TSTF-18-11, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-563, Revision 0, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program.

TSTF Comments on Draft Safety Evaluation for Traveler TSTF-563, Revision 0, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program.

ML18285A088
Person / Time
Site:	Technical Specifications Task Force
Issue date:	10/12/2018
From:	Gullott D, Joyce R, Miksa J, Sparkman W, Vaughan J BWR Owners Group, PWR Owners Group, Technical Specifications Task Force
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TSTF-18-11
Download: ML18285A088 (28)

Text

TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY October 12, 2018 TSTF-18-11 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

TSTF Comments on Draft Safety Evaluation for Traveler TSTF-563, Revision 0, "Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program"

REFERENCE:

Letter Victor Cusumano (NRC) to the TSTF, "Draft Safety Evaluation of Technical Specifications Task Force Traveler TSTF-563, Revision 0, 'Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program'," dated September 20, 2018 (ADAMS Accession No. ML18226A327).

On May 10, 2017, the TSTF submitted traveler TSTF-563, Revision 0, "'Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program," to the Nuclear Regulatory Commission (NRC) for review (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17130A819). In the referenced letter, the NRC provided the draft Safety Evaluations for TSTF-563 for 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) Ryan M. Joyce (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-563 Draft Safety Evaluations TSTF Markup of Draft Safety Evaluations cc: Michelle Honcharik, Technical Specifications Branch, NRC Victor Cusumano, Technical Specifications Branch, NRC

Attachment 1 TSTF Comments on the TSTF-563 Draft Safety Evaluations General Comments

1. The traveler SE states that the change is not applicable to AP1000 plants. NUREG-2194 was included in the traveler and the Request for Additional Information did not question its inclusion. There is no technical difference between the application of TSTF-563 to AP1000 plants and other plant designs. AP1000 plants should not be excluded from the traveler.

The footnote is revised to state that incorporation of TSTF-563 into a future revision of NUREG-2194 is dependent on incorporation of a Surveillance Frequency Control Program (SFCP).

AP1000 plants should not be excluded from the model Safety Evaluation because the traveler can only be adopted by plants that have an SFCP. If an AP1000 plant has previously adopted an SFCP, then TSTF-563 is applicable.

2. Changes "TSs" to "TS." The term Technical Specifications is already plural.

Page 3

Comments on the TSTF-563 Traveler Draft Safety Evaluation Page(s) Line(s)1 Comment 1 20-21, General Comment 1.

22-23 and footnote 2 17 Editorial change. The word "are" appears to be missing.

2 19,28 General Comment 2.

3 5-6 General Comment 1.

3 25 General Comment 1.

3 34 General Comment 1.

4 4 General Comment 2.

5 18, 24, General Comment 2.

42 8 45 General Comment 2.

9 34 Editorial change. Revise "evaluated" to "evaluate."

10 48 General Comment 1.

10 49, 50 General Comment 2.

11 11 General Comment 2.

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

Page 4

Comments on the TSTF-563 Draft Model Safety Evaluation Page(s) Line(s)2 Comment 1 39 Defined SFCP.

2 12, 15, General Comment 2.

25, 49 2 14-15 It is more accurate to refer to the plant-specific amendment that revised the plant's TS to incorporate an SFCP than to refer to TSTF-425, which only revised the STS.

4 23 General Comment 2.

5 4, 19, General Comment 2.

30, 36 5 10-11 The model SE example variation refers to differences in the plant design.

TSTF-563 is not dependent on the design. The model application refers to plant TS different from the STS, as wording differences in the affected definitions could be relevant to the change. Revisions to the model SE are provided.

5 40 It is more accurate to refer to the plant-specific amendment that revised the plant's TS to incorporate an SFCP than to refer to TSTF-425, which only revised the STS.

6 4 General Comment 2.

7 32-36 General Comment 1.

10 30, 33, General Comment 2.

41 11 1 General Comment 2.

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

Page 5

Attachment 2 TSTF Markup of Draft Safety Evaluations

1 DRAFT SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 2 TECHNICAL SPECIFICATIONS TASK FORCE Traveler 3 TSTF-563, REVISION 0 4 REVISE INSTRUMENT TESTING DEFINITIONS TO INCORPORATE THE SURVEILLANCE 5 FREQUENCY CONTROL PROGRAM 6 USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 7 (CAC NO. MF9955, EPID L-2017-PMP-0006) 8 9

10

1.0 INTRODUCTION

11 12 By letter dated May 10, 2017 (Agencywide Documents Access and Management System 13 (ADAMS) Accession No. ML17130A819), the Technical Specifications Task Force (TSTF) 14 submitted Traveler TSTF-563, Revision 0, Revise Instrument Testing Definitions to Incorporate 15 the Surveillance Frequency Control Program. By letter dated April 27, 2018, the TSTF 16 responded to the U.S. Nuclear Regulatory Commission (NRC) staff requests for additional 17 information (RAIs) (ADAMS Accession No. ML18117A326). Traveler TSTF-563 proposes 18 changes to the Standard Technical Specifications (STS) for all plant designs, including 19 Babcock & Wilcox (B&W), Combustion Engineering (CE), Westinghouse, General Electric (GE),

20 and Westinghouse AP1000 plants. However, the NRC staff did not review and has not 21 approved this change for Westinghouse AP1000 plants. These changes will be incorporated 22 into future revisions of NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, and 23 NUREG-1434, and NUREG-2194. 1 This traveler will be made available to licensees for 24 adoption through the consolidated line item improvement process (CLIIP).

25 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, respectively).

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, respectively).

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, respectively).

U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric, BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193, respectively).

U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric BWR/6 Plants, NUREG-1434, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A195 and ML12104A196, respectively).

U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse Advanced Passive (AP1000) Plants, NUREG-2194, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, April 2016 (ADAMS Accession Nos. ML16110A277 and ML16110A369, respectively). (Incorporation of TSTF-563 into a future revision of NUREG-2194 is dependent on incorporation of a Surveillance Frequency Control Program.)

Enclosure 1

1 The proposed changes would revise the current instrumentation testing definitions of Channel 2 Calibration, Channel Functional Test, Channel Operational Test (COT), and Trip Actuation 3 Device Operational Test (TADOT) to permit determination of the appropriate frequency to 4 perform the Surveillance Requirement (SR) based on the devices being tested in each step, for 5 those plants that have an approved Surveillance Frequency Control Program (SFCP) that uses 6 Nuclear Energy Institute (NEI) 04-10, Revision 1, Risk-Informed Method for Control of 7 Surveillance Frequencies, (ADAMS Accession No. ML071360456). NEI 04-10, Revision 1, 8 was approved by the NRC on September 19, 2007 (ADAMS Accession No. ML072570267).

9 Traveler TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control -

10 RITSTF [Risk-Informed TSTF] Initiative 5b, provided a model for incorporating an SFCP into 11 the STS. Traveler TSTF-425, Revision 3, was approved by the NRC staff on June 23, 2009 12 (ADAMS Accession No. ML090900716).

13 14

2.0 REGULATORY EVALUATION

15 16

2.1 DESCRIPTION

OF SURVEILLANCE FREQUENCY CONTROL PROGRAM AND 17 INSTRUMENT TESTING 18 19 The STS state the surveillances for instrumentation channels are to be performed within the 20 specified frequency, using any series of sequential, overlapping, or total channel steps.

21 Traveler TSTF-425 revised the TSs to relocate all periodic surveillance frequencies to licensee 22 control. Changes to the relocated surveillance frequencies are made in accordance with the TS 23 program referred to as the SFCP. The SFCP allows a new surveillance frequency to be 24 determined for the channel, but that frequency must consider all components in the channel and 25 applies to the entire channel.

26 27 A typical instrument channel consists of many different components, such as sensors, rack 28 modules, and indicators. These components have different short-term and long-term 29 performance (drift) characteristics, resulting in the potential for different calibration frequency 30 requirements. Under the current TSs, the most limiting component calibration frequency for the 31 channel must be chosen when a revised frequency is considered under the SFCP. As a result, 32 all components that make up a channel must be calibrated at a frequency equal to the channel 33 component with the shortest (i.e., most frequent) surveillance frequency.

34 35 Some channel components, such as pressure transmitters, are very stable with respect to drift 36 and could support a substantially longer calibration frequency than the other components in the 37 channel. Currently, the SRs in many plants are performed in steps (e.g., a pressure sensor or 38 transmitter is calibrated during a refueling outage and the rack signal conditioning modules are 39 calibrated while operating at power). The proposed change extends this concept to permit the 40 surveillance frequency of each step to be determined under the SFCP based on the 41 component(s) surveilled in the step instead of all components in the channel. This will allow 42 each component to be tested at the appropriate frequency based on the components long-term 43 performance characteristics.

44 45 Allowing an appropriate surveillance frequency for performing a channel calibration on each 46 component or group of components could reduce radiation dose associated with inplace 47 calibration of sensors, reduce wear on equipment, reduce unnecessary burden on plant staff, 48 and reduce opportunities for calibration errors.

49 50

2.2 PROPOSED CHANGE

S TO THE STANDARD TECHNICAL SPECIFICATIONS 51

1 The proposed changes to the STS would revise the definitions of Channel Calibration, Channel 2 Functional Test, COT, and TADOT by adding the words , and each step must be performed 3 within the Frequency in the Surveillance Frequency Control Program for the devices included in 4 the step at the end of the last sentence of each definition.

5 6 The following paragraph denotes the changes to the Channel Calibration definition for all plant 7 designs (B&W, CE, GE, and Westinghouse plants, NUREG-1430 through NUREG-1434 and 8 NUREG-2194). The Westinghouse plant definition (NUREG-1431 and NUREG-2194) does not 9 include the phrase shown in brackets and the CHANNEL FUNCTIONAL TEST. Changes are 10 shown in italics:

11 12 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the 13 channel output such that it responds within the necessary range and accuracy to 14 known values of the parameter that the channel monitors. The CHANNEL 15 CALIBRATION shall encompass all devices in the channel required for channel 16 OPERABILITY[ and the CHANNEL FUNCTIONAL TEST]. Calibration of 17 instrument channels with resistance temperature detector (RTD) or thermocouple 18 sensors may consist of an inplace qualitative assessment of sensor behavior and 19 normal calibration of the remaining adjustable devices in the channel. The 20 CHANNEL CALIBRATION may be performed by means of any series of 21 sequential, overlapping, or total channel steps [, and each step must be 22 performed within the Frequency in the Surveillance Frequency Control Program 23 for the devices included in the step].

24 25 The following paragraph denotes the changes to the Channel Functional Test definition for 26 B&W, CE, and GE plant designs (NUREG-1430 and NUREG-1432 through NUREG-1434). In 27 the Westinghouse plant definition (NUREG-1431 and NUREG-2194), the Channel Functional 28 Test is replaced with two tests: the COT and the TADOT. Changes are shown in italics:

29 30 ...The CHANNEL FUNCTIONAL TEST may be performed by means of any 31 series of sequential, overlapping, or total [channel] steps [, and each step must 32 be performed within the Frequency in the Surveillance Frequency Control 33 Program for the devices included in the step].

34 35 The following paragraphs denote the changes of the COT and TADOT definitions for 36 Westinghouse plants (NUREG-1431 and NUREG-2194). Changes are shown in italics:

37 38 A COT shall be the injection of a simulated or actual signal into the channel as 39 close to the sensor as practicable to verify OPERABILITY of all devices in the 40 channel required for channel OPERABILITY. The COT shall include 41 adjustments, as necessary, of the required alarm, interlock, and trip setpoints 42 required for channel OPERABILITY such that the setpoints are within the 43 necessary range and accuracy. The COT may be performed by means of any 44 series of sequential, overlapping, or total channel steps [, and each step must be 45 performed within the Frequency in the Surveillance Frequency Control Program 46 for the devices included in the step].

47 48 A TADOT shall consist of operating the trip actuating device and verifying the 49 OPERABILITY of all devices in the channel required for trip actuating device 50 OPERABILITY. The TADOT shall include adjustment, as necessary, of the trip 51 actuating device so that it actuates at the required setpoint within the necessary

1 accuracy. The TADOT may be performed by means of any series of sequential, 2 overlapping, or total channel steps [, and each step must be performed within the 3 Frequency in the Surveillance Frequency Control Program for the devices 4 included in the step].

5 6 The various instrumentation functions in the TSs require surveillances to verify the correct 7 functioning of the instrument channel. The proposed change extends the definition of 8 instrumentation channel components to permit the surveillance frequency of each step to be 9 determined under the SFCP based on the component(s) surveilled in the step instead of all 10 components in the channel. This will allow each component to be tested at the appropriate 11 frequency based on the components long-term performance characteristics.

12 13 The proposed changes in the definition for instrument testing would allow the licensee to control 14 the frequency of associated components being tested in each step. The SR for the overall 15 instrumentation channel remains unchanged. The proposed change has no effect on the 16 design, fabrication, use, or methods of testing the instrumentation channels and will not affect 17 the ability of the instrumentation to perform the functions assumed in the safety analysis.

18 19 Traveler TSTF-563 distinguished between instrumentation SRs (Channel Calibration, Channel 20 Functional Test, COT, and TADOT) and other SRs. These instrumentation testing definitions 21 state that, [t]he [test type] may be performed by means of any series of sequential, overlapping, 22 or total channel steps. Traveler TSTF-563 proposed the surveillance frequency of these 23 subsets to be established based on the characteristics of the components in the step rather than 24 the most limiting component characteristics in the entire channel. Each of these steps are 25 evaluated in accordance with the SFCP.

26 27 2.3 APPLICABLE REGULATORY REQUIREMENTS AND GUIDANCE 28 29 Section IV, The Commission Policy, of the Final Policy Statement on Technical Specifications 30 Improvements for Nuclear Power Reactors, published in the Federal Register on July 22, 1993 31 (58 FR 39132), states, in part:

32 33 The purpose of Technical Specifications is to impose those conditions or 34 limitations upon reactor operation necessary to obviate the possibility of an 35 abnormal situation or event giving rise to an immediate threat to the public health 36 and safety by identifying those features that are of controlling importance to 37 safety and establishing on them certain conditions of operation which cannot be 38 changed without prior Commission approval.

39 40 [T]he Commission will also entertain requests to adopt portions of the 41 improved STS [(e.g., TSTF-563)], even if the licensee does not adopt all STS 42 improvements. The Commission encourages all licensees who submit 43 Technical Specification related submittals based on this Policy Statement to 44 emphasize human factors principles.

45 46 In accordance with this Policy Statement, improved STS have been developed 47 and will be maintained for each NSSS [nuclear steam supply system] owners 48 group. The Commission encourages licensees to use the improved STS as the 49 basis for plant-specific Technical Specifications. [I]t is the Commission intent 50 that the wording and Bases of the improved STS be used to the extent 51 practicable.

1 2 As described in the Commissions Final Policy Statement on Technical Specifications 3 Improvements for Nuclear Power Reactors, the NRC and industry task groups for new STS 4 recommend that improvements include greater emphasis on human factors principles in order to 5 add clarity and understanding to the text of the STS, and provide improvements to the Bases of 6 STS, which provides the purpose for each requirement in the specification. The improved 7 vendor-specific STS were developed and issued by the NRC in September 1992.

8 9 The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) 10 requires:

11 12 Each license authorizing operation of a utilization facility will include 13 technical specifications. The technical specifications will be derived from the 14 analyses and evaluation included in the safety analysis report, and amendments 15 thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; 16 technical information]. The Commission may include such additional technical 17 specifications as the Commission finds appropriate.

18 19 The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). One such 20 category is SRs, which are defined in 10 CFR 50.36(c)(3) as requirements relating to test, 21 calibration, or inspection to assure that the necessary quality of systems and components is 22 maintained, that facility operation will be within safety limits, and that the limiting conditions for 23 operation will be met.

24 25 The regulation at 10 CFR 50.36(c)(5) requires TSs to include administrative controls, which are 26 the provisions relating to organization and management, procedures, recordkeeping, review and 27 audit, and reporting necessary to assure operation of the facility in a safe manner.

28 29 Traveler TSTF-425 revised and relocated most periodic surveillance frequencies to licensee 30 control. Changes to the relocated surveillance frequencies are made in accordance with the 31 SFCP. The SFCP requires that changes to the relocated frequencies be made in accordance 32 with the NRC staff approved topical report NEI 04-10.

33 34 Topical report NEI 04-10 describes an evaluation process and a multi-disciplinary plant 35 decisionmaking panel that considers the detailed evaluation of proposed surveillance frequency 36 revisions. The evaluations are based on operating experience, test history, manufacturers 37 recommendations, codes and standards, and other deterministic factors, in conjunction with risk 38 insights. The evaluation considers all components being tested by the SR. Process elements 39 are included for determining the cumulative risk impact of the changes, updating the licensees 40 probabilistic risk assessment (PRA) models, and for imposing corrective actions, if necessary, 41 following implementation of a revised frequency.

42 43 The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of 44 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for 45 Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ADAMS 46 Accession No. ML100351425). As described therein, as part of the regulatory standardization 47 effort, the NRC staff has prepared STS for each of the LWR nuclear designs. Accordingly, the 48 NRC staffs review includes consideration of whether the proposed changes are consistent with 49 the applicable reference STS (i.e., the current STS), as modified by NRC-approved Travelers.

50 In addition, the guidance states that comparing the change to previous STS can help clarify the 51 TS intent.

1 2 Regulatory Guide (RG) 1.174, Revision 2, An Approach for Using Probabilistic Risk 3 Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis 4 (ADAMS Accession No. ML100910006), describes an acceptable risk-informed approach for 5 assessing the nature and impact of proposed permanent licensing basis changes by 6 considering engineering issues and applying risk insights. This regulatory guide also provides 7 risk acceptance guidelines for evaluating the results of such evaluations.

8 9 RG 1.177, Revision 1, An Approach for Plant-Specific, Risk-Informed Decisionmaking:

10 Technical Specifications (ADAMS Accession No. ML100910008), describes an acceptable 11 risk-informed approach specifically for assessing proposed TS changes.

12 13 RG 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk 14 Assessment Results for Risk-Informed Activities (ADAMS Accession No. ML090410014),

15 describes an acceptable approach for determining the technical adequacy of PRAs.

16 17 The NRC staffs guidance for evaluating the technical basis for proposed risk-informed 18 changes is provided in SRP, Chapter 19, Section 19.2, Review of Risk Information Used to 19 Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance 20 (ADAMS Accession No. ML071700658). The NRC staffs guidance on evaluating PRA 21 technical adequacy is provided in SRP, Chapter 19, Section 19.1, Revision 3, Determining the 22 Technical Adequacy of Probabilistic Risk Assessment for Risk-Informed License Amendment 23 Requests After Initial Fuel Load (ADAMS Accession No. ML12193A107). More specific 24 guidance related to risk-informed TS changes is provided in SRP, Chapter 16, Section 16.1, 25 Revision 1, Risk-Informed Decision Making: Technical Specifications (ADAMS Accession 26 No. ML070380228), which includes changes to surveillance test intervals (STIs) (i.e.,

27 surveillance frequencies) as part of risk-informed decisionmaking. Section 19.2 of the SRP 28 references the same criteria as RG 1.177, Revision 1, and RG 1.174, Revision 2, and states 29 that a risk-informed application should be evaluated to ensure that the proposed changes meet 30 the following key principles:

31 32

• The proposed change meets the current regulations, unless it explicitly relates to a 33 requested exemption or rule change.

34 35

• The proposed change is consistent with the defense-in-depth philosophy.

36 37

• The proposed change maintains sufficient safety margins.

38 39

• When proposed changes result in an increase in risk associated with core damage 40 frequency or large early release frequency, the increase(s) should be small and 41 consistent with the intent of the Commissions Safety Goal Policy Statement.

42 43

• The impact of the proposed change should be monitored using performance 44 measurement strategies.

45 46

3.0 TECHNICAL EVALUATION

47 48 Revising the frequency of a Channel Calibration, Channel Functional Test, COT, and TADOT 49 instrument channel under the SFCP requires assurance that component performance 50 characteristics, such as drift between each test, will not result in undetected instrument errors

1 that exceed the assumptions of the safety analysis and supporting instrument loop uncertainty 2 calculations. These requirements are consistent with the methodology described in NEI 04-10, 3 which the SFCP requires to be followed. The SFCP does not permit changes to the TS 4 Allowable Values or Nominal Trip Setpoints; but allows only the surveillance frequency to be 5 changed when determined permissible by NEI 04-10. Therefore, prior to extending the test 6 intervals for an instrument channel component or components associated with a given 7 calibration step, the component performance characteristics must be evaluated to verify the 8 Allowable Value or Nominal Trip Setpoint will still be valid and to establish a firm technical basis 9 supporting the extension. In addition, each change must be reviewed by the licensee to ensure 10 the applicable uncertainty allowances are conservative (bounding) (e.g., sensor drift, rack drift, 11 indicator drift). Documentation to support the changes shall be retained per the guidance in 12 NEI 04-10.

13 14 In response to the NRC staff RAI, the TSTF identified that Section 4.0 of NEI 04-10, Steps 4, 7, 15 10a, 10b, 10c, 12, 14, 15, and 16, document the requirements pertaining to changing the SRs.

16 As an example, Step 4 requires documenting when STIs cannot be changed. These guidelines 17 include qualitative and quantitative measures to assess the acceptability of the change. Since 18 Traveler TSTF-425 and NEI 04-10 have been previously approved by the NRC, the explanation 19 provided is satisfactory and acceptable to NRC staff.

20 21 Five key safety principles that must be evaluated before changing any surveillance frequency 22 are identified in Section 3.0 of NEI 04-10. Principle 3 requires confirmation of the maintenance 23 of safety margins, which, in this case, includes performance of deterministic evaluations to 24 verify preservation of instrumentation trip setpoint and indication safety margins.

25 26 The evaluation methodology specified in NEI 04-10 also requires consideration of common 27 cause failure effects and monitoring of the instrument channel component performance 28 following the frequency change to ensure channel performance is consistent with the analysis to 29 support an extended frequency.

30 31 The method of evaluating a proposed surveillance frequency change is not dependent on the 32 number of components in the channel. Each step needs to be evaluated to determine the 33 acceptable surveillance frequency for that step. The proposed change to permit changing the 34 surveillance frequency of channel component(s) does not affect the test method or evaluation 35 method. The requirement to perform a Channel Calibration, Channel Functional Test, COT, or 36 TADOT on the entire channel is not changed.

37 38 For example, an evaluation in accordance with NEI 04-10 may determine that a field sensor 39 (e.g., a transmitter) should be calibrated every 48 months, the rack modules should be 40 calibrated every 30 months, and the indicators should be calibrated every 24 months. Under 41 the current TS requirements, all devices in the channel must be calibrated every 24 months.

42 However, under the proposed change, sensors, rack modules, and indicators would be 43 calibrated at the appropriate frequency for the tested devices. As required by the Channel 44 Calibration definition, the test would still encompass all devices in the channel required for 45 channel operability.

46 47 To address the issue of a potential extension of up to 48 months for field transmitters, the NRC 48 staff requested clarification regarding adequate data to support such long SR extensions. The 49 TSTF stated in the RAI response that NEI 04-10 methodology is used to evaluate surveillance 50 frequency changes to determine if such SR extensions could be applied. Process elements are 51 used to determine the cumulative risk impact of changes, updating the PRA, and imposition of

1 corrective actions, if needed, following implementation. Further, the applicant pointed to several 2 steps required by NEI 04-10, Step 7, to be evaluated prior to determining the acceptability of 3 changes. These steps include history of surveillance tests, industry and plant specific history, 4 impact on defense-in-depth, vendor recommendations, required test frequencies for the 5 applicable codes and standards, ensuring that the plant licensing basis would not be 6 invalidated, and other factors. The NRC staff finds these measures acceptable in determining 7 the SR extensions.

8 9 The NRC staff requested further information regarding the cumulative effect of various changes 10 on potential setpoint changes. The TSTF responded with the following:

11 12 The SFCP and NEI 04-10, Rev. 1, have no provisions to change 13 licensee-controlled setpoints, or TS values such as Allowable Values or Nominal 14 Trip Setpoints. If the surveillance frequency evaluation determines that the 15 proposed frequency would require a change to a TS limit, the change cannot be 16 made. If the proposed surveillance frequency change affects a 17 licensee-controlled setpoint (i.e., not a TS limit), the licensee would perform the 18 setpoint change following their procedures. TSTF-563 would not alter that 19 process.

20 21 TSTF-563 allows the NEI 04-10, Rev. 1, methodology to be applied to a subset 22 of instrument channel components instead of the entire channel when 23 considering a frequency change. It does not alter the technical approach 24 required by the SFCP that was approved by the NRC in NEI 04-10, Rev. 1, and 25 TSTF-425. TSTF-563 makes no changes to the method of evaluating a 26 surveillance frequency extension other than the scope of components considered 27 in an evaluation.

28 29 In addition, Step 16 of Section 4.0 of NEI 04-10 requires an Independent Decisionmaking Panel 30 (IDP) to review the cumulative impact of all STI changes over a period of time. This is also 31 required by RGs 1.174 and 1.177. The IDP is comprised of the site Maintenance Rule Expert 32 Panel, Surveillance Test Coordinator, and Subject Matter Expert who is a cognizant system 33 manager or component engineer. Based on the above information, the NRC staff finds that the 34 setpoint changes will be tracked in an acceptable manner.

35 36 The NRC staff reviewed the justification for the proposed revision to the instrumentation channel 37 definitions to ensure the request did not propose a change beyond the scope of NEI 04-10. In 38 response to the RAIs, the TSTF stated:

39 40 As stated in TSTF-563, Section 2.4, Description of the Proposed Change, only 41 plants that have adopted an SFCP (i.e., TSTF-425) may adopt the proposed 42 definition changes.

43 44 The NRC staff notes that limiting the proposed changes to licensees who have an approved 45 SFCP, allows for appropriate implementation of the program by incorporating NEI 04-10, 46 Revision 1, by reference into the Administrative Controls section of TSs.

47 48 Licensees with an SFCP may currently revise the surveillance frequency of instrumentation 49 channels. The testing of these channels may be performed by means of any series, sequential, 50 overlapping, or total channel steps. However, all required components in the instrumentation 51 channel must be tested in order for the entire channel to be considered Operable.

1 2 The NRC staff notes that industry practice is to perform instrument channel surveillances, such 3 as Channel Calibrations and Channel Functional Tests, using separate procedures based on 4 the location of the components. Each of these procedures may be considered a step. The 5 results of all these procedures are used to satisfy the SR using the existing allowance to 6 perform the SR by means of any series of sequential, overlapping, or total channel steps.

7 Traveler TSTF-563 allows for determining an acceptable surveillance frequency for each step.

8 As stated by the TSTF in the RAI response:

9 10 In response to Question b.I, the proposed approach can be reflected in the 11 current approaches for modelling actuation signals in the PRA. If the current 12 PRA model does not allow explicit consideration of subsets of the channel, a 13 bounding analysis may be performed, or the model may be revised to allow an 14 explicit evaluation.

15 16 In response to Question b.II, if the PRA currently cannot model subsets of an 17 instrument channel and cannot be modified to model the subsets of the channel, 18 a bounding evaluation may be used, the proposed frequency may be revised and 19 reevaluated, or the frequency change may be abandoned. These steps are 20 consistent with the guidance in NEI 04-10, Rev. 1, and risk informed decision 21 making which will ensure that only acceptable changes to the frequency will be 22 implemented.

23 24 The NRC staff notes that the NEI 04-10 methodology includes the determination of whether the 25 structure, system, and components (SSCs) affected by a proposed change to a surveillance 26 frequency are modeled in the PRA. Where the SSC is directly or implicitly modeled, a 27 quantitative evaluation of the risk impact may be carried out. The methodology adjusts the 28 failure probability of the impacted SSCs based on the proposed change to the surveillance 29 frequency. Where the SSC is not modeled in the PRA, bounding analyses are performed to 30 characterize the impact of the proposed change to the surveillance frequency. Potential 31 impacts on the risk analyses due to screening criteria and truncation levels are addressed by 32 the requirements for PRA technical adequacy, consistent with the guidance contained in 33 RG 1.200, and by sensitivity studies identified in NEI 04-10. Traveler TSTF-563 is not 34 proposing to change the methodology or the acceptance criteria for extending STIs, and 35 licensees will need to evaluated changes in the frequency for performing each of the steps in 36 the instrumentation surveillance test per the methodology in NEI 04-10.

37 38 Therefore, the NRC staff concludes that the proposed change to determine an acceptable 39 test frequency for individual steps within instrumentation channel surveillance tests is 40 acceptable, because any extended STIs from applying Traveler TSTF-563 will be developed 41 within the established constraints of the SFCP and NEI 04-10.

42 43 The regulatory requirements in 10 CFR 50.36 are not specific regarding the frequency of 44 performing surveillance tests. The proposed change only affects the frequency of performance 45 and does not affect the surveillance testing method or acceptance criteria. Therefore, the 46 proposed change is consistent with the surveillance testing requirements of 10 CFR 50.36.

47 48 PRA Acceptability 49 50 The guidance in RG 1.200 states that the quality of a licensees PRA should be commensurate 51 with the safety significance of the proposed TS change and the role the PRA plays in justifying

1 the change. That is, the greater the change in risk or the greater the uncertainty in that risk as a 2 result of the requested TS change, or both, the more rigor that should go into ensuring the 3 quality of the PRA.

4 5 Use of Traveler TSTF-563 by a licensee requires NRCs prior approval of the licensees request 6 to an SFCP that uses NEI 04-10. As part of its evaluation of that request, the NRC staff will 7 have performed an assessment of the PRA models used to support the approved SFCP that 8 uses NEI 04-10, using the guidance of RG 1.200 to assure that the PRA models are capable of 9 determining the change in risk due to changes to surveillance frequencies of SSCs, using 10 plant-specific data and models. Capability Category II of the NRC-endorsed PRA standard is 11 the target capability level for supporting requirements for the internal events PRA for this 12 application. Any identified deficiencies to those requirements are assessed further to determine 13 any impacts to proposed decreases to surveillance frequencies, including the use of sensitivity 14 studies where appropriate, in accordance with NEI 04-10.

15 16 Traveler TSTF-425 permits revising of the surveillance frequency for instrumentation channels.

17 The NRC staff asked the TSTF how NEI 04-10 can be applied to subsets in an instrument 18 channel when the SFCP currently specifies a surveillance interval that is applied to the entire 19 channel. The TSTF stated in its RAI response that the current channel surveillance may be 20 performed by means of any series of sequential, overlapping, or total channel steps. In 21 practice, this means that a channel is divided into subsets and each subset is tested 22 separately. Therefore, the current instrument channel testing is already composed of a 23 sequence of individual tests.

24 25 The NRC staff also requested the TSTF to clarify how the NEI 04-10 methodology can be 26 applied to the variety of current approaches for modeling actuation instrument channels in 27 PRAs. In the response to the RAI the TSTF stated that [a]n instrument function may be 28 modeled in the PRA differently depending on the site and the function (e.g., channel may be 29 modeled individually, subsets may be modeled, or the channel function may be modeled as a 30 single entity). The TSTF identified different steps through the evaluation methodology in 31 NEI 04-10 that could be used based on the different PRA modeling approaches. The 32 appropriate modeling of these different approaches is included in the NRC staffs review of the 33 PRA modeling during the review of the application to implement an SFCP.

34 35 Licensees who adopt Traveler TSTF-563 will use a PRA that was used to support the adoption 36 of Traveler TSTF-425 or an approved SFCP that uses NEI 04-10. Traveler TSTF-563 will give 37 licensees the capability to change the surveillance frequency of individual steps in the Channel 38 Calibration, Channel Functional Test, COT, and TADOT for instrumentation. The NRC staff 39 finds that changes to the surveillance frequency for individual steps can be appropriately 40 evaluated with the current SFCP and the current PRAs. The NRC staff finds that the 41 risk-informed methodology review and the PRA acceptability review that NRC staff performs 42 during approval of an SFCP that uses NEI 04-10 will be adequate to allow the adoption of 43 Traveler TSTF-563, and therefore, the NRC staff finds the proposed traveler acceptable for 44 use by plants that have an approved SFCP.

45 46

4.0 CONCLUSION

47 48 The NRC staff reviewed Traveler TSTF-563, which proposed changes to NUREG-1430, 49 NUREG-1431, NUREG-1432, NUREG-1433, and NUREG 1434, and NUREG-2194. The NRC 50 staff determined that the proposed changes to the STS meet the standards for TSs in 51 10 CFR 50.36(b). The regulations at 10 CFR 50.36 require that TSs include items in specified

1 categories, including SRs. The proposed changes modify the definitions applicable to 2 instrumentation channel components but do not alter the technical approach that was approved 3 by the NRC staff in NEI 04-10 and Traveler TSTF-425, and the TS, as revised, continue to 4 specify the appropriate SRs for tests and inspections to ensure the necessary quality of affected 5 SSCs is maintained.

6 7 Additionally, the changes to the STS were reviewed and found to be technically clear and 8 consistent with customary terminology and format in accordance with SRP Chapter 16.0. The 9 NRC staff reviewed the proposed changes against the regulations and concludes that the 10 changes continue to meet the requirements of Sections 50.36(b), 50.36(c)(3), and 50.36(c)(5) 11 of 10 CFR, for the reasons discussed above, and thus provide reasonable assurance that 12 adoption of these TSs will have the requisite requirements and controls to operate safely.

13 Therefore, the NRC staff concludes that the proposed TS changes are acceptable.

14 15 Principal Contributors: M. Chernoff, NRR/DSS 16 G. Singh, NRR/DE 17 J. Evans, NRR/DRA 18 19 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 563, Revision 0. 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 8 DRAFT MODEL SAFETY EVALUATION 9 BY THE OFFICE OF NUCLEAR REACTOR REGULATION 10 TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 11 TSTF-563, REVISION 0 12 REVISE INSTRUMENT TESTING DEFINITIONS TO INCORPORATE THE SURVEILLANCE 13 FREQUENCY CONTROL PROGRAM 14 USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 15 (CAC NO. MF9955, EPID L-2017-PMP-0006) 16 17 18

1.0 INTRODUCTION

19 20 By application dated [enter date] (Agencywide Documents Access and Management System 21 (ADAMS) Accession No. [MLXXXXXXXXX]), [as supplemented by letter(s) dated [enter 22 date(s))), [name of licensee] (the licensee) submitted a license amendment request (LAR) for 23 [name of facility (abbreviated name), applicable units].

24 25 The amendment would revise the current instrumentation testing definitions of Channel 26 Calibration(( and Channel Functional Test] OR [, Channel Operational Test (COT), and Trip 27 Actuation Device Operational Test (TADOT))) to permit determination of the appropriate 28 frequency to perform the Surveillance Requirement (SR) based on the devices being tested in 29 each step. The proposed changes are based on Technical Specifications Task Force (TSTF) 30 Traveler TSTF-563, Revision 0, Revise Instrument Testing Definitions to Incorporate the 31 Surveillance Frequency Control Program, dated May 10, 2017 (ADAMS Accession 32 No. ML17130A819). The U.S. Nuclear Regulatory Commission (NRC or the Commission) 33 issued a final safety evaluation (SE) approving TSTF-563, Revision 0, on [enter date] (ADAMS 34 Accession No. [MLXXXXXXXXX]).

35 36 {NOTE: TSTF-563 is only applicable to plants that have already adopted TSTF-425 or have an 37 approved SFCP that uses NEI 04-10.}

38 39 A Surveillance Frequency Control Program (n SFCP) was incorporated into the [PLANT] TS in 40 a license amendment dated [enter date] (ADAMS Accession No. [MLXXXXXXXXX]).

41 42 ((The licensee has proposed variations from the TS changes described in TSTF-563. The 43 variations are described in Section 2.2.1 of this SE and evaluated in Section 3.1.] OR [The 44 licensee is not proposing any variations from the TS changes described in TSTF-563 or 45 the applicable parts of the NRC staffs SE of TSTF-563.))

46 Enclosure 2

1 [The supplemental letters dated [enter date(s)], provided additional information that 2 clarified the application, did not expand the scope of the application as originally 3 noticed, and did not change the NRC staffs original proposed no significant hazards 4 consideration determination as published in the Federal Register on [enter date] (cite FR 5 reference).]

6 7

2.0 REGULATORY EVALUATION

8 9

2.1 DESCRIPTION

OF SURVEILLANCE FREQUENCY CONTROL PROGRAM AND 10 INSTRUMENT TESTING 11 12 The technical specifications (TSs) require the surveillances for instrumentation channels to be 13 performed within the specified frequency, using any series of sequential, overlapping, or total 14 channel steps. A previous amendment TSTF-425, Revision 3, Relocate Surveillance 15 Frequencies to Licensee Control - RITSTF [Risk-Informed TSTF] Initiative 5b, revised the TSs 16 to relocate all periodic surveillance frequencies to licensee control. Changes to the relocated 17 surveillance frequencies are made in accordance with the TS program referred to as the 18 Surveillance Frequency Control Program (SFCP). The SFCP allows a new surveillance 19 frequency to be determined for the channel, but that frequency must consider all components in 20 the channel and applies to the entire channel.

21 22 A typical instrument channel consists of many different components, such as sensors, rack 23 modules, and indicators. These components have different short-term and long-term 24 performance (drift) characteristics, resulting in the potential for different calibration frequency 25 requirements. Under the current TSs, the most limiting component calibration frequency for the 26 channel must be chosen when a revised frequency is considered under the SFCP. As a result, 27 all components that makeup a channel must be calibrated at a frequency equal to the channel 28 component with the shortest (i.e., most frequent) surveillance frequency.

29 30 Some channel components, such as pressure transmitters, are very stable with respect to drift 31 and could support a substantially longer calibration frequency than the other components in the 32 channel. Currently, the SRs in many plants are performed in steps (e.g., a pressure sensor or 33 transmitter is calibrated during a refueling outage and the rack signal conditioning modules are 34 calibrated while operating at power). The proposed change extends this concept to permit the 35 surveillance frequency of each step to be determined under the SFCP based on the 36 component(s) surveilled in the step instead of all components in the channel. This will allow 37 each component to be tested at the appropriate frequency based on the components long-term 38 performance characteristics.

39 40 Allowing an appropriate surveillance frequency for performing a channel calibration on each 41 component or group of components could reduce radiation dose associated with inplace 42 calibration of sensors, reduce wear on equipment, reduce unnecessary burden on plant staff, 43 and reduce opportunities for calibration errors.

44 45

2.2 PROPOSED CHANGE

S TO THE TECHNICAL SPECIFICATIONS 46 47 Currently, the Channel Calibration(( and Channel Functional Test] OR [, COT, and TADOT))

48 may be performed by any series of sequential, overlapping or total channel steps. The 49 proposed changes to the TSs would revise the definitions of Channel Calibration(( and Channel 50 Functional Test] OR [, COT, and TADOT)) to indicate that the step must be performed within

1 the most limiting frequency for the components included in that step by adding the words , and 2 each step must be performed within the Frequency in the Surveillance Frequency Control 3 Program for the devices included in the step at the end of the last sentence of each definition.

4 5 The following paragraph denotes the changes to the Channel Calibration definition. Changes 6 are shown in italics:

7 8 {NOTE: For B&W, CE, and GE plant designs use this paragraph.}

9 10 [A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the 11 channel output such that it responds within the necessary range and 12 accuracy to known values of the parameter that the channel monitors. The 13 CHANNEL CALIBRATION shall encompass all devices in the channel 14 required for channel OPERABILITY and the CHANNEL FUNCTIONAL TEST.

15 Calibration of instrument channels with resistance temperature detector 16 (RTD) or thermocouple sensors may consist of an inplace qualitative 17 assessment of sensor behavior and normal calibration of the remaining 18 adjustable devices in the channel. The CHANNEL CALIBRATION may be 19 performed by means of any series of sequential, overlapping, or total 20 channel steps, and each step must be performed within the Frequency in 21 the Surveillance Frequency Control Program for the devices included in the 22 step.]

23 24 {NOTE: For Westinghouse plant designs use this paragraph.}

25 26 [A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the 27 channel output such that it responds within the necessary range and 28 accuracy to known values of the parameter that the channel monitors. The 29 CHANNEL CALIBRATION shall encompass all devices in the channel 30 required for channel OPERABILITY. Calibration of instrument channels 31 with resistance temperature detector (RTD) or thermocouple sensors may 32 consist of an inplace qualitative assessment of sensor behavior and 33 normal calibration of the remaining adjustable devices in the channel. The 34 CHANNEL CALIBRATION may be performed by means of any series of 35 sequential, overlapping, or total channel steps, and each step must be 36 performed within the Frequency in the Surveillance Frequency Control 37 Program for the devices included in the step.]

38 39 {NOTE: For B&W, CE, and GE plant designs use this paragraph.}

40 41 [The following paragraph denotes the changes to the Channel Functional Test definition.

42 Changes are shown in italics:

43 44 ...The CHANNEL FUNCTIONAL TEST may be performed by means of any 45 series of sequential, overlapping, or total [channel] steps, and each step 46 must be performed within the Frequency in the Surveillance Frequency 47 Control Program for the devices included in the step.]

48 49 {NOTE: For Westinghouse plant designs use this paragraph.}

50

1 [The following paragraphs denote the changes to the COT and TADOT definitions.

2 Changes are shown in italics:

3 4 A COT shall be the injection of a simulated or actual signal into the channel 5 as close to the sensor as practicable to verify OPERABILITY of all devices 6 in the channel required for channel OPERABILITY. The COT shall include 7 adjustments, as necessary, of the required alarm, interlock, and trip 8 setpoints required for channel OPERABILITY such that the setpoints are 9 within the necessary range and accuracy. The COT may be performed by 10 means of any series of sequential, overlapping, or total channel steps, and 11 each step must be performed within the Frequency in the Surveillance 12 Frequency Control Program for the devices included in the step.

13 14 A TADOT shall consist of operating the trip actuating device and verifying 15 the OPERABILITY of all devices in the channel required for trip actuating 16 device OPERABILITY. The TADOT shall include adjustment, as necessary, 17 of the trip actuating device so that it actuates at the required setpoint 18 within the necessary accuracy. The TADOT may be performed by means of 19 any series of sequential, overlapping, or total channel steps, and each step 20 must be performed within the Frequency in the Surveillance Frequency 21 Control Program for the devices included in the step.]

22 23 The various instrumentation functions in the TSs require surveillances to verify the correct 24 functioning of the instrument channel. The proposed change extends the definition of 25 instrumentation channel components to permit the surveillance frequency of each step to be 26 determined under the SFCP based on the component(s) surveilled in the step instead of all 27 components in the channel. This will allow each component to be tested at the appropriate 28 frequency based on the components long-term performance characteristics.

29 30 The proposed changes in the definition for instrument testing would allow the licensee to control 31 the frequency of associated components being tested in each step. The SR for the overall 32 instrumentation channel remains unchanged. The proposed change has no effect on the 33 design, fabrication, use, or methods of testing the instrumentation channels and will not affect 34 the ability of the instrumentation to perform the functions assumed in the safety analysis.

35 36 These instrumentation testing definitions state that, [t]he [test type] may be performed by 37 means of any series of sequential, overlapping, or total channel steps. The surveillance 38 frequency of these subsets would be established based on the characteristics of the 39 components in the step rather than the most limiting component characteristics in the entire 40 channel. Each of these steps are evaluated in accordance with the SFCP.

41 42 2.2.1 Variations from TSTF-563 43 44 {NOTE: Technical reviewers and/or project manager are to assess the adequacy of any 45 variations from the approved traveler and document their acceptability. Choose the applicable 46 paragraphs based on information provided in the LAR.}

47 48 [The licensee is proposing the following variations from the TS changes described in 49 TSTF-563 or the applicable parts of the NRC staffs SE of TSTF-563. [Describe the

1 variations and why TSTF-563 is still applicable.] These variations do not affect the 2 applicability of TSTF-563 or the NRC staff's SE to the proposed LAR.]

3 4 [The [PLANT] TSs utilize different [numbering][and][titles] than the Standard Technical 5 Specifications on which TSTF-563 was based. Specifically, [describe differences 6 between the plant-specific TS numbering and/or titles and the TSTF-563 numbering 7 and/or titles.] These differences are editorial and do not affect the applicability of 8 TSTF-563 to the proposed LAR.]

9 10 [The [PLANT] TS contain requirements that differ from the design is different than the 11 model plant assumed in the Standard Technical Specifications, but the TSTF-563 12 justification and the NRC staff's SE are still applicable. [Describe differences and why 13 TSTF-563 is still applicable.))

14 15 2.3 APPLICABLE REGULATORY REQUIREMENTS AND GUIDANCE 16 17 Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires each 18 applicant for a license authorizing operation of a utilization facility to include in the application 19 proposed TSs.

20 21 The regulation at 10 CFR 50.36(b) requires:

22 23 Each license authorizing operation of a utilization facility will include 24 technical specifications. The technical specifications will be derived from the 25 analyses and evaluation included in the safety analysis report, and amendments 26 thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; 27 technical information]. The Commission may include such additional technical 28 specifications as the Commission finds appropriate.

29 30 The categories of items required to be in the TSs are provided in 10 CFR 50.36(c). One such 31 category is SRs, which are defined in 10 CFR 50.36(c)(3) as requirements relating to test, 32 calibration, or inspection to assure that the necessary quality of systems and components is 33 maintained, that facility operation will be within safety limits, and that the limiting conditions for 34 operation will be met.

35 36 The regulation at 10 CFR 50.36(c)(5) requires TSs to include administrative controls, which are 37 the provisions relating to organization and management, procedures, recordkeeping, review and 38 audit, and reporting necessary to assure operation of the facility in a safe manner.

39 40 A previous amendment Traveler TSTF-425 revised and relocated most periodic surveillance 41 frequencies to licensee control. Changes to the relocated surveillance frequencies are made in 42 accordance with the SFCP. The SFCP requires that changes to the relocated frequencies be 43 made in accordance with NRC staff approved topical report NEI 04-10.

44 45 Topical report NEI 04-10 describes an evaluation process and a multi-disciplinary plant 46 decisionmaking panel that considers the detailed evaluation of proposed surveillance frequency 47 revisions. The evaluations are based on operating experience, test history, manufacturers 48 recommendations, codes and standards, and other deterministic factors, in conjunction with risk 49 insights. The evaluation considers all components being tested by the SR. Process elements 50 are included for determining the cumulative risk impact of the changes, updating the licensees

1 probabilistic risk assessment (PRA) models, and for imposing corrective actions, if necessary, 2 following implementation of a revised frequency.

3 4 The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of 5 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for 6 Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ADAMS 7 Accession No. ML100351425). As described therein, as part of the regulatory standardization 8 effort, the NRC staff has prepared STS for each of the LWR nuclear designs. Accordingly, the 9 NRC staffs review includes consideration of whether the proposed changes are consistent with 10 the applicable reference STS (i.e., the current STS), as modified by NRC-approved Travelers.

11 In addition, the guidance states that comparing the change to previous STS can help clarify the 12 TS intent.

13 14 Regulatory Guide (RG) 1.174, Revision 2, An Approach for Using Probabilistic Risk 15 Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis 16 (ADAMS Accession No. ML100910006), describes an acceptable risk-informed approach for 17 assessing the nature and impact of proposed permanent licensing basis changes by 18 considering engineering issues and applying risk insights. This regulatory guide also provides 19 risk acceptance guidelines for evaluating the results of such evaluations.

20 21 RG 1.177, Revision 1, An Approach for Plant-Specific, Risk-Informed Decisionmaking:

22 Technical Specifications (ADAMS Accession No. ML100910008), describes an acceptable 23 risk-informed approach specifically for assessing proposed TS changes.

24 25 RG 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk 26 Assessment Results for Risk-Informed Activities (ADAMS Accession No. ML090410014),

27 describes an acceptable approach for determining the technical adequacy of PRAs.

28 29 The NRC staffs guidance for evaluating the technical basis for proposed risk-informed 30 changes is provided in SRP, Chapter 19, Section 19.2, Review of Risk Information Used to 31 Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance 32 (ADAMS Accession No. ML071700658). The NRC staffs guidance on evaluating PRA 33 technical adequacy is provided in SRP, Chapter 19, Section 19.1, Revision 3, Determining the 34 Technical Adequacy of Probabilistic Risk Assessment for Risk-Informed License Amendment 35 Requests After Initial Fuel Load (ADAMS Accession No. ML12193A107). More specific 36 guidance related to risk-informed TS changes is provided in SRP, Chapter 16, Section 16.1, 37 Revision 1, Risk-Informed Decision Making: Technical Specifications (ADAMS Accession 38 No. ML070380228), which includes changes to surveillance test intervals (STIs) (i.e.,

39 surveillance frequencies) as part of risk-informed decisionmaking. Section 19.2 of the SRP 40 references the same criteria as RG 1.177, Revision 1, and RG 1.174, Revision 2, and states 41 that a risk-informed application should be evaluated to ensure that the proposed changes meet 42 the following key principles:

43 44

• The proposed change meets the current regulations, unless it explicitly relates to a 45 requested exemption or rule change.

46 47

• The proposed change is consistent with the defense-in-depth philosophy.

48 49

• The proposed change maintains sufficient safety margins.

50

1

• When proposed changes result in an increase in risk associated with core damage 2 frequency or large early release frequency, the increase(s) should be small and 3 consistent with the intent of the Commissions Safety Goal Policy Statement.

4 5

• The impact of the proposed change should be monitored using performance 6 measurement strategies.

7 8 {NOTE: Choose applicable STS}

9 [U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Babcock and 10 Wilcox Plants, NUREG-1430, Volume 1, Specifications, and Volume 2, Bases, 11 Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12100A177 and ML12100A178, 12 respectively).

13 14 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse 15 Plants, NUREG-1431, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, 16 dated April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively).

17 18 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Combustion 19 Engineering Plants, NUREG-1432, Volume 1, Specifications, and Volume 2, Bases, 20 Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12102A165 and ML12102A169, 21 respectively).

22 23 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General 24 Electric BWR/4 Plants NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, 25 Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193, 26 respectively).

27 28 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General 29 Electric BWR/6 Plants NUREG-1434, Volume 1, Specifications, and Volume 2, Bases, 30 Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12104A195 and ML12104A196, 31 respectively).]

32 33 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse 34 Advanced Passive (AP1000) Plants, NUREG 2194, Volume 1, Specifications, and 35 Volume 2, Bases, Revision 4.0, April 2016 (ADAMS Accession Nos. ML16110A277 and 36 ML16110A369, respectively).]

37 38

3.0 TECHNICAL EVALUATION

39 40 Revising the frequency of a Channel Calibration(( and Channel Functional Test] OR [, COT, 41 and TADOT)) instrument channel under the SFCP requires assurance that component 42 performance characteristics, such as drift between each test, will not result in undetected 43 instrument errors that exceed the assumptions of the safety analysis and supporting instrument 44 loop uncertainty calculations. These requirements are consistent with the methodology 45 described in NEI 04-10, which the SFCP requires to be followed. The SFCP does not permit 46 changes to the TS Allowable Values or Nominal Trip Setpoints; but allows only the surveillance 47 frequency to be changed when determined permissible by NEI 04-10. Therefore, prior to 48 extending the test intervals for an instrument channel component or components associated 49 with a given calibration step, the component performance characteristics must be evaluated to 50 verify the Allowable Value or Nominal Trip Setpoint will still be valid and to establish a firm

1 technical basis supporting the extension. In addition, each change must be reviewed by the 2 licensee to ensure the applicable uncertainty allowances are conservative (bounding) (e.g.,

3 sensor drift, rack drift, indicator drift). Documentation to support the changes shall be retained 4 per the guidance in NEI 04-10.

5 6 Five key safety principles that must be evaluated before changing any surveillance frequency 7 are identified in Section 3.0 of NEI 04-10. Principle 3 requires confirmation of the maintenance 8 of safety margins, which, in this case, includes performance of deterministic evaluations to 9 verify preservation of instrumentation trip setpoint and indication safety margins.

10 11 The evaluation methodology specified in NEI 04-10 also requires consideration of common 12 cause failure effects and monitoring of the instrument channel component performance 13 following the frequency change to ensure channel performance is consistent with the analysis to 14 support an extended frequency.

15 16 The method of evaluating a proposed surveillance frequency change is not dependent on the 17 number of components in the channel. Each step needs to be evaluated to determine the 18 acceptable surveillance frequency for that step. The proposed change to permit changing the 19 surveillance frequency of channel component(s) does not affect the test method or evaluation 20 method. The requirement to perform a Channel Calibration, Channel Functional Test, COT, or 21 TADOT on the entire channel is not changed.

22 23 For example, an evaluation in accordance with NEI 04-10 may determine that a field sensor 24 (e.g., a transmitter) should be calibrated every 48 months, the rack modules should be 25 calibrated every 30 months, and the indicators should be calibrated every 24 months. Under 26 the current TS requirements, all devices in the channel must be calibrated every 24 months.

27 However, under the proposed change, sensors, rack modules, and indicators would be 28 calibrated at the appropriate frequency for the tested devices. As required by the Channel 29 Calibration definition, the test would still encompass all devices in the channel required for 30 channel operability.

31 32 The NEI 04-10 methodology is used to evaluate surveillance frequency changes to determine if 33 such SR extensions could be applied. Process elements are used to determine the cumulative 34 risk impact of changes, updating the PRA, and imposition of corrective actions, if needed, 35 following implementation. Several steps are required by NEI 04-10, Step 7, to be evaluated 36 prior to determining the acceptability of changes. These steps include history of surveillance 37 tests, industry and plant specific history, impact on defense-in-depth, vendor recommendations, 38 required test frequencies for the applicable codes and standards, ensuring that plant licensing 39 basis would not be invalidated and other factors. The NRC staff finds these measures 40 acceptable in determining the SR extensions.

41 42 In addition, Step 16 of Section 4.0 of NEI 04-10 requires an Independent Decisionmaking Panel 43 (IDP) to review the cumulative impact of all STI changes over a period of time. This is also 44 required by RGs 1.174 and 1.177. The IDP is comprised of the site Maintenance Rule Expert 45 Panel, Surveillance Test Coordinator, and Subject Matter Expert who is a cognizant system 46 manager or component engineer. Based on the above information, the NRC staff finds that the 47 setpoint changes will be tracked in an acceptable manner.

48 49 Licensees with an SFCP may currently revise the surveillance frequency of instrumentation 50 channels. The testing of these channels may be performed by means of any series, sequential,

1 overlapping, or total channel steps. However, all required components in the instrumentation 2 channel must be tested in order for the entire channel to be considered Operable.

3 4 The NRC staff notes that industry practice is to perform instrument channel surveillances, such 5 as Channel Calibrations and Channel Functional Tests, using separate procedures based on 6 the location of the components. Each of these procedures may be considered a step. The 7 results of all these procedures are used to satisfy the SR using the existing allowance to 8 perform it by means of any series of sequential, overlapping, or total channel steps. The 9 proposed changes would allow for determining an acceptable surveillance frequency for each 10 step.

11 12 The NRC staff notes that the NEI 04-10 methodology includes the determination of whether the 13 structure, system, and components (SSCs) affected by a proposed change to a surveillance 14 frequency are modeled in the PRA. Where the SSC is directly or implicitly modeled, a 15 quantitative evaluation of the risk impact may be carried out. The methodology adjusts the 16 failure probability of the impacted SSCs based on the proposed change to the surveillance 17 frequency. Where the SSC is not modeled in the PRA, bounding analyses are performed to 18 characterize the impact of the proposed change to the surveillance frequency. Potential 19 impacts on the risk analyses due to screening criteria and truncation levels are addressed by 20 the requirements for PRA technical adequacy, consistent with the guidance contained in 21 RG 1.200, and by sensitivity studies identified in NEI 04-10. The licensee is not proposing to 22 change the methodology, or the acceptance criteria for extending STIs, and licensees will need 23 to changes in the frequency for performing each of the steps in the instrumentation surveillance 24 test per the methodology in NEI 04-10.

25 26 Therefore, the NRC staff concludes that the proposed change determine an acceptable test 27 frequency for individual steps within instrumentation channel surveillance tests is acceptable 28 because any extended STIs will be developed within the established constraints of the 29 SFCP and NEI 04-10.

30 31 The regulatory requirements in 10 CFR 50.36 are not specific regarding the frequency of 32 performing surveillance tests. The proposed change only affects the frequency of performance 33 and does not affect the surveillance testing method or acceptance criteria. Therefore, the 34 proposed change is consistent with the surveillance testing requirements of 10 CFR 50.36.

35 36 PRA Acceptability 37 38 The guidance in RG 1.200 states that the quality of a licensees PRA should be commensurate 39 with the safety significance of the proposed TS change and the role the PRA plays in justifying 40 the change. That is, the greater the change in risk or the greater the uncertainty in that risk as a 41 result of the requested TS change, or both, the more rigor that should go into ensuring the 42 quality of the PRA.

43 44 The NRC staff will have performed an assessment of the PRA models used to support the 45 approved SFCP that uses NEI 04-10, using the guidance of RG 1.200 to assure that the PRA 46 models are capable of determining the change in risk due to changes to surveillance 47 frequencies of SSCs, using plant-specific data and models. Capability Category II of the NRC-48 endorsed PRA standard is the target capability level for supporting requirements for the internal 49 events PRA for this application. Any identified deficiencies to those requirements are assessed

1 further to determine any impacts to proposed decreases to surveillance frequencies, including 2 the use of sensitivity studies where appropriate, in accordance with NEI 04-10.

3 4 The SFCP permits revising of the surveillance frequency for instrumentation channels. The 5 NRC staff evaluated whether NEI 04-10 can be applied to subsets in an instrument channel 6 when the SFCP currently specifies a surveillance interval that is applied to the entire channel.

7 The NRC staff notes that the current channel surveillance may be performed by means of any 8 series of sequential, overlapping, or total channel steps. In practice, this means that a channel 9 is divided into subsets and each subset is tested separately. Therefore, the current instrument 10 channel testing is already composed of a sequence of individual tests.

11 12 The instrument function may be modeled in the PRA differently depending on the site and the 13 function (e.g., channel may be modeled individually, subsets may be modeled, or the channel 14 function may be modeled as a single entity). There are different steps through the evaluation 15 methodology in NEI 04-10 that could be used based on the different PRA modeling approaches.

16 The appropriate modeling of these different approaches is included in the NRC staffs review of 17 the PRA modeling during the review of the application to implement an SFCP that uses 18 NEI 04-10.

19 20 The licensee is using a PRA that was used to support their application that implemented an 21 SFCP that uses NEI 04-10. The amendment will change the capability of the licensee to 22 change the surveillance frequency of an entire channel to now change the frequency of each 23 subset of the channel. The NRC staff finds that changes to the surveillance frequency caused 24 by defining and using individual, testable component subsets can be appropriately evaluated 25 with the current SFCP and the current PRAs. The NRC staff finds that the risk-informed 26 methodology review and the PRA acceptability review that was performed during the review of 27 the licensees application to implement an SFCP that uses NEI 04-10 is adequate.

28 29 The NRC staff determined that the proposed changes to the TS meet the standards for TS in 30 10 CFR 50.36(b). The regulations at 10 CFR 50.36 require that TSs include items in specified 31 categories, including SRs. The proposed changes modify the definitions applicable to 32 instrumentation channel components but do not alter the technical approach that was approved 33 by the NRC in NEI 04-10, and the TSs, as revised, continue to specify the appropriate SRs for 34 tests and inspections to ensure the necessary quality of affected SSCs is maintained.

35 36 Additionally, the changes to the TS were reviewed and found to be technically clear and 37 consistent with customary terminology and format in accordance with SRP Chapter 16.0. The 38 NRC staff reviewed the proposed changes against the regulations and concludes that the 39 changes continue to meet the requirements of Sections 50.36(b), 50.36(c)(3), and 50.36(c)(5),

40 of 10 CFR, for the reasons discussed above, and thus provide reasonable assurance that 41 adoption of these TSs will have the requisite requirements and controls to operate safely.

42 Therefore, the NRC staff concludes that the proposed TS changes are acceptable.

43 44 [3.1 VARIATIONS FROM TSTF-563 45 46 The licensee described variations from TSTF-563 in Section 2.2 of the LAR. The licensee 47 provided justification for the proposed variations and exceptions. The staff reviewed the 48 justifications and concluded the variations are [not] acceptable because.

49

1 The [PLANT] TSs utilize different [numbering][and][titles] than the Standard Technical 2 Specifications on which TSTF-563 was based. The NRC staff agrees these differences 3 are editorial and do not affect the applicability of TSTF-563 to the proposed LAR.]

4 5

4.0 STATE CONSULTATION

6 7 {This section is to be prepared by the plant project manager.}

8 9 In accordance with the Commissions regulations, the [Name of State] State official was notified 10 of the proposed issuance of the amendment(s) on [date]. The State official had [no]

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

12 13

5.0 ENVIRONMENTAL CONSIDERATION

14 15 {This section is to be prepared by the plant project manager in accordance with current 16 procedures.}

17 18

6.0 CONCLUSION

19 20 {This section is to be prepared by the plant project manager.}

21 22 The Commission has concluded, based on the considerations discussed above, that: (1) there 23 is reasonable assurance that the health and safety of the public will not be endangered by 24 operation in the proposed manner, (2) there is reasonable assurance that such activities will be 25 conducted in compliance with the Commissions regulations, and (3) the issuance of the 26 amendment(s) will not be inimical to the common defense and security or to the health and 27 safety of the public.

28 29

7.0 REFERENCES

30 31 {Optional section to be prepared by the PM and primary reviewers. If document is publicly 32 available, the ADAMS Accession No. should be listed.}

33 34 {NOTE: These are the principal contributors for the model SE of the traveler. Replace these 35 names with those who prepared the plant-specific SE.}

36 37 Principal Contributors: M. Chernoff, NRR/DSS 38 G. Singh, NRR/DE 39 J. Evans, NRR/DRA 40 41 Date: