ML21188A225

Final Model SE of CLIIP TSTF-580, Revision 1, Provide Exception from Entering Mode 4 with No Operable RHR (Residual Heat Removal) Shutdown Cooling

ML21188A225
Person / Time
Site:	Technical Specifications Task Force
Issue date:	07/11/2021
From:	Michelle Honcharik NRC/NRR/DSS/STSB
To:	Technical Specifications Task Force
Honcharik M C-NRR/DSS
Shared Package
ML21188A283	List: ML21188A225 ML21188A227 ML21188A278
References
TSTF-580, Rev 1
Download: ML21188A225 (7)

Text

General Directions: This model SE provides the format for an SE of LARs to adopt traveler TSTF-580. TSTF-580 was approved as part of the CLIIP. This model SE can also be used as a template for LARs adopting TSTF-580 that have significant variations and are not using the CLIIP. The [bolded bracketed] information shows text that should be filled in for the specific amendment. The italicized wording provides guidance on what should be included in each section.

FINAL MODEL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO TSTF-580 AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX-XX]

AND AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX-XX]

[NAME OF LICENSEE]

[NAME OF FACILITY]

DOCKET NOS. 50-[XXX] AND 50-[XXX]

Application (i.e., initial and supplements) Safety Evaluation Date

• [Date], [ADAMS Accession No.] [Date]

Principal Contributors to Safety Evaluation

• [Caroline Tilton]

1.0 PROPOSED CHANGE

S

[Name of licensee] (the licensee) requested changes to the technical specifications (TSs) for

[name of facility] by license amendment request (LAR, application). In its application, the licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP). The proposed changes would revise the RHR [Residual Heat Removal] Shutdown Cooling System - Hot Shutdown, TS based on Technical Specifications Task Force (TSTF)

Traveler TSTF-580, Revision 1, Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling (TSTF-580) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21025A232), and the associated NRC staff safety evaluation (SE) of TSTF-580 (ADAMS Accession No. ML21188A227).

Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant. This decay heat must be removed to reduce the temperature of the reactor coolant to less than or equal to [200] degrees Fahrenheit (°F). This decay heat is removed by the RHR shutdown cooling system in preparation for performing refueling or maintenance operations, or for keeping the reactor in the hot shutdown condition or cold shutdown condition.

Enclosure [x]

{NOTE: Ensure the following paragraph is accurate for the plant. If not, modify accordingly.}

The [name of facility] design consists of two redundant, manually controlled shutdown cooling subsystems of the RHR system to provide decay heat removal. Each loop consists of motor-driven pumps, a heat exchanger, and associated piping and valves. The RHR heat exchangers transfer heat to the RHR service water system. Some piping and heat exchangers that are passive components may be common to both subsystems.

TS [3.4.8/3.4.9] Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, is applicable in Mode 3 when the reactor steam dome pressure is lower than the RHR cut-in permissive pressure. The limiting condition for operation (LCO) requires two operable RHR shutdown cooling subsystems and, if no recirculation pump is in operation, then at least one RHR shutdown cooling subsystem needs to be in operation.

1.1 Proposed TS Changes to Adopt TSTF-580 In accordance with NRC staff-approved TSTF-580, the licensee proposed changes that would revise the TS [3.4.8/3.4.9] Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, for [name of facility]. Specifically, the licensee proposed the following changes to adopt TSTF-580:

• Condition A is changed to be limited to a single inoperable subsystem by revising it to state: One [required] RHR shutdown cooling subsystem inoperable with a Required Action to Verify an alternate method of decay heat removal is available.

• Condition B addresses situations when Required Action A.1 and associated completion time (CT) are not met. The plural (s) is deleted in Required Action B.1 as a conforming change to Condition A which now addresses a single inoperable RHR shutdown cooling subsystem.

• A new Condition C is added which addresses two RHR shutdown cooling subsystems inoperable with a Required Action C.1 to verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem. The new Condition C Required Action has a CT of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter.

• A new Condition D is added to address situations when new Required Action C.1 and associated CT are not met. New Required Action D.1 requires action be initiated to restore one RHR shutdown cooling subsystem to operable status immediately.

Required Action D.1 is modified by a note that states that LCO 3.0.3 and all other LCO Required Actions requiring a mode change to Mode 4 may be suspended until one RHR shutdown cooling subsystem is restored to operable status.

• Existing Condition C and associated Required Actions are renumbered as a result of new Conditions C and D.

1.2 Additional Proposed TS Changes

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

Editorial variations discussed below in Section 1.2.1 do not warrant removal from the CLIIP and

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

In addition to the changes proposed consistent with the traveler discussed in Section 1.1, the licensee proposed the following variations.

1.2.1 Editorial Variations

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

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

than standard technical specifications (STSs).

1.2.2 Other Variations

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

2.0 REGULATORY EVALUATION

The regulation at paragraph 50.36(c)(2) of Title 10 of the Code of Federal Regulations (10 CFR) requires that TSs include LCOs. Per 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation also requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the [insert applicable NUREG from list in footnote]1, as modified by NRC-approved travelers.

Traveler TSTF-580 revised the STSs related to RHR shutdown cooling system. The NRC approved TSTF-580, under the CLIIP on July XX, 2021 (ADAMS Package Accession No. ML21188A283).

1 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric Plants, BWR/4, 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 Plants, BWR/6, NUREG-1434, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A195 and ML12104A196, respectively).

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Changes to Adopt TSTF-580 The NRC staff compared the licensees proposed TS changes in Section 1.1 of this SE against the changes approved in TSTF-580. In accordance with the SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-580 are applicable because [name of facility] is a boiling-water reactor (BWR) design plant and the NRC staff approved the TSTF-580 changes for BWR designs. The NRC finds that the licensees proposed changes to the [name of facility] TSs in Section 1.1 of this SE are consistent with those found acceptable in TSTF-580.

In the SE of TSTF-580, the NRC staff concluded that TSTF-580 changes to STS [3.4.8/3.4.9]

Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown, are acceptable because, without an operable RHR shutdown cooling subsystem and in a period of high decay heat load, it may not be possible to reduce the reactor coolant system temperature to the Mode 4 entry condition within the CT. Under this condition, remaining in Mode 3 allows fission product decay heat and other residual heat from the reactor core to be transferred at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary will not be exceeded. The CT reflects the importance of restoring a normal path for heat removal. Therefore, the NRC staff finds that proposed new Condition D, including its associated Required Action A.1 and CT, is acceptable because it continues to meet the requirements of 10 CFR 50.36(c)(2)(i), by providing remedial actions and shutting down the reactor if the remedial actions cannot be met.

The NRC staff finds that the proposed changes to the Actions of LCO [3.4.8/3.4.9] are adequate remedial actions to be taken until each LCO can be met and provide protection to the health and safety of the public. Thus, the proposed changes continue to meet the requirements of 10 CFR 50.36(c)(2)(i) as discussed in Section 3.0 of the NRC staffs SE of TSTF-580.

3.2 Additional Proposed TS Changes

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

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

3.2.1 Editorial

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

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

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

3.2.2 Other Variations

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

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

4.0 CONCLUSION

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

NOTICES AND ENVIRONMENTAL FINDINGS RELATED TO AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX-XX]

AND AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX-XX]

[NAME OF LICENSEE]

[NAME OF FACILITY]

DOCKET NOS. 50-[XXX] AND 50-[XXX]

Application (i.e., initial and supplements) Safety Evaluation Date

• [Date], [ADAMS Accession No.] [Date]

1.0 INTRODUCTION

The PM should prepare this required section.

[Name of licensee] (the licensee) requested changes to the technical specifications (TSs) for

[name of facility] by license amendment request (LAR, application). In its application, the licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP). The proposed changes would revise the RHR [Residual Heat Removal] Shutdown Cooling System - Hot Shutdown, TS based on Technical Specifications Task Force (TSTF)

Traveler TSTF-580, Revision 1, Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling (TSTF-580) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21025A232), and the associated NRC staff safety evaluation of TSTF-580 (ADAMS Accession No. ML21188A227).

2.0 STATE CONSULTATION

The PM should prepare this required section.

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

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

3.0 ENVIRONMENTAL CONSIDERATION

The PM should prepare this required section.

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding [enter Enclosure [x]

Federal Register citation (XX FR XXXX) and date]. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.