ML21069A172
| ML21069A172 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 03/24/2021 |
| From: | Victor Cusumano NRC/NRR/DSS/STSB |
| To: | Technical Specifications Task Force |
| Honcharik, M., NRR/DSS, 301-415-1774 | |
| Shared Package | |
| ML21069A190 | List: |
| References | |
| EPID L-2020-PMP-0005 | |
| Download: ML21069A172 (8) | |
Text
1 2
3 4
5 6 General Directions: This model safety evaluation (SE) provides the format and content for an 7 SE of license amendment requests to adopt TSTF-577, Revision 1 using the Consolidated Line 8 Item Improvement Process The [bolded bracketed] information shows text that should be 9 filled in for the specific amendment. The italicized wording provides guidance on what should 10 be included in each section.
11 DRAFT MODEL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO TSTF-577, REVISION 1 AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX-XX]
AND AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX-XX]
[NAME OF LICENSEE]
[NAME OF FACILITY]
DOCKET NOS. 50-[XXX] AND 50-[XXX]
Application (i.e., initial and supplements) Safety Evaluation Date
- [Date], [ADAMS Accession No.] [Date]
Principal Contributors to Safety Evaluation
- [Caroline Tilton]
12 13
1.0 PROPOSED CHANGE
S 14 15 [Name of licensee] (the licensee) requested changes to the technical specifications (TSs) for 16 [name of facility] by license amendment request (application). In its application, the licensee 17 requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) process the 18 proposed amendment under the Consolidated Line Item Improvement Process (CLIIP). The 19 proposed changes would revise the Steam Generator (SG) Program and the Steam 20 Generator Tube Inspection Report TSs based on Technical Specifications Task Force (TSTF) 21 Traveler TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections 22 (TSTF-577) (Agencywide Documents Access and Management System (ADAMS) Accession 23 No. ML21060B434), and the associated NRC staff safety evaluation (SE) of TSTF-577 (ADAMS 24 Accession No. MLXXXXXXXXX).
25 26 The tubes within an SG function as an integral part of the reactor coolant pressure boundary 27 and, in addition, isolate fission products in the primary coolant from the secondary coolant and 28 the environment. SG tube integrity means that the tubes are capable of performing this safety 29 function in accordance with the plant design and licensing basis.
30 31 {NOTE. Choose the type of alloy tubing in the plants SGs from the bracketed information. Units 32 may have SGs with different alloy tubing materials (for example, one unit with SGs with Alloy Enclosure [x]
1 600MA and another with SGs with Alloy 600TT). Repeat the second sentence below for each 2 unit.}
3 4 [Name of facility] has [X] unit[s]. The Unit [1] SGs have [Alloy 600 mil-annealed (Alloy 5 600MA), Alloy 600 thermally treated (Alloy 600TT), or Alloy 690 thermally treated (Alloy 6 690TT)] tubes.
7 8 1.1 Proposed TS Changes to Adopt TSTF-577 9
10 In accordance with NRC staff-approved TSTF-577, the licensee proposed changes that would 11 revise [name of facility] TS [5.5.9], Steam Generator (SG) Program, and TS [5.6.7], Steam 12 Generator Tube Inspection Report. Specifically, the licensee proposed the following changes 13 to adopt TSTF-577:
14 15 TS [5.5.9], Steam Generator (SG) Program:
16 17
- TS 5.5.9.d.2 would be revised by deleting the requirement to base inspection frequency 18 on the more restrictive metric between either the effective full power months (EFPM) or 19 refueling outage and to use just the EFPM metric.
20
- TS 5.5.9.d.2 would be revised by deleting the allowance to extend the inspection period 21 by 3 months and by deleting the discussion of prorating inspections.
22
- TS 5.5.9.d.3 would be revised by adding that each SG inspected at the next inspection 23 after crack indications are found, includes each affected and potentially affected SG.
24 The next inspection after crack indications are found would be changed from shall not 25 exceed 24 effective full power months or one refueling outage (whichever results in more 26 frequent inspections) to shall be at the next refueling outage.
27 28 {NOTE: The following bullet is only applicable for plants that have Alloy 600MA tubing.}
29
- TS 5.5.9.d.2 would be revised by changing the requirement to inspect 100 percent of the 30 tubes from every 60 EFPM to every 24 EFPM.
31 32 {NOTE: The following bullets are only applicable for plants that have Alloy 600TT tubing.}
33
- TS 5.5.9.d would be revised by adding a phrase regarding portions of the tube that are 34 exempt from inspection by alternate repair criteria.
35
- TS 5.5.9.d.2 would be revised by changing the requirement to inspect 100 percent of the 36 tubes at periods of 120, 90, and 60 EFPM to 54 EFPM. A 72 EFPM inspection period 37 would be permitted if SG tubing has never experienced cracking (not including regions 38 exempt from inspection by alternate repair criteria) and the SG inspection was 39 performed with enhanced probes. A description of the enhanced probe inspection would 40 be added.
41
- TS 5.5.9.d.3 would be revised by adding a phrase regarding portions of the tube that are 42 exempt from inspection by alternate repair criteria. An additional phrase would be added 43 that permits deferring SG inspections after cracking indications are found if the 44 100 percent inspection was performed with enhanced probes.
45
1 {NOTE: The following bullet is only applicable for plants that have Alloy 690TT tubing.}
2
- TS 5.5.9.d.2 would be revised by deleting the requirement to inspect 100 percent of the 3 tubes during each period in paragraphs d.2.a, d.2.b, d.2.c, and d.2.d (144, 120, 96, and 4 72 EFPM, respectively) and by adding the requirement to inspect 100 percent of the 5 tubes every 96 EFPM.
6 7 TS [5.6.7],Steam Generator Tube Inspection Report:
8 9
- Existing reporting requirement b. would be renumbered as c. and be revised by editorial 10 and punctuation changes.
11
- New reporting requirement b. would be added to require the nondestructive examination 12 (NDE) techniques utilized for tubes with increased degradation susceptibility be 13 reported.
14
- Existing reporting requirement c. would be renumbered as c.1. and be revised by 15 editorial and punctuation changes.
16
- Existing reporting requirement d. would be renumbered as c.2. and be revised to note 17 that the location, orientation (if linear), measured size (if available), and voltage 18 response do not need to be reported for tube wear indications at support structures that 19 are less than 20 percent through-wall. However, the total number of tube wear 20 indications at support structures that are less than 20 percent through-wall would be 21 reported.
22
- New reporting requirement d. would be added to require an analysis summary of the 23 tube integrity conditions predicted to exist at the next scheduled inspection relative to the 24 applicable performance criteria, including the analysis, methodology, inputs, and results.
25
- Existing reporting requirement e. would be renumbered as c.4. and be revised by 26 editorial and punctuation changes.
27
- Existing reporting requirements f. and h. would be combined, be renumbered as e., and 28 be revised by editorial and punctuation changes.
29
- New reporting requirement f. would be added to require the results of any SG secondary 30 side inspections be reported.
31
- Existing reporting requirement g. would be renumbered as c.3. and be revised to add the 32 requirements to report the margin to the tube integrity performance criteria and a 33 comparison with the margin predicted to exist at the inspection by the previous 34 forward-looking tube integrity assessment. In addition, the requirement to report the 35 results of tube pulls and in-situ testing would be deleted.
36
- New reporting requirement g. would require any plant-specific reporting requirements, if 37 applicable.
38
- Existing reporting requirement h. would be renumbered as c.5. and be revised by 39 editorial changes.
40
1 1.2 Additional Proposed TS Changes 2
3 {NOTE: Use this section if variations are proposed. Add additional subsections if needed.
4 Editorial variations discussed below in Section 1.2.1 do not warrant removal from the CLIIP and 5 do not require any additional technical branches to be on the review.}
6 7 1.2.1 Editorial Variations 8
9 {NOTE: Use this section if the plant has different numbering/nomenclature or modify 10 accordingly for other editorial changes made.}
11 12 The licensee noted that [name of facility] TSs have different numbering [and nomenclature]
13 than standard technical specifications (STSs).
14 15
2.0 REGULATORY EVALUATION
16 17 The regulations in Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.36(c)(5),
18 Administrative controls, state that [a]dministrative controls are the provisions relating to 19 organization and management, procedures, recordkeeping, review and audit, and reporting 20 necessary to assure operation of the facility in a safe manner. Each licensee shall submit any 21 reports to the Commission pursuant to approved technical specifications as specified in 22 [10 CFR] 50.4. Technical Specification Section 5.0, Administrative Controls, requires that an 23 SG Program be established and implemented to ensure that SG tube integrity is maintained.
24 Programs established by the licensee, including the SG Program, are listed in the administrative 25 controls section of the TS to operate the facility in a safe manner.
26 27 The NRC staffs guidance for the review of TSs is in NUREG-0800, Standard Review Plan for 28 the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor]
29 Edition (SRP), Chapter 16.0, Technical Specifications, Revision 3, dated March 2010 30 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory 31 standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs.
32 Accordingly, the NRC staffs review includes consideration of whether the proposed changes 33 are consistent with [insert applicable NUREG from list in footnote],1 as modified by 34 NRC-approved travelers.
35 36 TSTF-577 revised the STSs related to SG tube inspections and SG tube inspection reporting 37 requirements. The NRC approved TSTF-577, under the CLIIP on [Month Day, 2021 (ADAMS 38 Package Accession No. TBD)].
39 1 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Babcock and Wilcox Plants, NUREG-1430, Volume 1, Specifications, and Volume 2, Bases, Revision 4, April 2012 (ADAMS Accession Nos. ML12100A177 and ML12100A178, respectively).
U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse Plants, NUREG-1431, Volume 1, Specifications, and Volume 2, Bases, Revision 4, April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively).
U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Combustion Engineering Plants, NUREG-1432, Volume 1, Specifications, and Volume 2, Bases, Revision 4, April 2012 (ADAMS Accession Nos. ML12102A165 and ML12102A169, respectively).
1
3.0 TECHNICAL EVALUATION
2 3 3.1 Proposed TS Changes to Adopt TSTF-577 4
5 The NRC staff compared the licensees proposed TS changes in Section 1.1 of this SE against 6 the changes approved in TSTF-577. In accordance with SRP Chapter 16.0, the NRC staff 7 determined that the STS changes approved in TSTF-577 are applicable to the [name of 8 facility] TSs because [name of facility] is a PWR design plant and the NRC staff approved the 9 TSTF-577 changes for PWR designs. The NRC staff finds that the licensees proposed 10 changes to the [name of facility] TSs in Section 1.1 of this SE are consistent with those found 11 acceptable in TSTF-577.
12 13 In the SE of TSTF-577, the NRC staff concluded that the TSTF-577 changes to STS 5.5.9, 14 Steam Generator (SG) Program, and STS 5.6.7, Steam Generator Tube Inspection Report, 15 were acceptable because, as discussed in Section 3.0 of that SE, they continued to ensure SG 16 tube integrity and, therefore, protected the public health and safety. In particular, the structural 17 integrity performance criterion and accident-induced leakage performance criterion (explained in 18 STS 5.5.9.b, items 1 and 2, respectively) will continue to be met with the proposed revised SG 19 inspection intervals (maximum allowable time between SG inspections) and inspection periods 20 (maximum allowable time between 100 percent of SG tubes inspections). Additionally, the 21 proposed changes to the reporting requirements will provide more detailed and consistent 22 information to the NRC. Therefore, the NRC staff found that the proposed changes to the SG 23 program and inspection reporting requirements were acceptable because they continued to 24 meet the requirements of 10 CFR 50.36(c)(5) by providing administrative controls necessary to 25 assure operation of the facility in a safe manner. For these same reasons, the NRC staff 26 concludes that the corresponding proposed changes to the [name of facility] TSs in Section 27 1.1 of this SE continue to meet the requirements of 10 CFR 50.36(c)(5).
28 29 3.2 Additional Proposed TS Changes 30 31 {NOTE: Use this section if variations are proposed. Add additional subsections if needed.}
32 33 3.2.1 Editorial 34 35 {NOTE: Use this section if the plant has different numbering/nomenclature or modify 36 accordingly for other editorial changes made.}
37 38 The licensee noted that the [name of facility] TSs have different numbering [and 39 nomenclature] than the STS. The NRC staff finds that the different TS numbering [and 40 nomenclature] changes are acceptable because they do not substantively alter TS 41 requirements.
42 43 Finally, the NRC staff reviewed the proposed TS changes for technical clarity and consistency 44 with the existing requirements for customary terminology and formatting. The NRC staff finds 45 that the proposed changes are consistent with SRP Chapter 16.0 and, therefore, are 46 acceptable.
47 48
4.0 CONCLUSION
49 50 The Commission has concluded, based on the considerations discussed above, that: (1) there 51 is reasonable assurance that the health and safety of the public will not be endangered by
1 operation in the proposed manner, (2) there is reasonable assurance that such activities will be 2 conducted in compliance with the Commissions regulations, and (3) the issuance of the 3 amendment will not be inimical to the common defense and security or to the health and safety 4 of the public.
5
NOTICES AND ENVIRONMENTAL FINDINGS RELATED TO AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX-XX]
AND AMENDMENT NO. [XXX] TO FACILITY OPERATING LICENSE NO. [XXX-XX]
[NAME OF LICENSEE]
[NAME OF FACILITY]
DOCKET NOS. 50-[XXX] AND 50-[XXX]
Application (i.e., initial and supplements) Safety Evaluation Date
- [Date], [ADAMS Accession No.] [Date]
1.0 INTRODUCTION
The PM should prepare this required section.
[Name of licensee] (the licensee) requested changes to the technical specifications (TSs) for
[name of facility] by license amendment request (application). In its application, the licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP). The proposed changes would revise the Steam Generator (SG) Program and the Steam Generator Tube Inspection Report TSs based on Technical Specifications Task Force (TSTF)
Traveler TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections (TSTF-577) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21060B434), and the associated NRC staff safety evaluation (SE) of TSTF-577 (ADAMS Accession No. MLXXXXXXXXX).
2.0 STATE CONSULTATION
The PM should prepare this required section.
In accordance with the Commissions regulations, the [Name of State] State official was notified of the proposed issuance of the amendment on [insert date]. The State official had [no]
comments. [If comments were provided, they should be addressed here].
3.0 ENVIRONMENTAL CONSIDERATION
The PM should prepare this required section.
The amendment relates, in part, to changes in recordkeeping, reporting, or administrative procedures or requirements. The amendment also relates, in part, to changing requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding Enclosure [x]
that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on [Month Day, Year (XX FR XXX)]. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.