Linda Williams; BWR Owners Group, Babcock & Wilcox, Combustion Engineering, PWR Owners Group, Technical Specifications Task Force, Westinghouse
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-18-04
	Download: ML18106B172 (37)
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TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY April 16, 2018 TSTF-18-04 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

TSTF Comments on Draft Safety Evaluation for Traveler TSTF-567, Revision 1, "Add Containment Sump TS to Address GSI-191 Issues"

REFERENCE:

Letter Victor Cusumano (NRC) to the TSTF, "Draft Safety Evaluation of Technical Specifications Task Force Traveler TSTF-567, Revision 1, 'Add Containment Sump TS to Address GSI-191 Issues'," dated March 26, 2018 (ADAMS Accession No. ML17341A333).

On August 2, 2017, the TSTF submitted traveler TSTF-567, Revision 1, "Add Containment Sump TS to Address GSI-191 Issues," to the Nuclear Regulatory Commission (NRC) for review (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17214A813). In the referenced letter, the NRC provided the draft Safety Evaluations for TSTF-567for comment.

Attachment 1 contains a summary table providing the TSTF's comments on the draft Safety Evaluations. Attachment 2 contains a mark-up reflecting the TSTF's comments.

Should you have any questions, please do not hesitate to contact us.

James P. Miksa (PWROG/CE) Lisa L. Williams (BWROG)

David M. Gullott (PWROG/W) Jordan L. Vaughan (PWROG/B&W)

Wesley Sparkman (APOG) 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation TSTF Comments on the TSTF-567 Draft Safety Evaluations TSTF Markup of Draft Safety Evaluations cc: Michelle Honcharik, Technical Specifications Branch, NRC Robert Tjader, Technical Specifications Branch, NRC Victor Cusumano, Technical Specifications Branch, NRC

Attachment 1 TSTF Comments on the TSTF-567 Draft Safety Evaluations General Comments

1. The two Safety Evaluations (SEs) contain in multiple locations, the term "Limiting Condition for Operation" or "LCO" instead of the correct term "Technical Specifications" or "TS." The TS for a system consist of the LCO, Applicability, Actions, and Surveillance Requirements (SRs). The LCO section of the TS provides a detailed statement describing the LCO. For example, an SR is part of a TS, not part of an LCO. The only exception to the use of this terminology is the discussion of the Required Action B.1 Note. The Standard Technical Specifications (STS) convention is to state, "Enter applicable Conditions and Required Actions of LCO 3.X.X." While technically incorrect, this convention is well established in the STS and is not altered in the traveler. Discussion in the SEs of this note should use terminology consistent with the TS. The recommended changes are shown in the documents.

2. The TSTF-567, Revision 1, change to the Safety Function Determination Program, TS 5.5.15, is plant-specific based on applicability (i.e. LCO 3.0.6 and the SFDP have been incorporated into the plant specific TS) and previous adoption of TSTF-273, and therefore it is denoted as optional in TSTF-567. The language was previously approved by the NRC as TSTF-273, Revision 2, "SFDP Clarifications," on August 16, 1999, and has been included in the STS. Therefore, this change does not need to be discussed in staff's SE of the incorporation of the traveler into the STS, but should be included as an optional change in the model plant-specific SE. Recommended changes are shown in the documents.

3. The SE discussions of the optional inclusion of a Risk Informed Completion Time (RICT) for Required Action B.1 present the RICT as a replacement for the Completion Time.

However, the RICT is an additional, optional Completion Time. The recommended changes are shown in the documents.

4. TSTF-567, Revision 1, states that the Completion Time for Required Action B.1 is plant-specific. The Completion Time should be the less restrictive (i.e., longer) of the Completion Times for a single inoperable ECCS train or CSS train. This allows the ECCS and CSS Required Actions to control the licensee's actions if the sump is inoperable for reasons other than containment accident generated and transported debris exceeding the analyzed limits.

For some licensees, the Completion Time for a single inoperable CSS train is 7 days, not 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (consistent with NUREG-1431, TS 3.6.6B, Condition A). For those licensees, the containment sump Required Action B.1 Completion Time would be 7 days instead of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This aspect of the traveler is not discussed in the SEs and has been added.

Page 3

Comments on the Traveler Draft Safety Evaluation Page(s) Line(s)1 Comment 1 17 Changed "STSs" to "STS." This term "Standard Technical Specifications" is already plural.

1 19, 20, The traveler SE evaluates changing the STS, which includes the Bases.

footnote Added discussions of the Bases changes and added STS Volume 2 references.

1 22,23,25 See General Comment 1.

1 24 See General Comment 2.

1 23 Add spaces to be consistent with the STS title.

1 29,30 The discussion of the applicability of TSTF-567 is not relevant to the traveler SE. Moved the discussion to the model SE.

2 6 Editorial recommendations.

2 10, 25, See General Comment 1.

28, 44, 47, 49 3 1-8 See General Comment 2.

3 12, 14, See General Comment 1 17, 19, 30, 31, 35, 37, 38, 42, 43 3 10 Changed "STSs" to "STS." This term "Standard Technical Specifications" is already plural.

3 38 The Section 2.2.2 discussion of SR TS 3.5.3.1 implies it only references one TS 3.5.2 SR. A clarification is made.

3 31, 44, The traveler SE evaluates changing the STS, which includes the Bases.

45 Added discussions of the Bases changes.

3 42 Editorial recommendations.

4 1-12 See General Comment 2.

4 14, 16, See General Comment 1.

17, 42, 46, 47 4 17-25 Editorial recommendations.

4 34 Editorial correction. The term CSS had not been previously defined.

4 48-49 The traveler SE evaluates changing the STS, which includes the Bases.

Added discussions of the Bases.

5 1 Changed "STSs" to "STS." This term "Standard Technical Specifications" is already plural.

1 Line numbers correspond to the attached proposed revision, not to the documents provided by the NRC.

Page 4

Page(s) Line(s)1 Comment 5 2 The traveler SE evaluates changing the STS, which includes the Bases.

Added discussions of the Bases changes and added STS Volume 2 references.

5 2 See General Comment 1.

5 36 Changed "STSs" to "STS." This term "Standard Technical Specifications" is already plural.

6 17, 18, The traveler SE evaluates changing the STS, which includes the Bases.

19 Added discussions of the Bases.

6 27-28 Changed "STSs" to "STS." This term "Standard Technical Specifications" is already plural.

6 38, 41 See General Comment 1.

7 5, 12 See General Comment 1.

7 7-8 Editorial correction. The phrase "as well as" appears to be incorrect.

7 24-50 See General Comment 2.

8 1-14 See General Comment 2.

8 16, 18, See General Comment 1.

20, 21, 22, 30, 40, 46, 47, 50 8 26-27 The traveler SE evaluates changing the STS, which includes the Bases.

Added discussions of the Bases changes.

9 12 Editorial recommendation.

9 20 Deleted the term "degraded or nonconforming" to describe conditions.

That term is used in IMC-0326 related to operability determinations, and in this situation the sump has already been determined to be inoperable.

Using that term will be confusing and is unnecessary.

9 24 The traveler SE evaluates changing the STS, which includes the Bases.

Added discussions of the Bases changes.

10 50 Editorial recommendation.

11 1, 3, 4, See General Comment 4.

5, 6, 25, 26, 27 11 12, 13, See General Comment 3.

16, 31 11 31, 32, Editorial correction. As originally worded, the SE implies that two LARs 33 would be required: one to adopt TSTF-567 and one to add the RICT. The intent is that a single plant-specific LAR is required.

11 50, 51 See General Comment 1.

12 14 Changed "STSs" to "STS." This term "Standard Technical Specifications" is already plural.

12 21, 22, See General Comment 1.

30, 32 Page 5

Page(s) Line(s)1 Comment 12 24-28, The traveler SE evaluates changing the STS, which includes the Bases.

38, 46, Added discussions of the Bases changes.

51 Page 6

Comments on the Draft Model Safety Evaluation Page(s) Line(s)2 Comment 1 23, 24, See General Comment 1.

26 1 24, 25, See General Comment 2.

26 1 25 Per the STS Writer's Guide Section 2.1.1, 5.5.15 is a specification, not a section.

1 34,35 Relocated the discussion of the applicability of the change from the traveler SE to the model SE.

2 6,7 Editorial recommendation.

2 11, 26, See General Comment 1.

30, 46 3 1, 3, 22, See General Comment 1.

24, 27, 29, 38, 39, 43, 45, 48, 49 3 7, 8, 10, See General Comment 2.

12-18, 22, 23 3 10, 12, Per the STS Writer's Guide Section 2.1.1, 5.5.15 is a specification, not a 23 section.

4 3-4, See General Comment 2.

6-16 4 6, 9 Per the STS Writer's Guide Section 2.1.1, 5.5.15 is a specification, not a section.

4 18, 20, See General Comment 1.

43 4 24-27 Recommended editorial improvement.

4 31 See General Comment 3.

4 36 The acronym CSS had not been previously defined.

4 50-51 Instead of requiring the reviewer to develop a justification for applying 5 1-2 the containment sump to plants with more than one sump, recommend using the existing justification for this design in the traveler SE.

5 3, 9 See General Comment 1.

5 5, 6, 8, 9 Whether the Table of Contents is part of the license is plant-specific.

Recommend making the discussion of the Table of Contents optional and added a Reviewer's Note.

2 Line numbers correspond to the attached proposed revision, not to the documents provided by the NRC.

Page 7

Page(s) Line(s)2 Comment 5 33-51 Recommended that the model SE include optional discussions of all the 6 1-14 optional variations included in the TSTF-567, Revision 1, model application.

6 17 See General Comment 3.

7 8-10, The licensee submittal included Bases changes for information, 23-25, conforming with the regulation. Recommend that the requirement for 28-30, Bases and the STS Bases be included in the model SE discussion.

33-35 7 39, 41, See General Comment 1.

42 8 8, 13 See General Comment 1.

8 28 Per the STS Writer's Guide Section 2.1.1, 5.5.15 is a specification, not a section.

8 25, 26, See General Comment 2.

28-50 9 1-18 9 8, 13 Corrected TS number.

9 20, 22, See General Comment 1.

24, 25, 28, 37, 48, 49 9 45-46 Added a reviewer's note pointing to the acceptance applicability variation.

10 2 See General Comment 1.

10 14 Editorial recommendation.

10 22 Deleted the term "degraded or nonconforming" to describe conditions.

That term is used in IMC-0326 related to operability determinations, and in this situation the sump has already been determined to be inoperable.

Using that term will be confusing and is unnecessary.

10 26, 27 The following list was in the TS Bases. As the list contains examples, it is not inappropriate to discuss Bases content.

11 33, 34, A key sentence from the traveler and traveler SE is added to the model 35 SE.

11 49 See General Comment 1.

11 50 Editorial recommendation.

12 1-5, 18 See General Comment 4.

12 5, 13 See General Comment 3.

12 24, 25, Added a reviewer's note pointing to an allowable variation for a Mode 4 29 end state.

12 32 Changed "STSs" to "STS." This term "Standard Technical Specifications" is already plural.

12 39, 40 See General Comment 1.

Page 8

Page(s) Line(s)2 Comment 13 7,8, Whether the Table of Contents is part of the license is plant-specific.

10-14 Recommend making the discussion of the Table of Contents optional and added a Reviewer's Note.

13 13, 14, See General Comment 1.

23, 25 13 16-21, The plant-specific SE should acknowledge the Bases were provided and 23 met the description in 50.36(a). This allows the licensee to reference the TS SE in the Bases change made under the TS Bases Control Program.

13 43, 45 Revised the referenced regulations to be consistent with the traveler SE.

Added a missing parenthesis.

13 49 Added braces to be consistent with other italicized directions.

14 7, 8, 12, Added braces to be consistent with other italicized directions.

23, 24 Page 9

Attachment 2 TSTF Markup of Draft Safety Evaluations

1 2 DRAFT SAFETY EVALUATION 3 BY THE OFFICE OF NUCLEAR REACTOR REGULATION 4 TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 5 TSTF-567, REVISION 1 6 ADD CONTAINMENT SUMP TS TO ADDRESS GSI-191 ISSUES 7 USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 8 (CAC NO. MF9568, EPID L-2017-PMP-0005) 9 10 11

1.0 INTRODUCTION

12 13 By letter dated August 2, 2017 (Agencywide Documents Access and Management System 14 (ADAMS) Accession No. ML17214A813), the Technical Specifications Task Force (TSTF) 15 submitted Traveler TSTF-567, Revision 1, Add Containment Sump TS [Technical Specification]

16 to Address GSI [Generic Safety Issue]-191 Issues. Traveler TSTF-567, Revision 1, proposes 17 changes to the Standard Technical Specifications (STSs) for pressurized-water reactor (PWR) 18 designs.1 These changes would be incorporated into future revisions of NUREG-1430, 19 Volume 1, NUREG-1431, Volume 1, and NUREG-1432 , Volume 1. Associated changes are 20 also made to the TS BasesThere were no bases changes proposed.

21 22 The proposed changes would revise STS Limiting Condition for Operation (LCO) 3.5.2, ECCS 23 [Emergency Core Cooling System] - Operating, and TSLCO 3.5.3, ECCS - Shutdown., and 24 TS Section 5.5.15, Safety Function Determination Program (SFDP). The proposed changes 25 would also add a new TS TSLCO, Containment Sump, to Section 3.6, Containment Systems.

26 This STS change will be made available to licensees through the consolidated line item 27 improvement process (CLIIP).

28 29 Revision 1 of TSTF-567 is not applicable to non-STS plants due to its dependence on 30 LCO 3.0.6 and the SFDP.

31 1 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Babcock and Wilcox Plants, NUREG-1430, Volume 1, Specifications, and Volume 2, "Bases," Revision 4.0, April 2012 (ADAMS Accession Nos. ML12100A177 and ML12100A178).

U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse Plants, NUREG-1431, Volume 1, Specifications, and Volume 2, "Bases," Revision 4.0, April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228).

U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Combustion Engineering Plants, NUREG-1432, Volume 1, Specifications, and Volume 2, "Bases," Revision 4.0, April 2012 (ADAMS Accession Nos. ML12102A165 and ML12102A169).

Enclosure 1

1

2.0 REGULATORY EVALUATION

2 3

2.1 DESCRIPTION

OF STS SECTIONS 4

5 LCOs specify minimum requirements for ensuring safe operation of the plant. The actions 6 applicable when an LCO is not met associated with an LCO state conditions that typically 7 describe the ways in which the requirements of the LCO can fail to be met. Specified with each 8 stated condition are required action(s) and completion time(s).

9 10 2.1.1 LCO TS 3.5.2, ECCS-Operating 11 12 The function of the ECCS is to provide core cooling and negative reactivity to ensure the reactor 13 core is protected after any of the following accidents:

14 15 a. Loss-of-coolant accident (LOCA), coolant leakage greater than the capability of the 16 normal charging system, 17 18 b. Rod ejection accident, 19 20 c. Loss of secondary coolant accident, including uncontrolled steam release or loss of 21 feedwater, and 22 23 d. Steam generator tube rupture.

24 25 LCO TS 3.5.2 is applicable in Modes 1, 2, and 3 and requires that two ECCS trains be operable 26 to ensure that sufficient ECCS flow is available, assuming a single failure affecting either train.

27 28 LCO TS 3.5.2 helps ensure the following acceptance criteria for ECCS, established by Title 10 29 of the Code of Federal Regulations (10 CFR) 50.46, will be met following a LOCA:

30 31 a. Maximum fuel element cladding temperature is 2200 degrees Fahrenheit (°F),

32 33 b. Maximum cladding oxidation is 0.17 times the total cladding thickness before 34 oxidation, 35 36 c. Maximum hydrogen generation from a zirconium water reaction is 0.01 times the 37 hypothetical amount generated if all of the metal in the cladding cylinders surrounding 38 the fuel, excluding the cladding surrounding the plenum volume, were to react, 39 40 d. Core is maintained in a coolable geometry, and 41 42 e. Adequate long-term core cooling capability is maintained.

43 44 LCO TS 3.5.2 also limits the potential for a post-trip return to power following a main steam line 45 break event and ensures that containment temperature limits are met.

46 47 2.1.2 LCO TS 3.5.3, ECCS-Shutdown 48 49 LCO TS 3.5.3 is applicable in Mode 4 and requires one of the two ECCS trains to be operable to 50 ensure that sufficient ECCS flow is available to the core following a design-basis accident.

51

1 2.1.3 TS Section 5.5.15, Safety Function Determination Program (SFDP) 2 3 Section 5.5.15 establishes the SFDP which implements the requirements of LCO 3.0.6. The 4 SFDP ensures loss of safety function is detected and appropriate actions are taken. Upon entry 5 into LCO 3.0.6, an evaluation shall be made to determine if loss of safety function exists.

6 Additionally, other appropriate actions may be taken as a result of the support system 7 inoperability and corresponding exception to entering supported system(s) condition(s) and 8 required action(s).

9 10

2.2 PROPOSED CHANGE

S TO THE STSs 11 12 The proposed changes would revise LCO TS 3.5.2, ECCS - Operating, and LCO TS 3.5.3, 13 ECCS-Shutdown., and Section 5.5.15, Safety Function Determination Program (SFDP). The 14 proposed changes would also add a new STS LCO, Containment Sump, to Section 3.6, 15 Containment Systems. The proposed changes are described below.

16 17 2.2.1 Proposed Changes to LCO TS 3.5.2, ECCS-Operating 18 19 STS LCO TS 3.5.2 for Babcock and Wilcox (B&W) plants currently contains Surveillance 20 Requirement (SR) 3.5.2.9 (SR 3.5.2.8 for Westinghouse (W) plants and SR 3.5.2.10 for 21 Combustion Engineering (CE) plants). This SR requires the following at a frequency of 22 18 months or in accordance with the Surveillance Frequency Control Program (SFCP):

23 24 Verify, by visual inspection, each ECCS train containment sump 25 suction inlet is not restricted by debris and suction inlet trash racks 26 and screens show no evidence of structural distress or abnormal 27 corrosion.

28 29 Traveler TSTF-567, Revision 1, proposed to modify and move this SR (B&W SR 3.5.2.9, W 30 SR 3.5.2.8, and CE SR 3.5.2.10) from LCO TS 3.5.2 and include it in the new containment 31 sump LCOTS. Conforming changes are made to the STS Bases.

32 33 This change is evaluated in Section 3.1 of this safety evaluation (SE).

34 35 2.2.2 Proposed Changes to LCO TS 3.5.3, ECCS-Shutdown 36 37 STS LCO 3.5.3 currently contains SR 3.5.3.1 which refers to applicable SRs under 38 LCO TS 3.5.2. The applicable SRs include are B&W SR 3.5.2.9, W SR 3.5.2.8, and CE 39 SR 3.5.2.10, as described in Section 2.2.1 of this SE.

40 41 Because TSTF-567, Revision 1, proposed to modify and move the referenced SRs (B&W 42 SR 3.5.2.9, W SR 3.5.2.8, and CE SR 3.5.2.10) from LCO TS 3.5.2 and include it them in the 43 new containment sump LCOTS, the references to these SRs (B&W SR 3.5.2.9, W SR 3.5.2.8, 44 and CE SR 3.5.2.10), in SR 3.5.3.1 would be deleted. Conforming changes are made to the 45 STS Bases.

46 47 This change is evaluated in Section 3.2 of this SE.

48

1 2.2.3 Proposed Changes to Section 5.5.15, Safety Function Determination 2 Program (SFDP) 3 4 Traveler TSTF-567, Revision 1, proposed to add the following sentence at the end of TS 5 Section 5.5.15:

6 7 When a loss of safety function is caused by the inoperability of a 8 single Technical Specification support system, the appropriate 9 Conditions and Required Actions to enter are those of the support 10 system.

11 12 This change is evaluated in Section 3.3 of this SE.

13 14 2.2.4 Proposed Addition of a New Containment Sump LCOTS 15 16 Traveler TSTF-567, Revision 1, proposed to add a new TS n LCO (LCO TS 3.6.8 for B&W 17 plants, LCO TS 3.6.19 for W plants, and LCO TS 3.6.13 for CE plants). The TS LCO requires 18 requiring the containment sump to be operable. The LCO is applicable in during Modes 1, 2, 3, 19 and 4. Condition A specifies that if the containment sump is inoperable due to containment 20 accident generated and transported debris exceeding the analyzed limits, Required Actions A.1, 21 A.2, and A.3 require initiation of action to mitigate containment accident generated and 22 transported debris immediately, performance of SR 3.4.13.1 once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , and restoration 23 ofe the containment sump to operable status in 90 days, respectively. SR 3.4.13.1 requires 24 verification of reactor coolant system (RCS) operational leakage within limits by performance of 25 an RCS water inventory balance.

26 27 Condition B specifies that if the containment sump is inoperable for reasons other than 28 Condition A, Required Action B.1 requires restoration of the containment sump to operable 29 status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance with the Risk Informed Completion Time (RICT) 30 Program. Required Action B.1 is modified by two notes which direct entering applicable 31 conditions and required actions of LCO 3.5.2, ECCS-Operating, and LCO 3.5.3, 32 ECCS-Shutdown, for ECCS trains made inoperable by the containment sump and entering 33 applicable conditions and required actions of LCO 3.6.6, Containment Spray and Cooling 34 Systems, for Containment Spray and Cooling System (CSS) trains made inoperable by the 35 containment sump.

36 37 Condition C specifies that if required actions and associated completion times (CTs) under 38 Condition A and B are not met, Required Actions C.1 and C.2 require licensees to be in Mode 3 39 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , respectively.

40 41 Traveler TSTF-567, Revision 1, proposed to expand and relocate an SR currently located in 42 LCO TS 3.5.2. The new SR would require licensees to verify, by visual inspection, that the 43 containment sump does not show structural damage, abnormal corrosion, or debris blockage 44 every 18 months or in accordance with the SFCP.

45 46 Some plant designs have more than one containment sump. The new containment sump LCO 47 TS proposed in TSTF-567, Revision 1, is also applicable to plants that have more than one 48 containment sump. Application of the TS to plants with more than one sump is described in a 49 Reviewer's Note in the TS Bases.

50

1 Traveler TSTF-567, Revision 1, also proposed a conforming change to the STSs Table of 2 Contents (Volumes 1 and 2) to reflect the addition of the new containment sump LCOTS.

3 4 This change is evaluated in Section 3.4 of this SE.

5 6 2.3 APPLICABLE REGULATORY REQUIREMENTS AND GUIDANCE 7

8 Section IV, The Commission Policy, of the Final Policy Statement on Technical Specifications 9 Improvements for Nuclear Power Reactors, published in the Federal Register on July 22, 1993 10 (58 FR 39132), states, in part:

11 12 The purpose of Technical Specifications is to impose those 13 conditions or limitations upon reactor operation necessary to 14 obviate the possibility of an abnormal situation or event giving rise 15 to an immediate threat to the public health and safety by 16 identifying those features that are of controlling importance to 17 safety and establishing on them certain conditions of operation 18 which cannot be changed without prior Commission approval.

19 20 [T]he Commission will also entertain requests to adopt portions 21 of the improved STS [(e.g., TSTF-567)], even if the licensee does 22 not adopt all STS improvements. The Commission encourages 23 all licensees who submit Technical Specification related submittals 24 based on this Policy Statement to emphasize human factors 25 principles.

26 27 In accordance with this Policy Statement, improved STS have 28 been developed and will be maintained for each NSSS [nuclear 29 steam supply system] owners group. The Commission 30 encourages licensees to use the improved STS as the basis for 31 plant-specific Technical Specifications. [I]t is the Commission 32 intent that the wording and Bases of the improved STS be used 33 to the extent practicable.

34 35 As described in the Commissions Final Policy Statement on Technical Specifications 36 Improvements for Nuclear Power Reactors, NRC and industry task groups for new STSs 37 recommended that improvements include greater emphasis on human factors principles in order 38 to add clarity and understanding to the text of the STS, and provide improvements to the Bases 39 of STS, which provides the purpose for each requirement in the specification. The improved 40 vendor-specific STS were developed and issued by the NRC in September 1992.

41 42 The regulation at 10 CFR 50.36(b) requires:

43 44 Each license authorizing operation of a utilization facility will 45 include technical specifications. The technical specifications will 46 be derived from the analyses and evaluation included in the safety 47 analysis report, and amendments thereto, submitted pursuant to 48 [10 CFR] 50.34 [Contents of applications; technical information].

49 The Commission may include such additional technical 50 specifications as the Commission finds appropriate.

51

1 The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). As required 2 by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability 3 or performance levels of equipment required for safe operation of the facility. Per 4 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut 5 down the reactor or follow any remedial action permitted by the TSs until the condition can be 6 met.

7 8 The regulation at 10 CFR 50.36(c)(3) requires TSs to include SRs, which are requirements 9 relating to test, calibration, or inspection to assure that the necessary quality of systems and 10 components is maintained, that facility operation will be within safety limits, and that the LCOs 11 will be met.

12 13 The regulation at 10 CFR 50.36(c)(5) requires TSs to include administrative controls, which are 14 the provisions relating to organization and management, procedures, recordkeeping, review and 15 audit, and reporting necessary to assure operation of the facility in a safe manner.

16 17 The regulation at 10 CFR 50.36(a)(1) requires each applicant for a license provide a summary 18 statement of the bases or reasons for specifications, other than those covering administrative 19 controls, in the application, but these statements are not part of the technical specifications.

20 21 The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of 22 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for 23 Nuclear Power Plants (SRP), March 2010 (ADAMS Accession No. ML100351425). As 24 described therein, as part of the regulatory standardization effort, the NRC staff has prepared 25 STSs for each of the light-water reactor nuclear designs. Accordingly, the NRC staffs review 26 includes consideration of whether the proposed changes are consistent with the applicable 27 reference STSs (i.e., the current STSs), as modified by NRC-approved Travelers. In addition, 28 the guidance states that comparing the change to previous STSs can help clarify the TS intent.

29 30

3.0 TECHNICAL EVALUATION

31 32 During the review of TSTF-567, Revision 1, the NRC staff considered generally the guidance on 33 acceptance criteria of the SRP sections described in Section 2.3 of this SE and, in particular, 34 the acceptance criteria in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3.

35 Additionally, the NRC staff evaluated the proposed changes to the STS against what is required 36 to be in the TS under 10 CFR 50.36(c).

37 38

3.1 PROPOSED CHANGE

S TO LCO TS 3.5.2, ECCS-OPERATING 39 40 In TSTF-567, Revision 1, the TSTF proposed to modify and move SR 3.5.2.9 (B&W); SR 3.5.2.8 41 (W), and SR 3.5.2.10 (CE) from LCO TS 3.5.2 to the new containment sump LCOTS. The new 42 SR does not limit the visual inspection to the suction inlet, trash racks, and screens as currently 43 required by the STSs, but instead requires inspection of the entire containment sump system.

44 Traveler TSTF-567, Revision 1, describes the containment sump as consisting of the 45 containment drainage flow paths, any design features upstream of the containment sump that 46 are credited in the containment debris analysis, the containment sump strainers (or screens),

47 the pump suction trash racks, and the inlet to the ECCS and CSS piping.

48 49 The NRC staff concludes the proposed change is acceptable since the existing requirements 50 are either unchanged or expanded and continue to ensure the containment sump is unrestricted 51 (i.e., unobstructed) and stays in proper operating condition. The proposed change meets the

1 requirements of 10 CFR 50.36(c)(3) because it provides SRs to assure the necessary quality of 2 systems and components are maintained, that facility operation will be within safety limits, and 3 that the LCOs will be met.

4 5

3.2 PROPOSED CHANGE

S TO LCO TS 3.5.3, ECCS-SHUTDOWN 6

7 In TSTF-567, Revision 1, the TSTF proposed to delete the reference to relocated SRs (as well 8 as SR 3.5.2.9 (B&W), SR 3.5.2.8 (W), and SR 3.5.2.10 (CE)) in SR 3.5.3.1.

9 10 The NRC staff concludes the proposed change is acceptable since the SRs (B&W SR 3.5.2.9, 11 W SR 3.5.2, and CE SR 3.5.2.10) were modified and relocated to the new containment sump 12 LCOTS. The existing SR on the containment sump is augmented (by requiring inspection of 13 additional sump components) and moved to the new specification, and a duplicative 14 requirement to perform the SR in TS 3.5.3 is removed. The new specification retains or 15 expands existing requirements on the containment sump and the actions to be taken when the 16 containment sump is inoperable with the exception of adding new actions to be taken when the 17 containment sump is inoperable due to containment accident generated and transported debris 18 exceeding the analyzed limits. The new action provides time to evaluate and correct the 19 condition instead of requiring an immediate plant shutdown. The proposed change meets the 20 requirements of 10 CFR 50.36(c)(3) because it provides SRs to assure the necessary quality of 21 systems and components are maintained, that facility operation will be within safety limits, and 22 that the LCOs will be met.

23 24

3.3 PROPOSED CHANGE

S TO SECTION 5.5.15, SAFETY FUNCTION 25 DETERMINATION PROGRAM (SFDP) 26 27 STS LCO 3.0.6 states:

28 29 When a supported system LCO is not met solely due to a support 30 system LCO not being met, the Conditions and Required Actions 31 associated with this supported system are not required to be 32 entered. Only the support system LCO ACTIONS are required to 33 be entered. This is an exception to LCO 3.0.2 for the supported 34 system. In this event, an evaluation shall be performed in 35 accordance with Specification 5.5.15, Safety Function 36 Determination Program (SFDP). If a loss of safety function is 37 determined to exist by this program, the appropriate Conditions 38 and Required Actions of the LCO in which the loss of safety 39 function exists are required to be entered.

40 41 When a support systems Required Action directs a supported 42 system to be declared inoperable or directs entry into Conditions 43 and Required Actions for a supported system, the applicable 44 Conditions and Required Actions shall be entered in accordance 45 with LCO 3.0.2.

46 47 When a loss of safety function is determined to exist, the SFDP requires entry into the 48 appropriate conditions and required actions of the LCO in which the loss of safety function 49 exists. Where a loss of function is solely due to a single TS support system (e.g., a single 50 containment sump train), the appropriate LCO is the LCO for that support system. When the

1 loss of function is the result of multiple support systems, the appropriate LCO is the LCO for the 2 supported systems.

3 4 Traveler TSTF-567, Revision 1, proposed to add the following statement to STS 5.5.12, [W]hen 5 a loss of safety function is caused by the inoperability of a single Technical Specification support 6 system, the appropriate Conditions and Required Actions to enter are those of the support 7 system.

8 9 The NRC staff finds that the proposed addition to STS 5.5.12 clarifies the intent of the allowance 10 (not to enter Conditions and Required Actions) provided by LCO 3.0.6 and the SFDP for 11 single-train support systems. The NRC staff concludes the proposed change is acceptable 12 because the actions for the support system LCO adequately address the inoperability of that 13 system. Therefore, as required by 10 CFR 50.36(c)(5), it continues to provide adequate 14 administrative controls to assure safe operation.

15 16 3.4 PROPOSED ADDITION OF CONTAINMENT SUMP LCOTS 17 18 3.4.1 Considerations of the LCOTS 19 20 Traveler TSTF-567, Revision 1, proposed to add a new LCO TS to address operability 21 requirements of the containment sump. The numbering for this new LCO TS is as follows:

22 LCO TS 3.6.8 for B&W, LCO TS 3.6.19 for W, and LCO TS 3.6.13 for CE. The new LCO TS is 23 also applicable to plants that have more than one containment sump, because the multiple 24 sumps are considered to be part of a single support system. If containment accident generated 25 and transported debris would render one sump inoperable, then it would render all of the sumps 26 inoperable. A Reviewer's Note in the Bases explains how to apply the TS to plants with more 27 than one containment sump.

28 29 The containment sump supports the post-accident operation of the ECCS and CSS. However, 30 only the current ECCS LCOs TS contain SRs related to the containment sump and the STSs do 31 not specify required actions that specifically address an inoperable containment sump. If the 32 containment sump were found to be inoperable, as an ECCS and CSS support system, those 33 respective LCOs would not be met. In order to address concerns related to containment sump 34 operability due to debris accumulation described in GSI-191, Assessment of Debris 35 Accumulation on Pressurized-Water Reactor Sump Performance, TSTF-567, Revision 1, 36 proposed to add a new specification to address containment sump inoperability and create a 37 condition for when the sump is inoperable due to analyzed containment accident generated and 38 transported debris.

39 40 Based on the above evaluation, the NRC staff determined that proposed LCO TS satisfies the 41 requirements of 10 CFR 50.36(c)(2)(i) because the LCO specifies the lowest functional 42 capability or performance levels of equipment required for safe operation of the facility.

43 44 3.4.2 Considerations of the Applicability 45 46 The new LCO TS requires the containment sump to be operable during Modes 1, 2, 3, and 4.

47 The ECCS and CSS LCOs TS currently in the STSs are applicable during Modes 1, 2, 3, and 4.

48 49 The NRC staff finds the proposed applicability is acceptable because the applicability is 50 consistent with the applicability of the ECCS and CSS LCOsTS, the containment sump 51 supported systems.

1 2 3.4.3 Considerations of Condition A 3

4 Licensees have analyzed the susceptibility of the ECCS and CSS to the adverse effects of 5 post-accident debris blockage and operation with debris-laden fluids. Most licensees have 6 established Final Safety Analysis Report (FSAR) limits on the allowable quantities of 7 containment accident generated debris that could be transported to the containment sump 8 based on their current plant configuration. In the current STS, if unanalyzed debris sources are 9 discovered inside containment, if errors are discovered in debris-related analyses, or if a 10 previously unevaluated phenomenon that can affect containment sump performance is 11 discovered, the containment sump, and the supported ECCS and CSS, may be inoperable and 12 the STS would require an immediate plant shutdown with no time provided to evaluate the 13 condition.

14 15 In order to address this situation and to provide sufficient time to evaluate the condition, 16 TSTF-567, Revision 1, proposed Condition A, which is applicable when the containment sump 17 is inoperable due to containment accident generated and transported debris exceeding the 18 analyzed limits. Under Condition A, the operability of the containment sump with respect to 19 debris is based on a quantity of debris identified and evaluated by the licensee to be acceptable.

20 Emergent nonconforming or degraded conditions affecting the quantity of analyzed debris shall 21 be evaluated using a deterministic process.

22 23 Under Condition A, Required Action A.1 mandates immediate action to be initiated to mitigate 24 the condition. The TS Bases for Required Action A.1 provide Revision 1 of TSTF-567 provided 25 the following examples of mitigating actions:

26 27

Removing the debris source from containment or 28 preventing the debris from being transported to the 29 containment sump; 30 31

Evaluating the debris source against the assumptions in 32 the analysis; 33 34

Deferring maintenance that would affect availability of the 35 affected systems and other LOCA-mitigating equipment; 36 37

Deferring maintenance that would affect availability of 38 primary defense-in-depth systems, such as containment 39 coolers; 40 41

Briefing operators on LOCA debris management actions; 42 or 43 44

Applying an alternative method to establish new limits.

45 46 The NRC staff finds the proposed Required Action A.1 and its CT are acceptable because they 47 place urgency on the appropriate actions that could mitigate or reduce the impact of the 48 identified conditions.

49

1 Concurrently, Required Action A.2 mandates SR 3.4.13.1, the RCS water inventory balance, to 2 be performed at an increased frequency of once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . An unexpected increase in RCS 3 leakage could be indicative of an increased potential for an RCS pipe break, which could result 4 in debris being generated and transported to the containment sump.

5 6 The NRC staff finds the proposed Required Action A.2 and its CT are acceptable because the 7 more frequent monitoring allows operators to act in a timely fashion to minimize the potential for 8 an RCS pipe break while the containment sump is inoperable.

9 10 In addition, Required Action A.3 requires the inoperable containment sump to be restored to 11 operable status in 90 days.

12 13 The NRC staff finds the proposed Required Action A.3 and its CT are acceptable because they 14 provide a reasonable amount of time to diagnose, plan, and possibly reduce the severity of, or 15 mitigate the unanalyzed debris condition and prevent a loss of ECCS and CSS safety function.

16 In addition, 90 days is adequate given the conservatisms in the analysis and the proposed 17 compensatory actions required to be implemented immediately by Required Action A.1. Also, 18 as discussed later in this SE section, the new SR will require visual inspection of the 19 containment sump system (including the containment drainage flow paths, any design features 20 upstream of the containment sump that are credited in the containment debris analysis, the 21 containment sump strainers, the pump suction trash racks, and the inlet to the ECCS and CSS 22 piping) for evidence of structural degradation, potential for debris bypass, and presence of 23 corrosion or debris blockage, to ensure no loose debris is present and there is no evidence of 24 structural distress or abnormal corrosion.

25 26 For plants that have more than one containment sump, the sumps are considered part of a 27 single support system because containment accident generated and transported debris issues 28 that would render one sump inoperable would render all of the sumps inoperable. The NRC 29 staff finds this proposed change is acceptable since it is a conservative assumption. Plants with 30 separate sumps are generally designed so that one sump will remain operable with the 31 design-basis debris load. The second sump is assumed to be out of service due to a single 32 failure in the ECCS or CSS. The single sump in a plant with multiple sumps is equivalent to the 33 sump in a plant with only one sump because the multiple sumps are considered to be part of a 34 single support system. If containment accident generated and transported debris were to 35 render one sump inoperable, then it would render all of the sumps inoperable. In any case 36 where the single failure did not occur, the second sump would be in service and provide 37 significant additional surface area for debris to collect, thus reducing the severity of the effects 38 of the debris. The second sump provides redundancy in these cases.

39 40 3.4.4 Considerations of Condition B 41 42 Condition B specifies the required actions for when the containment sump is inoperable for 43 reasons other than containment accident generated and transported debris exceeding the 44 analyzed limits.

45 46 Required Action B.1 requires restoring the containment sump to operable status and is modified 47 by two notes. These two notes direct entry into the conditions and required actions for the 48 supported systems (ECCS and CSS). Since Required Action B.1 directs entry to the 49 corresponding ECCS and CSS LCOs, these notes retain the existing TS actions for ECCS or 50 CSS trains made inoperable by an inoperable containment sump inoperable for reasons other 51 than containment accident generated and transported debris exceeding the analyzed limits.

1 The proposed CT for Required Action B.1 is a plant-specific time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or in accordance 2 with the RICT Program. Traveler TSTF-567, Revision 1, shows these CTs in brackets to show 3 the licensee has the option to insert its plant-specific licensing bases requirement. A Reviewer's 4 Note in the Bases for Required Action B.1 states that the Completion Time should be the same 5 as the TS 3.6.6 Completion Time for a single inoperable CSS train (typically 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or 7 6 days).

7 8 If a licensee has received an amendment that authorizes the adoption of TSTF-505, Provide 9 Risk-Informed Extended Completion Times - RITSTF Initiative 4B, or plant-specific RICT 10 Program and the licensee has a Risk-Informed Completion Time (RICT) Program in TS 11 Section 5.0, Administrative Controls, the licensee can propose via a license amendment 12 application the option to calculate a RICT for Required Action B.1 in addition to the fixed 13 completion time. However, a plant-specific justification, consistent with the justification provided 14 when adopting TSTF-505 or a plant-specific RICT Program, needs to be provided in the license 15 amendment request (LAR) to adopt TSTF-567, Revision 1. This SE does not approve the use 16 of the RICT Program for Required Action B.1. For the purposes of this SE, the bracketed OR 17 In accordance with the Risk Informed Completion Time (RICT) Program, only indicates that the 18 licensees have an additional option. If a licensee chooses to use the RICT Program for 19 Required Action B.1, its LAR would not be processed as a CLIIP for adoption of TSTF-567, 20 Revision 1, and additional technical information would need to be provided to justify the use of 21 the RICT Program for this required action.

22 23 The NRC staff finds the proposed change is acceptable since it continues to provide remedial 24 actions for when the containment sump is inoperable for reasons other than Condition A and 25 ensures safe operation of the plant. In addition, the proposed plant-specific CT of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is 26 acceptable because it is no more limiting than the ECCS or CSS Completion Times for a single 27 inoperable train, it provides a reasonable time for repairs, and there is a low probability of an 28 accident occurring during this period necessitating the containment sump. Licensees who have 29 received an amendment authorizing the adoption of TSTF-505, Provide Risk-Informed 30 Extended Completion Times - RITSTF Initiative 4B, or plant-specific RICT Program, have the 31 option to select add an additional the RICT Program as a CT by submitting additional 32 justification in separate the license amendment request supported by a plant-specific 33 justification. The use of this traveler in combination with a RICT Program is outside the scope of 34 this SE and would be reviewed on a plant-specific basis.

35 36 3.4.5 Considerations of Condition C 37 38 If operators are unable to restore the affected containment sump to operable status under 39 Conditions A or B, Required Action C.1 requires the unit to be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months followed by 40 Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , as required by Required Action C.2.

41 42 The NRC staff finds the proposed condition and its required actions are acceptable because 43 they are consistent with the STS and require the operators to place the unit in a condition in 44 which the LCO no longer applies. In addition, the proposed CTs allow a reasonable amount of 45 time to reach the required plant conditions from full-power conditions in an orderly manner and 46 without challenging plant systems.

47 48 3.4.6 Considerations of the New SR 49 50 A new SR is provided in the new containment sump LCOTS. This SR was originally located in 51 STS LCO 3.5.2 and STSLCO 3.5.3. The numbering for this new SR is as follows: SR 3.6.8.1

1 for B&W, SR 3.6.19.1 for W, and SR 3.6.13.1 for CE. The frequency of the new SR is 2 18 months or as specified in the SFCP.

3 4 The proposed SR requires verification, by visual inspection, that the containment sump does not 5 show structural damage, abnormal corrosion, or debris blockage.

6 7 The new SR is stated in generic terms and expands the scope of the required visual inspection 8 to include the entire containment sump system. A containment sump system consists of the 9 containment drainage flow paths, the containment sump strainers (or screens), the pump 10 suction trash racks, and the inlet to the ECCS and CSS piping.

11 12 The NRC staff finds the proposed new SR is acceptable since it expands the scope of 13 inspection of the original SR. In addition, the proposed frequency is acceptable since it is the 14 same as that currently required by the STSs. Therefore, the NRC staff finds that, as required by 15 10 CFR 50.36(c)(3), the necessary quality of systems will be maintained in accordance with the 16 associated LCOs.

17 18 3.4.7 Considerations of Changes to Table of Contents 19 20 Traveler TSTF-567, Revision 1, also proposed a conforming change to the Table of Contents to 21 include the new containment sump LCOTS. This conforming change is acceptable since it is an 22 editorial change to support the inclusion of the new containment sump STS LCO.

23 24 3.4.8 Considerations of Changes to the STS Bases 25 26 Traveler TSTF-567, Revision 1, proposed conforming changes to the STS Bases. These 27 conforming changes are acceptable as they are consistent with the proposed TS and satisfy the 28 10 CFR 50.36(a) requirement for bases or reasons for such specifications.

29 30 3.4.98 Conclusion Regarding Proposed Containment Sump LCOTS 31 32 The new containment sump LCO TS retains and expands the existing STS requirements with 33 the exception of the addition of Condition A. Condition A provides a condition for an inoperable 34 containment sump due to containment accident generated and transported debris exceeding the 35 analyzed limits.

36 37 The NRC staff reviewed the proposed STS changes against the regulations and concludes that 38 the changes continue to meet the requirements of 10 CFR 50.36(a), 50.36(c)(2), 50.36(c)(3),

39 and 50.36(c)(5), for the reasons discussed above, and thus provide reasonable assurance that 40 plants that adopt these TSs will have the requisite requirements and controls to operate safely.

41 Therefore, the staff concludes that the proposed STS changes are acceptable.

42 43

4.0 CONCLUSION

44 45 The NRC staff reviewed Traveler TSTF-567, Revision 1, which proposed changes to 46 NUREG-1430, Volume 1, NUREG-1431, Volume 1, and NUREG-1432, Volume 1. The NRC 47 staff determined that the proposed changes to the STS meet the standards for TS in 48 10 CFR 50.36(b). Additionally, the changes to the STS were reviewed and found to be 49 technical clear and consistent with customary terminology and format in accordance with 50 SRP Chapter 16.0. The NRC staff reviewed the proposed changes against the regulations and 51 concludes that the changes continue to meet the requirements of 10 CFR 50.36(a), 50.36(c)(2),

1 50.36(c)(3) and 50.36(c)(5), for the reasons discussed above, and thus provide reasonable 2 assurance that adoption of these TSs will have the requisite requirements and controls to 3 operate safely. Therefore, the NRC staff concludes that the proposed TS changes are 4 acceptable.

5 6

7 Principal Contributors: C. Tilton, NRR/DSS 8 S. Smith, NRR/DSS 9 P. Klein, NRR/DMLR 10 11 Date:

1 General Directions: This Model SE provides the format and content to be used when preparing 2 the plant-specific SE of an LAR to adopt TSTF-567, Revision 1. The bolded bracketed 3 information shows text that should be filled in for the specific amendment; individual licensees 4 would furnish site-specific nomenclature or values for these bracketed items. The italicized 5 wording provides guidance on what should be included in each section and should not be 6 included in the SE.

7 DRAFT MODEL SAFETY EVALUATION 8 BY THE OFFICE OF NUCLEAR REACTOR REGULATION 9 TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 10 TSTF-567, REVISION 1 11 ADD CONTAINMENT SUMP TS TO ADDRESS GSI-191 ISSUES 12 USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 13 (CAC NO. MF9568, EPID L-2017-PMP-0005) 14 15 16

1.0 INTRODUCTION

17 18 By application dated [enter date], (Agencywide Documents Access and Management System 19 (ADAMS) Accession No. [MLXXXXXXXXX]), [as supplemented by letters dated, [enter 20 date(s))) [name of licensee] (the licensee) submitted a license amendment request (LAR) for 21 [name of facility (abbreviated name). applicable units].

22 23 The amendment would revise Technical Specification (TS)Limiting Condition for Operation 24 (LCO) 3.5.2, ECCS [Emergency Core Cooling System]-Operating, [and] LCO TS 3.5.3, 25 ECCS-Shutdown, [and TS Section 5.5.15, Safety Function Determination Program 26 (SFDP).] The proposed changes would also add a new TSLCO, Containment Sump, to TS 27 Section 3.6, Containment Systems. The proposed changes are based on Technical 28 Specifications Task Force (TSTF) Traveler TSTF-567, Revision 1, Add Containment Sump TS 29 to Address GSI [Generic Safety Issue]-191 Issues, dated August 2, 2017 (ADAMS Accession 30 No. ML17214A813). The U.S. Nuclear Regulatory Commission (NRC or the Commission) 31 issued a final safety evaluation (SE) approving TSTF-567, Revision 1, on [Month, Day, Year]

32 (ADAMS Accession No. [MLXXXXXXXXX]).

33 34 {Note: TSTF-567 is not applicable to plants with TS not based on the current STS (i.e., NUREG-35 1430, NUREG-1431, or NUREG-1542) due to its dependence on LCO 3.0.6 and the SFDP.}

36 37 [The licensee has proposed several variations from the TS changes described in 38 TSTF-567. The variations are described in Section [2.2.5] of this SE and evaluated in 39 Section [X.X].]

40 41 [The supplemental letters dated [enter date(s)], provided additional information that 42 clarified the application, did not expand the scope of the application as originally 43 noticed, and did not change the NRC staffs original proposed no significant hazards 44 consideration determination as published in the Federal Register on [enter date] (cite FR 45 reference).]

46 Enclosure 2

1

2.0 REGULATORY EVALUATION

2 3 2.1 SYSTEM DESCRIPTION AND CHANGES TO THE TS 4

5 LCOs are the lowest functional capability or performance levels of equipment required for safe 6 operation of the facility. The actions applicable when an LCO is not met associated with an 7 LCO state conditions that typically describe the ways in which the requirements of the LCO can 8 fail to be met. Specified with each stated condition are required action(s) and completion 9 time(s).

10 11 2.1.1 LCO TS 3.5.2, ECCS-Operating 12 13 The function of the ECCS is to provide core cooling and negative reactivity to ensure the reactor 14 core is protected after any of the following accidents:

15 16 a. Loss-of-coolant accident (LOCA), coolant leakage greater than the capability of the 17 normal charging system, 18 19 b. Rod ejection accident, 20 21 c. Loss of secondary coolant accident, including uncontrolled steam release or loss of 22 feedwater, and 23 24 d. Steam generator tube rupture.

25 26 LCO TS 3.5.2 is applicable in Modes 1, 2, and 3 and requires that two independent ECCS trains 27 be operable to ensure that sufficient ECCS flow is available, assuming a single failure affecting 28 either train.

29 30 LCO TS 3.5.2 helps ensure the following acceptance criteria for ECCS, established by Title 10 31 of the Code of Federal Regulations (10 CFR) 50.46, will be met following a LOCA:

32 33 a. Maximum fuel element cladding temperature is 2200 degrees Fahrenheit (°F),

34 35 b. Maximum cladding oxidation is 0.17 times the total cladding thickness before 36 oxidation, 37 38 c. Maximum hydrogen generation from a zirconium water reaction is 0.01 times the 39 hypothetical amount generated if all of the metal in the cladding cylinders surrounding 40 the fuel, excluding the cladding surrounding the plenum volume, were to react, 41 42 d. Core is maintained in a coolable geometry, and 43 44 e. Adequate long-term core cooling capability is maintained.

45 46 LCO TS 3.5.2 also limits the potential for a post-trip return to power following a main steam line 47 break event and ensures that containment temperature limits are met.

48

1 2.1.2 LCO TS 3.5.3, ECCS-Shutdown 2

3 LCO TS 3.5.3 is applicable in Mode 4 and requires one of the two independent (and redundant) 4 ECCS trains to be operable to ensure that sufficient ECCS flow is available to the core following 5 a design-basis accident.

6 7 {NOTE: The change to TS 5.5.15 is optional. Some plants may have already adopted this 8 change into their TS.}

9 10 [2.1.3 TS SectionTS 5.5.15, Safety Function Determination Program (SFDP) 11 12 Section TS 5.5.15 establishes the Safety Function Determination Program (SFDP) which 13 implements the requirements of LCO 3.0.6. The SFDP ensures loss of safety function is 14 detected and appropriate actions are taken. Upon entry into LCO 3.0.6, an evaluation 15 shall be made to determine if loss of safety function exists. Additionally, other 16 appropriate actions may be taken as a result of the support system inoperability and 17 corresponding exception to entering supported system(s) condition(s) and required 18 action(s).]

19 20

2.2 PROPOSED CHANGE

S TO THE TECHNICAL SPECIFICATIONS 21 22 The proposed changes would revise LCO TS 3.5.2, ECCS-Operating, [and] LCO TS 3.5.3, 23 ECCS-Shutdown, [and TSSection 5.5.15, Safety Function Determination Program.] The 24 proposed changes would also add a new TS LCO, Containment Sump to Section 3.6, 25 Containment Systems. The proposed changes are described below.

26 27 2.2.1 Proposed Changes to LCO TS 3.5.2, ECCS-Operating 28 29 LCO TS 3.5.2 currently contains Surveillance Requirement (SR) 3.5.2.[9], which requires the 30 following at a frequency [of 18 months][in accordance with the Surveillance Frequency 31 Control Program (SFCP)]:

32 33 Verify, by visual inspection, each ECCS train containment sump 34 suction inlet is not restricted by debris and suction inlet trash racks 35 and screens show no evidence of structural distress or abnormal 36 corrosion.

37 38 The licensee proposed to modify and move SR 3.5.2.[9] from LCO TS 3.5.2 and include it in the 39 new containment sump LCOTS.

40 41 This change is evaluated in Section 3.1 of this SE.

42 43 2.2.2 Proposed Changes to LCO TS 3.5.3, ECCS-Shutdown 44 45 LCO TS 3.5.3 currently contains SR 3.5.3.1 which refers to applicable SRs under LCO TS 3.5.2.

46 One of those referenced SRs is SR 3.5.2.[9], as described in Section 2.2.1 of this SE.

47 48 Because the licensee proposed to move SR 3.5.2.[9] from LCO TS 3.5.2 and include it in the 49 new containment sump LCOTS, the licensee also proposed to delete the reference to 50 SR 3.5.2.[9] in SR 3.5.3.1.

51

1 This change is evaluated in Section 3.2 of this SE.

2 3 {NOTE: The change to TS 5.5.15 is optional. Some plants may have already adopted this 4 change into their TS.}

5 6 [2.2.3 Proposed Changes to TS Section 5.5.15, Safety Function 7 Determination Program (SFDP) 8 9 The licensee proposed to add the following sentence at the end of TS Section 5.5.15:

10 11 When a loss of safety function is caused by the inoperability 12 of a single Technical Specification support system, the 13 appropriate Conditions and Required Actions to enter are 14 those of the support system.

15 16 This change is evaluated in Section 3.3 of this SE.]

17 18 2.2.4 Proposed Addition of a New Containment Sump LCOTS 19 20 The licensee proposed to add LCO TS 3.6.[8] requiring the containment sump to be operable 21 during Modes 1, 2, 3, and 4. Condition A specifies that if the containment sump is inoperable 22 due to containment accident generated and transported debris exceeding the analyzed limits, 23 Required Actions A.1, A.2, and A.3 require immediate initiation of action to mitigate containment 24 accident generated and transported debris, performance of ing SR 3.4.13.1 once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 25 and restoration ofing the containment sump to operable status in 90 days, respectively. The 26 SR 3.4.13.1 requires verification that the reactor coolant system (RCS) operational leakage is 27 within limits by performance of an RCS water inventory balance.

28 29 Condition B specifies that if the containment sump is inoperable for reasons other than 30 Condition A, Required Action B.1 requires restoration of the containment sump to operable 31 status [within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s][or in accordance with the Risk Informed Completion Time (RICT) 32 Program]. Required Action B.1 is modified by two notes which directs entering the applicable 33 conditions and required actions of LCO 3.5.2, ECCS-Operating, and LCO 3.5.3, 34 ECCS-Shutdown, for ECCS trains made inoperable by the containment sump and entering the 35 applicable conditions and required actions of LCO 3.6.6, Containment Spray and Cooling 36 Systems, for Containment Spray and Cooling System (CSS) trains made inoperable by the 37 containment sump.

38 39 Condition C specifies that if required action and associated completion time (CT) under 40 Condition A and B are not met, Required Actions C.1 and C.2 require licensees to be in Mode 3 41 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , respectively.

42 43 The licensee proposed to expand and relocate an SR currently located in LCO TS 3.5.2. The 44 new SR requires the licensee to verify, by visual inspection, the containment sump does not 45 show structural damage, abnormal corrosion, or debris blockage [every 18 months][in 46 accordance with the SFCP].

47 48 {NOTE: If the plant has more than one containment sump, include the following paragraph :}

49 [Plant name]s containment sump design includes more than one containment sump. [Enter 50 additional details of the plants containment sump design and justification detailing why 51 the new proposed LCO is applicable.] The sumps are considered part of a single support

1 system because containment accident generated and transported debris issues that would 2 render one sump inoperable would render all of the sumps inoperable. The new containment 3 sump LCO TS proposed is applicable to plants that have more than one containment sump.

4 5 {NOTE: The Table of Contents is not part of the license for all licensees. If the licensee 6 included revised Table of Contents pages in the request, include the following paragraph.}

7 8 [The licensee also proposed a conforming change to the TS Table of Contents to reflect 9 the addition of the new containment sump TSLCO.]

10 11 This change is evaluated in Section 3.4 of this SE.

12 13 2.2.5 Variations from TSTF-567, Revision 1 14 15 {NOTE: Technical reviewers and/or project manager to discuss variations from the approved 16 traveler and whether they are acceptable. Choose the applicable paragraphs based on 17 information provided in the LAR.}

18 19 [The licensee is not proposing any variations from the TS changes described in 20 TSTF-567 or the applicable parts of the NRC staffs safety evaluation (SE) of TSTF-567.]

21 22 [The licensee is proposing the following variations from the TS changes described in 23 TSTF-567 or the applicable parts of the NRC staffs safety evaluation (SE) of TSTF-567.

24 These variations do not affect the applicability of TSTF-567 or the NRC staff's SE to the 25 proposed license amendment.]

26 27 [The [PLANT] TS utilize different [numbering][and][titles] than the Standard Technical 28 Specifications on which TSTF-567 was based. Specifically, [describe differences 29 between the plant-specific TS numbering and/or titles and the TSTF-567 numbering 30 and/or titles.] These differences are editorial and do not affect the applicability of 31 TSTF-567 to the [PLANT] TS.]

32 33 [The [PLANT] design is different than the model plant assumed in the Standard Technical 34 Specifications, but the TSTF-567 justification and the NRC staff's SE are still applicable.

35 [Describe differences and why TSTF-567 is still applicable.))

36 37 [The [PLANT] TS for the Emergency Core Cooling System (ECCS) and Containment 38 Spray System (CSS) have a different Applicability than the Standard Technical 39 Specifications on which TSTF-567 was based. Because the Containment Sump is a 40 support system to the ECCS and CSS systems, the Containment Sump Applicability is 41 revised to be consistent with these specifications. This does not affect the applicability 42 of the TSTF-567 justification or the NRC staff's SE.]

43 44 [The [PLANT] TS for the Emergency Core Cooling System (ECCS) and Containment 45 Spray System (CSS) were revised by adoption of TSTF-432-A, Rev. 1, "Change in 46 Technical Specifications End States (WCAP-16294)." The terminal action in the ECCS 47 and CSS TS is to be in Mode 4, not Mode 5. Because the only function of the 48 Containment Sump is to support the ECCS and CSS systems, Required Action C.2 is 49 revised from being in Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to being in Mode 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , consistent with 50 the ECCS and CSS specifications. To be consistent with the ECCS and CSS TS and the 51 justification of TSTF-432, Required Action C.2 is modified by a Note that states that LCO

1 3.0.4.a is not applicable when entering Mode 4. This difference does not affect the 2 applicability of the TSTF-567 justification or the NRC staff's SE.]

3 4 [TSTF-567 discusses applicable regulatory requirements and guidance, including the 5 10 CFR 50, Appendix A, General Design Criteria (GDC). [PLANT] was not licensed to the 6 10 CFR 50, Appendix A, GDC. The [PLANT] equivalents of the referenced GDC are 7 [reference including UFSAR location, if applicable]. [Discuss the equivalence of the 8 referenced plant-specific requirements to the Appendix A GDC as related to the 9 proposed change.] This difference does not alter the conclusion that the proposed 10 change is applicable to [PLANT].]

11 12 [The [PLANT] Technical Specifications contain a Surveillance Frequency Control 13 Program. Therefore, the Frequency for Surveillance Requirement 3.6.[8].1 is "In 14 accordance with the Surveillance Frequency Control Program."]

15 16 {NOTE: Use of a RICT for Required Action B.1, is a permissible variation, but requires 17 plant-specific review. Therefore, use addition of a RICT will remove the LAR from the CLIIP.}

18 [The licensee is proposing the use of a RICT Program for Required Action B.1.

19 Additional plant-specific technical information and justification, consistent with the 20 justification provided when adopting [TSTF-505 or the plant-specific RICT Program], was 21 provided in the submittal. This SE does not approve the use of the RICT Program. The 22 NRC staffs evaluation of the proposed RICT for Required Action B.1 is in Section 3.4 of 23 this SE.]

24 25 2.3 APPLICABLE REGULATORY REQUIREMENTS AND GUIDANCE 26 27 2.3.1 Technical Specifications 28 29 Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires each 30 applicant for a license authorizing operation of a utilization facility to include in the application 31 proposed TSs. A summary statement of the bases or reasons for such specifications 32 33 The regulation at 10 CFR 50.36(b) requires:

34 35 Each license authorizing operation of a utilization facility will 36 include technical specifications. The technical specifications will 37 be derived from the analyses and evaluation included in the safety 38 analysis report, and amendments thereto, submitted pursuant to 39 [10 CFR] 50.34 [Contents of applications; technical information].

40 The Commission may include such additional technical 41 specifications as the Commission finds appropriate.

42 43 The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). As required 44 by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability 45 or performance levels of equipment required for safe operation of the facility. Per 46 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut 47 down the reactor or follow any remedial action permitted by the TSs until the condition can be 48 met.

49 50 The regulation at 10 CFR 50.36(c)(3) requires TSs to include SRs, which are requirements 51 relating to test, calibration, or inspection to assure that the necessary quality of systems and

1 components is maintained, that facility operation will be within safety limits, and that the LCOs 2 will be met.

3 4 The regulation at 10 CFR 50.36(c)(5) requires TSs to include administrative controls, which are 5 the provisions relating to organization and management, procedures, recordkeeping, review and 6 audit, and reporting necessary to assure operation of the facility in a safe manner.

7 8 The regulation at 10 CFR 50.36(a)(1) requires each applicant for a license provide a summary 9 statement of the bases or reasons for specifications, other than those covering administrative 10 controls, in the application, but these statements are not part of the technical specifications.

11 12 2.3.2 Guidance 13 14 The guidance that the NRC staff considered in its review of this LAR included the following:

15 16 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports 17 for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Chapter 16, Technical 18 Specifications, dated March 2010 (ADAMS Accession No. ML100351425), provides 19 guidance on review of TSs.

20 21 {NOTE: Choose applicable STS}

22 [U.S. Nuclear Regulatory Commission, Standard Technical Specifications, 23 Babcock and Wilcox Plants, NUREG-1430, Volume 1, Specifications, and Volume 2, 24 "Bases," Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12100A177 and 25 ML12100A178).

26 27 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, 28 Westinghouse Plants, NUREG-1431, Volume 1, Specifications, and Volume 2, "Bases,"

29 Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12100A222 and 30 ML12100A228).

31 32 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, 33 Combustion Engineering Plants, NUREG-1432, Volume 1, Specifications, and 34 Volume 2, "Bases," Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12102A165 35 and ML12100A228).]

36 37

3.0 TECHNICAL EVALUATION

38 39

3.1 PROPOSED CHANGE

S TO LCO TS 3.5.2, ECCS-OPERATING 40 41 The licensee proposed to modify and move SR 3.5.2.[9] from LCO TS 3.5.2 to the new 42 containment sump LCOTS. Therefore, the licensee proposed deletion of SR 3.5.2.[9].

43 44 The new SR does not limit the visual inspection to the suction inlet, trash racks and screens as 45 currently required by the TSs, but instead requires inspection of the entire containment sump 46 system. The containment sump system consists of the containment drainage flow paths, any 47 design features upstream of the containment sump that are credited in the containment debris 48 analysis, the containment sump strainers (or screens), the pump suction trash racks, and the 49 inlet to the ECCS and CSS piping.

50

1 The NRC staff concludes the proposed change is acceptable since the existing requirements 2 are either unchanged or expanded and continue to ensure the containment sump is unrestricted 3 (i.e., unobstructed) and stays in proper operating condition. The proposed change meets the 4 requirements of 10 CFR 50.36(c)(3) because it provides SRs to assure the necessary quality of 5 systems and components are maintained, that facility operation will be within safety limits, and 6 that the LCOs will be met.

7 8

3.2 PROPOSED CHANGE

S TO LCO TS 3.5.3, ECCS-SHUTDOWN 9

10 The licensee proposed to delete the reference to SR 3.5.2.[9] in SR 3.5.3.1.

11 12 The NRC staff concludes the proposed change is acceptable since SR 3.5.2.[9] was modified 13 and relocated to the new containment sump LCOTS. The existing SR on the containment sump 14 is augmented (by requiring inspection of additional sump components) and moved to the new 15 specification, and a duplicative requirement to perform the SR in TS 3.5.3 is removed. The new 16 specification retains or expands the existing requirements on the containment sump and the 17 actions to be taken when the containment sump is inoperable with the exception of adding new 18 actions to be taken when the containment sump is inoperable due to containment accident 19 generated and transported debris exceeding the analyzed limits. The new action provides time 20 to evaluate and correct the condition instead of requiring an immediate plant shutdown. The 21 proposed change meets the requirements of 10 CFR 50.36(c)(3) because it provides SRs to 22 assure the necessary quality of systems and components are maintained, that facility operation 23 will be within safety limits, and that the LCOs will be met.

24 25 {NOTE: The change to TS 5.5.15 is optional. Some plants may have already adopted this 26 change into their TS.}

27 28 [

3.3 PROPOSED CHANGE

S TO SECTION TS 5.5.15, SAFETY FUNCTION 29 DETERMINATION PROGRAM (SFDP) 30 31 LCO 3.0.6 states:

32 33 When a supported system LCO is not met solely due to a 34 support system LCO not being met, the Conditions and 35 Required Actions associated with this supported system are 36 not required to be entered. Only the support system LCO 37 ACTIONS are required to be entered. This is an exception to 38 LCO 3.0.2 for the supported system. In this event, an 39 evaluation shall be performed in accordance with 40 Specification 5.5.15, Safety Function Determination Program 41 (SFDP). If a loss of safety function is determined to exist by 42 this program, the appropriate Conditions and Required 43 Actions of the LCO in which the loss of safety function exists 44 are required to be entered.

45 46 When a support systems Required Action directs a 47 supported system to be declared inoperable or directs entry 48 into Conditions and Required Actions for a supported 49 system, the applicable Conditions and Required Actions shall 50 be entered in accordance with LCO 3.0.2.

51

1 When a loss of safety function is determined to exist, the SFDP requires entry into the 2 appropriate conditions and required actions of the LCO in which the loss of safety 3 function exists. Where a loss of function is solely due to a single TS support system 4 (e.g., a single containment sump train) the appropriate LCO is the LCO for that support 5 system. When the loss of function is the result of multiple support systems, the 6 appropriate LCO is the LCO for the supported systems.

7 8 The licensee proposed to add the following statement to TS 5.5.1215, [W]hen a loss of 9 safety function is caused by the inoperability of a single Technical Specification support 10 system, the appropriate Conditions and Required Actions to enter are those of the 11 support system.

12 13 The NRC staff finds that the proposed addition to TS 5.5.12 15 clarifies the intent of the 14 allowance (not to enter the Conditions and Required Actions) provided by LCO 3.0.6 and 15 the SFDP for single-train support systems. The NRC staff concludes the proposed 16 change is acceptable since the actions for the support system LCO adequately address 17 the inoperability of that system. Therefore, as required by 10 CFR 50.36(c)(5), it 18 continues to provide adequate administrative controls to assure safe operation.]

19 20 3.4 PROPOSED ADDITION OF CONTAINMENT SUMP LCOTS 21 22 3.4.1 Considerations of the LCOTS 23 24 The licensee proposed to add a new LCO TS to address operability requirements of the 25 containment sump. The numbering for this new LCO TS is LCO TS 3.6.[8].

26 27 The containment sump supports the post-accident operation of the ECCS and CSS. However, 28 only the current ECCS TS LCOs contain SRs related to the containment sump and the TS do 29 not specify required actions that specifically address an inoperable containment sump. If the 30 containment sump were found to be inoperable, as an ECCS and CSS support system, those 31 respective LCOs would not be met. In order to address concerns related with to containment 32 sump operability due to debris accumulation described in GSI-191, Assessment of Debris 33 Accumulation on Pressurized-Water Reactor Sump Performance, the licensee proposed to add 34 a new specification to address containment sump inoperability and create a condition for when 35 the sump is inoperable due to analyzed containment accident generated and transported debris.

36 37 Based on the above evaluation, the NRC staff determined that proposed LCO TS satisfies the 38 requirements of 10 CFR 50.36(c)(2)(i) because the LCO specifies the lowest functional 39 capability or performance levels of equipment required for safe operation of the facility. There is 40 reasonable assurance that the required actions to be taken when the LCO is not met can be 41 conducted without endangering the health and safety of the public.

42 43 3.4.2 Considerations of the Applicability 44 45 {NOTE: There is an allowable variation, discussed in Section 2.2.5 of this SE, for a different 46 Applicability using the same justification.}

47 48 The new LCO TS requires the containment sump to be operable during Modes 1, 2, 3, and 4.

49 The ECCS and CSS LCOs TS currently in TS are applicable during Modes 1, 2, 3, and 4.

50

1 The NRC staff finds the proposed applicability is acceptable because the applicability is 2 consistent with the applicability of the ECCS and CSS LCOsTS, the containment sump 3 supported systems.

4 5 3.4.3 Considerations of Condition A 6

7 The licensee has analyzed the susceptibility of the ECCS and CSS to the adverse effects of 8 post-accident debris blockage and operation with debris-laden fluids. The licensee has 9 established [Final Safety Analysis Report] limits on the allowable quantities of containment 10 accident generated debris that could be transported to the containment sump based on its 11 current plant configuration. In the current TSs, if unanalyzed debris sources are discovered 12 inside containment, if errors are discovered in debris-related analyses, or if a previously 13 unevaluated phenomenon that can affect containment sump performance is discovered, the 14 containment sump, and the supported ECCS and CSS, may be inoperable and the TSs would 15 require an immediate plant shutdown with no time provided to evaluate the condition.

16 17 In order to address this situation and to provide sufficient time to evaluate the condition, the 18 licensee proposed Condition A, which is applicable when the containment sump is inoperable 19 due to containment accident generated and transported debris exceeding the analyzed limits.

20 Under Condition A, the operability of the containment sump with respect to debris is based on a 21 quantity of debris evaluated and determined to be acceptable by the licensee. Emergent 22 nonconforming or degraded conditions affecting the quantity of analyzed debris shall be 23 evaluated using a deterministic process.

24 25 Under Condition A, Required Action A.1 mandates immediate action to be initiated to mitigate 26 the condition. The licensee's proposed TS Bases for Required Action A.1 provided In its 27 submittal, the licensee provided the following examples of mitigating actions:

28 29

Removing the debris source from containment or preventing the 30 debris from being transported to the containment sump; 31 32

Evaluating the debris source against the assumptions in the 33 analysis; 34 35

Deferring maintenance that would affect availability of the affected 36 systems and other LOCA mitigating equipment; 37 38

Deferring maintenance that would affect availability of primary 39 defense-in-depth systems, such as containment coolers; 40 41

Briefing operators on LOCA debris management actions; or 42 43

Applying an alternative method to establish new limits.

44 45 The NRC staff finds the proposed Required Action A.1 and its completion time (CT) are 46 acceptable because they place urgency on the appropriate actions that could mitigate or reduce 47 the impact of the identified conditions.

48 49 Concurrently, Required Action A.2 mandates SR 3.4.13.1, the RCS water inventory balance, to 50 be performed at an increased frequency of once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . An unexpected increase in RCS

1 leakage could be indicative of an increased potential for an RCS pipe break, which could result 2 in debris being generated and transported to the containment sump.

3 4 The NRC staff finds the proposed Required Action A.2 and its CT are acceptable because the 5 more frequent monitoring allows operators to act in a timely fashion to minimize the potential for 6 an RCS pipe break while the containment sump is inoperable.

7 8 In addition, Required Action A.3 requires the inoperable containment sump to be restored to 9 operable status in 90 days.

10 11 The NRC staff finds the proposed Required Action A.3 and its CT are acceptable because they 12 provide a reasonable amount of time to diagnose, plan and possibly reduce the severity of, or 13 mitigate the unanalyzed debris condition and prevent a loss of ECCS and CSS safety function.

14 In addition, 90 days is adequate given the conservatisms in the analysis and the proposed 15 compensatory actions required to be implemented immediately by Required Action A.1. Also, 16 as discussed later in this SE section, the new SR will require visual inspection of the 17 containment sump system (including the containment drainage flow paths, any design features 18 upstream of the containment sump that are credited in the containment debris analysis, the 19 containment sump strainers, the pump suction trash racks, and the inlet to the ECCS and CSS 20 piping for evidence of structural degradation, potential for debris bypass, and presence of 21 corrosion or debris blockage) to ensure no loose debris is present and there is no evidence of 22 structural distress or abnormal corrosion.

23 24 {NOTE: If the plant has more than one containment sump, include the following paragraph, 25 ensuring the plant-specific containment sump design aligns with this justification and modifying 26 accordingly :}

27 [Specifically for Condition A, multiple containment sumps are considered part of a single 28 support system. The NRC staff finds this proposed change is acceptable since it is a 29 conservative assumption. The plant is designed so that one sump will remain operable 30 with the design-basis debris load. The second sump is assumed to be out of service due 31 to a single failure in the ECCS or CSS. The single sump in a plant with multiple sumps is 32 equivalent to the sump in a plant with only one sump because the multiple sumps are 33 considered to be part of a single support system. If containment accident generated and 34 transported debris were to render one sump inoperable, then it would render all of the 35 sumps inoperable. In any case where the single failure did not occur, the second sump 36 would be in service and provide significant additional surface area for debris to collect, 37 thus reducing the severity of the effects of the debris. The second sump provides 38 redundancy in these cases.]

39 40 3.4.4 Considerations of Condition B 41 42 Condition B specifies the required actions for when the containment sump is inoperable for 43 reasons other than containment accident generated and transported debris exceeding the 44 analyzed limits.

45 46 Required Action B.1 requires restoring the containment sump to operable status and is modified 47 by two notes. These two notes direct entry into the conditions and required actions for the 48 supported systems (ECCS and CSS). Since Required Action B.1 directs entry to the 49 corresponding ECCS and CSS LCOsTS, these notes retain the existing TS actions for ECCS or 50 CSS trains made inoperable by an inoperable containment sump inoperable for reasons other 51 than containment accident generated and transported debris exceeding the analyzed limits.

1 {NOTE: If the proposed CT is 7 days instead of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , include the bracketed phrases.}

2 3 The proposed CT for Required Action B.1 is [72 hours][7 days]. This CT is consistent with the 4 [less limiting] CT for a single inoperable ECCS train or CSS train [so that the ECCS and CSS 5 TS Actions control the licensee's response].or in accordance with the RICT Program].

6 7 {NOTE: If the licensee has a previously approved Risk-Informed Completion Time (RICT) 8 Program in TS Section 5.0, Administrative Controls, use this paragraph and revise the last 9 sentence of the following paragraph.}

10 [The licensee has an NRC-approved [adoption of TSTF-505, Provide Risk-Informed 11 Extended Completion Times - RITSTF Initiative 4B,][plant-specific RICT Program] and 12 has a Risk-Informed Completion Time (RICT) Program in TS Section 5.0, Administrative 13 Controls. Therefore, the licensee has proposed the option to calculate a RICT for 14 Required Action B.1. [Insert NRC staff technical evaluation of proposed use of a RICT.]

15 16 The NRC staff finds the proposed change is acceptable since it continues to provide remedial 17 actions for when the containment sump is inoperable for reasons other than Condition A and 18 ensures safe operation of the plant. In addition, the proposed CT of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is acceptable 19 since it provides a reasonable time for repairs, and there is a low probability of an accident 20 occurring during this period necessitating the containment sump.

21 22 3.4.5 Considerations of Condition C 23 24 {NOTE: There is an allowable variation, discussed in Section 2.2.5 of this SE, for a different end 25 state using the same justification.}

26 27 If operators are unable to restore the affected containment sump to operable status under 28 Condition A or B, Required Action C.1 requires the unit to be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months followed by 29 [Mode 5 in 36 hour4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months s][Mode 4 in 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s], as required by Required Action C.2.

30 31 The NRC staff finds this proposed condition and its required actions are acceptable because the 32 condition is consistent with the STSs and requires the operators to place the unit in a condition 33 in which the LCO no longer applies. In addition, the proposed CTs allow a reasonable amount 34 of time to decrease from full power conditions to the required plant conditions in an orderly 35 manner and without challenging plant systems.

36 37 3.4.6 Considerations of the New SR 38 39 The licensee proposed a new SR in the new containment sump LCOTS. This SR was originally 40 located in LCO TS 3.5.2 and referred to in LCO TS 3.5.3. The numbering for this new SR is 41 SR 3.6.8.[1]. The frequency of the new SR is [18 months][as specified in the SFCP].

42 43 The proposed SR requires verification, by visual inspection, that the containment sump does not 44 show structural damage, abnormal corrosion, or debris blockage.

45 46 The new SR is stated in generic terms and expands the scope of the required visual inspection 47 to include the entire containment sump system. The entire containment sump system consists 48 of the containment drainage flow paths, the containment sump strainers (or screens), the pump 49 suction trash racks, and the inlet to the ECCS and CSS piping.

50

1 The NRC staff finds the proposed new SR is acceptable since it expands the scope of 2 inspection of the original SR. In addition, the proposed frequency is acceptable since it is the 3 same as that currently required by the TSs. Therefore, the NRC staff finds that, as required by 4 10 CFR 50.36(c)(3), the necessary quality of systems will be maintained in accordance with the 5 associated LCOs.

6 7 {NOTE: The Table of Contents is not part of the license for all licensees. If the licensee 8 included revised Table of Contents pages in the request, include the following paragraph.}

9 10 [3.4.7 Considerations of Changes to Table of Contents 11 12 The licensee also proposed a conforming change to the Table of Contents to include the 13 new containment sump LCOTS. This conforming change is acceptable since it is an 14 editorial change to support the inclusion of the new containment sump TS LCO.]

15 16 3.4.8 Considerations of Changes to the TS Bases 17 18 The licensee provided proposed conforming changes to the TS Bases for information. The 19 NRC staff does not approve Bases as they are not part of the TS, but the NRC staff did confirm 20 that the changes are consistent with the proposed TS and satisfy the 10 CFR 50.36(a) 21 requirement for bases or reasons for such specifications.

22 23 3.4.98 Conclusion Regarding Proposed Containment Sump LCOTS 24 25 The new containment sump LCO TS retains and expands the existing TS requirements with the 26 exception of the addition of Condition A. Condition A provides a condition for an inoperable 27 containment sump due to containment accident generated and transported debris exceeding the 28 analyzed limits.

29 30 The NRC staff reviewed the proposed changes against the regulations and concludes that the 31 changes continue to meet the requirements of 10 CFR 50.36(c)(2), 50.36(c)(3) and 50.36(c)(5),

32 for the reasons discussed above, and thus provide reasonable assurance that adoption of these 33 TSs will have the requisite requirements and controls to operate safely. Therefore, the NRC 34 staff concludes that the proposed TS changes are acceptable.

35 36 3.5 VARIATIONS 37 38 [Insert evaluation of any variations discussed in Section 2.2.5]

39 40

3.6 TECHNICAL EVALUATION

CONCLUSION 41 42 The NRC staff determined that the proposed changes meet the standards for TS in 43 10 CFR 50.36(a), 50.36(b), and 50.36(c). The proposed changes to the SR assure that the 44 necessary quality of systems and components is maintained, that facility operation will be within 45 safety limits, and that the LCOs will be met, and satisfy 10 CFR 50.36(c)(3).

46 47

4.0 STATE CONSULTATION

48 49 {This section is to be prepared by the plant project manager.}

50

1 In accordance with the Commission's regulations, the [Name of State] State official was notified 2 of the proposed issuance of the amendment(s) on [date]. The State official had [no] comments.

3 [If comments were provided, they should be addressed here.]

4 5

5.0 ENVIRONMENTAL CONSIDERATION

6 7 {This section is to be prepared by the plant project manager in accordance with current 8 procedures.}

9 10

6.0 CONCLUSION

11 12 {This section is to be prepared by the plant project manager.}

13 14 The Commission has concluded, based on the considerations discussed above, that: (1) there 15 is reasonable assurance that the health and safety of the public will not be endangered by 16 operation in the proposed manner, (2) there is reasonable assurance that such activities will be 17 conducted in compliance with the Commission's regulations, and (3) the issuance of the 18 amendment(s) will not be inimical to the common defense and security or to the health and 19 safety of the public.

20 21

7.0 REFERENCES

22 23 {Optional section to be prepared by the PM and primary reviewers. If document is publicly 24 available, the ADAMS Accession No. should be listed.}

25 26 {NOTE: These are the principal contributors for the model SE of the traveler. Replace these 27 names with those who prepared the plant-specific SE.}

28 Principal Contributors: C. Tilton, NRR/DSS 29 S. Smith, NRR/DSS 30 P. Klein, NRR/DMLR 31 M. Honcharik, NRR/DSS 32 33 Date:

v t e Letter Sequence Draft Other
CAC:MF9568, (Open) EPID:L-2017-PMP-0005, TSTF-567 (Open)
Initiation Request Acceptance... Administration Questions Answers Results Approval... Other:
MONTHYEAR2018-04-16 [Table View]

TSTF-18-04, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-567, Revision 1, Add Containment Sump TS to Address GSI-191 Issues.

Text

SUBJECT:

REFERENCE:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

2.1 DESCRIPTION

2.2 PROPOSED CHANGE

3.0 TECHNICAL EVALUATION

3.1 PROPOSED CHANGE

3.2 PROPOSED CHANGE

3.3 PROPOSED CHANGE

4.0 CONCLUSION

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

2.2 PROPOSED CHANGE

3.0 TECHNICAL EVALUATION

3.1 PROPOSED CHANGE

3.2 PROPOSED CHANGE

3.3 PROPOSED CHANGE

3.6 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

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TSTF-18-04, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-567, Revision 1, Add Containment Sump TS to Address GSI-191 Issues.

Text

SUBJECT:

REFERENCE:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

2.1 DESCRIPTION

2.2 PROPOSED CHANGE

3.0 TECHNICAL EVALUATION

3.1 PROPOSED CHANGE

3.2 PROPOSED CHANGE

3.3 PROPOSED CHANGE

4.0 CONCLUSION

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

2.2 PROPOSED CHANGE

3.0 TECHNICAL EVALUATION

3.1 PROPOSED CHANGE

3.2 PROPOSED CHANGE

3.3 PROPOSED CHANGE

3.6 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

7.0 REFERENCES

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