ML101340271

Model Application and Model Safety Evaluation for Notice of Availability for TSTF-513, Revision 3

ML101340271
Person / Time
Site:	Technical Specifications Task Force
Issue date:	12/20/2010
From:	Office of Nuclear Reactor Regulation
To:
References
TSTF-513, Rev 3
Download: ML101340271 (12)

Text

MODEL APPLICATION FOR PLANT-SPECIFIC ADOPTION OF TSTF-513, REVISION 3, REVISE PWR OPERABLIITY REQUIREMENTS AND ACTIONS FOR RCS LEAKAGE INSTRUMENTATION U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555

SUBJECT:

[PLANT]

DOCKET NO. 50-[XXX]

LICENSE AMENDMENT REQUEST FOR ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE (TSTF)-513, REVISION 3, AREVISE PWR OPERABILITY REQUIREMENTS AND ACTIONS FOR RCS LEAKAGE INSTRUMENTATION@

In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT].

The proposed amendment would revise the TS to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable; and make TS Bases changes which reflect the proposed changes and more accurately reflect the contents of the facility design basis related to operability of the RCS leakage detection instrumentation. These changes are consistent with NRC-approved Revision 3 to TSTF Improved Standard Technical Specification (STS) Change Traveler TSTF-513, ARevise PWR Operability Requirements and Actions for RCS Leakage Instrumentation.@ The availability of this TS improvement was announced in the Federal Register on [DATE] ([ ] FR [ ]) as part of the consolidated line item improvement process (CLIIP).

• provides an evaluation of the proposed changes.

• provides the markup pages of existing TS to show the proposed changes.

• provides a markup pages of the existing TS Bases to show the proposed changes.

• provides revised (clean) TS pages.

[LICENSEE] requests approval of the proposed license amendment by [DATE], with the amendment being implemented [BY DATE OR WITHIN X DAYS].

In accordance with 10 CFR 50.91(a)(1), Notice for Public Comment, the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission in accordance with the distribution requirements in 10 CFR 50.4.

In accordance with 10 CFR 50.91(b)(1), State Consultation, a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated [STATE] Official.

I declare [or certify, verify, state] under penalty of perjury that the foregoing is correct and true.

Executed on [date] [Signature]

If you should have any questions about this submittal, please contact [NAME, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Attachments: [As stated or provide list]

cc:

[NRR Project Manager]

[Regional Office]

[Resident Inspector]

[State Contact]

ATTACHMENT 1 EVALUATION OF PROPOSED CHANGES License Amendment Request for Adoption of TSTF-513, Revision 3, Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation

1.0 DESCRIPTION

The proposed amendment would revise the Technical Specifications (TS) to define a new time limit for restoring inoperable Reactor Coolant System (RCS) leakage detection instrumentation to operable status; establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable; and make conforming TS Bases changes. These changes are consistent with NRC-approved Revision 3 to Technical Specification Task Force (TSTF)

Standard Technical Specification (STS) Change Traveler TSTF-513, ARevise PWR Operability Requirements and Actions for RCS Leakage Instrumentation.@ The availability of this TS improvement was announced in the Federal Register on [DATE] ([ ] FR [ ]) as part of the consolidated line item improvement process (CLIIP).

2.0 PROPOSED CHANGE

S The proposed changes revise and add a new Condition [D] to TS [3.4.15], [RCS Leakage Detection Instrumentation], and revise the associated bases. New Condition [D] is applicable when the containment atmosphere gaseous radioactivity monitor is the only operable TS-required monitor (i.e., all other monitors are inoperable). New Condition [D] Required Actions require analyzing grab samples of the containment atmosphere every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and restoring another monitor within 7 days. Additionally, the TS Bases, which summarize the reasons for the specifications, are revised to clarify the specified safety function for each required instrument in the limiting condition for operation (LCO) Bases, delete discussion from the Bases that could be construed to alter the meaning of TS operability requirements, and reflect the changes made to TS [3.4.15].

[The proposed changes also correct inappropriate references to required equipment in TS [3.4.15]. In several locations the specifications incorrectly refer to a required [equipment name]. The term required is reserved for situations in which there are multiple ways to meet the LCO, such as the requirement for either a gaseous or particulate radiation monitor. The incorrect use of the term required is removed from TS [3.4.15] Conditions [A, B, and C)).

[LICENSEE] is [not] proposing variations or deviations from the TS changes described in TSTF-513, Revision 3, or the NRC staffs model safety evaluation (SE) published in the Federal Register on [DATE] ([ ] FR [ ]) as part of the CLIIP Notice of Availability. [Discuss any differences with TSTF-513, Revision 3, and the effect of any changes on the NRC staff model SE].

3.0 BACKGROUND

NRC Information Notice (IN) 2005-24, Nonconservatism in Leakage Detection Sensitivity, dated August 3, 2005, informed addressees that the reactor coolant activity assumptions for primary containment atmosphere gaseous radioactivity monitors may be non-conservative. This means the monitors may not be able to detect a one gallon per minute leak within one hour.

Some licensees have taken action in response to IN 2005-24 to remove the gaseous radioactivity monitor from the TS list of required monitors. However, industry experience has shown that the primary containment atmosphere gaseous radiation monitor is often the first monitor to indicate an increase in RCS leak rate. As a result, the TSTF and the NRC staff met on April 29, 2008, and April 14, 2009, to develop an alternative approach to address the issue identified in IN 2005-24. The agreed solution is to retain the primary containment atmosphere gaseous radiation monitor in the LCO list of required equipment, revise the specified safety function of the gas monitor to specify the required instrument sensitivity level, revise the Actions to require additional monitoring, and provide less time before a plant shutdown is required when the primary containment atmosphere gaseous radiation monitor is the only operable monitor.

4.0 TECHNICAL ANALYSIS

[LICENSEE] has reviewed TSTF-513, Revision 3, and the model SE published on [DATE]

([ ] FR [ ]) as part of the CLIIP Notice of Availability. [LICENSEE] has concluded that the technical bases presented in TSTF Traveler-513, Revision 3, and the model SE prepared by the NRC staff are applicable to [PLANT].

The proposed amendment revises the language in the TS Bases that describes when the gaseous and particulate containment atmosphere radioactivity monitor is operable. The proposed amendment requires additional batch or manual RCS leakage monitoring to be performed when the primary containment atmosphere gaseous radiation monitor is the only operable continuous or automatic monitor. These alternative batch methods provide an RCS leakage detection capability similar to the TS-required methods. The grab sample has an RCS leakage detection capability that is comparable to that of the containment particulate radiation monitor. The proposed Actions and Completion Times for grab samples are adequate because use of frequent grab samples provides additional assurance (in addition to the mass balances required by Conditions [A] and [C]) that any significant RCS leakage will be detected prior to significant RCPB degradation. {NOTE: Discuss how the plant licensing basis meets General Design Criterion 30.}

5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

[LICENSEE] has evaluated the proposed changes to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below:

Description of Amendment Request: The proposed amendment would revise TS [3.4.15],

[Reactor Coolant System (RCS) Leakage Detection Instrumentation] Conditions and Required Actions and the licensing basis for the gaseous radiation monitor, as well as make associated TS Bases changes for TS [3.4.15].

Basis for proposed no significant hazards consideration determination: As required by 10 CFR 50.91(a), the [LICENSEE] analysis of the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

1:

Does the Proposed Change Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. The monitoring of RCS leakage is not a precursor to any accident previously evaluated. The monitoring of RCS leakage is not used to mitigate the consequences of any accident previously evaluated. Therefore, it is concluded that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2:

Does the Proposed Change Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change maintains sufficient continuity and diversity of leak detection capability that the probability of piping evaluated and approved for Leak-Before-Break progressing to pipe rupture remains extremely low. Therefore, it is concluded that the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3:

Does the Proposed Change Involve a Significant Reduction in a Margin of Safety?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. Reducing the amount of time the plant is allowed to operate with only the containment atmosphere gaseous radiation monitor operable increases the margin of safety by increasing the likelihood that an increase in RCS leakage will be detected before it potentially results in gross failure.

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

Based upon the above analysis, [LICENSEE] concludes that the requested change does not involve a significant hazards consideration, as set forth in 10 CFR 50.92(c), Issuance of Amendment.

5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA

{Note: Use the following paragraph if the regulatory evaluation section of the NRC staffs model IS applicable.}

A description of the proposed TS change and its relationship to applicable regulatory requirements were published in the Federal Register Notice of Availability on [DATE] ([ ] FR [ ]).

[LICENSEE] has reviewed the NRC staffs model SE referenced in the CLIIP Notice of Availability and concluded that the regulatory evaluation section is applicable to [PLANT].

{Note: Use the following paragraphs if the regulatory evaluation section of the NRC staffs model is NOT applicable.}

A description of the proposed TS change and its relationship to applicable regulatory requirements were published in the Federal Register Notice of Availability on [DATE] ([ ] FR [ ]).

[LICENSEE] has reviewed the NRC staffs model SE referenced in the CLIIP Notice of Availability and concluded that the regulatory evaluation section is not applicable to [PLANT].

The following regulatory requirements apply to [PLANT].

[Include a brief description of the regulatory requirement(s) applicable to the [PLANT] current licensing basis for the RCS leakage detection instrumentation required by the Limiting Condition for Operation, commitment to General Design Criteria (GDC) 30 or any plant-specific criteria equivalent to 10 CFR 50, Appendix A, GDC 30, any commitment to Regulatory Guide 1.45, Revision [1], and cite the applicable Final Safety Analysis Report references.]

6.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

7.0 REFERENCES

{NOTE: Provide list of references.}

MODEL SAFETY EVALUATION FOR PLANT-SPECIFIC ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE CHANGE TSTF-513, REVISION 3, AREVISE PWR OPERABILITY REQUIREMENTS AND ACTIONS FOR RCS LEAKAGE INSTRUMENTATION@

1.0 INTRODUCTION

By letter dated [DATE], [LICENSEE] (the licensee) proposed changes to the Technical Specifications (TSs) for [PLANT]. The proposed changes revise TS [3.4.15], [Reactor Coolant System (RCS) Leakage Detection Instrumentation], and includes TS Bases changes that summarize and clarify the purpose of the TS and the specified safety function of the leakage detection monitors.

The licensee stated that the license amendment request (LAR) is consistent with NRC-approved Revision 3 to Technical Specification Task Force (TSTF) Standard Technical Specification (STS) Change Traveler, TSTF-513, ARevise PWR [pressurized water reactor] Operability Requirements and Actions for RCS [reactor coolant system] Leakage Instrumentation.@

[Discuss any differences with TSTF-513, Revision 3.] The availability of this TS improvement was announced in the Federal Register on [DATE] ([ ] FR [ ]) as part of the consolidated line item improvement process (CLIIP).

2.0 REGULATORY EVALUATION

The NRC=s regulatory requirements related to the content of the TS are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36. Paragraph (c)(2)(i) of 10 CFR 50.36 states that limiting conditions for operation (LCOs) are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Paragraph (c)(2)(ii) of 10 CFR 50.36 lists four criteria for determining whether particular items are required to be included in the TS LCOs. The first criterion applies to installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary (RCPB). As described in the Federal Register Notice associated with this regulation (60 FR 36953, July 16, 1995), the scope of TS includes two general classes of technical matters: (1) those related to prevention of accidents, and (2) those related to mitigation of the consequences of accidents. Criterion 1 addresses systems and process variables that alert the operator to a situation when accident initiation is more likely, and supports the first of these two general classes of technical matters which are included in TS. As specified in Paragraph (c)(2)(i) of 10 CFR 50.36, when a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by TS until the condition can be met.

The NRCs guidance for the format and content of PWR TS can be found in [NUREG-1430, Revision 3.0, Standard Technical Specifications Babcock and Wilcox Plants.][NUREG-1431, Revision 3.0, Standard Technical Specifications Westinghouse Plants.][NUREG-1432, Revision 3.0, Standard Technical Specifications Combustion Engineering Plants.] STS 3.4.15 RCS Leakage Detection Instrumentation contains the guidance specific to the RCS leakage detection instrumentation for PWRs. The STS Bases provide a summary statement of the reasons for the STS.

The Bases for STS 3.4.15 contained in [NUREG-1430, Revision 3.0][NUREG-1431, Revision 3.0][NUREG-1432, Revision 3.0], provide background information, the applicable safety analyses, a description of the LCO, the applicability for the RCS leakage detection instrumentation TS, and describe the Actions and Surveillance Requirements. The TS Bases provide the purpose or reason for the TS which are derived from the analyses and evaluation included in the safety analysis report, and for these Specifications, the RCS leakage detection instrumentation design assumptions and licensing basis for the plant.

As stated in NRC Information Notice (IN) 2005-24, Nonconservatism in Leakage Detection Sensitivity (Agencywide Documents Access and Management System (ADAMS) Accession No. ML051780073), the reactor coolant activity assumptions for containment atmosphere gaseous radioactivity monitors may be nonconservative. This means the monitors may not be able to detect a one gpm leak within one hour under all likely operating conditions.

The issue described in IN 2005-24 has raised questions regarding the operability requirements for containment atmosphere gaseous radioactivity monitors. TSTF-513, Revision 3, revises the TS Bases to reflect the proposed TS changes and more accurately describe the contents of the facility design basis related to operability of the RCS leakage detection instrumentation. Part of the TS Bases changes revise the specified safety function of the RCS leakage detection monitors to specify the required instrument sensitivity level. In addition, TSTF-513, Revision 3, includes revisions to TS Actions for RCS leakage detection instrumentation to establish limits for operation during conditions of reduced monitoring sensitivity because of inoperable RCS leakage detection instrumentation.

{NOTE: Explain the current licensing basis and licensee commitment to General Design Criterion 30 from the plant-specific information in the FSAR or alternative license document.}

The regulation at 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 30, Quality of Reactor Coolant Pressure Boundary, requires means for detecting and, to the extent practical, identifying the location of the source of RCS leakage. Regulatory Guide (RG) 1.45, Revision 0, Reactor Coolant Pressure Boundary Leakage Detection Systems, May 1973, describes acceptable methods of implementing the GDC 30 requirements with regard to the selection of leakage detection systems for the RCPB.

RG 1.45, Revision 0, Regulatory Position C.2, states that Leakage to the primary reactor containment from unidentified sources should be collected and the flow rate monitored with an accuracy of one gallon per minute (gpm) or better.

RG 1.45, Revision 0, Regulatory Position C.3 states:

At least three separate detection methods should be employed and two of these methods should be (1) sump level and flow monitoring and (2) airborne particulate radioactivity monitoring. The third method may be selected from the following: a. monitoring of condensate flow rate from air coolers [or]

b. monitoring of airborne gaseous radioactivity. Humidity, temperature, or pressure monitoring of the containment atmosphere should be considered as alarms or indirect indication of leakage to the containment.

RG 1.45, Revision 0, Regulatory Position C.5 states, The sensitivity and response time of each leakage detection system in regulatory position 3. above employed for unidentified leakage should be adequate to detect a leakage rate, or its equivalent, of one gpm in less than one hour. RG 1.45, Revision 0, states, In analyzing the sensitivity of leak detection systems using airborne particulate or gaseous radioactivity, a realistic primary coolant radioactivity concentration assumption should be used. The expected values used in the plant environmental report would be acceptable. The appropriate sensitivity of a plants containment atmosphere gaseous radioactivity monitors is dependent on the design assumptions and the plant-specific licensing basis as described in the plants final safety analysis report (FSAR). The NRC staffs approval of the use of expected primary coolant radioactivity concentration values used in the environmental report creates a potential licensing conflict when a licensee is able to achieve and maintain primary coolant radioactivity concentration values lower than the value assumed in the environmental report.

RG 1.45, Revision 1, Guidance on Monitoring and Responding to Reactor Coolant System Leakage, was issued in May 2008. RG 1.45, Revision 1, describes methods for implementing GDC 30 requirements that are different from those in RG 1.45, Revision 0, and was developed and issued to support new reactor licensing. Revision 1 allows that having two TS leakage detection methods capable of detecting a one gpm leak within one hour provides adequate leakage detection capability from a safety perspective. It recommends that other potential indicators (including the gaseous radiation monitors) be maintained even though they may not have the same detection capability. These indicators, in effect, provide additional defense-in-depth.

The regulation in GDC 4 of Appendix A to 10 CFR Part 50, Environmental and dynamic effects design bases, requires structures, systems, and components important to safety to be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. GDC 4 allows the use of leak before break (LBB) technology to exclude dynamic effects of pipe ruptures in the design bases when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping.

3.0 TECHNICAL EVALUATION

In adopting the changes to TS included in TSTF-513, Revision 3, the licensee proposed to revise TS [3.4.15], [Reactor Coolant System (RCS) Leakage Detection Instrumentation]

Conditions and Required Actions. The licensee proposed adding new Condition [D] to TS [3.4.15]. New Condition [D] would be applicable when the containment atmosphere gaseous radioactivity monitor is the only operable RCS leakage detection monitor. This new Condition is necessary because improved fuel integrity and the resulting lower primary coolant radioactivity concentration affects a plants containment atmosphere gaseous radioactivity monitor to a greater extent than other monitors. The proposed Required Actions for new Condition [D]

require the licensee to analyze grab samples of the containment atmosphere once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and restore the required containment sump monitor to operable status within 7 days, or analyze grab samples of the containment atmosphere once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and restore the containment air cooler condensate flow rate monitor to operable status within 7 days. These actions are in addition to the Required Actions of Condition[s] [A], [and [C)) which require[s] performing an RCS mass balance once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> [and a CHANNEL CHECK of the containment atmosphere radioactivity monitor once per eight hours].

The NRC staff determined that the proposed Condition [D] is more restrictive than the current requirement, because the current Condition that would apply to the situation when the containment atmosphere gaseous radioactivity monitor is the only operable RCS leakage detection monitor would allow the licensee 30 days to restore the inoperable monitors to operable status. The proposed Actions and Completion Times are adequate because the grab samples combined with the more frequent RCS mass balances [and CHANNEL CHECKS] will provide an alternate method of monitoring RCS leakage when the containment atmosphere gaseous radioactivity monitor is the only operable RCS leakage detection monitor and the 12-hour interval is sufficient to detect increasing RCS leakage long before a piping flaw could progress to a catastrophic failure of the primary RCPB. Allowing 7 days to restore another RCS leakage monitor to operable status is reasonable given the diverse methods employed in the Required Actions to detect an RCS leak and the low probability of a large RCS leak during this period. Proposed Condition [D] is conservative relative to the STS, sufficiently alerts the operating staff, provides a comparable ability to detect RCS leakage, and provides time intervals that are reasonable. Therefore, the NRC staff determined that proposed Condition [D]

provides an adequate assurance of safety when judged against current regulatory standards.

Certain ASME Code Class 1 piping systems in [Facility] have been approved by the NRC for LBB. The basic concept of LBB is that certain piping material has sufficient fracture toughness (i.e., ductility) to resist rapid flaw propagation; thereby minimizing the probability of a pipe rupture. The licensee has evaluated postulated flaws in [RCS loop] piping and determined the piping has sufficient fracture toughness that the postulated flaw would not lead to pipe rupture and potential damage to adjacent safety related systems, structures and components before the plant could be placed in a safe, shutdown condition. The NRC staff has previously reviewed and approved these plant-specific LBB analyses. Before remotely approaching a pipe rupture, the postulated flaw would lead to limited but detectable leakage, which would be identified by the leak detection systems in time for the operator to take action. The NRC staff previously addressed concerns that LBB depends on erroneous leak rate measurements in the final rule making for use of LBB technology. In addressing the concerns, it was noted that:

One criterion for application of leak-before-break is that postulated flaw sizes be large enough so that the leakage is about ten times the leak detection capability, and that this flaw be stable even if earthquake loads are applied to the pipe in addition to the normal operating loads. This margin of a factor of ten is more than ample to account for uncertainties in both leakage rate calculations and leak detection capabilities.

Furthermore, additional sensitivity studies reported by Lawrence Livermore National Laboratory in NUREG/CR-2189, dated September 1981, entitled Probability of Pipe Fracture in the Primary Coolant Loop of a PWR Plant indicate that even in the absence of leak detection, the probability of pipe ruptures in PWR primary coolant loop piping is sufficiently low to warrant exclusion of these events from the design basis. (51 FR 12502-01)

The proposed actions for inoperable RCS leakage detection instrumentation maintain sufficient continuity, redundancy, and diversity of leakage detection capability that an extremely low probability of undetected leakage leading to pipe rupture is maintained. This extremely low probability of pipe rupture continues to satisfy the basis for acceptability of LBB in GDC 4.

The licensee proposes minor changes to ensure continuity of the TS format. These changes re-letter current Condition [D], which applies when the containment sump monitor is the only operable leakage detection instrument, to Condition [E], and current Condition [E], which applies when the required action and the associated completion time are not satisfied, to Condition [G].

Similar changes were made to the associated Required Actions. The NRC staff determines that these changes are editorial, and therefore acceptable.

The associated TS Bases submitted with the licensees proposed revision for TS [3.4.15] reflect the proposed TS changes and more accurately describe the contents of the facility design basis related to operability of the RCS leakage detection instrumentation and reflect the proposed TS changes. The proposed TS Bases changes related to the operability of the RCS leakage detection instrumentation are acceptable because they provide background information, the applicable safety analyses, a description of the limiting condition for operation, and the applicability for the RCS leakage detection instrumentation TS and are consistent with the design basis of the facility. These instruments satisfy Criterion 1 of 10 CFR 50.36(c)(2)(ii) in that they are installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the RCPB.

The NRC staff evaluated the licensees proposed changes against the applicable regulatory requirements listed in Section 2 of this SE. The NRC staff also compared the proposed changes to the changes made to STS by TSTF-513, Revision 3. The NRC staff determined that all the proposed changes afford adequate assurance of safety when judged against current regulatory standards. Therefore, the NRC staff finds the proposed changes acceptable.

4.0 STATE CONSULTATION

{NOTE: Per LIC-101, the PM is responsible for contacting the state official and verifying that this statement is correct.}

In accordance with the Commission's regulations, the [Name of State] State official was notified of the proposed issuance of the amendment. The State official had [no] comments. [If comments were provided, they should be addressed here].

5.0 ENVIRONMENTAL CONSIDERATION

{NOTE: Caution per LIC-101: The environmental consideration discussed below is written for a categorical exclusion based on 10 CFR 51.22(c)(9). The PM is responsible to ensure that this is accurate for the specific amendment being issued.}

The amendments change 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 amendments involve 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding

([ ] FR [ ]). Accordingly, the amendments meet 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 amendments.

6.0 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) such activities will be conducted in compliance with the Commission=s regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

{NOTE: Provide list of references.}

Principal Contributor:

Date: