Text

TSTF Response to NRC Request for Additional Information on TSTF-601, Revision 0, Extend Shield Builidng Completion Time After Refueling
	ML25065A247
Person / Time
Site:	99902042
Issue date:	03/06/2025
From:	Jurek S, Richards A, Steinman R, Vaughan J; Technical Specifications Task Force
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	TSTF-25-01
	Download: ML25065A247 (1)
	v • d • e

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 804-339-7034 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF March 6, 2025 TSTF-25-01 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

TSTF Response to NRC Request for Additional Information on TSTF-601, Revision 0, "Extend Shield Building Completion Time After Refueling" On May 31, 2024, the TSTF submitted traveler TSTF-601, Revision 0, "Extend Shield Building Completion Time After Refueling," (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24152A200). On November 4, 2024, the NRC provided a Request for Additional Information (RAI) (ADAMS Accession No. ML24309A216).

The TSTF's response to the NRC RAI is attached.

The responses to the NRC's questions resulted in a revision to the traveler. Revision 1 of TSTF-601 is enclosed.

Should you have any questions, please do not hesitate to contact us.

Jordan L. Vaughan (PWROG/B&W)

Shane M. Jurek, PE (BWROG)

Andrew M. Richards, Jr. (PWROG/W)

Rebecca L. Steinman, PhD, PE (PWROG/CE)

Attachment Enclosure cc:

Michelle Honcharik, Technical Specifications Branch Shivani Mehta, Technical Specifications Branch

TSTF Response to NRC Questions on TSTF-601, "Extend Shield Building Completion Time After Refueling" Page 1 The NRC request is repeated below in italics, followed by the TSTF response in unitalicized text.

By letter dated May 31, 2024 (Agencywide Documents Access and Management System Accession No. ML24152A200), the Technical Specifications Task Force (TSTF) submitted Traveler TSTF 601, Revision 0, "Extend Shield Building Completion Time After Refueling," to the U.S. Nuclear Regulatory Commission (NRC). Traveler TSTF 601 proposed changes to the Standard Technical Specifications (STSs)1 for pressurized water reactors (PWRs) of the Westinghouse and Combustion Engineering designs that have a shield building. The proposed change would revise the Westinghouse and Combustion Engineering shield building STS to extend the Completion Time (CT) following a refueling outage and prior to criticality.

REGULATORY BASIS FOR REQUEST Section 182(a) of the Atomic Energy Act requires nuclear power plant operating licenses to include TS. The provisions in 10 CFR 50.36, "Technical specifications," establishes the NRC regulatory requirements related to the content of the TS.

10 CFR 50.36(a)(1) states in part: "A summary statement of the bases or reasons for such specification shall also be included in the application but shall not become part of the technical specifications."

10 CFR 50.36(c)(2) states: "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation (LCO) of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met."

REQUESTS FOR ADDITIONAL INFORMATION STSB RAIs:

1. The STS Bases for the shield building state that 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (in Modes 1-4) is a reasonable CT because of the low leakage design of the containment building and the low probability of an event. The proposed STS Bases for Action A.1 for the shield building specification do not maintain the premise that the containment building has a low leakage design. There is no discussion of why the "low leakage" aspect is no longer important, especially considering that the primary containment pressure could be relatively high following a loss of coolant accident (LOCA) in Mode 3. Alternatively, the STS Bases could recognize the low leakage design of the primary containment for Action A.1. The NRC staff requests that the STS Bases be reviewed and updated as needed.

1-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).

TSTF Response to NRC Questions on TSTF-601, "Extend Shield Building Completion Time After Refueling" Page 2 TSTF Response The TS Bases of Required Action A.1 are revised to state, in part, "The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable in MODE 3 or 4 immediately following a refueling when the reactor has not been critical because of the reduced decay heat generation and radionuclide inventory, the limited leakage design of the containment, the OPERABLE TS systems in the applicable MODES, and the low probability of an event requiring the shield building."

2. LCO 3.0.4 prohibits entering the Applicability of an LCO with the LCO not met unless one of three conditions (i.e., a, b, or c) is satisfied. TSTF-601 proposed shield building STS markups included a new Condition A that states, "Shield building inoperable in Mode 3 or 4 following refueling" as modified by a Note that states "Only applicable if Mode 2 has not been entered following refueling." In addition, new Required Action A.1 states, "Restore shield building to OPERABLE status," as modified by a Note that states "LCO 3.0.4.c is applicable." The addition of the LCO 3.0.4.c Note would permit a licensee to enter Modes 4 and 3 following a refueling outage and prior to criticality before completion of the surveillance requirements needed to establish the operability of the shield building.

Section 3.1 of TSTF-601, details multiple STS containment systems specifications (e.g., Spray and Cooling Systems), with LCO Applicability in Modes 1-4, that must be operable prior to entry into Mode 4. The STS Actions Bases for Spray and Cooling describe that " there is no restriction on the use of LCO 3.0.4.b because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate." The NRC staff did not identify any STS related to containment systems that specifies LCO 3.0.4.c is applicable. According to the STS Bases for LCO 3.0.4.c, the risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.c is typically applied to Specifications which describe values and parameters (e.g., reactor coolant system (RCS)

Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

LCO 3.0.4.b applies if a risk assessment determines the acceptability of entering the Applicability while relying on the Action. The risk assessment, for the purposes of LCO 3.0.4.b, must take into account all inoperable technical specification equipment. Section 3.3 of TSTF-601, describes applying LCO 3.0.4 to an inoperable shield building and concluded that LCO 3.0.4.b is not a practical option to enable entering Mode 4 (Applicability of LCO). According to the STS Bases cited above, it appears that use of LCO 3.0.4.b for entering Mode 4 would be permitted for containment systems such as spray and cooling. As such, it appears to the NRC staff that STS LCO 3.0.4.b would be applicable to the shield building for entering Mode 4 for the same reasons that STS LCO 3.0.4.b is applicable to other containment systems for entering Mode 4. In addition, if the status of systems related to containment integrity may be changing during startup, it is appropriate to assess the risk of shield building inoperability considering the overall plant status instead of just allowing entry into the Applicability without consideration of the overall plant status.

TSTF Response to NRC Questions on TSTF-601, "Extend Shield Building Completion Time After Refueling" Page 3 Therefore, based on the discussion above, the NRC staff determined that the use of LCO 3.0.4.b should be considered a practical option for the shield building and the Note that states LCO 3.0.4.c is applicable should be removed.

TSTF Response As discussed in the traveler, the purpose of the addition of Action A is to permit planned startup to Modes 4 and 3 following a refueling with the shield building inoperable. This will require the application of LCO 3.0.4 to enter the Applicability of the technical specification (TS) with the LCO not met. LCO 3.0.4.a is not applicable to this situation as the proposed Action A does not permit continued operation in the Applicability for an unlimited period of time. Either LCO 3.0.4.b or LCO 3.0.4.c could satisfy the purpose of the proposed change.

The TSTF agrees that the use of LCO 3.0.4.b is preferable because its use would consider the availability of other plant equipment and other conditions which could affect the acceptability of entering the Applicability with the shield building inoperable. Therefore, the traveler is revised to remove the LCO 3.0.4.c note and to discuss the use of LCO 3.0.4.b to enter the proposed Action.

3. The current STS requires the shield building to be operable in Modes 1, 2, 3, and 4. If the shield building is inoperable, for example while in Mode 1 (or other Mode of Applicability) it must be returned to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The reason for the TSTF-601 proposed change is that during a refueling outage, sections of the shield building are removed to allow access to the containment equipment hatch. At the end of the outage after the equipment hatch is installed, restoring the shield building boundary, including cure time for sealants, and performing necessary surveillance tests to verify the shield buildings integrity, are among the last activities performed prior to entering Mode 4. This places restoration of the shield building on or near the outage critical path. The TSTF-601 proposed approach, it appears, would allow reinstalling the removed sections of the shield building after entering Mode 4 or Mode 3.

The shield building was designed and constructed in accordance with NRC and industry code requirements to fulfill certain safety functions. Some of the requirements include the ability to maintain structural integrity during seismic events and to provide environmental protection of the containment vessel from adverse weather conditions including flying objects generated by tornados.

The potential for reinstalling sections of the shield building during Modes 4 and 3, would unnecessarily expose the limited leakage containment to external hazards. Based on this understanding, the NRC staff conclude that entering Mode 4 after an outage should not be permitted unless all shield building sections are installed and secured in place. As such, reinstallation of shield building sections should occur prior to entering a Mode of Applicability. Therefore, the TSTF-601 proposed change which permits entry into Mode 4 and 3 with an inoperable shield building following a refueling outage and prior to criticality, should include additional constraints that require all access openings to be operable and all

TSTF Response to NRC Questions on TSTF-601, "Extend Shield Building Completion Time After Refueling" Page 4 shield building sections to be installed and secured in place with inoperability of the shield building limited to the application and curing of sealants necessary to support the performance of surveillance requirements that demonstrate the shield buildings integrity.

TSTF Response The TSTF does not agree with adding additional constraints to the TS to require all shield building access openings to be operable and all shield building sections to be installed and secured in place prior to entering Mode 4.

At most of the applicable plants, the shield building is a reinforced concrete structure that surrounds the steel primary containment. At Millstone Units 2 and 3, the Enclosure Buildings are sheet metal buildings that enclose the exterior of the concrete primary containment. In both cases, the shield building provides a volume for collection, recirculation and filtration of fission-product leakage from the primary containment following a DBA. The concrete shield buildings may also provide other functions, such as post-accident and normal operation radiation protection, and protection of the primary containment from adverse atmospheric conditions, external missiles, and floods.

It is not necessary to impose a TS requirement in the Condition to protect the plant from external hazards. As discussed in the response to Question 2, the traveler has been revised to require the use of LCO 3.0.4.b to enter Mode 4 and Mode 3. LCO 3.0.4.b requires a risk assessment using the plant program, procedures in place to implement 10 CFR 50.65(a)(4). The risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Section 11 requires consideration of external conditions such as weather, external flooding, and other external impacts. Therefore, use of the proposed Action A would require consideration of external conditions and whether changing modes without any covers or shield blocks in place is appropriate.

Practically, use of the proposed change will require the restoration of the shield building to be started prior to entering Mode 4 in order to establish operability prior to a scheduled entry into Mode 2. Sealing and successfully testing the shield building typically requires:

Removing all required outage-related materials and equipment from the containment;

Installing the containment equipment hatch. This must be completed prior to entering Mode 4;

The shield building opening outside of the containment equipment hatch must be closed.

This may be a metal cover or shield blocks.

The shield building enclosure or shield blocks must be sealed with chemical sealant.

All other shield building openings (a few dozen) must be closed and mechanically or chemically sealed.

The chemical sealant must be allowed to dry.

Some licensees perform smoke testing of the sealed surfaces.

TSTF Response to NRC Questions on TSTF-601, "Extend Shield Building Completion Time After Refueling" Page 5

A draw-down test must be performed, and any necessary repairs made, or additional sealant applied.

The draw-down Surveillance Requirements must be performed successfully.

In addition, modifying the proposed Action to only apply when the covers and shield blocks are in place could have the unintended consequence of extending the Completion Time. For example, if the unit was in Mode 4 and it was determined that a shield block needed to be removed to reapply sealant, the proposed Condition A would no longer be applicable once the shield block was removed. Condition B would then apply which has a 24-hour Completion Time. If the shield block is replaced within the Condition B Completion Time, Condition A would again apply with a 72-hour Completion Time. That is not the intent of the change.

SNSB RAI:

4. STS Table 1.1-1. MODES, specifies RCS temperature in Mode 4 as [350] > Tavg > [200]°F and in Mode 3 [350]°F. In Mode 3, with temperature [350]°F and pressure equal to full operating pressure, the RCS will be in a higher subcooled state compared to its state during Mode 1 plant operation at normal temperature and pressure. Therefore, a large break LOCA in Mode 3 could result in comparable (or higher due to higher mass release resulting from a higher density of subcooled RCS) blowdown pressure and subsequent pressure transient in containment as compared to the blowdown pressure and pressure transient during a Mode 1 large break LOCA. Therefore, given the Mode 3 scenario discussed above, the NRC staff requests the TSTF assess whether the TSTF-601 claims of "reduced likelihood of containment pressurization and significant leakage into the shield building" remain valid.

TSTF Response The justification is revised to clarify the referenced paragraph. It states:

In the proposed conditions, the containment is required to be operable. The containment maximum allowable leakage rate, La, is established at the maximum assumed containment pressure (Pa) following a LOCA calculated using the Appendix K assumptions. The TS Bases state that the current 24-hour Completion Time is reasonable given the limited leakage design of the containment. Given that the existing 24-hour Completion Time for an inoperable shield building is acceptable at full power, the proposed 72-hour Completion Time is reasonable in Modes 4 and 3 prior to criticality after refueling because of the lower energy in the reactor, the limited time spent in the condition, the reduced radioactive inventory in the reactor, and the limited leakage design of the containment. and the reduced likelihood of containment pressurization and significant leakage into the shield building.

ARCB RAI:

5. In traveler TSTF-601, it is noted that reductions in source term inventory would occur due to two factors: removal of 1/3 of the irradiated fuel and time for radioactive decay, thereby

TSTF Response to NRC Questions on TSTF-601, "Extend Shield Building Completion Time After Refueling" Page 6 reducing the radiological consequences associated with a LOCA following refueling and prior to criticality. Please provide further qualitative evaluation to support the premise that the radiological consequences of an accident during the proposed new Action A are significantly lower than what would be expected during the currently allowed Actions associated with Mode 1 operations. Please include in the response the status of other safety systems (e.g. Control Room envelope) during the proposed LCO.

TSTF Response In addition to the replacement of approximately one-third of the reactor core with fresh fuel and the decay of the radionuclides during the refueling outage, other plant systems are required to be operable in Modes 4 and 3 that would significantly lower any radioactive release in the event of an accident while in the proposed Action A, including the primary containment, the containment isolation valves, and the shield building ventilation system. The control room operators would also be protected by the control room emergency filtration system. These systems in conjunction with the limitations on the use of the Action justify a 72-hour Completion Time instead of the existing 24-hour Completion Time.

TSTF-601, Rev. 1 PWROG-16, Rev. 0 NUREGs Affected:

Extend Shield Building Completion Time After Refueling Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement:

Improvement NRC Fee Status:

Not Exempt Benefit:

Shortens Outages Changes Marked on ISTS Rev 5.0 PWROG RISD & PA (if applicable): PA-LSC-1955 RS-2022-001 See attached.

Revision History OG Revision 0 Revision Status: Closed Original Issue Revision

Description:

Revision Proposed by:

PWROG Owners Group Review Information Date Originated by OG:

26-May-23 Owners Group Comments (No Comments)

Date: 14-Jun-23 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

15-May-24 Date Distributed for Review 15-May-25 TSTF Comments:

TSTF reviewed and approved draft on 7/6/2023.

Date: 31-May-24 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

31-May-24 The NRC provided comments on the draft traveler on 9/14/2023. A teleconference was held on 9/18/2023.

Comments were incorporated into the traveler.

NRC Comments:

TSTF Revision 1 Revision Status: Active 06-Mar-25 Copyright(C) 2025, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-601, Rev. 1 PWROG-16, Rev. 0 Affected Technical Specifications TSTF Revision 1 Revision Status: Active The traveler was revised in response to an NRC Request for Additional Information (RAI) dated November 4, 2024. The changes are:

The LCO 3.0.4.c Note is removed from Requried Action A.1.

The justification is revised to discuss application of LCO 3.0.4.b when entering Action A.

The justification is expanded to address other operable systems.

Revision

Description:

Revision Proposed by:

TSTF Owners Group Review Information Date Originated by OG:

27-Nov-24 Owners Group Comments (No Comments)

Date:

Owners Group Resolution:

Action 3.6.8.A NUREG(s)- 1431 Only Renamed B and revised.

Change

Description:

Shield Building Action 3.6.8.A NUREG(s)- 1431 Only New Action Change

Description:

Shield Building Action 3.6.8.A Bases NUREG(s)- 1431 Only Renamed B and revised.

Change

Description:

Shield Building Action 3.6.8.A Bases NUREG(s)- 1431 Only New Action Change

Description:

Shield Building Action 3.6.8.B NUREG(s)- 1431 Only Renamed C.

Change

Description:

Shield Building Action 3.6.8.B Bases NUREG(s)- 1431 Only Renamed C.

Change

Description:

Shield Building Action 3.6.11.A NUREG(s)- 1432 Only Renamed B and Revised.

Change

Description:

Shield Building Action 3.6.11.A NUREG(s)- 1432 Only New Action Change

Description:

Shield Building Action 3.6.11.A Bases NUREG(s)- 1432 Only Renamed B and Revised.

Change

Description:

Shield Building Action 3.6.11.A Bases NUREG(s)- 1432 Only New Action Change

Description:

Shield Building Action 3.6.11.B NUREG(s)- 1432 Only Renamed C.

Change

Description:

Shield Building 06-Mar-25 Copyright(C) 2025, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-601, Rev. 1 PWROG-16, Rev. 0 Action 3.6.11.B Bases NUREG(s)- 1432 Only Renamed C.

Change

Description:

Shield Building 06-Mar-25 Copyright(C) 2025, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-601, Rev. 1 Page 1 TABLE OF CONTENTS

1.

SUMMARY

DESCRIPTION............................................................................................ 2

2.

DETAILED DESCRIPTION............................................................................................ 2 2.1.

System Design and Operation.................................................................................. 2 2.2.

Current Technical Specifications Requirements...................................................... 2 2.3.

Reason for the Proposed Change.............................................................................. 3 2.4.

Description of the Proposed Change........................................................................ 3

3.

TECHNICAL EVALUATION.......................................................................................... 4 3.1.

Plant Conditions in Modes 4 and 3 Following a Refueling Outage......................... 4 3.2.

Applicability of an Extended Completion Time Prior to Criticality........................ 4 3.3.

Entering the Applicability with the LCO Not Met................................................... 6 3.4.

Interaction with Shield Building Ventilation Systems............................................. 6 3.5.

Applicability of the NUREG-1432 End State.......................................................... 7 3.6.

Reportability............................................................................................................. 7 3.7.

Conclusion................................................................................................................ 7

4.

REGULATORY EVALUATION..................................................................................... 7

5.

REFERENCES................................................................................................................... 8 Model Application

TSTF-601, Rev. 1 Page 2

1.

SUMMARY

DESCRIPTION The proposed change revises the shield building Technical Specifications (TS) to extend the Completion Time following a refueling outage and prior to criticality. The proposed change affects the Standard Technical Specifications (STS) in NUREG-1431 and NUREG-14321.

2. DETAILED DESCRIPTION 2.1. System Design and Operation In both the Westinghouse and Combustion Engineering design for some plants, the shield building is a structure that surrounds the containment. The shield building has several other plant-specific names, such as the enclosure building and the secondary containment. In this document, the STS term "shield building" is used, but the change encompasses all designs.

Between the containment and the shield building inner wall is an annular space that collects containment leakage that may occur following an accident. The shield building ensures that the release of radioactive material from the containment atmosphere is restricted to the leakage paths and associated leakage rates assumed in the accident analyses. The annular space also allows for periodic inspection of the outer surface of the containment.

The shield building design basis is established by the consequences of the limiting design basis accident (DBA), which is a large break loss of coolant accident (LBLOCA).

2.2. Current Technical Specifications Requirements NUREG-1431, Specification 3.6.8, "Shield Building (Dual and Ice Condenser)," requires the shield building to be operable in Modes 1, 2, 3, and 4.

NUREG-1432, Specification 3.6.11, "Shield Building (Dual)," requires the shield building to be operable in Modes 1, 2, 3, and 4.

In both specifications, if the shield building is inoperable, it must be restored to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Otherwise, the unit must be in Mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Westinghouse STS requires being in Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and the Combustion Engineering STS requires being in Mode 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This difference is due to the incorporation of TSTF-4222, which is only applicable to Combustion Engineering plants.

The Surveillances applicable to the shield building require the annulus pressure to be less than a plant-specific limit and at least one access door in each access opening to be closed, as well as other tests related to structural integrity and negative pressure "draw-down" time.

1 NUREG-1431 provides the STS for Westinghouse plant designs.

NUREG-1432 provides the STS for Combustion Engineering plant designs.

2 TSTF-422, Rev. 2, "Change in Technical Specifications End States (CE NPSD-1186)." The Notice of Availability was published in the Federal Register on May 11, 2012 (76 FR 19510). The traveler is available at NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML093570241.

TSTF-601, Rev. 1 Page 3 2.3. Reason for the Proposed Change During a refueling outage, sections of the shield building boundary are removed to allow access to the containment equipment hatch. At the end of the outage after the equipment hatch is installed, restoring the shield building boundary is among the last activities performed prior to entering Mode 4, which places restoration of the shield building on or near the outage critical path.

The purpose of the shield building is to contain radioactive releases from the containment following a LBLOCA and to direct radioactive material to the shield building ventilation system for filtration prior to release to the environment. However, following a refueling outage and prior to criticality, the decay heat generation and the radionuclide inventory are significantly reduced compared to full power operation. As a result, it is appropriate to provide a longer Completion Time to restore the shield building to operable status in Modes 4 and 3 after a refueling and prior to criticality. The longer Completion Time will permit the establishment of shield building operability to continue prior to criticality in Modes 4 and 3, and avoid those activities from potentially disrupting the startup schedule.

2.4. Description of the Proposed Change NUREG-1431, Specification 3.6.8, and NUREG-1432, Specification 3.6.11, are revised to add a new Action A:

A. ----------NOTE------------

Only applicable if MODE 2 has not been entered following refueling.

Shield building inoperable in MODE 3 or 4 following refueling.

A.1 Restore shield building to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months The existing Condition A, which states, "Shield Building inoperable," is renamed Condition B and modified to state, "Shield building inoperable for reasons other than Condition A." The Required Action and Completion Time are unaffected. Existing Action B is renamed Action C but otherwise unchanged.

The wording of the new Action is modeled on an existing allowance in Action A in the NUREG-1431 and NUREG-1432 specifications for the Auxiliary Feedwater (AFW) System," which permits a longer Completion Time for an inoperable turbine driven AFW pump in Mode 3 following refueling if Mode 2 has not been entered.

The TS Bases are revised to describe the changes to the TS.

TSTF-601, Rev. 1 Page 4 The proposed change does not justify the adoption of TSTF-422 by Combustion Engineering plants if it has not already been incorporated into the plant's TS.

A model application is attached. The model may be used by licensees desiring to adopt the traveler following NRC approval.

3. TECHNICAL EVALUATION The proposed change would allow extension of the Completion Time to restore an inoperable shield building from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in Modes 4 and 3 after a refueling outage and before reactor criticality (Mode 2).

3.1. Plant Conditions in Modes 4 and 3 Following a Refueling Outage At the end of a refueling outage, the following containment systems must be operable prior to entry into Mode 4 (i.e., average reactor coolant temperature above approximately 200):

Containment;

Containment air locks;

Containment isolation valves;

Containment Spray System (Applicability is plant-specific);

Containment Cooling System (if applicable); and

Containment air temperature and pressure must be within limits.

In addition, the shield building ventilation systems must be operable.

Under the current TS, the shield building must also be operable prior to entering Mode 4. An operable shield building must be maintained at a negative pressure. Both NUREG-1431 and NUREG-1432 contain a Surveillance Requirement to verify the shield building annulus negative pressure is greater than a specified limit. In order to meet this SR, shield building boundary integrity must be established.

3.2. Applicability of an Extended Completion Time Prior to Criticality The NUREG-1431 and NUREG-1432 Action Bases for an inoperable shield building state that the 24-hour Completion Time is reasonable considering the limited leakage design of the containment (i.e., not the shield building) and the low probability of a DBA occurring during this time period. This 24-hour Completion Time is applicable under full-power conditions. The proposed change would extend the Completion Time for an inoperable shield building from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months following a refueling in Modes 4 and 3 before the reactor is critical. This change is reasonable given the differences in the plant conditions under the proposed Action compared to the plant conditions at full power. This longer Completion Time would not be applicable for other entries into Modes 4 or 3. For the purposes of this discussion, a refueling

TSTF-601, Rev. 1 Page 5 outage duration of 14 days is assumed as a limiting case, as this is less than the typical PWR refueling outage of more than 20 days. However, the exact length of the refueling outage is not critical to the comparison.

The energy released into the containment from a LOCA is calculated using the assumptions in Title 10 of the Code of Federal Regulations (CFR), Part 50, (10 CFR 50) Appendix K.

Appendix K requires that LOCA analyses be performed assuming that the reactor has been operating continuously at the licensed power level plus an allowance for instrument error.

Appendix K also requires that the assumed fission product decay heat generation rates be equal to 1.2 times the value for infinite operating time. In order to use the proposed 72-hour Completion Time, the reactor will have been shut down for refueling, which takes at least 14 days. ANSI/ANS-5.1, "Decay Heat Power in Light Water Reactors," indicates that after a 2-week shutdown, the decay heat from fission products would be approximately one-quarter of one percent of the full power heat generation. In addition, during the preceding refueling outage approximately one-third of the core will have been replaced with new, unirradiated fuel. This will further reduce the heat being produced by the core. As a result, the energy in the core under the proposed conditions would be less than that assumed for the Appendix K LOCA analysis by approximately three orders of magnitude.

In the proposed conditions, the containment is required to be operable. The containment maximum allowable leakage rate, La, is established at the maximum assumed containment pressure (Pa) following a LOCA calculated using the Appendix K assumptions. The TS Bases state that the current 24-hour Completion Time is reasonable given the limited leakage design of the containment. Given that the existing 24-hour Completion Time for an inoperable shield building is acceptable at full power, the proposed 72-hour Completion Time is reasonable in Modes 4 and 3 prior to criticality after refueling because of the lower energy in the reactor, the limited time spent in the condition, the reduced radioactive inventory in the reactor, and the limited leakage design of the containment.

As stated in the TS Bases, the shield building ensures that the release of radioactive material from the containment atmosphere is restricted to those leakage paths and associated leakage rates assumed in the accident analyses. The amount of radioactive material available to be released would also be reduced in the proposed conditions. Approximately one-third of the core will be new, unirradiated fuel resulting in a significant reduction of the radioactive material available for release from the core in accident conditions. Also, during the refueling outage, shorter-lived radioisotopes in the irradiated fuel have been reduced due to decay. For example, Iodine-131 (a significant contributor to dose) has a half-life of 8 days and will have been reduced in activity by almost a factor of 4 during a hypothetical 14-day shutdown. These factors reduce the radioactive material available to be released into the shield building, also supporting a longer Completion Time for the proposed conditions.

Other plant systems will be required to be operable in Modes 4 and 3 that would significantly reduce any radioactive release in the event of an accident while in the proposed Action A, including the containment, the containment isolation valves, and the shield building ventilation system. The control room operators would also be protected by the control room emergency filtration system. These systems in conjunction with the limitations on the use of the Action justify a 72-hour Completion Time instead of the existing 24-hour Completion Time.

TSTF-601, Rev. 1 Page 6 In summary, the lower energy conditions in the reactor, the reduced radioactive material in Modes 4 and 3 following a refueling and before criticality, the limited leakage design of the containment, the operable TS systems, and the low probability of an accident support extending the Completion Time for an inoperable shield building from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

3.3. Entering the Applicability with the LCO Not Met The proposed change would permit a licensee to enter Modes 4 and 3 following a refueling outage and prior to criticality before completion of the surveillance requirements needed to establish the operability of the shield building.

SR 3.0.4 states (emphasis added):

Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

Under the proposed change, licensees would apply LCO 3.0.4.b to enter Mode 4 and Mode 3 with the shield building inoperable. LCO 3.0.4.b permits entry into the Applicability after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the Mode or other specified condition in the Applicability, and establishment of risk management actions, if appropriate. The LCO 3.0.4.b risk assessment must consider all inoperable Technical Specification equipment, such as the containment, containment isolation valves, the shield building ventilation system, and the control room emergency filtration system. The risk assessment must also consider other conditions such as severe weather and likelihood of weather-generated missiles. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." Regulatory Guide 1.160 endorses the guidance in Section 11 of NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.

3.4. Interaction with Shield Building Ventilation Systems On February 16, 2000, the NRC approved3 TSTF-322, Revision 2, "Secondary Containment and Shield Building Boundary Integrity SRs4." TSTF-322 was incorporated into Revision 2 of NUREG-1431 and NUREG-1432. The traveler revised the shield building SRs to clarify that shield building operability is distinct from shield building ventilation system operability. As a result, the proposed change can be utilized without changing the shield building ventilation system requirements.

3 ADAMS Accession No. ML003683642.

4 ADAMS Accession No. ML003671481.

TSTF-601, Rev. 1 Page 7 3.5. Applicability of the NUREG-1432 End State NUREG-1432, Specification 3.6.11, provides a Mode 4 end state if the shield building is inoperable and is not restored to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The analysis in TSTF-422 considered the shield building to be inoperable for any reason. As a result, the Mode 4 end state would be applicable to new Condition A and no exception is necessary.

3.6. Reportability The shield building is a single train system that prohibits the release of radioactive materials.

NUREG-1022, "Event Report Guidelines, 10 CFR 50.72 and 50.73," Section 3.2.7, "Event or Condition that Could Have Prevented Fulfillment of a Safety Function," provides guidance on reporting criteria 50.72(b)(3)(v) and 50.73(a)(2)(v), both of which refer to systems which "control the release of radioactive material," such as the shield building. The NUREG states, "reports are not required when systems are declared inoperable as part of a planned evolution for maintenance or surveillance testing when done in accordance with an approved procedure and the plants TS." Using the proposed TS change to enter Mode 4 or 3 following a refueling outage and prior to entering Mode 2 while the shield building is inoperable would not be reportable because it would be part of a planned evolution performed in accordance with the plant's TS.

3.7. Conclusion The proposed change provides a longer Completion Time when the shield building is inoperable in Mode 4 or 3 following a refueling and before criticality. The longer Completion Time is reasonable based on the reduced decay heat generation and radionuclide inventory compared to the at-power conditions applicable to the 24-hour Completion Time. In addition, the containment and associated systems are required to be operable to provide a barrier to radioactive release. The proposed change will permit restoration of the shield building to operable status to occur while in Modes 4 and 3, potentially avoiding a disruption of a planned startup sequence.

4. REGULATORY EVALUATION The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The Commission may include such additional technical specifications as the Commission finds appropriate.

Regulation 10 CFR 50.36(c), Paragraph (2), states that when a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. The proposed change provides a remedial action to be taken when the limiting condition for operation is not met, and therefore, is in compliance with 10 CFR 50.36(c)(2).

TSTF-601, Rev. 1 Page 8 Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate.

Section IV, "The Commission Policy," of the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58FR39132), dated July 22, 1993, states in part that improved STS have been developed and will be maintained for each NSSS owners group. The Commission Policy encourages licensees to use the improved STS as the basis for plant-specific Technical Specifications." The industry's proposal of travelers and the NRC's approval of travelers is the method used to maintain the improved STS as described in the Commission's Policy. Following NRC approval, licensees adopt travelers into their plant-specific technical specifications following the requirements of 10 CFR 50.90. Therefore, the traveler process facilitates the Commission's policy while satisfying the requirements of the applicable regulations.

The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls. The proposed traveler revises the Bases to be consistent with the Technical Specifications, and therefore, is in compliance with 10 CFR 50.36(a)(1).

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

5. REFERENCES None.

TSTF-601, Rev. 1 Model Application

TSTF-601, Rev. 1 Page 1

[DATE]

10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOCKET NO. PLANT NAME

[50]-[xxx]

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-601, "Extend Shield Building Completion Time After Refueling" Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].

[LICENSEE] requests adoption of TSTF-601, "Extend Shield Building Completion Time After Refueling," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-601 revises the [shield building] TS to add a new Action that is applicable prior to criticality following a refueling outage.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. [Attachment 2 provides revised (clean) TS pages.] Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

[LICENSEE] requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within [90] days.

There are no regulatory commitments in this letter.

[In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated [STATE] Official.]

[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.

Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]

TSTF-601, Rev. 1 Page 2 If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Enclosure:

Description and Assessment Attachments: 1.

Proposed Technical Specification Changes (Mark-Up)

[2. Revised Technical Specification Pages]

3.

Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only

[The attachments are to be provided by the licensee and are not included in the model application.]

cc:

NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact

TSTF-601, Rev. 1 Page 3 ENCLOSURE DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

[LICENSEE] requests adoption of TSTF-601, "Extend Shield Building Completion Time After Refueling," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] Technical Specifications (TS). TSTF-601 revises the [shield building] TS to add a new Action that is applicable prior to criticality following a refueling outage.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation

[LICENSEE] has reviewed the safety evaluation for TSTF-601 provided to the Technical Specifications Task Force in a letter dated [DATE]. This review included the NRC staffs evaluation, as well as the information provided in TSTF-601. [LICENSEE] has concluded that the justifications presented in TSTF-601 and the safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS.

2.2 Variations

[LICENSEE is not proposing any variations from the TS changes described in TSTF-601 or the applicable parts of the NRC staffs safety evaluation.] [LICENSEE is proposing the following variations from the TS changes described in TSTF-601 or the applicable parts of the NRC staffs safety evaluation:]

[The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-601 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-601 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-601 to the [PLANT] TS.]

[The [PLANT] TS contain requirements that differ from the STS on which TSTF-601 was based but are encompassed in the TSTF-601 justification. [The [PLANT] TS do not include the changes in TSTF-422, Rev. 2, "Change in Technical Specifications End States (CE NPSD-1186),"] [Describe the difference between the plant TS and the STS.] These differences do not affect the applicability of TSTF-601 to the [PLANT] TS.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

[LICENSEE] requests adoption of TSTF-601, "Extend Shield Building Completion Time After Refueling," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] Technical Specifications (TS). TSTF-601 revises the [shield

TSTF-601, Rev. 1 Page 4 building] TS to add a new Action that is applicable prior to criticality following a refueling outage.

[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change provides a longer Completion Time for the [shield building] to be inoperable in Modes 4 and 3 following the refueling of the reactor and prior to reactor criticality. The [shield building] is not an initiator of any accident previously evaluated.

As a result, the probability of an accident during the extended Completion Time is not significantly increased. The consequences of a previously analyzed accident during the extended Completion Time are no different than the consequences of the accident during the existing Completion Time. Further, the limitations on the use of the extended Completion Time ensure that the consequences are reduced from those that would occur when at power. Hence, the consequences are not significantly increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change provides a longer Completion Time for the [shield building] to be inoperable in Modes 4 and 3 following the refueling of the reactor and prior to reactor criticality. No new or different accidents result from utilizing the proposed change. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). Permitting the [shield building] to be restored to operable status in Mode 4 or 3 instead of Mode 5 does not create a significant change in the methods governing normal plant operation. In addition, the changes only affect a TS Action and therefore do not alter the assumptions made in the safety analysis.

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

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change provides a longer Completion Time for the [shield building] to be inoperable in Modes 4 and 3 following the refueling of the reactor and prior to reactor

TSTF-601, Rev. 1 Page 5 criticality. The proposed change does not adversely affect existing plant safety margins, or significantly affect the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

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

Based on the above, [LICENSEE] concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

TSTF-601, Rev. 1 Technical Specifications Changes

Shield Building (Dual and Ice Condenser) 3.6.8 Westinghouse STS 3.6.8-1 Rev. 5.0 3.6 CONTAINMENT SYSTEMS 3.6.8 Shield Building (Dual and Ice Condenser)

LCO 3.6.8 The shield building shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. -----------NOTE------------

Only applicable if MODE 2 has not been entered following refueling.

Shield building inoperable in MODE 3 or 4 following refueling.

A.1 Restore shield building to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months BA. Shield building inoperable for reasons other than Condition A.

BA.1 Restore shield building to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months CB. Required Action and associated Completion Time not met.

CB.1 Be in MODE 3.

AND CB.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.8.1

[ Verify annulus negative pressure is > [5] inches

[ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months TSTF-601, Rev. 1

Shield Building (Dual and Ice Condenser)

B 3.6.8 Westinghouse STS B 3.6.8-2 Rev. 5.0 BASES ACTIONS A.1 If the shield building is inoperable in MODE 3 or MODE 4 following a refueling, shield building OPERABILITY must be restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Condition A is modified by a Note which limits the applicability of the Condition to when the unit has not entered MODE 2 following a refueling. Condition A allows the shield building to be inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months instead of the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time in Condition B. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable in MODE 3 or 4 immediately following a refueling when the reactor has not been critical because of the reduced decay heat generation and radionuclide inventory, the limited leakage design of the containment, the OPERABLE TS systems in the applicable MODES, and the low probability of an event requiring the shield building.

BA.1 In the event shield building OPERABILITY is not maintained for reasons other than Condition A, shield building OPERABILITY must be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Twenty-four hours is a reasonable Completion Time considering the limited leakage design of containment and the low probability of a Design Basis Accident occurring during this time period.

CB.1 and CB.2 If the shield building cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE

[ SR 3.6.8.1 REQUIREMENTS Verifying that shield building annulus negative pressure is within limit ensures that operation remains within the limit assumed in the containment analysis. [ The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency of this SR was developed considering operating experience related to shield building annulus pressure variations and pressure instrument drift during the applicable MODES.

OR TSTF-601, Rev. 1

Shield Building (Dual) 3.6.11 Combustion Engineering STS 3.6.11-1 Rev. 5.0 3.6 CONTAINMENT SYSTEMS 3.6.11 Shield Building (Dual)

LCO 3.6.11 Shield building shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. -----------NOTE------------

Only applicable if MODE 2 has not been entered following refueling.

Shield building inoperable in MODE 3 or 4 following refueling.

A.1 Restore shield building to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months BA. Shield building inoperable for reasons other than Condition A.

BA.1 Restore shield building to OPERABLE status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months CB. Required Action and associated Completion Time not met.

CB.1 Be in MODE 3.

AND CB.2

NOTE--------------

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours TSTF-601, Rev. 1

Shield Building (Dual)

B 3.6.11 Combustion Engineering STS B 3.6.11-2 Rev. 5.0 BASES ACTIONS A.1 If the shield building is inoperable in MODE 3 or MODE 4 following a refueling, shield building OPERABILITY must be restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Condition A is modified by a Note which limits the applicability of the Condition to when the unit has not entered MODE 2 following a refueling. Condition A allows the shield building to be inoperable for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months instead of the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time in Condition B. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable in MODE 3 or 4 immediately following a refueling when the reactor has not been critical because of the reduced decay heat generation and radionuclide inventory, the limited leakage design of the containment, the OPERABLE TS systems in the applicable MODES, and the low probability of an event requiring the shield building.

BA.1 In the event shield building OPERABILITY is not maintained for reasons other than Condition A, shield building OPERABILITY must be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Twenty-four hours is a reasonable Completion Time considering the limited leakage design of the containment and the low probability of a DBA occurring during this time period.

CB.1 and CB.2

REVIEWERS NOTE ----------------------------------

Adoption of a MODE 4 end state requires the licensee to make the following commitments:

1. [LICENSEE] will follow the guidance established in Section 11 of NUMARC 93-01, Industry Guidance for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Nuclear Management and Resource Council, Revision [4F].

2. [LICENSEE] will follow the guidance established in Revision 2 of WCAP-16364-NP, Implementation Guidance for Risk Informed Modification to Selected Required Action End States at Combustion Engineering NSSS Plants (TSTF-422), Westinghouse, May 2010.

If the shield building cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which overall plant risk is minimized. To achieve this status, the plant must be TSTF-601, Rev. 1

v t e Letter Sequence Response to RAI
EPID:L-2024-PMP-0007, TSTF-601 (Open)
Initiation Request, Request Acceptance Administration Meeting Questions 4 November 2024 Answers Results Approval... Other: ML25247A258
MONTHYEAR2024-05-31 [Table View]

TSTF-25-01, TSTF Response to NRC Request for Additional Information on TSTF-601, Revision 0, Extend Shield Builidng Completion Time After Refueling

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TSTF-25-01, TSTF Response to NRC Request for Additional Information on TSTF-601, Revision 0, Extend Shield Builidng Completion Time After Refueling

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