ML012950345

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October 12, 2001: Summary of Meeting with Risk-Informed Technical Specification Task Force (RITSTF)
ML012950345
Person / Time
Issue date: 10/19/2001
From: Beckner W
Technical Specifications Branch
To: Bradley B
Nuclear Energy Institute
Tjader T., NRC/RTSB, 415-1187
References
Download: ML012950345 (53)
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Text

October 19, 2001 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 1Street, NW Washington, DC 20006-3708

SUBJECT:

OCTOBER 12,2001:

SUMMARY

OF MEETING WITH RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)

Dear Mr. Bradley:

The purpose of this letter is to transmit the summary of a meeting with the RITSTF. The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on October 12, 2001.

Sincerely,

/RA/

William D. Beckner, Chief Technical Specifications Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation

Enclosures:

1. Meeting Summary
2. Attendance List
3. Agenda
4. Initiative 1, Comparison of CEOG-1 52, CE NPSD-1 186 &

NRC SE of 7/17/01

5. Initiative 3, Draft for Comment TSTF-359, Revision 6
6. Initiative 4 Preliminary Description Paper cc w/encl: See attached list DISTRIBUTION:

See next page ADAMS ACCESSION NUMBER:

El Publicly Available Q Non-Publicly Available 0 Sensitive El Non-Sensitive DOCUMENT NAME: G:\RTSB\TJADER\ --MTG-10-12-01.wpd OFFICE SE/RTSB/DRIP SC/RT I BC/RTSB/DRIP NAME TRTjader -. '(,RLDer g'v WDBeckne0,T DATE 102L"/2001 10/11/ 2 0 01 10/*1/2001 OFkICIAL RECORD COPY

DISTRIBUTION:

ADAMS RTSB R/F RTSB Staff SJCollins/JRJohnson BWSheron DBMafthews/FPGillespie GMHolahan RJBarrett WDBeckner RLDennig FMReinhart MLWohl NTSaltos TSB Staff JAZwolinski JFWilliams AWMarkley SLMagruder RFDudley JNHannon TRQuay DFThatcher WEScott JSCushing RMPulsifer MLScott MACunningham, RES MMarkley, ACRS Staff

UNITED STATES NUCLEAR REGULATORY COMMISSION 0 WASHINGTON, D.C. 20555-0001 October 19, 2001 Mr. Biff Bradley Nuclear Energy Institute Suite 400 1776 1Street, NW Washington, DC 20006-3708

SUBJECT:

OCTOBER 12, 2001:

SUMMARY

OF MEETING WITH RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE (RITSTF)

Dear Mr. Bradley:

The purpose of this letter is to transmit the summary of a meeting with the RITSTF. The meeting was held at the U.S. Nuclear Regulatory Commission offices in Rockville, Maryland, on October 12, 2001.

Sincerely,

.týdizý /a ~

William D. Beckner, Chief Technical Specifications Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation

Enclosures:

1. Meeting Summary
2. Attendance List
3. Agenda
4. Initiative 1, Comparison of CEOG-1 52, CE NPSD-1 186 &

NRC SE of 7/17/01

5. Initiative 3, Draft for Comment TSTF-359, Revision 6
6. Initiative 4 Preliminary Description Paper cc w/encl: See attached list

Mr. Biff Bradley cc via e-mail:

Mr. Tony Pietrangelo Mr. Rick Hill Nuclear Energy Institute General Electric Nuclear Energy Mr. Biff Bradley Mr. Michael S. Kitlan, Jr.

Nuclear Energy Institute Duke Energy Corporation Mr. Mike Schoppman Mr. Noel Clarkson Nuclear Energy Institute Duke Energy Corporation Mr. Alan Hackerott, Chairman Mr. Donald Hoffman Omaha Public Power District EXCEL Services Corporation Mr. Jim Kenny Mr. Stanley Levinson Pennsylvania Power & Light Company Framatome Technologies Mr. James Andrachek Mr. R. J. Schomaker Westinghouse Electric Company Framatome Technologies Mr. Jack Stringfellow Mr. J. E. Rhoads Southern Nuclear Operating Company Energy Northwest Mr. Donald McCamy Ms. Deann Raleigh Browns Ferry Nuclear Plant Scientech Mr. Ray Schneider Mr. Ken Canavan Westinghouse Electric Company DS&S Mr. Jerry Andre Westinghouse Electric Company

SUMMARY

OF THE OCTOBER 12,2001, NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCE The NRC staff met with the NEI Risk-Informed Technical Specification Task Force (RITSTF) on October 12, 2001, from 8:30 am to 12:15 pm. The meeting attendees are listed in Enclosure 2.

The agenda (Enclosure 3) consisted of discussions of the seven active Risk Informed Technical Specification initiatives. Following is a brief description of the status of the initiatives in the order in which they were discussed.

Initiative 1, TS Actions End States Modifications: NRC staff review of the industry topicals supporting this Risk Informed Technical Specifications Task Force (RITSTF) initiative is in progress. The CE topical SER was issued on July 17, 2001. The BWR topical SER is in review and RAIs were issued on July 30, 2001. The RITSTF has reviewed both the CE topical SER and the BWR topical RAIs. The RITSTF has provided, in Enclosure 4, a list of CE topical SER stipulations that are not necessary to be explicitly stated in the TS because they are already addressed by existing TS or other regulatory requirements. RTSB will review and comment on by October 31, 2001. A proposed CE TSTF is planned to be submitted early in 2002. The BWROG responses to the RAIs are expected to be submitted by October 19, 2001.

If the RAI responses are acceptable, a BWR topical SER is expected to be completed early in 2002.

Initiative 3, TSTF-359, Modification of mode restraint requirements of LCO 3.0.4: In response to staff RAIs and questions raised at the last meeting, the RITSTF has begun to rework TSTF-359 in order to gain consistency between the OGs submittals. The RITSTF has submitted, in Enclosure 5, a partial draft TSTF-359, Revision 6, for staff review and comment.

It introduces consistency between the OGs tables of risk significant systems that require risk assessments, and it proposes LCO and Bases modifications. The RITSTF will provide RAI responses by October 19, 2001, and revised analyses for the new systems tables by the end of December 2001. The staff will provide feedback to the partial draft TSTF-359, Revision 6, by November 15, 2001. The RITSTF plans to submit a final TSTF-359, Revision 6, by January 15, 2001. The staff will prepare new milestone time lines for each of the ongoing initiatives.

Initiative 4, Risk Informed AOTs, use of a configuration risk management program (CRMP):

The RITSTF presented a new preliminary description paper (Enclosure 6) at the meeting. The proposal involves a combination of the current TS AOTs, an (a)(4) risk assessment to determine AOT extension feasibility, and AOT backstop limits. The paper will be discussed at the upcoming NRR management RMOT meeting, and RTSB will provide staff feedback on this paper by January 15, 2002. NEI will prepare a presentation to be given to the NRC staff on the 10 CFR 50.65 (a)(4) risk assessment process that is utilized extensively in the proposed risk management technical specifications.

Initiative 5, Relocation of non-safety SRs and relocation of all SR freguency requirements out of TS: In September 2001, the staff provided RAIs to the RITSTF on the concept/white paper that they presented to the NRC at the last meeting. The RITSTF will provide RAI responses and a revised white paper by December 31, 2001.

Enclosure 1

-2 Initiative 7, Non-TS support system impact on TS operability determinations: A RITSTF concept/white paper was presented at the last meeting, and the NRC provided feedback. The RITSTF will submit a TSTF early in 2002 to comprehensively address Non-TS support system impact on TS operability determinations.

Initiative 6, Modification of LCO 3.0.3 Actions and Completion Times: A CEOG submittal (on 6b/c) was received on January 24, 2001, and it was reviewed by the staff. RAIs were issued on May 9, 2001. The RITSTF is planning to submit RAI responses by November 30, 2001. A comprehensive TSTF, for all OGs, is planned to be submitted in September 2002.

The identification in the TS Bases of RG 1.177 Tier 2 configuration limitations, as they affect entry into TS Conditions, was discussed. No conclusion was reached on the necessity of Bases entries for these situations.

The next RTSB/NEI RITSTF meeting is tentatively scheduled for Wednesday, December 19, 2001.

NRC/INDUSTRY MEETING OF THE RISK-INFORMED TECHNICAL SPECIFICATION TASK FORCEATTENDANCE LIST OCTOBER 12, 2001 NAME AFFILIATION TONY PIETRANGELO NUCLEAR ENERGY INSTITUTE BIFF BRADLEY NUCLEAR ENERGY INSTITUTE JACK STRINGFELLOW SOUTHERN NUCLEAR OPERATING COMPANY DONALD HOFFMAN EXCEL SERVICES JIM ANDRACHEK WESTINGHOUSE/WOG RAY SCHNEIDER WESTINGHOUSE/WOG JERRY ANDRE WESTINGHOUSE/WOG DON McCAMY TENNESSEE VALLEY AUTHORITY/BWROG MICHAEL S. KITLAN DUKE POWER/BWOG KEN CANAVAN DS&S R. J. SCHOMAKER FRAMATOME ANP DEANN RALEIGH SCIENTECH WILLIAM BECKNER NRC/NRRIDRIP/RTSB BOB TJADER NRC/NRRIDRIP/RTSB F. MARK REINHART NRC/NRR/DSSAISPSB NICK SALTOS NRC/NRR/DSSNSPSB WAYNE SCOTT NRC/NRR/DIPM MICHAEL MARKLEY ACRS STAFF Enclosure 2

AGENDA TSB/NEI RITSTF Meeting October 12, 2001 from 8:30 AM to 4:00 PM, in O-13B4 Status of Initiatives

- Initiative 1, End States Content of TSTF BWR RAI responses

- Initiative 3, SR 3.0.4 (Mode Restraint) Flexibility Content of TSTF-359 R6

- Initiative 4, RI AOTs with CRMP Industry presentation of proposed approach

- Initiative 5, STI Evaluation Methodology Initial feedback on NRC response to industry paper

- Initiative 7, Non-TS Support System Operability Impact on TS System Schedule to submit

- Initiative 6, LCO 3.0.3 Actions and Completion Times Status?

TS AOT Changes; RG 1.177 Tier 2 Limitations

- Reflection of Configuration Limitations in TS o Schedule Next Meeting Closing Comments Enclosure 3

Attachment 1 Comparison of CEOG-152, CE NSPD-1186 and the NRC's July 17, 2001 Safety Evaluation General:

1. Section 6.0 of the Safety Evaluation states, "To be consistent with the staff s approval, any licensee requesting to operate in accordance with the CEOG request, as approved in this safety evaluation, should commit to operate in accord with the following stipulations." Each of these stipulations are addressed below.
a. "Entry into the shutdown modes approved in this safety evaluation should be for the primary purpose of accomplishing the short duration repairs which necessitated exiting the original operating mode." Implementation: As stated in the Topical, the revised end states were requested in order to minimize the time in which a plant is not in power operation. Longer duration repairs will often necessitate entry into MODE 5 either due to decreasing decay heat or to accomplish other maintenance in parallel with the original repair.
b. "Unless exceptions are stated in the individual TS descriptions of Section 5 of Reference 6, operation as approved in this safety evaluation should be limited to an entry that is initiated by inoperability of a single train of equipment or a restriction on a plant operational parameter." Implementation: The conditions under which the revised end states may be applied are described in the Traveler.
c. "Licensees should include the restrictions and guidance documented in Section 5.5 and Table 5.5-1 of Reference 6 in appropriate plant procedures and administrative controls when the plant is being operated in accordance with the proposed end states.

Procedures and/or controls should include actions to expeditiously exit a risk significant configuration in case such actions should be needed." Implementation:

This restriction will be managed through the program in place to implement 10 CFR 50.65(a)(4).

d. "Entry and use of the proposed changes should be performed in accordance with the requirements of 10 CFR 50.65(a)(4). This should include a risk assessment with respect to performance of key shutdown safety functions as described in Section 3 of this safety evaluation." Implementation: This restriction will be managed through the program in place to implement 10 CFR 50.65(a)(4).
e. "The following conditions should be met unless exceptions are identified in Section 5 of this SE:
i. Should SG cooling be lost while operating in Mode 4, there should be sufficient water in the SGs and operational procedures shall exist to ensure that long-term SDC can be initiated.

ii. Uncontrolled loss-of-inventory events should be minimized by in-depth planning, maintaining the RCS at its nominal inventory and configuration control. In-depth event response capability, such as inventory addition, procedures, and training, should be provided.

iii. The LTOP and SDC are not aligned when the plant is operated in Mode 4 on SG cooling unless the plant is being transitioned to or from SDC operation.

Page I of 13 Enclosure 4

LTOP shall be operational when the SDC system is hydraulically connected to the RCS."

Implementation: These items are part of standard operational practice developed in response to the loss of shutdown cooling and loss of RCS inventory initiatives.

LTOP will be aligned when required by the Technical Specifications. The risks associated with transitioning from MODE 4 SG heat removal to MODE 4 SDC heat removal are required to be assessed and managed by 10 CFR 50.65(a)(4).

f. "The RCS pressure boundary should remain functional and, if isolated from the SDC system, should be capable of operating with pressure relief via the pressurizer safety valves." Implementation: If the RCS pressure boundary is not functional, LCO 3.4.13 requires a plant shutdown. RCS pressure relief requirements are contained in LCO 3.4.10, Pressurizer Safety Valves, 3.4.11, Pressurizer PORVs, and 3.4.12, LTOP.
g. "The primary purpose of the CEOG request is to allow corrective maintenance in an operating mode consistent with safe operation after an AOT has been exceeded and, secondarily, to minimize the correction time so that the plant can be restored to power operation. Ordinarily, conditions addressed in this request, and in this SE, involve failures that result in a degraded plant condition. Consequently, with respect to additional licensee outage activities that could affect the safe conduct of operations and that are not directly required for correction of the failure(s) that caused the AOT to be exceeded, a licensee should:
i. Perform a safety assessment in accordance with the maintenance rule prior to undertaking such additional activities.

ii. If conditions change so that the safety assessment is no longer valid, to suspend all such additional activities via a process consistent with safety until such time as the assessment has been re-performed and is again valid."

Implementation: This restriction will be managed through the program in place to implement 10 CFR 50.65(a)(4).

In summary, the stipulations contained in Section 6.0 of the SE are addressed by existing Technical Specifications, other regulatory initiatives, or the requirements of 10 CFR 50.65(a)(4). No restrictions in the Traveler are needed to address these stipulations.

2. In the majority of the individual TS evaluations in the Topical and the NRC's SE, it was stated that there was risk benefit to remaining in MODE 4 on SG heat removal by averting the risks associated with the alignment of the SDC system. This information is not placed in the revised TS or Bases. LCO 3.4.6, RCS Loops - MODE 4, allows SG heat removal, SDC heat removal, or a combination of SG and SDC heat removal. The risks associated with transitioning from MODE 4 SG heat removal to MODE 4 SDC heat removal are required to be assessed and managed by 10 CFR 50.65(a)(4). Therefore, it is unnecessary to repeat those requirements in the various TS and would be in conflict with LCO 3.4.6.

Page 2 of 13

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 Industry/TSTF Standard Technical Specification Change Traveler Increase Flexibility in MODE Restraints Classification: 1) Technical Change Priority 1)High NUREGs Affected: 2 1430 R] 1431 [] 1432 [] 1433 [] 1434

Description:

ITS LCO 3.0.4 is revised to allow entry into a MODE or other specified condition in the Applicability while relying on the associated ACTIONS, provided that there is risk evaluation performed which justifies the use of LCO 3.0.4 or the ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. The current ITS LCO 3.0.4 allows entry into a MODE or a specified condition in the Applicability, while relying on the associated ACTIONS, only if the ACTIONS permit continued operation in the MODE or other specified condition in the Applicability for a unlimited period of Time. SR 3.0.4 is revised to reflect the concepts of the change to LCO 3.0.4.

Justification:

See Attached.

Industry Contact: Clarkson, Noel (864) 855-3077 ntclarks@duke-energy.com NRC Contact: Beckner, Bill (301) 415-1161 wdb@nrc.gov Revision History OG Revision 0 Revision Status: Closed Revision Proposed by: RITSTF Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 30-Aug-99 Owners Group Comments (No Comments)

Owners Group Resolution: Superceeded Date:

OG Revision 1 Revision Status: Closed Revision Proposed by: RITSTF Revision

Description:

Revision 1 was created to incorporate the comments of the RITSTF. The major changes include the deletion of the Tables from the Traveler and the determination that the proposed change is not an exception to SR 3.0.1, but rather a failure to meet SR 3.0.1.

10/12/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regp Commission is granted. All other use without written permission is prohibited.

Enclosure 5

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 OG Revision 1 Revision Status: Closed Owners Group Review Information Date Originated by 00: 06-Oct-99 Owners Group Comments (No Comments)

Owners Group Resolution: Superceeded Date:

OG Revision 2 Revision Status: Closed Revision Proposed by: TSTF Revision

Description:

Revision 2 was created to incorporate the comments of the TSTF and the industry. The major changes include 1) changes to the Bases to make the terminology consistent with the LCO and SR requirements, and

2) other editorial changes.

Owners Group Review Information Date Originated by OG: 24-Nov-99 Owners Group Comments (No Comments)

Owners Group Resolution: Superceeded Date:

TSTF Review Information TSTF Received Date: 25-Oct-99 Date Distributed for Review OG Review Completed: E] BWOG [] WOG F1 CEOG E] BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Date:

OG Revision 3 Revision Status: Closed Revision Proposed by: TSTF Revision

Description:

Revision 3 was created to incorporate further comments of the TSTF and the Industry. The major changes include (1) deletion of SR 3.0.4 and Bases SR 3.0.4 insert regarding failure of SR 3.0.1 due to the inconsistency of interpretation of meaning of the insert and the determination that the interrelationships need no further explanation, and (2) minor wording changes for clarity.

TSTF Review Information TSTF Received Date: 08-Nov-99 Date Distributed for Review 08-Nov-99 OG Review Completed: 2 BWOG 2 WOG 2) CEOG [ BWROG TSTF Comments:

(No Comments) 10/12/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regp Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 OG Revision 3 Revision Status: Closed TSTF Resolution: Approve ~d Date: 09-Nov-99 NRC Review Information NRC Received Date: 17-Nov-99 NRC Comments:

(No Comments)

Final Resolution: Superceded by Revision Final Resolution Date: 14-Feb-00 TSTF Revision 1 Revision Status: Closed Revision Proposed by: TSTF Revision

Description:

The Description and Justification are completely replaced to address the NRC's request for sufficient information to support creation of an SER for this change.

TSTF Review Information TSTF Received Date: 15-Feb-00 Date Distributed for Review 15-Feb-00 OG Review Completed: [] BWOG E] WOG [] CEOG [] BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Superceeded Date: 26-Jun-00 TSTF Revision 2 Revision Status: Closed Revision Proposed by: TSTF Revision

Description:

Revised Description, Justification, and Inserts to address Industry comments.

TSTF Review Information TSTF Received Date: 26-Jun-00 Date Distributed for Review 26-Jun-00 OG Review Completed: Sa BWOG [& WOG 2] CEOG [6 BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Superceeded Date: 16-Aug-00 TSTF Revision 3 Revision Status: Closed Revision Proposed by: RITSTF Revision

Description:

The following changes were made:

Proposed Change:

10/12/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regi Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 TSTF Revision 3 Revision Status: Closed

1. First paragraph, following "(b) After performance of a risk evaluation", Added: after performance of a risk evaluation, consideration of the results, and establishment of risk management actions if appropriate.
2. Third paragraph, replaced second sentence with following: The risk evaluation may use quantitative, qualitative, or blended approaches, and should be consistent with the approach of Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants". The results of the risk evaluation shall be considered in determining the acceptability of the mode change, and any corresponding risk management actions.
3. Deleted last sentence of third paragraph.
4. Fourth paragraph: Deleted sentence beginning "Acceptable risk", and next sentence (1.174 reference).

Replaced with "Regulatory guide 1.182 addresses general guidance for conduct of the risk evaluation, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed mode change is unacceptable."

5. Last sentence of paragraph is clarified to state that actions may include changing modes. "determine safest course of action" is replaced with "determine the risk impact, and the need for risk management actions as appropriate."

Justification:

1. Second paragraph, first sentence. The phrase "minimizing risk" is replaced with "maintaining acceptable plant risk."
2. Paragraph beginning "In addition." The reference to the CEOG end state report is eliminated and the following is substituted, "the additional mitigation capability provided by steam driven systems at higher modes." The statement that a risk evaluation would only be required if the risk is increased is circular logic and is deleted.

Effect on Risk-Informed Analysis:

1. Replaced the first paragraph with the following: "A quantitative, qualitative, or blended risk evaluation should be performed to assess the risk impact of the mode change, based on the specific plant configuration at that time. The following table, developed for CE plants, shows the results of a qualitative risk analysis taking into account the impact on initiating event frequency and mitigation capability as a function of plant mode. From such an evaluation, systems/components can be identified whose unavailability results in an equal or greater risk impact in Modes 2-4 than in Mode 1. For these systems/components, it would be generally acceptable to utilize the 3.0.4 exemption. However, the applicability of the table should be reviewed with respect to the actual plant configuration at that time. Entry into more than one 3.0.4 exemption at the same time, or for plant systems/components identified in the table as potentially higher risk for mode I operation, would require a more rigorous analysis, and consideration of risk management actions as discussed in Regulatory Guide 1.182."
2. Deleted the second paragraph.
3. Deleted paragraph beginning, "Based upon a general review of the San Onofre PRA."

TS changes: - Inserts 1, 2, 3, and 4 10/12/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regi Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 TSTF Revision 3 Revision Status: Closed

1. Revised Inserts to reflect changes described in "Proposed Changes," above.

TSTF Review Information TSTF Received Date: 16-Aug-00 Date Distributed for Review 16-Aug-00 OG Review Completed: [3 BWOG C] WOG Q] CEOG Q] BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Date:

TSTF Revision 4 Revision Status: Closed Revision Proposed by: TSTF Revision

Description:

Revised the justification to apply to all NUREGs, not just the CEOG NUREG. Revised the LCO 3.0.4 and SR 3.0.4 changes to require determination of the acceptability of MODE change, expanded MODE descriptions to address both PWRs and BWRVs, eliminated reference to the San Onofre evaluation and substituted Owners Groups evaluations, TSTF Review Information TSTF Received Date: 20-Aug-00 Date Distributed for Review OG Review Completed: [] BWOG [] WOG [] CEOG M BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Superceeded Date: 22-Jan-01 TSTF Revision 5 Revision Status: Closed Revision Proposed by: RITSTF Revision

Description:

I - Indicated that the attached reports (Attachments 1 - 4) are generic and that the individual plants may perform plant specific evaluations along with the TSTF.

2 - Included a statement in the Bases: "The following is a list of those systems that have been generically determined to be risk significant systems and do not typically have the LCO 3.0.4 flexibility allowed."

System MODE or other Specified Condition in the Applicability Diesel Generators 1,2,3,4, 5, 6 (Owners Groups Specific Information Will Be Provided In Each NUREG Bases)

3. Added a sentence in the TSTF that clearly states that the Bases will be plant specific.
4. Included a statement that the LCO 3.0.4 exception typically only applies to systems and components and that values and parameters are not addressed by LCO 3.0.4.
5. Made statement in the Bases that the list of parameter / value exclusions can be found in other "licensee 10/12/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regi Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 TSTF Revision 5 Revision Status: Closed controlled documents."

6. Provided a statement in the Bases that TSTF-359 acknowledges the previous flexibility some plants may have had for LCO 3.0.4 exceptions and application and that each plant may use plant-specific justification to retain those previous flexibilities.

TSTF Review Information TSTF Received Date: 22-Jan-01 Date Distributed for Review 02-Mar-01 OG Review Completed: [] BWOG (] WOG [] CEOG [ BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 02-Mar-01 NRC Review Information NRC Received Date: 02-Mar-01 NRC Comments:

The NRC provided questions in a meeting between the NRC and the RITSTF on 7/30/01 and in a Request for Additional Information dated 8/14/01.

Final Resolution: Superceded by Revision Final Resolution Date:

TSTF Revision 6 Revision Status: Active Next Action: TSTF Revision Proposed by: RITSTF Revision

Description:

TSTF-359, Revision 6 - Draft for Industry Review and NRC comment This revision was developed for Industry and NRC review and comment. This is not the formal TSTF-359, Revision 6.

This revision made many changes that were proposed in large part by comments from the Industry and comments from the NRC, both at the 7/30/01 NRC / RITSTF meeting and in the NRC Request for Additional Information dated 8/14/01. The changes address:

1) Consistency of terminology
2) NRC comments and questions
3) Additional clarification and justification
4) Standardization of OG Tables, and
5) Bases revisions to support plant-specific adoption.

TSTF Review Information TSTF Received Date: 29-Sep-01 Date Distributed for Review 29-Sep-01 10/12/2001 Regi Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 TSTF Revision 6 Revision Status: Active Next Action: TSTF OG Review Completed: El BWOG F] WOG (] CEOG Q1 BWROG TSTF Comments:

(No Comments)

TSTF Resolution: Date:

Incorporation Into the NUREGs File to BBS/LAN Date: TSTF Informed Date: TSTF Approved Date:

NUREG Rev Incorporated:

Affected Technical Specifications LCO 3.0.4 LCO Applicability LCO 3.0.4 Bases LCO Applicability SR 3.0.4 SR Applicability SR 3.0.4 Bases SR Applicability PAM Instrumentation NUREG(s)- 1430 Only Action 3.3.17 NUREG(s)- 1430 Only Action 3.3.17 Bases PAM Instrumentation NUREG(s)- 1430 Only Action 3.3.18 Remote Shutdown Sysem NUREG(s)- 1430 Only Action 3.3.18 Bases Remote Shutdown Sysem NUREG(s)- 1430 Only Action 3.4.15.A RCS Leakage Detection Instrumentation NUREG(s)- 1430 Only Action 3.4.15.A Bases RCS Leakage Detection Instrumentation NUREG(s)- 1430 Only Action 3.4.15.B RCS Leakage Detection Instrumentation NUREG(s)- 1430 Only Action 3.4.15.B Bases RCS Leakage Detection Instrumentation NUREG(s)- 1430 Only Action 3.4.16.A RCS Specific Activity NUREG(s)- 1430 Only Action 3.4.16.A Bases RCS Specific Activity NUREG(s)- 1430 Only Action 3.7.4.A AVVs NUREG(s)- 1430 Only Action 3.7.4.A Bases AVVs NUREG(s)- 1431 Only Action 3.3.3 PAM Instrumentation NUREG(s)- 1431 Only Action 3.3.3 Bases PAM Instrumentation 10/12/2001 utility clients, and the U.S. Nuclear Regi Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 Action 3.3.4 Remote Shutdown System NUREG(s)- 1431 Only NUREG(s)- 1431 Only Action 3.3.4 Bases Remote Shutdown System NUREG(s)- 1431 Only Action 3.4.11 Pressurizer PORVs NUREG(s)- 1431 Only Action 3.4.11 Bases Pressurizer PORVs NUREG(s)- 1431 Only Action 3.4.15.A RCS Leakage Detection Instrumentation NUREG(s)- 1431 Only Action 3.4.15.A Bases RCS Leakage Detection Instrumentation NUREG(s)- 1431 Only Action 3.4.15.B RCS Leakage Detection Instrumentation NUREG(s)- 1431 Only Action 3.4.15.B Bases RCS Leakage Detection Instrumentation NUREG(s)- 1431 Only Action 3.4.16.A RCS Specific Activity NUREG(s)- 1431 Only Action 3.4.16.A Bases RCS Specific Activity NUREG(s)- 1431 Only Action 3.6.8.A Hydrogen Recombiners (Atmospheric, Subatmospheric, Ice Condenser, and Dual)

NUREG(s)- 1431 Only Action 3.6.8.A Bases Hydrogen Recombiners (Atmospheric, Subatmospheic, Ice Condenser, and Dual)

NUREG(s)- 1431 Only Action 3.6.9.A HMS (Atmospheric, Ice Condenser, and Dual)

NUREG(s)- 1431 Only Action 3.6.9.A Bases HMS (Atmospheric, Ice Condenser, and Dual)

NUREG(s)- 1431 Only Action 3.7.4.A ADVs NUREG(s)- 1431 Only Action 3.7.4.A Bases ADVs NUREG(s)- 1432 Only Action 3.3.1..B RPS Instrumentation - Operating (Analog)

NUREG(s)- 1432 Only Action 3.3.1 .B RPS Instrumentation - Operating (Digital)

NUREG(s)- 1432 Only Action 3.3.1.B Bases RPS Instrumentation - Operating (Analog)

NUREG(s)- 1432 Only Action 3.3.1.B Bases RPS Instrumentation - Operating (Digital)

NUREG(s)- 1432 Only Action 3.3.1 .D RPS Instrumentation - Operating (Digital)

NUREG(s)- 1432 Only Action 3.3.1.D Bases RPS Instrumentation - Operating (Digital)

NUREG(s)- 1432 Only Action 3.3.1.E RPS Instrumentation - Operating (Analog)

NUREG(s)- 1432 Only Action 3.3.1.E Bases RPS Instrumentation - Operating (Analog)

NUREG(s)- 1432 Only Action 3.3.2.B RPS Instrumentation - Shutdown (Analog)

NUREG(s)- 1432 Only Action 3.3.2.B RPS Instrumentation - Shutdown (Digital) 10/12/2001 U.S. Nuclear Regi Traveler Rev. 2. Copyright (C) 200 1, Excel Services Corporation. Use by Excel Services associates, utility clients, and the Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 Action 3.3.2.8 Bases RPS Instrumentation - Shutdown (Analog) NUREG(s)- 1432 Only Action 3.3.2.B Bases RPS Instrumentation - Shutdown (Digital) NUREG(s)- 1432 Only Action 3.3.2.0 RPS Instrumentation - Shutdown (Analog) NUREG(s)- 1432 Only Action 3.3.2.D RPS Instrumentation - Shutdown (Digital) NUREG(s)- 1432 Only Action 3.3.2.D Bases RPS Instrumentation - Shutdown (Analog) NUREG(s)- 1432 Only Action 3.3.2.D Bases RPS Instrumentation - Shutdown (Digital) NUREG(s)- 1432 Only Action 3.3.4.C ESFAS Instrumentation (Analog) NUREG(s)- 1432 Only Action 3.3.4.C Bases ESFAS Instrumentation (Analog) NUREG(s)- 1432 Only Action 3.3.4.E ESFAS Instrumentation (Analog) NUREG(s)- 1432 Only Action 3.3.4.E Bases ESFAS Instrumentation (Analog) NUREG(s)- 1432 Only Action 3.3.5.B ESFAS Instrumentation (Digital) NUREG(s)- 1432 Only Action 3.3.5.B Bases ESFAS Instrumentation (Digital) NUREG(s)- 1432 Only Action 3.3.5.D ESFAS Instrumentation (Digital) NUREG(s)- 1432 Only Action 3.3.5.D Bases ESFAS Instrumentation (Digital) NUREG(s)- 1432 Only Action 3.3.6.B DG - LOVS (Analog) NUREG(s)- 1432 Only Action 3.3.6.B Bases DG - LOVS (Analog) NUREG(s)- 1432 Only Action 3.3.7.B DG - LOVS (Digital) NUREG(s)- 1432 Only Action 3.3.7.B Bases DG - LOVS (Digital) NUREG(s)- 1432 Only Action 3.3.11 PAM Instrumentation (Analog) NUREG(s)- 1432 Only Action 3.3.11 PAM Instrumentation (Digital) NUREG(s)- 1432 Only Action 3.3.11 Bases PAM Instrumentation (Analog) NUREG(s)- 1432 Only Action 3.3.11 Bases PAM Instrumentation (Digital) NUREG(s)- 1432 Only Action 3.3.12 Remote Shutdown System (Analog) NUREG(s)- 1432 Only Action 3.3.12 Remote Shutdown System (Digital) NUREG(s)- 1432 Only Action 3.3.12 Bases Remote Shutdown System (Analog) NUREG(s)- 1432 Only Action 3.3.12 Bases Remote Shutdown System (Digital) NUREG(s)- 1432 Only Action 3.4.11 Pressurizer PORVs NUREG(s)- 1432 Only 10/12/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regi Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 Action 3.4.11 Bases Pressurizer PORVs NUREG(s)- 1432 Only NUREG(s)- 1432 Only Action 3.4.15.A RCS Leakage Detection Instrumentation NUREG(s)- 1432 Only Action 3.4.15.A Bases RCS Leakage Detection Instrumentation NUREG(s)- 1432 Only Action 3.4.15.B RCS Leakage Detection Instrumentation NUREG(s)- 1432 Only Action 3.4.15.B Bases RCS Leakage Detection Instrumentation Action 3.4.16.A NUREG(s)- 1432 Only RCS Specific Activity Action 3.4.16.A Bases RCS Specific Activity NUREG(s)- 1432 Only NUREG(s)- 1432 Only Action 3.6.8.A Hydrogen Rcombiners (Atmospheric and Dual)

NUREG(s)- 1432 Only Action 3.6.8.A Bases Hydrogen Rcombiners (Atmospheric and Dual)

Action 3.6.9.A HMS (Atmospheric and Dual) NUREG(s)- 1432 Only Action 3.6.9.A Bases HMS (Atmospheric and Dual) NUREG(s)- 1432 Only Action 3.7.4.A ADVs NUREG(s)- 1432 Only Action 3.7.4.A Bases ADVs NUREG(s)- 1432 Only Action 3.3.3.1 PAM Instrumentation NUREG(s)- 1433 Only Action 3.3.3.1 Bases PAM Instrumentation NUREG(s)- 1433 Only Action 3.3.3.2 NUREG(s)- 1433 Only Remote Shutdown System Action 3.3.3.2 Bases Remote Shutdown System NUREG(s)- 1433 Only NUREG(s)- 1433 Only Action 3.3.6.3.A LLS Instrumentation Action 3.3.6.3.A Bases LLS Instrumentation NUREG(s)- 1433 Only Action 3.4.6.A RCS Leakage Detection Instrumentation NUREG(s)- 1433 Only Action 3.4.6.A Bases NUREG(s)- 1433 Only RCS Leakage Detection Instrumentation NUREG(s)- 1433 Only Action 3.4.6.B RCS Leakage Detection Instrumentation NUREG(s)- 1433 Only Action 3.4.6.B Bases RCS Leakage Detection Instrumentation Action 3.4.6.D NUREG(s)- 1433 Only RCS Leakage Detection Instrumentation Action 3.4.6.D Bases NUREG(s)- 1433 Only RCS Leakage Detection Instrumentation Action 3.4.7.A RCS Specific Activity NUREG(s)- 1433 Only NUREG(s)- 1433 Only Action 3.4.7.A Bases RCS Specific Activity 10/12/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regi Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 Action 3.4.8 RHR and Shutdown Cooling System - Hot Shutdown NUREG(s)- 1433 Only Action 3.4.8 Bases RHR and Shutdown Cooling System - Hot Shutdown NUREG(s)- 1433 Only Action 3.6.3.1.A Primary Containment Hydrogen Recombiners NUREG(s)- 1433 Only Action 3.6.3.1.A Bases Primary Containment Hydrogen Recombiners NUREG(s)- 1433 Only Action 3.6.3.2.A Drywell Cooling System Fans NUREG(s)- 1433 Only Action 3.6.3.2.A Bases Drywell Cooling System Fans NUREG(s)- 1433 Only Action 3.6.3.4.A CAD System NUREG(s)- 1433 Only Action 3.6.3.4.A Bases CAD System NUREG(s)- 1433 Only Action 3.7.3.A DG (1B] SSW System NUREG(s)- 1433 Only Action 3.7.3.A Bases DG [1B] SSW System NUREG(s)- 1433 Only Action 3.3.3.1 PAM Instrumentation NUREG(s)- 1434 Only Action 3.3.3.1 Bases PAM Instrumentation NUREG(s)- 1434 Only Action 3.3.3.2 Remote Shutdown System NUREG(s)- 1434 Only Action 3.3.3.2 Bases Remote Shutdown System NUREG(s)- 1434 Only Action 3.4.7.A RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only Action 3.4.7.A Bases RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only Action 3.4.7.B RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only Action 3.4.7.B Bases RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only Action 3.4.7.D RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only Action 3.4.7.D Bases RCS Leakage Detection Instrumentation NUREG(s)- 1434 Only Action 3.4.8.A RCS Specific Activity NUREG(s)- 1434 Only Action 3.4.8.A Bases RCS Specific Activity NUREG(s)- 1434 Only Action 3.4.9 RHR and Shutdown Cooling System - Hot Shutdown NUREG(s)- 1434 Only Action 3.4.9 Bases RHR and Shutdown Cooling System - Hot Shutdown NUREG(s)- 1434 Only Action 3.6.3.1 .A Primary Containment Hydrogen Recombiners NUREG(s)- 1434 Only Action 3.6.3.1.A Bases Primary Containment Hydrogen Recombiners NUREG(s)- 1434 Only Action 3.6.3.2.A Primary Containment and Drywell Hydrogen Ignitors NUREG(s)- 1434 Only 10/12/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regi Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT (CEOG-141, Rev. 3) TSTF-359, Rev. 6 Action 3.6.3.2.A Bases Primary Containment and Drywell Hydrogen Ignitors N JREG(s)- 1434 Only Action 3.6.3.3.A Drywell Purge System NtJREG(s)- 1434 Only Action 3.6.3.3.A Bases Drywell Purge System NIJREG(s)- 1434 Only 10/12/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regi Commission is granted. All other use without written permission is prohibited.

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment JUSTIFICATION

Background

LCO 3.0.4 states. "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time." The allowance to enter MODES or specified conditions in the Applicability while relying on ACTIONS is given because ACTIONS which permit continued operation of the unit for an unlimited period provide an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change.

The allowances of LCO 3.0.4 are based on NRC Generic Letter 87-09 which states with respect to unnecessary MODE changes, "Specification LCO 3.0.4 unduly restricts facility operation when conformance with Action Requirements provides an acceptable level of safety for continued operation. For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operation MODE or other specified condition of operation should be permitted in accordance with the Action Requirements."

In the development of ITS, many improvements were made to LCO 3.0.4 including clarification of its applicability regarding normal shutdown and Required Action shutdowns, and MODE changes during Cold Shutdown and Refueling Operations. During ITS development, almost all the LCOs with A4ll ... d 4uage

.. Completion Times greater than or equal to 30 days, and many of the LCOs with AQTs

.4i.es Completion Times greater than or equal to 7 days, were given individual LCO 3.0.4 exceptions. During many plant specific ITS conversions, individual plants provided justifications for other LCO 3.0.4 exceptions. These specific exceptions allow entry into a MODE or specified condition in the Applicability while relying on these ACTIONS.

Need for Change ITS LCO 3.0.4 and SR 3.0.4 are still overly restrictive. The startup of a unit is frequently delayed due to the current restrictions of LCO 3.0.4. For example, a single maintenance activity that is almost complete can cause significant delays and changes in the previously well thought out plans for returning the unit to service.

Allowing the unit to enter the MODE or other specified condition in the Applicabii ty efapp4icibiliy for tht speeifieagie -a Specification for such situations would allow the work to be completed without creating the potential for error likely situations due to artificially shorter periods of time to complete all appropriate Surveillances and maintenance activitiesmid a....id,hages .the. in ......... ,

Proposed Change The proposed change revises LCO 3.0.4 and SR 3.0.4. LCO 3.0.4 is revised to state, "When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made" and SR 3.0.4 is revised to state. "When an LCO is not met due to Surveillances not havin2 been met. entry into a MODE or Page 1 of 6

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment other specified condition in the Applicability shall only be made:." Both LCO 3.0.4 and SR 3.0.4 then continue. "

(a.) When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period or time, of, (b.) After performance of a risk evaluation, consideration of the results, determination of the acceptability of etrgn .the MODE or other specified condition in the ApplicabiliL,~ange, and establishment of risk management actions, if appropriate."

The current LCO 3.0.4.a allowance is retained without the need for risk evaluation because the Required Actions which allow indefinite operation already satisfy the safety function.

The paragraph in LCO 3.0.4 which describes exceptions is deleted. Individual LCO 3.0.4 exceptions would be deleted throughout the ITS and replaced with use of the risk evaluation provision being added to LCO 3.0.4 and SR 3.0.4.

"TheLCO 3.0.4 allowance typically only applies to systems and components. The values and parameters of the Technical Specifications that have their own respective LCOs (e..g.. Containment Air Temperature, Containment Pressure, MCPR. Moderator Temperature Coefficient, etc.) are typically not addressed by LCO 3.0.4.

The Bases of LCO 3.0.4 are revised to explain the use of the new LCO 3.0.4 e*eept allowance: The Bases of SR 3.0.4 are also revised to reflect the changes made to the Specifications.

While these Bases changes are being proposed as part of the generic justification of this proposed change, the Bases for each plant will be revised to be plant specific.

Justification The proposal to allow entry into a MODE or other specified condition in the Applicability while relying on ACTIONS based on a risk evaluation is reasonable based on many factors. The licensee, and particularly the licensee management, is always responsible for maintaining overall plant configuration and safety.

Developments in the Maintenance Rule and other Industry/NRC initiatives (including the configuration risk management programs) enhance the tools available to licensees to evaluate the risk associated with various plant configurations. This change is a logical step of requiring licensees to evaluate the application of LCO 3.0.4 e.. ep.... allowances in light of the newly available tools and information.

The risk evaluation may consider a variety of factors, but will focus on maintaining acceptable plant risk.

Consideration would be given to the probability of completing restoration such that the requirements of the LCO would be met prior to entering ACTIONS that would require exiting the Applicability. The evaluation may also establish appropriate compensatory measures to enhance safe and effective operations until restoration of compliance with the LCO. The proposed change would provide the flexibility of not restricting which LCOs, MODES, or Applicability can be entered while relying on the ACTIONS as do the current LCO 3.0.4 exceptions, but would add the requirement to evaluate the risks prior to making the MODE change. This evaluation is not currently required. In addition, the ITS Completion Times provide a limit to Page 2 of 6

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment how long a licensee could be in a MODE or specified condition of the Applicability without meeting the LCO requirements.

When an LCO is not met, the licensee must restore compliance with the LCO consistent with the requirements of the Technical Specifications. This restoration may include corrective maintenance. The recent revisions to 10CFR50.65 require that licensees assess the effect equipment maintenance will have on the plant's capability to perform safety functions before beginning any maintenance activity on structures, systems, or components within the scope of the maintenance rule. The final rule clarifies that these requirements apply under all conditions of operation, including shutdown, and that the assessments are to be used so that the increase in risk that may result from the maintenance activity will be managed to ensure that the plant is not inadvertently placed in a condition of significant risk. So effectively, t.r.e is be a regulato.y r.equirement to evaluate the risks prior to making the 4ODE *cha"e. NRC Rehulatory Guide 1.182 endorses the guidance of NUMARC 93

01. Section 11, as revised in February 2000. as an acceptable approach to meet 10 CFR 50.65(a)(4).

Section 11.3.1 of NUMARC 93-01 addresses assessment process. control. and responsibilities, as follows:

The process for conducting the assessment and using the result of the assessment in plant decisionmakina should be proceduralized. The procedures should denote responsibilities for conduct and use of the assessment, and should specifv the plant functional organizations and personnel involved, including, as appropriate, operations. engineering, and risk assessment (PSA) personnel.

The procedures should denote responsibilities and process for conducting the assessment for cases when the plant configuration is not covered by the normal assessment tool.

Plants choosing to adopt LCO 3.0.4.b should ensure that plant procedures in place to implement 10 CFR 50.65(a)(4) address the situation where entering a MODE or other specified condition in the Applicability is contemplated with plant equipment not OPERABLE. Section 11.3.8 of NUMARC 93-01 discusses the need to treat plant MODE changes as an emergent condition that may affect a previously performed risk assessment, and would require re-performance of the assessment. Adoption of LCO 3.0.4.b would result in this consideration applying to assessments for planned activities, as well as emergent conditions.

1. The procedures should state that the risk assessment (and risk management actions) will consider the impact of being in a higher plant MODE, for the expected duration. considering the plant equipment configuration at the time of the MODE change.
2. The guidance of NUMARC 93-01. Section 11. and Appendix E (addressing PSA quality) should be followed in assessing and imanaging the risk resulting from the MODE change.
3. Since the MODE chanae necessitating the use of LCO 3.0.4.b would involve a transition upward in MODE. towards power operation, the "power operations" .guidance of NUMARC 93-01. Sections 11.3.3 (scope) and 11.3.4 (assessment) should be followed for situations where LCO 3.0.4.b is entered.
4. The assessment should include consideration that there is a reasonable probability of completing Page 3 of 6

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment restoration such that the requirements of the LCO would be met prior to the expiration of the ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4.b should not be used unless there is a hieh likelihood that the system or component LCO will be satisfied following the MODE change. The revised plant oversight process treats unplanned power changes as a factor that could lead to a finding under the significance determination process. Thus, the oversight process would provide a significant disincentive to entering the MODE of Applicability of an LCO. and moving up in power. when there was some likelihood that the MODE of applicability would have to be subsequentlv exited due to failure to restore the unavailable system or component to service within the Completion Time.

This proposed change would provide standardization and consistency to the use and application of LCO 3.0.4. Currently there are numerous variations of LCO 3.0.4 requirements in the Technical Specifications of individual plants. Additionally, the ITS NUREGs are not totally consistent in their treatment of LCO 3.0.4._

This proposed change will further ensure consistency in appropriate levels of risk assessment for plant configuration.

In addition, as the unit goes up in MODE the complement of systems available to mitigate certain events is increased (e.g., for PWRs - availability of SGs for cooling, in addition to shutdown cooling, for BWRs availability of HPCI and RCIC). In most cases, increasing in MODE from shutdown cooling results in a reduction of risk due to termination of shutdown coolin and the additional mitigation capability provided by steam driven systems at higher MODES. This is due to the added level of protection to prevent core damage on a loss of cooling, and the added ability to respond to a station blackout using steam driven systems. Thus in most cases, risk can be reduced by allowing entry into a MODE or other specified condition in the Applicability. F er.ases beynd the generic evaluatin, a 144i evalu ti e

.i- d. For those cases where the risk of the MODE chanee may be greater (i.e., the systems listed on the Table), the risk assessment and associated risk manaaement actions, if any, must be documented and retained. This actiornwl ensures that no MODE changes allowed by this change will result in an unacceptable risk increase. Overall, since most MODE changes allowed by this TSTF result in a risk decrease from one MODE to the next, and a risk evaluation is required for any potential MODE change resulting in a r*sk in.r..as. when an equipment LCO is not met, this change is considered risk neutral.

Most plants have some pre-existing exceptions to the applicability of LCO 3.0.4 for certain systems or components. These pre-existing exceptions would be removed by the proposed change, and replaced with the risk-informed approach to LCO 3.0.4.b as described above. Pre-existine plant-specific exceptions to parameter or value LCOs are not affected by this change and may be retained.

This change in LCO 3.0.4 philosophy weuid Fa~irereauies a change in SR 3.0.4. If a Surveillance Requirement is not met prior to entering the MODE or specified condition in the Applicability, the LCO would be declared not met and LCO 3.0.4 would apply.

Page 4 of 6

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment Effect on Safety Analyses Accident analyses presented in the UFSAR do not address the effects of the plant being in ACTIONS. The accident analyses assume that the necessary equipment is available and then, in most cases, assumes the single most limiting active failure occurs. It is this assumption that leads to limiting the length of Completion Times in order to minimize the length of time that the plant is not within the initial conditions of the accident analysis.

This change does not affect the Completion Times. Therefore, this proposal would not affect the accident analyses.

Effect on Risk Informed Analysis A quantitative, qualitative, or blended risk evaluation .4,her-mustbe performed to assess the risk impact of the MODE change, based on the specific plant configuration at that time, and the risk impacts must be manaaed in accordance with the assessment results. From generic evaluations, systems/components can be identified which are equally or more important to risk in MODE 1than in the transition MODES. The Technical Specifications allow continued operation with this equipment unavailable during MODE 1 operation for the duration the Completion Time. Since this is allowable, and since the risk impact bounds the risk of transitioning up in MODE and entering the Conditions and Required Actions, the use of the LCO 3.0.4 allowance for these systems should be generally acceptable, as long as the risk is assessed and managed as stated above. However. ThLis ... n.tat*cqualitative, 8F blended Fisk.. alu.... . sh.ould . take into aec.unt the mpat onigaitiain evenRt frEequeny and mi~tigatin capabilty as a frmnctio ofplant MODE. Fro~m such evalatinsystems/com-poenllts can be identifiedA4hose una-vailability. results in an equal or- greater- risk impact in44MODES 2 5 for -PWRs and MOD&ES 2 4 for- BWARs than in MODE 4. Foer these sy...m./com.onent.. ,Ould it be g*en*e..y acceptable to utile the LC-9 3.0.4 e*ceptions*.Tthere is a small subset of systems that have been generically determined to be ,iki emprators and do not typically have the LCO 3.0.4 .. eep*e..allowance allewe . The Bases of each ITS NUREG contain this generic Owners Group list.

The applicability of the LCO should be reviewed with respect to the actual plant configuration at that time.

Entry into more than one LCO 3.0.4.b ..eep.ie..llowance at the same time would be evaluated under the auspices of 10 CFR 50.65t.a-.X(4) and consideration of risk management actions discussed in Regulatory Guide 1.182. To apply the LCO 3.0.4.b e..eept.E.allowance to plant systems/components identified in the Bases as potentially higher risk than for MODE 1 operation, a plant specific justification would be required.

Owners Groups Qualitative Risk Assessment Each of the Owners Groups has developed a Qualitative Risk Assessment to justify the relaxation and increased flexibility of the MODE restrictions. These reports are generic to the respective Owners Groups.

Individual plants may perform plant specific evaluations and assessments along with their respective Owners Groups reports and this TSTF- 359 to justify additional flexibility beyond the generic flexibility provided by this TSTF. These Owners Groups assessments are Attachments 1 - 4 of this TSTF-359.

Page 5 of 6

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment Determination of No Significant Hazards Considerations A change is proposed to the Improved Technical Specifications NUREGs 1430 - 1434, LCO 3.0.4 to allow entry into a MODE or other specified condition in the Applicability while relying on ACTIONS after performance of a risk evaluation. LCO 3.0.4 exceptions in individual Specifications would be eliminated. SR 3.0.4 is revised to reflect the LCO 3.0.4 allowance.

In accordance with the criteria set forth in 10 CFR 50.92, the Industry has evaluated these proposed Improved Technical Specification changes and determined they do not represent a significant hazards consideration. The following is provided in support of this conclusion.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change allows entry into a MODE while relying on ACTIONS. Being in an ACTION is not an initiator of any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The consequences of an accident while relying on ACTIONS as allowed by the proposed LCO 3.0.4 are no different than the consequences of an accident while relying on ACTIONS for other reasons, such as equipment inoperability. Therefore, the consequences of an accident previously evaluated are not significantly increased by this change. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

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

3. Does this change involve a significant reduction in a margin of safety?

The proposed change allows entry into a MODE while relying on ACTIONS. The Technical Specifications allow operation of the plant without a fulil complement of equipment. The risk associated with this allowance is managed by the imposition of ACTIONS and Completion Times. The net effect of ACTIONS and Completion Times on the margin of safety is not considered significant The proposed change does not change the ACTIONS or Completion Times of the Technical Specifications. The proposed change allows the ACTIONS and Completion used in new Times to be gmanasg circumstances. However, this use is predicated on an evaluation which fcuses on mi plant risk. In addition, current allowances to utilize the ACTIONS and Completion Times which do not require risk evaluation tm ii are eliminated. As a result, the net change to the margin of safety is insignificant. Therefore, this change does not involve a significant reduction in a margin of safety.

Page 6 of 6

DRAFT FOR NRC COMMENT ATTACHMENTS The Attachments 1 - 4, Owners Groups Qualitative Risk Assessments, have been removed in this Revision 6, Draft for Review, of TSTF-359. Attachments 1 -4 have been replaced with only the revised versions of the Tables of more important or limited systems for LCO 3.0.4 flexibility which appeared in TSTF-359, Revision 5 Attachments 1 - 4.

These tables have been modified to provide consistency and standardization across the Owners Groups. In addition, it has been clarified that support systems will be considered under the definition of OPERABILITY, the provisions of LCO 3.0.6, and the Safety Function Determination Program (SFPD) and, as such, these support systems are not listed separately in the Tables. Support system requirements will be addressed through existing Technical Specifications requirements.

The Owners Groups Qualitative Risk Assessments will be formally modified and included in the final version of TSTF-359, Revision 6, after the concepts are agreed to by the Industry and the NRC.

DRAFT FOR NRC COMMENT ATTACHMENT 1 BWR Technical Justification to Support Risk-Informed Improvements to Technical Specification Mode Restraints for BWR Plants

DRAFT FOR NRC COMMENT Table 1 List of Risk-Significant BWR Systems/Components* During Full Power (MODE 1)

"* High Pressure Coolant Injection (HPCI) System - BWR 3 and 4 Plants

"* High Pressure Core Spray (HPCS) - BWR 5 and 6 Plants

"* Reactor Core Isolation Cooling (RCIC) System - BWR 3, 4, and 5 and 6 Plants

"* Isolation Condenser - BWR 2 Plants

"* Diesel Generators (including other Emergency / Shutdown AC Power Supplies)

"* Hardened Wetwell Vent System - BWR 2, 3, and 4 plants with Mark I Containment Table 2 2)

List of Risk-Significant BWR Systems/Components* During Low Power (MODE

"* High Pressure Coolant Injection (HPCI) System - BWR 3 and 4 Plants

"* High Pressure Core Spray (HPCS) - BWR 5 and 6 Plants

"* Reactor Core Isolation Cooling (RCIC) System - BWR 3, 4, and 5 and 6 Plants

"* Isolation Condenser - BWR 2 Plants

"* Diesel Generators (including other Emergency / Shutdown AC Power Supplies)

"* Hardened Wetwell Vent System - BWR 2, 3, and 4 plants with Mark I Containment Table 3 3)

List of Risk-Significant BWR Systems/Components* During Shutdown (MODE

"* Diesel Generators (including other Emergency / Shutdown AC Power Supplies)

"* Hardened Wetwell Vent System - BWR 2, 3, and 4 plants with Mark I Containment Table 4 4)

List of Risk-Significant BWR Systems/Components* During Shutdown (MODE

"* Diesel Generators (including other Emergency / Shutdown AC Power Supplies)

"* Residual Heat Removal System

  • Including systems supporting the OPERABILITY of the listed systems.

DRAFT FOR NRC COMMENT ATTACHMENT 2 B&W Owners Group Qualitative Risk Assessment for Increased Flexibility in MODE Restraints

DRAFT FOR NRC COMMENT B&WOG Qualitative Risk Assessment for Increased Flexibility in MODE Restraints Table 4 Results of B&WOG Systems "More" Imnortant Assessment To Enter Plant Systems More Important' Operating Mode 5 DHR EDG (hydro-electric units for Oconee]

4 DHR EDG [hydro-electric units for Oconee]

3 EDG [hydro-electric units for Oconee]

2 EDG [hydro-electric units for Oconee]

I EFW2 EDG [hydro-electric units for Oconee]

Notes:

I. Includes systems supporting the operation of the systems listed in this column.

2. In Modes 5, 4, 3 and 2, EFW is not as important because of the availability of other multiple separate systems to supply feedwater to the SGs. Other systems include multiple condensate and main feedwater systems (some plants also have additional SG feed systems available).

PAGE- 14 10/1/01 DATE: 10/1/01 PAGE - 14

DRAFT FOR NRC COMMENT ATTACHMENT 3 CEOG Qualitative Risk Assessment for Relaxation of MODE Entry Restraints

CE-NPSD- 1207 Table 4*,**

Candidate Systems and Components Exempted from 3.0.4 Relaxation System/Component ENTERING MODE 1 2 3 4 5 (Startup) (Hot Standby) (Hot (Cold Shutdown) Shutdown)

SDC Component Not Component Not Component Not Component Not Relaxation Not Required Required Required Required Allowed LTOP/ PORVs (when used for LTOP) Component Not Component Not Component Not Component Not Relaxation Not Required Required Required Required above Allowed Set Temperature n otherwise relaxation not -ri allowed -n EDG Relaxation Not Relaxation Not Relaxation Not Relaxation Not Relaxation Not 0 Allowed Allowed Allowed Allowed HPSI Relaxation Relaxation Relaxation allowed Relaxation Not Allowed Component Not z;U Allowed Allowed above [1700 Allowed Required PSIA] only Otherwise Relaxation Not 0 allowed AFW/EFW

  • Relaxation Not

_. Allowed Relaxation Not Allowed Relaxation Not Relaxation Not Component Not zm Allowed Allowed Required --

  • Support systems required for operability.
    • Restricted relaxation may be allowed based on results of PSA risk assessment
      • If AFW not used for heat removal relaxation is allowed Page 1 of 15

CE-NPSD-1207 ADDITIONAL INFORMATION (Do not include in table)

CE units use LPSI pumps for SDC. Availability of LPSI is important to the robustness of the SDC system.

HPSI is required in mode 4 as the only inventory makeup capability for a flow diversion event. HPSI is also required in mode 3 <

1700 psia LCO relaxation would result in total HPSI system unavailability since the LCO does not require 2 HPSIs for Operability..

Hence no relaxation recommended.

"n

--I

"-nl 0

z;Ui 0

00 m

z Page 2 of 15

DRAFT FOR NRC COMMENT ATTACHMENT 4 WOG Qualitative Risk Assessment Supporting Increased Flexibility in MODE Restraints

Table 4 SU~mmrv nf Mn~d- Chan a I*.iql'*t r2 To Enter Plant OperatingEnteMod To~,r Operating Mode Plant Limitations to Enter Plant Operating Mode 5 0 Two trains of RIIR available, one train of RHR in service 0 Cold overpressure protection system in service 0 EDGs available

  • The systems supporting the operation of the above systems 4
  • AFW system available (consistent with the plant specific Technical Specifications and only if dependent on AFW for startup)
  • High head safety injection available
  • Cold overpressure protection system in service 0
  • The systems supporting the operation of the above systems ---t 3

q

  • AFW system available (only if dependent on AFW for startup) -n
  • The systems supporting the operation of the above systems 2 0 AFW system available (only if dependent on AFW for startup) z
  • The systems supporting the operation of the above systems 1 AFW system available 0
  • The systems supporting the operation of the above systems zH

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment LCO / BASES INSERTS Page 1 of 9

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment Insert 1 (LCO 3.0.4) (All Owners Groups)

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other speei k-cspecified condition in the Applicability for an unlimited period of time, or,
b. After performance of a risk evaluation, consideration of the results, determination of the acceptability of entering the MODE eh-angeor other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

Insert 2 (L-CO-SR 3.0.4) (All Owners Groups) I When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specific I condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other spee*444 specifiedecondition in the Applicability for an unlimited period of time, or, I
b. After performance of a risk evaluation, consideration of the results, determination of the acceptability of entering the MODEhane or other specified condition in the Applicability and establishment of risk management actions, if appropriate.

Page 2 of 9

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment Insert 3 (LCO 3.0.4 Bases)

When an LCO is not met, LCO 3.0.4 also allows el 'in-entering MODES or other specified conditions in the Applicability after a ;isk evaluatio.following assessment of the risk impact and determination that the impact can be managed. The risk evaluation may use quantitative, qualitative, or blended approaches, and should be.ensistent with the appro- ofihe risk evaluation will be conducted using the plant program. procedures, and criteria in place to implement 10 CFR 50.65(a)(4),

which requires that risk impacts of maintenance activities to be assessed and managed. The risk evaluations will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."

The results of the risk evaluation shall be considered in determining the acceptability of entering the MODE -e.....or other specified condition in the Applicability, and any corresponding risk management actions. Consideration will be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

A f.-*-risk_ assessment and establishment of risk management actions, as appropriate. are of

,is configuratin speeific risk- analy..; required for determination of acceptable risk for ehaiies ifentering MODES or other specified conditions in the Applicability when an LCO is not met. The elements of the risk assessment and risk management actions are included in Regulatory Guide 1.182 which addresses general guidance for conduct of the risk evaluation, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is *+aacceptable. If the.sk cf changing MODPES is dctcRainfed to be g+rcater- than ;h@ aec-eptable risk, the configur-atien specifi r-isk evaluiation m~ay be used te deateFRmine the FiSl im:pact, and thle Aeed for risk mngmn cin saporae

.which miay include changing, MODE~S.

A quantitative, qualitative, or blended risk evaluation 4hR%4-must be performed to assess the risk impact of entering the MODE e-ang&or other specified condition in the Applicability, based on the specific plant configuration at that time and the risk impacts must be managed in accordance with the assessment results.

This quantitative, qua.itative, or- bleded risk evalu.ation. shul.d take into acc.t thc im.pact o iniiain eent frequency an4d in~itig-ation ea-pability as efintion of plant MODPE. Pfrcmf such evauatons sytem/coponntscanbe denifid wcseunaai~bi~'r-esults in an equial or- gre@ater Fisk imnpact in [MODES 2 5 (for- PSARs) / MOQDES 2 41 (for- BWRs;)] than in MODPE 1. Fcr-;the-se copcnnts itwould be gencr-ally aecceptable te uatilize the LCO9 ;.0.4 eEceptions.-From sysems generic evaluations, systems/components can be identified which are equally or more important to risk in MODE 1than in the transition MODES. The Technical Specifications allow continued operation with this equipment unavailable during MODE Ioperation for the duration of the Completion Time.

Since this is allowable, and since the risk impact bounds the risk of transitioning up in MODE and Page 3 of 9

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment

.entering the Conditions and Required Actions. the use of the LCO 3.0.4 allowance for these systems should be generally acceptable, as long as the risk is assessed and managed as stated above. However, t-there is a small subset of systems that have been generically determined to be more important to risk in [MODES 2 - 5 (for PWRs) / MODES 2 - 4 (for BWRs)] and do not typically have-meet the LCO 3.0.4 ,ýEeep;*iaowaniceQ 44ed. The Bases of each*,ITS Ut EG ontain tThis Fspee4*e-genenc were-SgF-p-elist is provided below.

The 4ehe-9

.pp.iebi...ty-Aphlicabilitv should be reviewed with respect to the actual plant configuration at that time. Each individual application of LCO 3.0.4.b. whether due to one or more than one LCO 3.0.4.b allowance at the same time, is required to be Entyit mr hn n C

' .b *eceptin at the sa.... time would be evaluated under the auspices of 10 CFR 50.65.-ah4) and

.Q0.

consideration of risk management actions discussed in Regulatory Guide 1.182. To apply-utilize the LCO 3.0.4.b eieep eiallowance to plant systems/components identified in the Bases list below as potentially higher risk than for MODE 1 operation, a plao-documented specific justification would be required.

The LCO 3.0.4 exeeptie*-allowance typically only applies to systems and components. The values and parameters of the Technical Specifications that have their own respective LCOs (e. a.. Containment Air Temperature. Containment Pressure. MCPR, Moderator Temperature Coefficient, etc.) are typically not addressed by this LCO 3.0.4.b allowance, and the list cf the i,'aiii and par-ameter- cxc his ions arc found inf liccnsee contrelmlcd dou~maents.

nrt ddrssfiedibilith beynidt LCOalloanc.3.0.14.b Some plants may ha'e had apprvcrd fore LCO 3ar eciceptiefls anid application m:ay be juastified using plant; specific- justifiation to be retainRed along with the gen:eric LC 3.0.4.

In order to support the conduct of the appropriate assessments, each Owners Group has performed an evaluation to identify plant systems or components which are more important to risk in the transition MODES than in MODE 1. These systems are listed in the following table.

I Page 4 of 9

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment FSystem Table for BWR/41 System* MODE or Other Specified Con dition in the Applicability I High Pressure Coolant Injection 1,2 (HPCI) System (BWR 3 and 4 plants)

Reactor Core Isolation Cooling 1, 2 (RCIC) System (BWR 3 and 4 plants)

Isolation Condenser (BWR 2 1, 2 plants)

Diesel Generators. including 1, 2, 3, 4 Emergency / Shutdown AC Power Supplies Hardened Wetwell Vent System 1, 2, 3,-4 Residual Heat Removal System 4

  • Includina systems supporting the OPERABILITY of tie listed systems.

II Page 5 of 9

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment

[System Table for BWR/61 System MODE or Other Specified Condition in the Applicability I High Pressure Core Spray 1,2 (HPCS) (BWR 5 and 6 plants)

Reactor Core Isolation Cooling 1,2 (RCIC) System (BWR 5 and 6 plants)

Diesel Generators. including 1,2,3,4 Emergency / Shutdown AC Power Supplies Hardened Wetwell Vent System 1,2,3-,4 I Residual Heat Removal System 4

  • Including systems supporting the OPERABILITY of the listed systems.

[System Table for BWOG]

System7 MODE or Other Specified Condition in the Applicability II EDG (Hydro-electric units for L2,3,4,5 Oconee)

L-P-DHR 4,5 EFW 12-,-4 Including systems supporting the OPERABILITY of the listed systems.

Page 6 of 9

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment

[System Table for CEOG]

I System*

AFF a**d AG,r DC P.we.

MODE or Other Specified Condition in the Applicability 3*4 I

Spet...."ng' AFWýHPSI Emergency Diesels z .P... 4,5 AF-WLTOP / PORVs (when used for LTOP)

Emergency Diesels Generators 51,2.3 4 5 I Turbine D*rvei. AF*V?

PtWAFW / EFW 5

SDC Including systems supporting the OPERABILITY of the listed systems.

    • Below 1700 psia.

[System Table for WOG]

System* MODE or Other Specified Con dition in the Applicability I RCS Loops (RHR) 5 LTOP System 4,5-,6 ECCS Shutdown (ECCS High 4 Head Subsystem)

AFW System 1, 2*.,3** 4**

AC Sources (Diesel Generators) 1, 2, 3, 4, 5,6 "Includingsystems supporting the OPERABILITY of the listed systems.

    • If dependant upon AFW for startup.

Page 7 of 9

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment rThe following is applicable to all NUREGs]

NUMARC 93-01. "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants:" states that the rigor of the risk analysis should be commensurate with the risk impact of the proposed configuration. For unavailable plant systems or components listed on the above table, a plant MODE change has been determined, through generic evaluation, to result in a potential risk increase. The rigor of the risk analysis performed to support use of LCO 3.0.4.b should reflect this result, and risk management actions should be employed accordingly. Further. when plant systems or components in the of the above table are unavailable (or otherwise inoperable), use of LCO 3.0.4.b requires documentation risk assessment and associated risk management actions.

For unavailable plant systems or components not appearing in the above table. proposed plant MODE changes will generally not involve a risk increase greater than the system or component being unavailable in MODE 1. The risk assessment performed to support use of LCO 3.0.4.b for systems or components not appearing on the above table must meet all considerations of NUMARC 93-01. but need not be documented.

LCO 3.0.4.b may be used with single, or multiple systems or components unavailable. NUMARC 93-01 provides guidance relative to consideration of simultaneous umavailabilitv of multiple systems or components.

Page 8 of 9

DRAFT FOR NRC COMMENT TSTF-359, Rev. 6 - Draft for NRC Comment Insert 4 (SR 3.0.4 Bases) (All Owners Groups)

A provision is included to allow entry into a MODE or other specified condition in the Applicability:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specific condition in the Applicability for an unlimited period of time, for,
b. After performance of a risk evaluation, consideration of the results, determination of the acceptability of the MODE change, and establishment of risk management actions, if appropriate.1 Page 9 of 9

Preliminary Description Paper Risk-Informed Technical Specifications Initiative 4B The purpose of this paper is to describe the general considerations in establishing a risk informed process to supplement the existing technical specification allowed outage times for systems/equipment with a configuration risk management approach.

Configuration risk management One fundamental purpose of tech specs is to provide plant configuration control.

Plants are designed with multiple redundant systems, and supporting systems to accomplish safety functions in accordance with the plant design basis and accident analysis as contained in the FSAR. Tech specs place limits on the times that systems, or supporting systems can be out of service, and establish actions that must be taken (often leading to plant shutdown) in the event these time limits are not met. Tech specs are not risk-informed, in that the allowed outage times do not typically have a risk basis, each out of service condition is considered independently, and few limits are imposed on the number of times an out of service condition can be entered.

The requirements of the maintenance rule impose additional constraints on equipment out of service times (unavailability). These requirements are more risk informed, in that they address unavailability of a train or piece of equipment over a period of time. Plant maintenance generally involves temporary impacts on equipment availability that are balanced by increased reliability. The maintenance rule requires availability of risk-significant equipment to be balanced with reliability, through the use of PSA insights. This has the effect of establishing availability targets for important equipment in accordance with those values assumed in the PSA.

In November 2000, a risk-informed plant configuration control provision was added to the maintenance ride, 10 CFR 50.65, requiring assessment and consideration of risk prior to performance of both online and shutdown maintenance. Industry developed guidance to accompany this rulemaking through a revision to the maintenance rule implementation guideline. That document, NUMARC 93-01, revision 3, provides guidance on the use of quantitative probabilistic safety assessment (PSA), qualitative risk assessment, and plant operating experience to assessplant risk due to maintenance activities. It also provides guidance on actions that may be taken to manage the risk as determined by the assessment. The guidance also incorporates the shutdown risk management approach of NUMARC 91-06, which is based on preservation of key shutdown safety functions.

Page 1 October 12, 2001 Enclosure 6

It is recognized that the configuration control requirements of technical specifications (deterministic) and the maintenance rule (risk informed) may be in conflict; however, the licensee is required to comply with both, resulting in limitations on configuration control flexibility that are unrelated to plant safety.

The intent of this initiative is to address the incompatibilities between these methods, and provide a single, consistent approach for plant configuration control.

The scope of this initiative is limited to those action requirements and limiting conditions for operation that address configuration and operability of plant equipment, and are thus amenable to a risk assessment process. Existing technical specification actions and limiting conditions relative to plant parameters, such as fuel limits, pressure limits, or power-flow distribution maps, would not be affected.

Further, this initiative applies to systems, components, and equipment that are explicitly addressed by technical specifications. Initiative 7 addresses the treatment of design features that are implicitly captured into technical specifications through the definition of OPERABILITY.

The intent of this initiative is to address situations where the train or system is unavailable, or the equipment's primary safety function is degraded (e.g. a IIPSI injection valve is out of service, but the other active components of the system are available). Initiative 7 is intended to address situations where design features required for low probability initiating events are degraded, but the system's primary safety function is maintained. This would allow deferral of entrance into the Limiting Condition for Operation (LCO) for a specific time frame.

General guidelines of approach:

1. The existing AOTs and action requirements of tech specs would be retained.
2. An option will be added to use a configuration risk management approach to extend the AOT and undertake risk management actions as appropriate.
3. The risk assessment and management approach would be in accord with the guidelines of NUMARC 93-01, with additions as detailed below.
4. A backstop AOT will be developed, which cannot be exceeded regardless of the results of tl~e risk analysis.

Explanation Attachment 1 provides a draft tech spec page illustrating the format of the approach.

A planned maintenance condition may result in equipment either being removed from service, or rendered inoperable due to a degradation of the equipment's Page 2 October 12, 2001

function such that it no longer meets the tech spec operability definition. This results in entrance into the limiting condition for operation.

Following the determination of inoperability, the tech spec ACTIONS must be entered, and a risk assessment must be performed in accordance with the maintenance rule (a)(4) guidance. Risk management actions are also established in accordance with the (a)(4) guidance. These actions could include the need to perform a mode change prior to expiration of the Tech Spec AOT. The above combination of actions, which is the same as is currently in use, provides appropriate control of plant configuration risk up until the expiration of the AOT.

The configuration risk management approach would optionally entered upon expiration of the existing AOT (frontstop).

Under the proposed approach, the licensee may make the decision to utilize the configuration risk management option to extend the AOT. This entails performance of an enhanced risk assessment in accordance with the description below. The risk assessment and determination of risk management actions must be completed prior to expiration of the existing AOT (frontstop). The risk management actions must be established prior to expiration of the frontstop.

A backstop AOT limit is implemented for all tech spec systems/equipment within the scope of this initiative. In no case can the AOT exceed the backstop limit. This is further explained below.

In the event of an emergent condition (as described in NUMARC 93-01), the enhanced risk assessment and associated risk management actions must be re evaluated in a timely manner. Revised risk management actions must be in place within a timely manner.

Flexible AOT risk assessment and management The flexible AOT assessment would include all provisions of the existing (a)(4) implementation guidance, with the following additions:

1. The assessment would require, as a minimum, a quantitative assessment using a level one internal events PSA and simplified LERF model for power operation.
2. All elements of the level one PSA must meet the minimum attributes for a risk-informed application when evaluated by a peer review team in accordance with NEI 00-02, industry peer review guidance document, or "conditional" grades must be resolved.

Page 3 October 12, 2001

3. The PSA should be evaluated for update (model update and data update) on a minimum interval of two refueling cycles. Modifications to the plant resulting in non-minimal risk effects (changes to baseline risk, or changes to distribution of significant equipment or actions) must be reflected in the PSA, or otherwise accommodated in the risk assessment process, within X weeks.
4. The risk-informed decisionmaking process should have the capability to model the real time plant configuration, and calculate the configuration specific CDF and LERF. That is, it should use the "zero maintenance" model, and be capable of timely requantification to address emergent conditions.
5. The assessment must consider instantaneous risk, integrated risk for a given configuration, and aggregate risk as discussed in NUMARC 93-01. The quantitative guidelines for each of these parameters are specified in NUMARC 93-01.
6. Explicit risk management actions (e.g., mode change, compensatory measure) based on the above quantitative guidelines, and other qualitative PSA and risk insights, may be developed and documented in advance for anticipated combinations of equipment with more significant risk impacts.
7. Regardless of the risk assessment outcome, planned maintenance activities must not be performed that would render both trains of a safety system inoperable at the same time. Emergent conditions may allow this situation for a limited time, based on the outcome of the assessment and management actions.
8. The assessment, results, and associated risk management actions must be documented and available for subsequent NRC audit or inspection.

Backstop AOT A tech spec not-to-exceed value for each AOT subject to this initiative would be provided. This AOT would be referred to as the "backstop AOT", which could never be exceeded regardless of the risk evaluation results. For systems with very low risk impact, the backstop AOT provides for return to a configuration as described in the deterministic accident analysis, and obviates plant "modifications" involving very long allowed outage times.

The backstop is in place to address deterministic considerations. It is not necessary that the backstop AOT be derived from risk analyses. The risk assessment and management process required to utilize any portion or all of the backstop AOT is complete and self sufficient with regard to consideration of risk. Further, if a backstop value were to be derived from risk analyses (e.g., use of a Reg Guide 1.177 Page 4 October 12, 2001

approach to calculate ICDP, etc) it would have to be based on specific assumptions with regard to the degree of degradation of the equipment. Typically a Reg Guide 1.177 evaluation assumes the equipment is out of service; however, for many anticipated conditions, the equipment could still be partially functional, and a backstop AOT calculated based on out of service equipment would preclude proper consideration of the actual equipment performance capability in the risk assessment and management process.

The backstop AOT would typically be 30 days. Individual exceptions may be identified.

Page 5 October 12, 2001

ATTACHMENT 1 INITIATIVE 4B CONCEPT GENERIC RISK INFORMED AOT'S WITH A BACKSTOP EXAMPLE FORMAT A rrTTINT CONDITION I REQUIRED ACTION : COMPLETION TIME I [Current Front Stop AOT A. One required A. 1. Restore required

[subsystem, component] inoperable [subsystem, (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, 7 days)]

inoperable. component] to OPERABLE status, OR A.2.1. Determine that the [Current Front Stop AOT configuration is acceptable (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, 7 days)]

for Completion Time extension beyond the [Front Stop AOT] but not to exceed 30 days, AND A.2.2. Determine that the [Continuously]

configuration is acceptable for continued operation beyond the [Front Stop AOT],

AND A.2.3. Restore required [Acceptable Completion inoperable [subsystem, Time Extension or Back component] to OPERABLE Stop AOT, Whichever is status. Lessi I

B. Required Action and B.l. [Be in MODE [3] or [12 hours]

associated Completion other appropriate Time not met. compensatory action consistent with the level of degradation.]

DRAFT FORMAT

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