ML23269A151

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Draft Model SE of TSTF-591, Revision 0, Revise Risk-Informed Completion Time (RICT) Program
ML23269A151
Person / Time
Site: Technical Specifications Task Force
Issue date: 09/26/2023
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NRC/NRR/DSS/STSB
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Download: ML23269A151 (9)
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1 2

3 4 General Directions: This model SE provides the format for an SE of LARs to adopt traveler 5 TSTF-591. TSTF-591 was approved as part of the CLIIP. This model SE can also be used as a 6 template for LARs adopting TSTF-591 that have significant variations and are not using the 7 CLIIP. The [bolded bracketed] information shows text that should be filled in for the specific 8 amendment. The italicized wording provides guidance on what should be included in each 9 section.

DRAFT MODEL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO TSTF-591, REVISE RISK-INFORMED COMPLETION TIME (RICT) PROGRAM 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

  • [Andrea Russell]

10 11

1.0 PROPOSED CHANGE

S 12 13 [Name of licensee] (the licensee) requested changes to the technical specifications (TSs) for 14 [name of facility] by license amendment request (LAR, application). In its application, the 15 licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) 16 process the proposed amendment under the Consolidated Line Item Improvement Process 17 (CLIIP). The proposed changes would revise the TS based on Technical Specifications Task 18 Force (TSTF) Traveler TSTF-591, Revision 0, Revise Risk-Informed Completion Time (RICT) 19 Program (TSTF-591) (Agencywide Documents Access and Management System (ADAMS) 20 Accession No. ML22081A224), and the associated NRC staff safety evaluation (SE) of 21 TSTF-591 (ML23262B230).

22 23 The proposed changes would revise the TS Section 5.5 Program, Risk Informed Completion 24 Time Program, by referencing RG 1.200, Revision 3, instead of Revision 2. The proposed

1 changes would also add a requirement in TS Section 5.6, Reporting Requirements for the 2 licensee to submit a report to the NRC before calculating a RICT using an NDM.

3 4 Description of Risk-Informed Completion Time Program 5

6 The TS LCOs are the lowest functional capability or performance levels of equipment required 7 for safe operation of the facility. When an LCO is not met, the licensee must shut down the 8 reactor or follow any remedial or required action (e.g., testing, maintenance, or repair activity) 9 permitted by the TSs until the condition can be met. The remedial actions (i.e., ACTIONS) 10 associated with an LCO contain Conditions that typically describe the ways in which the 11 requirements of the LCO can fail to be met. Specified with each stated Condition are Required 12 Action(s) and CTs. The CTs are referred to as the front stops in the context of this SE. For 13 certain Conditions, the TS require exiting the Mode of Applicability of an LCO (i.e., shutdown the 14 reactor).

15 16 The Topical Report NEI 06-09-A (ML12286A321) provides a methodology for extending existing 17 CTs and thereby delay exiting the operational mode of applicability or taking Required Actions if 18 risk is assessed and managed within the limits and programmatic requirements established by a 19 RICT Program.

20 21 1.1 Proposed TS Changes to Adopt TSTF-591 22 23 TS 5.5.[20] Risk Informed Completion Time Program 24 25 TS 5.5.[20], which describes the RICT program, is revised. Existing paragraph e would be 26 replaced with the paragraph e below. Paragraphs f and g would be added.

27 28 e. A RICT calculation must include the following hazard groups: [list 29 specific hazards and the associated PRA models or alternate means 30 of assessing the hazard for each applicable hazard group approved 31 by NRC. For example, internal flood and internal events PRA model, 32 internal fire PRA model, and seismic penalty factor]. Changes to 33 these means of assessing the hazard groups require prior NRC approval.

34 35 f. The PRA models used to calculate a RICT shall be maintained and 36 upgraded in accordance with the processes endorsed in the regulatory 37 positions of Regulatory Guide 1.200, Revision 3, "Acceptability of 38 Probabilistic Risk Assessment Results for Risk-Informed Activities."

39 40 g. A report shall be submitted in accordance with Specification 5.6.[X]

41 before a newly developed method is used to calculate a RICT.

42 43 TS 5.6.[8], Risk Informed Completion Time Program Upgrade Report 44 45 A new specification, TS 5.6.[8], would be added as follows:

46 47 Risk Informed Completion Time (RICT) Program Upgrade Report 48 49 A report describing newly developed methods and their implementation must be 50 submitted following a probabilistic risk assessment (PRA) upgrade associated

1 with newly developed methods and prior to the first use of those methods to 2 calculate a RICT. The report shall include:

3 4 a. The PRA models upgraded to include newly developed methods; 5

6 b. A description of the acceptability of the newly developed methods 7 consistent with Section 5.2 of PWROG-19027-NP, Revision 2, "Newly 8 Developed Method Requirements and Peer Review;"

9 10 c. Any open findings from the peer-review of the implementation of the 11 newly developed methods and how those findings were dispositioned; 12 and 13 14 d. All changes to key assumptions related to newly developed methods or 15 their implementation.

16 17 1.2 Additional Proposed TS Changes 18 19 {NOTE: Use this section if variations are proposed. Add additional subsections if needed.

20 Editorial variations discussed below in section 1.2.1 do not warrant removal from the CLIIP and 21 do not require any additional technical branches to be on the review. Variations discussed in 22 section 1.2.2, may remove the LAR from the CLIIP and may require additional technical review 23 depending on the significance of the variations.}

24 25 In addition to the changes proposed consistent with the traveler discussed in section 1.1, the 26 licensee proposed the variation[s] below.

27 28 1.2.1 Editorial Variations 29 30 {NOTE: Use this section if the plant has different numbering/nomenclature or modify accordingly 31 for other editorial changes made.}

32 33 The licensee noted that [name of facility] TSs have different numbering [and nomenclature]

34 than standard technical specifications (STSs).

35 36 1.2.2 Other Variations 37 38 {NOTE: Use this section if the plant has variations other than editorial variations discussed in 39 section 1.2.1.}

40 41

2.0 REGULATORY EVALUATION

42 43 2.1 Applicable Regulatory Requirements and Guidance 44 45 The regulation under Title 10 of the Code of Federal Regulations (10 CFR) 50.36(b) requires 46 that:

47 48 Each license authorizing operation of a utilization facility will include 49 technical specifications. The technical specifications will be derived from the

1 analyses and evaluation included in the safety analysis report, and amendments 2 thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; 3 technical information]. The Commission may include such additional technical 4 specifications as the Commission finds appropriate.

5 6 The categories of items required to be in the TSs are listed in 10 CFR 50.36(c).

7 8 The regulation at 10 CFR 50.36(c)(5), states that administrative controls are the provisions 9 relating to organization and management, procedures, recordkeeping, review and audit, and 10 reporting necessary to assure operation of the facility in a safe manner.

11 12 NRC Regulatory Guides (RGs) provide one way to ensure that the regulations continue to be 13 met. The NRC staff considered during its review of the proposed changes, along with industry 14 guidance endorsed by the NRC, the guidance in RG 1.200, Revision 3, Acceptability of 15 Probabilistic Risk Assessment Results for Risk-Informed Activities, December 2020 16 (ML20238B871).

17 18* NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for 19 Nuclear Power Plants: LWR [light-water reactor] Edition (SRP):

20 21

  • Chapter 19, Section 19.2, Review of Risk Information Used to Support Permanent 22 Plant-Specific Changes to the Licensing Basis: General Guidance, dated 23 June 2007 (ML071700658).

24

  • Chapter 16, Section 16.0, Technical Specifications, March 2010 (ML100351425).

25 The NRC staffs review includes consideration of whether the proposed changes 26 are consistent with the [insert applicable NUREG from list in footnote]1 27

  • Chapter 16, Section 16.1, Risk-Informed Decision Making: Technical 28 Specifications, March 2007 (ML070380228).

29 30* NEI 06-09-A, Revision 0, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed 31 Technical Specifications (RMTS) Guidelines (ML063390639), provides guidance for 32 risk-informed TS. The NRC staff issued a final SE approving NEI 06-09 on May 17, 2007 33 (ML071200238).

34 35* NEI 17-07, Revision 2, "Performance of PRA Peer Reviews Using the ASME/ANS PRA 36 Standard," provides guidance material for conducting and documenting a probabilistic risk 37 assessment (PRA) peer review using the American Society of Mechanical Engineers 38 (ASME)/American Nuclear Society (ANS) PRA Standard, issued August 2019 (ML19231A182).

1

  • NRC NUREG-1430, Standard Technical Specifications, Babcock and Wilcox Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21272A363 and ML21272A370, respectively).
  • NRC NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21259A155 and ML21259A159, respectively).
  • NRC NUREG-1432, Standard Technical Specifications, Combustion Engineering Plants, Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21258A421 and ML21258A424, respectively).
  • NRC NUREG-1433, Standard Technical Specifications, General Electric, BWR/4 Plants Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21272A357 and ML21272A358, respectively).
  • NRC NUREG-1434, Standard Technical Specifications, General Electric, BWR/6 Plants Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21271A582 and ML21271A596, respectively).

1 2* PWR Owners Group (PWROG) topical report PWROG-19027-NP, Revision 2, "Newly 3 Developed Method Requirements and Peer Review," establishes the definitions, processes, and 4 technical requirements necessary to implement newly developed methods, issued July 2020 5 (ML20213C660). RG 1.200, Revision 3, endorsed specified portions of PWROG-19027-NP.

6 7

3.0 TECHNICAL EVALUATION

8 9 3.1 Proposed TS Changes to Adopt TSTF-591 10 11 In accordance with traveler TSTF-591, the licensee proposes to replace the TS requirement to 12 maintain and upgrade2 the PRA in accordance with RG 1.200, Revision 2, with a requirement to 13 follow RG 1.200, Revision 3. RG 1.200, Revision 3, does not change the factors used to assess 14 PRA technical adequacy and acceptability. Revision 3 of RG 1.200 continues to include 15 guidance to maintain and upgrade the PRA while adding a glossary of key terms, a list of 16 hazards to be considered in the development and use of the PRA, and enhanced guidance 17 related to key assumptions and sources of uncertainty. Furthermore, RG 1.200, Revision 3, 18 does the following:

19 20

  • Endorses, with NRC staff exceptions and clarifications, the ASME/ANS RA-S Case 1, 21 Case for ASME/ANS RA-Sb-2013 Standard for Level 1/Large Early Release Frequency 22 Probabilistic Risk Assessment of Nuclear Power Plant Applications, dated 23 November 22, 2017.

24 25

  • Endorses NEI 17-07, Revision 2, Performance of PRA Peer Reviews Using the 26 ASME/ANS PRA Standard, issued August 2019.

27 28

  • Endorses the following portions of PWROG-19027-NP:

29 o Process for the peer review of NDMs, 30 o Process for determining whether a change to a PRA is classified as PRA 31 maintenance or a PRA upgrade, and 32 o Key definitions related to NDMs, PRA maintenance, and PRA upgrade.

33 34 The proposed language for TS 5.5.[20] paragraph e incorporates defined terms provided in the 35 glossary of RG 1.200, Revision 3. The NRC staff concludes that the proposed changes using 36 the defined terms provided in RG 1.200, Revision 3, do not introduce any technical 37 discrepancies for the implementation of the RICT program.

38 39 The proposed change to add paragraph f to TS 5.5.[20] incorporates a TS requirement that 40 PRA models used to calculate a RICT be maintained and upgraded in accordance with the 41 processes endorsed in the regulatory positions of RG 1.200, Revision 3. RG 1.200 Regulatory 42 Position C.2.2.2.2, states, in part:

43 44 [a]n acceptable approach to performing a peer review for an NDM is the 45 guidance in NEI 17-07, Revision 2. NEI 17-07, Revision 2, [as endorsed by RG 2

Per RG 1.200, Revision 3, PRA upgrade is defined as: A change in the PRA that results in the applicability of one or more supporting requirements that were not previously included within the PRA (e.g., performing qualitative screening for Part 4 of ASME/ANS Level 1/LERF PRA Standard when the related high-level requirement was previously not applicable, or adding a new hazard model), an implementation of a PRA method in a different context, or the incorporation of a PRA method not previously used.

1 1.200, Revision 3,] states, in part, that if an NDM is deemed not technically 2 acceptable in the NDM peer review report, or if at least one finding-level F&O on 3 the NDM remain open, a licensee or applicant may not use it in a PRA supporting 4 risk-informed licensing applications.

5 6 The report that will be submitted to the NRC staff for NDM use in the RICT program can only be 7 used to describe NDMs that are technically acceptable with all the open F&Os resulting from the 8 technical review of the NDM closed using an NRC-endorsed peer review process.

9 10 The proposed change to add paragraph g to TS 5.5.[20] incorporates a TS requirement for a 11 licensee to submit a report before an NDM is used to calculate a RICT. RG 1.200, Revision 3, 12 defines a consensus method/model as follows:

13 14 Consensus method/model: In the context of risk-informed regulatory decisions, 15 a method or model approach that the NRC has used or accepted for the specific 16 risk-informed application for which it is proposed. A consensus method or model 17 may also have a publicly available, published basis and may have been peer 18 reviewed and widely adopted by an appropriate stakeholder group.

19 20 In response to RAI 2.a, example (c) provided, the TSTF stated, [t]he appendix can be made 21 available to the NRC to be loaded on ADAMS (no formal request of review or endorsement 22 would be needed). The use of consensus method(s) by licensees is governed within the 23 guidance of RG 1.200, Revision 3. Consistent with the definition per RG 1.200, Revision 3, and 24 provided above, a consensus method/model is one that has been used or accepted by the NRC 25 for the specific risk-informed application for which it is proposed. Specifically, reporting of an 26 NDM by a licensee under the requirements stipulated in TS 5.6.[8] does not justify the NDM to 27 meet the definition of consensus/method/model for future use. Therefore, the NRC staff 28 concludes that for an NDM to be reported to the NRC under the requirements stipulated in 29 TS 5.6.[8], it is not a consensus method or model is defined in RG 1.200, Revision 3.

30 31 Consistent with RG 1.200, Revision 3, if the NDM has been determined to be acceptable using 32 NRC-endorsed processes, NRC staff action is not needed prior to the licensees use of an NDM 33 in a RICT calculation. The NRC staff finds that the proposed changes to TS 5.5.[20] and the 34 addition of TS 5.6.[8] remains consistent with the guidance in RG 1.200, Revision 3, that also 35 endorses NEI 17-07, Revision 2, and specific portions of PWROG-19027-NP. Section 4, 36 Tables 1-7.2-1 through 1-7.2-7 of PWROG-19027-NP, as endorsed by the NRC staff, stipulates 37 a list of technical supporting requirements that must be met to determine an NDM acceptable.

38 39 Furthermore, the RICT program is incorporated as a program into the Administrative Controls 40 section of the TS. As described in 10 CFR 50.36(c)(5), administrative controls are the provisions 41 relating to, among other things, recordkeeping and reporting necessary to assure operation of 42 the facility in a safe manner, and each licensee shall submit any reports to the Commission 43 pursuant to approved technical specifications as specified in 10 CFR 50.4.

44 45 3.

1.1 CONCLUSION

46 47 The NRC staff concludes the proposed changes to TS 5.5.[20] and the addition of TS 5.6.[8]

48 continue to ensure the PRA models used to calculate a RICT are maintained and upgraded by 49 the licensees appropriate use of endorsed guidance (i.e., the ASME/ANS PRA Standard 50 requirements, and specific industry guidance that the NRC staff has determined are sufficient 51 for determining the acceptability of PRA models and NDMs for use in the RICT program).

1 Furthermore, the NRC staff concludes that the addition of TS 5.6.[8] that describes the contents 2 of a RICT program upgrade report to the NRC staff does not preclude any staff oversight of 3 PRA changes performed to ensure the PRA model(s) continues to be maintained and upgraded 4 consistent with RG 1.200, Revision 3. The NRC staff finds that the proposed changes are 5 acceptable because they continue to ensure operation of the facility in a safe manner in 6 accordance with 10 CFR 50.36(c)(5).

7 8 3.2 Additional Proposed Changes 9

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

11 Variations evaluated in section 3.2.2 may remove the LAR from the CLIIP and may require 12 additional technical review depending on the significance of the variations. Additionally, the 13 variations may require additional regulations/guidance being included in the Regulatory 14 Evaluation Section.}

15 3.2.1 Variations That Do Not Affect the Applicability of the Traveler 16 {NOTE: Use this section if the plant has different numbering/nomenclature or modify accordingly 17 for other changes described in section 1.2.1 of this SE.}

18 The LAR noted that the [name of facility] TSs have different numbering [and nomenclature]

19 than STS. The NRC staff finds that the different TS numbering [and nomenclature] changes 20 proposed in the LAR are acceptable because they do not alter TS requirements.

21 3.2.2 Variations That Do Affect the Applicability of the Traveler 22 {NOTE: Use this section if the plant has variations other than changes discussed in section 23 3.2.1 of this SE.}

24 3.3 TS Change Consistency 25 The NRC staff reviewed the proposed TS changes for technical clarity and consistency with the 26 existing requirements for customary terminology and formatting. The NRC staff finds that the 27 proposed changes are consistent with chapter 16.0 of the SRP and are therefore acceptable.

28

4.0 CONCLUSION

29 30 The Commission has concluded, based on the considerations discussed above, that: (1) there 31 is reasonable assurance that the health and safety of the public will not be endangered by 32 operation in the proposed manner, (2) there is reasonable assurance that such activities will be 33 conducted in compliance with the Commission's regulations, and (3) the issuance of the 34 amendment will not be inimical to the common defense and security or to the health and safety 35 of the public.

36 Principle Contributors: Adrienne Brown 37 Andrea Russell 38 Edward Miller 39

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 2

1.0 INTRODUCTION

3 {NOTE: The PM should prepare this section.}

4 [Name of licensee] (the licensee) requested changes to the technical specifications (TSs) for 5 [name of facility] by license amendment request (LAR, application). In its application, the 6 licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) 7 process the proposed amendment under the Consolidated Line Item Improvement Process 8 (CLIIP). The proposed changes would revise the TS based on Technical Specifications Task 9 Force (TSTF) Traveler TSTF-591, Revision 0, Revise Risk-Informed Completion Time (RICT) 10 Program (TSTF-591) (Agencywide Documents Access and Management System (ADAMS) 11 Accession No. ML22081A224), and the associated NRC staff safety evaluation (SE) of 12 TSTF-591 (ML23262B230).

13 14

2.0 STATE CONSULTATION

15 {NOTE: The PM should prepare this section.}

16 In accordance with the Commission's regulations, the [Name of State] State official was notified 17 of the proposed issuance of the amendment on [insert date]. The State official had [no]

18 comments. [If comments were provided, they should be addressed here and modify 19 language of section 3.0 below per SE Template for Power Reactors].

20

3.0 ENVIRONMENTAL CONSIDERATION

21 {NOTE: The PM should prepare this required section.}

22 The amendment changes a requirement with respect to installation or use of a facility 23 component located within the restricted area as defined in Title 10 of the Code of Federal 24 Regulations (10 CFR) Part 20. The NRC staff has determined that the amendment involves no 25 significant increase in the amounts, and no significant change in the types, of any effluents that 26 may be released offsite, and that there is no significant increase in individual or cumulative 27 occupational radiation exposure. The Commission has previously issued a proposed finding that

1 the amendment involves no significant hazards consideration, and there has been no public 2 comment on such finding [enter Federal Register citation (XX FR XXXX) and date].

3 Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 4 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or 5 environmental assessment need be prepared in connection with the issuance of the 6 amendment.

7

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