Notice of Availability of Model Application Concerning Technical Specifications for Boiling Water Reactor Plants to Risk-Inform Requirements Regarding Selected Required Action End States Using the Consolidated Line Item Improvement Process, 14726-14745 [06-2803]
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Federal Register / Vol. 71, No. 56 / Thursday, March 23, 2006 / Notices
Dated: March 16, 2006.
Andrew L. Bates,
Advisory Committee Management Officer.
[FR Doc. E6–4193 Filed 3–22–06; 8:45 am]
NUCLEAR REGULATORY
COMMISSION
Notice of Availability of Model
Application Concerning Technical
Specifications for Boiling Water
Reactor Plants to Risk-Inform
Requirements Regarding Selected
Required Action End States Using the
Consolidated Line Item Improvement
Process
BILLING CODE 7590–01–P
NUCLEAR REGULATORY
COMMISSION
Advisory Committee on Reactor
Safeguards Meeting of the
Subcommittee on Plant License
Renewal; Notice of Meeting
Nuclear Regulatory
Commission.
ACTION: Notice of availability.
AGENCY:
The ACRS Subcommittee on Plant
License Renewal will hold a meeting on
April 5, 2006, Room T–2B3, 11545
Rockville Pike, Rockville, Maryland.
The entire meeting will be open to
public attendance. The agenda for the
subject meeting shall be as follows:
Wednesday, April 5, 2006—8:30 a.m.–
12 Noon
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The purpose of this meeting is to
discuss the License Renewal
Application for Nine Mile Point and the
related Safety Evaluation Report (SER)
with open items prepared by the NRR
staff. The Subcommittee will hear
presentations by and hold discussions
with representatives of the NRC staff,
Constellation Energy Group, and other
interested persons regarding this matter.
The Subcommittee will gather
information, analyze relevant issues and
facts, and formulate proposed positions
and actions, as appropriate, for
deliberation by the full Committee.
Members of the public desiring to
provide oral statements and/or written
comments should notify the Designated
Federal Official, Mr. John G. Lamb
(telephone 301/415–6855) five days
prior to the meeting, if possible, so that
appropriate arrangements can be made.
Electronic recordings will be permitted.
Further information regarding this
meeting can be obtained by contacting
the Designated Federal Official between
7:30 a.m. and 4:15 p.m. (ET). Persons
planning to attend this meeting are
urged to contact the above named
individual at least two working days
prior to the meeting to be advised of any
potential changes to the agenda.
Dated: March 16, 2006.
Michael R. Snodderly,
Acting Branch Chief, ACRS/ACNW.
[FR Doc. E6–4194 Filed 3–22–06; 8:45 am]
BILLING CODE 7590–01–P
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SUMMARY: Notice is hereby given that
the staff of the Nuclear Regulatory
Commission (NRC) has prepared a
model application related to the
revision of Boiling Water Reactor (BWR)
plant required action end state
requirements in technical specifications
(TS). The purpose of this model is to
permit the NRC to efficiently process
amendments that propose to revise BWR
TS required action end state
requirements. Licensees of nuclear
power reactors to which the model
applies may request amendments
utilizing the model application.
DATES: The NRC staff issued a Federal
Register Notice (70 FR 74037, December
14, 2005) that provided a model safety
evaluation (SE) and a model no
significant hazards consideration
(NSHC) determination relating to
changing BWR TS required action end
state requirements. The NRC staff
hereby announces that the model SE
and NSHC determination may be
referenced in plant-specific applications
to adopt the changes. The staff has
posted a model application on the NRC
Web site to assist licensees in using the
consolidated line item improvement
process (CLIIP) to revise the BWR TS
required action end state requirements.
The NRC staff can most efficiently
consider applications based upon the
model application if the application is
submitted within a year of this Federal
Register Notice.
FOR FURTHER INFORMATION CONTACT: T. R.
Tjader, Mail Stop: O12H2, Division of
Inspection and Regional Support, Office
of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Commission,
Washington, DC 20555–0001, telephone
301–415–1187.
SUPPLEMENTARY INFORMATION:
Background
Regulatory Issue Summary 2000–06,
‘‘Consolidated Line Item Improvement
Process for Adopting Standard
Technical Specification Changes for
Power Reactors,’’ was issued on March
20, 2000. The Consolidated Line Item
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Improvement Process (CLIIP) is
intended to improve the efficiency of
NRC licensing processes. This is
accomplished by processing changes to
the standard TS (STS) in a manner that
supports subsequent license amendment
applications. The CLIIP includes an
opportunity for the public to comment
on proposed changes to the STS
following a preliminary safety
assessment by the NRC staff and finding
that the change will likely be offered for
adoption by licensees. The CLIIP
includes NRC staff evaluation of any
comments received for a proposed
change to the STS, and either a
reconsideration of the change or an
announcement of the availability of the
change for adoption by licensees. Those
licensees opting to apply for the subject
change to their TS are responsible for
reviewing the staff’s evaluation,
referencing the applicable technical
justifications, and providing any
necessary plant-specific information.
Each amendment application made in
response to the notice of availability
will be processed and noticed in
accordance with applicable rules and
NRC procedures.
This notice involves the revision of
BWR TS required action end state
requirements. This change was
proposed for incorporation into the STS
by participants in the Owners Groups
Technical Specification Task Force
(TSTF) and is designated TSTF–423,
Revision 0. TSTF–423, as well as the
NRC staff’s safety evaluation and model
application, may be examined, and/or
copied for a fee, at the NRC’s Public
Document Room, located at One White
Flint North, 11555 Rockville Pike (first
floor), Rockville, Maryland. Publicly
available records are accessible
electronically from the ADAMS Public
Library component on the NRC Web
site, (the Electronic Reading Room).
TSTF–423, the NRC staff’s safety
evaluation, and the model application,
can be viewed on the NRC Web site at:
(https://www.nrc.gov/reactors/operating/
licensing/techspecs.html).
Applicability
This proposal to modify technical
specification requirements by the
adoption of TSTF–423 is applicable to
all licensees of BWR plants who have
adopted or will adopt, in conjunction
with the change, technical specification
requirements for a Bases control
program consistent with the TS Bases
Control Program described in Section
5.5 of the BWR STS. Licensees that have
not adopted requirements for a Bases
control program by converting to the
improved STS or by other means, are
requested to include the requirements
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for a Bases control program consistent
with the STS in their application for the
change. The need for a Bases control
program stems from the need for
adequate regulatory control of some key
elements of the proposal that are
contained in the Bases in TSTF–423.
The staff is requesting that the Bases
changes be included with the proposed
license amendments consistent with the
Bases in TSTF–423, prior to
implementing TSTF–423. To ensure that
the overall change, including the Bases,
includes appropriate regulatory
controls, the staff plans to condition the
issuance of each license amendment on
the licensee’s incorporation of the
changes into the Bases document and on
requiring the licensee to control the
changes in accordance with the Bases
Control Program. The CLIIP does not
prevent licensees from requesting an
alternative approach or proposing the
changes without the requested Bases
and Bases control program. However,
deviations from the approach
recommended in this notice may require
additional review by the NRC staff and
may increase the time and resources
needed for the review. Significant
variations from the approach, or
inclusion of additional changes to the
license, will result in staff rejection of
the submittal. Instead, licensees desiring
significant variations and/or additional
changes should submit a LAR that does
not claim to adopt TSTF–423.
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Public Notices
In a notice in the Federal Register
dated December 14, 2005 (70 FR 74037),
the staff requested comment on the use
of the CLIIP to process requests to revise
the BWR TS regarding required action
end state requirements, designated as
TSTF–423.
In response to the notice soliciting
comments from interested members of
the public about modifying the TS
requirements regarding revising
required action end state requirements,
the staff received one set of comments
(from the Owners Groups TSTF,
representing licensees). Specific
comments on the model SE were
offered, and are summarized and
discussed below:
1. Comment: We commend the staff
for adopting a draft Safety Evaluation
format that simplifies the application of
the model Safety Evaluation for TSTF–
423 to individual licensees. For
example, providing blanks for plant
name, operating license number, etc. We
encourage the staff to follow this
example for future CLIIP model Safety
Evaluations.
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Response: The NRC staff
acknowledges the comment; no action
taken.
2. Comment: The ‘‘Applicability’’
portion of the notice states that each
licensee applying for the changes
proposed in TSTF–423 should include
Bases for the proposed Technical
Specifications (TS) consistent with the
Bases proposed in TSTF–423. We
request that the section be revised to not
require licensees to submit Bases
changes. The Bases changes in TSTF–
423 are not integral to the change and
both licensee and NRC resources could
be saved by allowing licensees to adopt
the necessary Bases changes using the
Technical Specifications Bases Control
Program. As a precedent, the CLIIP for
TSTF–460 (Notice of Availability
published in the Federal Register on
August 23, 2004) allowed licensees to
commit to updating their TS Bases
under the TS Bases Control Program
instead of requiring licensees to submit
their Bases changes for NRC review. We
propose that the TSTF–423 CLIIP take a
similar approach.
Response: The NRC staff does not
agree with the comment. The associated
TS Bases changes are an essential and
integral element of the change, must be
consistent with the Bases in TSTF–423,
and should be submitted by the
licensees with the license amendment
request for adoption of TSTF–423.
3. Comment: Section 1.0 of the model
Safety Evaluation, in the first paragraph,
states that TSTF–423 was proposed by
the Nuclear Energy Institute Risk
Informed Technical Specification Task
Force. That is incorrect. TSTF–423,
Revision 0, was submitted by the
Owners Group Technical Specifications
Task Force in a letter to the NRC dated
August 12, 2003.
Response: The NRC staff agrees with
the comment. The correction has been
made.
4. Comment: Section 1.0 of the model
Safety Evaluation, the last sentence of
section, states, ‘‘Short duration repairs
are on the order of 2-to-3 days, but not
more than a week.’’ We recommend
replacing this sentence with the
statement from the Implementation
Guidance (TSTF–IG–05–02), which
states, ‘‘A ‘short duration’ is envisioned
to be the duration that boiling water
reactors (BWRs) are most physically and
practicably able to remain in the hot
shutdown condition (i.e., from a few
days to approximately one week).’’ This
clarifies that the time frames are a
statement of fact rather than a restriction
which must be incorporated in plant
operating controls.
Response: The NRC staff does not
agree with the comment. This issue was
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discussed thoroughly and the one week
limit was determined appropriate. The
one week limit is explicitly stated in the
Implementation Guidance (Reference 8
to the SE) submitted by industry, agreed
to by the NRC staff, and to which the
licensees must commit. Section 1
paragraph 6 of the Implementation
Guidance (TSTF–IG–05–02) states,
‘‘Any entry into Mode 3 using this TS
allowance must be limited to no more
than seven days.’’ No action has been
taken.
5. Comment: In Section 3.2,
‘‘Assessment of TS Changes,’’ of the
model Safety Evaluation, each
subsection is titled with the applicable
Topical Report section number and the
ITS LCO number. The abbreviation
‘‘TS’’ is used to indicate the Topical
Report section number (e.g., ‘‘TS 4.5.1.2
and LCO 3.4.3 (BWR/4); TS 4.5.2.2 and
LCO 3.4.4 (BWR/6), Safety/Relief Valves
(SRVs).’’ The labels ‘‘4.5.1.2’’ and
‘‘4.5.2.2’’ are the Topical Report sections
associated with these LCO changes.
These references also appear in the text
of Section 3.2. This presentation is
confusing as ‘‘TS’’ is defined in the
model Safety Evaluation as ‘‘Technical
Specifications’’ and non-ITS plants have
Technical Specification requirements
with numbers similar to the Topical
Report numbers. We recommend
replacing this use of the abbreviation
‘‘TS’’ with either ‘‘Topical Report
section’’ or defining another acronym,
such as ‘‘TR.’’
Response: The NRC staff agrees with
the comment. The abbreviation for the
Topical Report Section was poorly
chosen, in that it was easily confused
with the abbreviation for Technical
Specification. The Topical Report
Section abbreviation has been changed
to ‘‘TRS.’’
6. Comment: In Section 3.2.4 of the
model Safety Evaluation, in the title and
in the first paragraph, the LCO name
‘‘Low-Low Set Logic (LLS) Valves’’ is
used. The word ‘‘logic’’ should not
appear in the LCO name. The document
should be revised to state ‘‘Low-Low Set
(LLS) Valves.’’
Response: The NRC staff agrees with
the comment. The correction has been
made.
7. Comment: Section 5.0,
‘‘Environmental Consideration,’’ of the
model Safety Evaluation states that the
amendments meet the eligibility criteria
for categorical exclusion set forth in ‘‘10
CFR 51.22(c)(9) [and (c)(10)].’’ 10 CFR
51.22(c)(10) pertains to issuance of an
amendment pursuant to ‘‘parts 30, 31,
32, 33, 34, 35, 36, 39, 40, 50, 60, 61, 70
or part 72 of this chapter which (i)
changes surety, insurance and/or
indemnity requirements, or (ii) changes
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recordkeeping, reporting, or
administrative procedures or
requirements.’’ Paragraph (c)(10) is not
applicable to this change and the
reference should be deleted.
Response: The NRC staff agrees with
the comment. The correction has been
made.
8. Comment: Section 7.0,
‘‘References,’’ of the model Safety
Evaluation, Reference 1, states the date
of NEDC–32988–A, Revision 2, as
September 2005. The correct date of the
document is December 2002.
Response: The NRC staff agrees with
the comment. The correction has been
made.
The NRC staff has made editorial
changes to the previously published
model SE related to TSTF–423 resulting
from the disposition of comments 3, 5,
6, 7, and 8. The staff finds that
technically the previously published SE
remains unaltered. Below are the
republished model SE and model NSHC
determination (previously published in
the Federal Register; 70 FR 23238,
December 14, 2005), and the model
application prepared by the staff that
licensees may reference in their plantspecific applications.
Dated at Rockville, Maryland, this 16th day
of March 2006.
For the Nuclear Regulatory Commission.
Thomas H. Boyce,
Branch Chief, Technical Specifications
Branch, Division of Inspection and Regional
Support, Office of Nuclear Reactor
Regulation.
Model Plant Specific Safety Evaluation
for Technical Specification Task Force
(TSTF) Change TSTF–423, Risk
Informed Modification to Selected
Required Action End States, a
Consolidated Line Item Improvement
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U.S. Nuclear Regulatory Commission,
Safety Evaluation by the Office of
Nuclear Reactor Regulation Related to
Amendment No. [lll] to Facility
Operating License NFP–[lll [Utility
Name] [Plant Name], [Unit lll]
Docket No. –[ll]
1.0 Introduction
By letter dated lllll, 20l,
[Utility Name] (the licensee) proposed
changes to the technical specifications
(TS) for [plant name]. The requested
changes are the adoption of TSTF–423,
Revision 0, to the Boiling Water Reactor
(BWR) Standard Technical
Specifications (STS) (NUREG 1433 and
NUREG 1434), which was proposed by
the Owners Groups Technical
Specifications Task Force (TSTF) on
August 12, 2003, on behalf of the
industry. TSTF–423, Revision 0,
incorporates the BWR Owners Group
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(BWROG) approved Topical Report
NEDC–32988, Revision 2, ‘‘Technical
Justification to Support Risk Informed
Modification to Selected Required
Action End States for BWR Plants’’
(Reference 1), into the BWR STS (NOTE:
The changes in TSTF–423 are made
with respect to Revision 2 of the BWR
STS NUREGs).
TSTF–423 is one of the industry’s
initiatives developed under the Risk
Management Technical Specifications
(RMTS) program. These initiatives are
intended to maintain or improve safety
through the incorporation of risk
assessment and management techniques
in TS, while reducing unnecessary
burden and making TS requirements
consistent with the Commission’s other
risk-informed regulatory requirements,
in particular the maintenance rule.
The Code of Federal Regulations, 10
CFR 50.36, ‘‘Technical Specifications,’’
states: ‘‘When a limiting condition for
operation of a nuclear reactor is not met,
the licensee shall shut down the reactor
or follow the remedial action permitted
by the technical specification until the
condition can be met.’’ The STS and
most plant TS provide a completion
time (CT) for the plant to meet the
limiting condition for operation (LCO).
If the LCO or the remedial action cannot
be met, then the reactor is required to
be shut down. When the STS and
individual plant technical specifications
were written, the shutdown condition or
end state specified was usually cold
shutdown.
Topical Report NEDC–32988,
Revision 2, provides the technical basis
to change certain required end states
when the TS Actions for remaining in
power operation cannot be met within
the CTs. Most of the requested TS
changes permit an end state of hot
shutdown (Mode 3), if risk is assessed
and managed, rather than an end state
of cold shutdown (Mode 4) contained in
the current TS. The request was limited
to those end states where: (1) entry into
the shutdown mode is for a short
interval, (2) entry is initiated by
inoperability of a single train of
equipment or a restriction on a plant
operational parameter, unless otherwise
stated in the applicable TS, and (3) the
primary purpose is to correct the
initiating condition and return to power
operation as soon as is practical.
The STS for BWR plants define five
operational modes. In general, they are:
• Mode 1—Power Operation. The
reactor mode switch is in run position.
• Mode 2—Reactor Startup. The
reactor mode switch is in refuel position
(with all reactor vessel head closure
bolts fully tensioned) or in startup/hot
standby position.
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• Mode 3—Hot Shutdown. The
reactor coolant system (RCS)
temperature is above 200 degrees F (TS
specific) and the reactor mode switch is
in shutdown position (with all reactor
vessel head closure bolts fully
tensioned).
• Mode 4—Cold Shutdown. The RCS
temperature is equal to or less than 200
degrees F and the reactor mode switch
is in shutdown position (with all reactor
vessel head closure bolts fully
tensioned).
• Mode 5—Refueling. The reactor
mode switch is in shutdown or refuel
position, and one or more reactor vessel
head closure bolts are less than fully
tensioned.
Criticality is not allowed in Modes 3
through 5.
TSTF–423 generally allows a Mode 3
end state rather than a Mode 4 end state
for selected initiating conditions in
order to perform short-duration repairs
which necessitate exiting the original
Mode of operation. Short duration
repairs are on the order of 2-to-3 days,
but not more than a week.
2.0 Regulatory Evaluation
In 10 CFR 50.36, the Commission
established its regulatory requirements
related to the content of TS. Pursuant to
10 CFR 50.36(c), TS are required to
include items in the following five
specific categories related to station
operation: (1) Safety limits, limiting
safety system settings, and limiting
control settings; (2) limiting conditions
for operation (LCOs); (3) surveillance
requirements (SRs); (4) design features;
and (5) administrative controls. The rule
does not specify the particular
requirements to be included in a plant’s
TS. As stated in 10 CFR 50.36(c)(2)(i),
the ‘‘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 of a nuclear reactor is not met,
the licensee shall shut down the reactor
or follow any remedial action permitted
by the technical specifications * * *.’’
Reference 1 states: ‘‘Cold shutdown is
normally required when an inoperable
system or train cannot be restored to an
operable status within the allowed time.
Going to cold shutdown results in the
loss of steam-driven systems, challenges
the shutdown heat removal systems,
and requires restarting the plant. A more
preferred operational mode is one that
maintains adequate risk levels while
repairs are completed without causing
unnecessary challenges to plant
equipment during shutdown and startup
transitions.’’ In the end state changes
under consideration here, a problem
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with a component or train has or will
result in a failure to meet a TS, and a
controlled shutdown has begun because
a TS Action requirement cannot be met
within the TS CT.
Most of today’s TS and the design
basis analyses were developed under
the perception that putting a plant in
cold shutdown would result in the
safest condition and the design basis
analyses would bound credible
shutdown accidents. In the late 1980s
and early 1990s, the NRC and licensees
recognized that this perception was
incorrect and took corrective actions to
improve shutdown operation. At the
same time, standard TS were developed
and many licensees improved their TS.
Since enactment of a shutdown rule was
expected, almost all TS changes
involving power operation, including a
revised end state requirement, were
postponed (see, for example the Final
Policy Statement on TS Improvements,
Reference 2). However, in the mid
1990s, the Commission decided a
shutdown rule was not necessary in
light of industry improvements.
Controlling shutdown risk
encompasses control of conditions that
can cause potential initiating events and
responses to those initiating events that
do occur. Initiating events are a function
of equipment malfunctions and human
error. Responses to events are a function
of plant sensitivity, ongoing activities,
human error, defense-in-depth, and
additional equipment malfunctions.
In practice, the risk during shutdown
operations is often addressed via
voluntary actions and application of 10
CFR 50.65 (Reference 3), the
maintenance rule. Section 50.65(a)(4)
states: ‘‘Before performing maintenance
activities * * * the licensee shall assess
and manage the increase in risk that
may result from the proposed
maintenance activities. The scope of the
assessment may be limited to structures,
systems, and components that a riskinformed evaluation process has shown
to be significant to public health and
safety.’’ Regulatory Guide (RG) 1.182
(Reference 4) provides guidance on
implementing the provisions of 10 CFR
50.65(a)(4) by endorsing the revised
Section 11 (published separately) to
NUMARC 93–01, Revision 2. The
revised Section 11 of NUMARC 93–01,
Revision 2, was subsequently
incorporated into Revision 3 of
NUMARC 93–01 (Reference 5).
However, Revision 3 has not yet been
formally endorsed by the NRC. The
changes in TSTF–423 are consistent
with the rules, regulations and
associated regulatory guidance, as noted
above.
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3.0
Technical Evaluation
The changes proposed in TSTF–423
are consistent with the changes
proposed and justified in Topical Report
GE NEDC–32988–A, Revision 2,
(Reference 1) and approved by the
associated NRC SE (Reference 6). The
evaluation included in Reference 6, as
appropriate and applicable to the
changes of TSTF–423 (Reference 7), is
reiterated here and differences from the
SE are justified. In its application the
licensee commits to TSTF–IG–05–02,
Implementation Guidance for TSTF–
423, Revision 0, ‘‘Technical
Specifications End States, NEDC–
32988–A,’’ (Reference 8), which
addresses a variety of issues such as
considerations and compensatory
actions for risk-significant plant
configurations. An overview of the
generic evaluation and associated risk
assessment is provided below, along
with a summary of the associated TS
changes justified by Reference 1.
3.1
Risk Assessment
The objective of the BWROG topical
report (Reference 1) risk assessment was
to show that any risk increases
associated with the changes in TS end
states are either negligible or negative
(i.e., a net decrease in risk).
The BWROG topical report
documents a risk-informed analysis of
the proposed TS change. Probabilistic
Risk Assessment (PRA) results and
insights are used, in combination with
results of deterministic assessments, to
identify and propose changes in ‘‘end
states’’ for all BWR plants. This is in
accordance with guidance provided in
RG 1.174 (Reference 9) and RG 1.177
(Reference 10). The three-tiered
approach documented in RG 1.177, ‘‘An
Approach for Plant-Specific, RiskInformed Decision Making: Technical
Specifications,’’ was followed. The first
tier of the three-tiered approach
includes the assessment of the risk
impact of the proposed change for
comparison to acceptance guidelines
consistent with the Commission’s Safety
Goal Policy Statement, as documented
in RG 1.174. The first tier aims at
ensuring that there are no unacceptable
temporary risk increases as a result of
the TS change, such as when equipment
is taken out of service. The second tier
addresses the need to preclude
potentially high-risk configurations
which could result if equipment is taken
out of service concurrently with the
equipment out of service as allowed by
this TS change. The third tier addresses
the application of 10 CFR 50.65(a)(4) of
the Maintenance Rule for identifying
risk-significant configurations resulting
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14729
from maintenance related activities and
taking appropriate compensatory
measures to avoid such configurations.
This TS invokes a risk assessment
because 10 CFR 50.65(a)(4) is applicable
to maintenance related activities and
does not cover other operational
activities beyond the effect they may
have on existing maintenance related
risk.
BWROG’s risk assessment approach
was found comprehensive and
acceptable in the SE for the topical
report. In addition, the analyses show
that the three-tiered approach criteria
for allowing TS changes are met as
follows:
• Risk Impact of the Proposed Change
(Tier 1). The risk changes associated
with the TS changes in TSTF–423, in
terms of mean yearly increases in core
damage frequency (CDF) and large early
release frequency (LERF), are risk
neutral or risk beneficial. In addition,
there are no significant temporary risk
increases, as defined by RG 1.177
criteria, associated with the
implementation of the TS end state
changes.
• Avoidance of Risk-Significant
Configurations (Tier 2). The performed
risk analyses, which are based on single
LCOs, shows that there are no high-risk
configurations associated with the TS
end state changes. The reliability of
redundant trains is normally covered by
a single LCO. When multiple LCOs
occur, which affect trains in several
systems, the plant’s risk-informed
configuration risk management program
(CRMP), or the risk assessment and
management program implemented in
response to the Maintenance Rule 10
CFR 50.65(a)(4), shall ensure that highrisk configurations are avoided. As part
of the implementation of TSTF–423, the
licensee has committed to follow
Section 11 of NUMARC 93–01, Revision
3, and include guidance in appropriate
plant procedures and/or administrative
controls to preclude high-risk plant
configurations when the plant is at the
proposed end state. The staff finds that
such guidance is adequate for
preventing risk-significant plant
configurations.
• Configuration Risk Management
(Tier 3). The licensee has a program, as
described above, in place to comply
with 10 CFR 50.65(a)(4) to assess and
manage the risk from maintenance
activities. This program can support a
licensee decision in selecting the
appropriate actions to control risk for
most cases in which a risk-informed TS
is entered.
The generic risk impact of the end
state mode change was evaluated
subject to the following assumptions
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which are incorporated into the TS, TS
Bases, and TSTF–IG–05–02 (Reference
8):
1. The entry into the end state is
initiated by the inoperability of a single
train of equipment or a restriction on a
plant operational parameter, unless
otherwise stated in the applicable
technical specification.
2. The primary purpose of entering
the end state is to correct the initiating
condition and return to power as soon
as is practical.
3. When Mode 3 is entered as the
repair end state, the time the reactor
coolant pressure is above 500 psig will
be minimized. If reactor coolant
pressure is above 500 psig for more than
12 hours, the associated plant risk will
be assessed and managed.
These assumptions are consistent
with typical entries into Mode 3 for
short duration repairs, which is the
intended use of the TS end state
changes.
The staff concludes that, in general,
going to Mode 3 (hot shutdown) instead
of going to Mode 4 (cold shutdown) to
carry out equipment repairs that are of
short duration, does not have any
adverse effect on plant risk.
3.2
Assessment of TS Changes
The changes proposed by the licensee
and in TSTF–423 are consistent with
the changes in topical report GE NEDC–
32988 (Reference 1), and approved by
the NRC SE (Reference 6). The following
are the changes, including a synopsis of
the STS LCO, and a conclusion of
acceptability.
3.2.1 Topical Report Section (TRS)
4.5.1.2 and LCO 3.4.3 (BWR/4); TRS
4.5.2.2 and LCO 3.4.4 (BWR/6), Safety/
Relief Valves (SRVs).
The function of the SRVs is to protect
the plant against severe
overpressurization events. These TS
provide the operability requirements for
the SRVs as described below. The TS
change allows the plant to remain in
Mode 3 until the repairs are completed.
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[Note: Plant Applicability, BWR4/6]
LCO: The safety function of 11 SRVs
must be operable (BWR/4 plants). The
safety function of seven SRVs must be
operable and the relief function of seven
additional SRVs must be operable
(BWR/6 plants).
Condition requiring entry into end
state: If the LCO cannot be met with one
or two SRVs inoperable, the inoperable
valves must be returned to operability
within 14 days. If the SRVs cannot be
returned to operable status within that
time, the plant must be placed in Mode
3 within 12 hours and in Mode 4 within
36 hours.
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Modification for end state required
actions: If the LCO cannot be met with
one or two SRVs inoperable, the
inoperable valves must be returned to
operability within 14 days. If the one or
two inoperable SRVs cannot be returned
to operable status within 14 days, the
plant must be placed in Mode 3 within
12 hours. If three or more SRVs become
inoperable, the plant must be placed in
Mode 4 within 36 hours.
Assessment: The BWROG topical
report did a comparative PRA
evaluation of the core damage risks of
operation in the current end state and in
the Mode 3 end state. The evaluation
indicates that the core damage risks are
lower in Mode 3 than in Mode 4. Going
to Mode 4 for one inoperable SRV
would cause loss of the high-pressure
steam-driven injection system (reactor
core isolation cooling (RCIC)/high
pressure coolant injection (HPCI)), and
loss of the power conversion system
(condenser/feedwater), and require
activating the residual heat removal
(RHR) system. In addition, emergency
operating procedures (EOPs) direct the
operator to take control of the
depressurization function if low
pressure injection/spray systems are
needed for reactor pressure vessel (RPV)
water makeup and cooling. Based on the
low probability of loss of the necessary
overpressure protection function and
the number of systems available in
Mode 3, the staff concluded in the SE
(reference 6) for the BWROG topical
report that the risks of staying in Mode
3 are approximately the same as, and in
some cases lower than, the risks of going
to the Mode 4 end state. The change
allows the inoperable SRV to be
repaired in a plant operating mode with
lower risks. After repairs are made, the
plant can be brought to full-power
operation with less potential for
transients and errors. The plant is taken
into cold shutdown only when three or
more SRVs are inoperable.
Finding: Based on the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the staff
finds that the requested change to allow
operation in Mode 3 with a minimum
number of SRVs inoperable, after plant
risk has been assessed and managed, is
acceptable.
3.2.2 TRS 4.5.1.3 and LCO
3.5.1(BWR/4); TRS 4.5.2.3 and LCO
3.5.1 (BWR/6), Emergency Core Cooling
Systems (ECCS) (Operating).
The ECCS systems provide cooling
water to the core in the event of a lossof-coolant accident (LOCA). This set of
ECCS TS provide the operability
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requirements for the various ECCS
subsystems as described below. This TS
change would delete the secondary
actions. The plant can remain in Mode
3 until the required repair actions are
completed. The reactor is not
depressurized.
[Note: Plant Applicability, BWR4/6]
LCO: Each ECCS injection/spray
subsystem and the automatic
depressurization system (ADS) function
of seven BWR/4, or eight BWR/6, SRVs
must be operable.
Conditions requiring entry into end
state: If the LCO cannot be met, the
following actions must be taken for the
listed conditions:
a. If one low-pressure ECCS injection/
spray subsystem is inoperable, the
subsystem must be restored to operable
status in 7 days.
b. If the inoperable ECCS injection/
core spray cannot be restored to
operable status, the plant must be
placed in Mode 3 within 12 hours and
Mode 4 within 36 hours (BWR/4 plants
only).
c. If two ECCS injection subsystems
are inoperable or one ECCS injection
subsystem and one ECCS spray system
are inoperable, one ECCS injection/
spray subsystem must be restored to
operable status within 72 hours. If this
required action cannot be met, the plant
must be placed in Mode 3 within 12
hours and in Mode 4 within 36 hours
(BWR/6 plants only).
d. If the HPCI/High Pressure Core
Spray (HPCS) system is inoperable, the
RCIC system must be verified to be
operable by administrative means
within 1 hour and the HPCI/HPCS
system restored to operable status
within 14 days.
e. If one ADS valve is inoperable, it
must be restored to operable status
within 14 days.
f. If one ADS valve is inoperable and
one low-pressure ECCS injection/spray
subsystem is inoperable, the ADS valve
must be restored to operable status
within 72 hours or the low-pressure
ECCS injection/spray subsystem must
be restored to operable status within 72
hours.
g. If two or more ADS valves become
inoperable, or the required actions
described in items e and/or f cannot be
met, the plant must be placed in Mode
3 within 12 hours and the reactor steam
dome pressure reduced to less than 150
psig within 36 hours.
Modification for End State Required
Actions:
a. No change
b. If the ECCS injection or spray
system is inoperable, the plant must be
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restored to operable status within 12
hours. The plant is not taken into Mode
4 (cold shutdown).
c. If two ECCS injection subsystems
are inoperable or one ECCS injection
subsystem and one ECCS spray system
are inoperable, one ECCS injection/
spray subsystem must be restored to
operable status within 72 hours. If this
required action cannot be met, the plant
must be placed in Mode 3 within 12
hours. The plant is not taken into Mode
4 (BWR/6 plants only).
d. No change
e. No change
f. No change
g. If two or more ADS valves become
inoperable or the required actions
described in item e and/or f cannot be
met, the plant must be placed in Mode
3 within 12 hours. The reactor is not
depressurized and not taken to Mode 4.
Assessment: The BWROG topical
report did a comparative PRA
evaluation of the core damage risks of
operation in the current end state and
the Mode 3 end state. The evaluation
indicates that the core damage risks are
lower in Mode 3 than in the current end
state Mode 4. Going to Mode 4 for one
ECCS subsystem or one ADS valve
would cause loss of the high-pressure
steam-driven injection system (RCIC/
HPCI), and loss of the power conversion
system (condenser/feedwater), and
require activating the RHR system. In
addition, Plant Emergency Operating
Procedures (EOPs) direct the operator to
take control of the depressurization
function if low-pressure injection/spray
systems are needed for RPV water
makeup and cooling. Based on the low
probability of loss of the reactor coolant
inventory and the number of systems
available in Mode 3, the staff concludes
in the SE to the BWR topical report that
the risks of staying in Mode 3 are
approximately the same as, and in some
cases lower than, the risks of going to
the Mode 4 end state.
Finding: Based on the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.3 TRS 4.5.1.4 and LCO 3.5.3
(BWR/4 only), Reactor Core Isolation
Cooling (RCIC) System.
The function of the RCIC system is to
provide reactor coolant makeup during
loss of feedwater and other transient
events. This TS provides the operability
requirements for the RCIC system as
described below. The TS change allows
the plant to remain in Mode 3 until the
repairs are completed.
[Note: Plant Applicability, BWR/4]
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LCO: The RCIC system must be
operable during Modes 1, 2 and 3 when
the reactor steam dome pressure is
greater than 150 psig.
Condition requiring entry into end
state: If the LCO cannot be met, the
following actions must be taken: (a)
Verify by administrative means within 1
hour that the HPCI system is operable,
(b) restore the RCIC system to operable
status within 14 days. If either or both
actions cannot be completed within the
allotted time, the plant must be placed
in Mode 3 within 12 hours and the
reactor steam dome pressure reduced to
less than 150 psig within 36 hours.
Modification for end state required
actions: This TS change keeps the plant
in Mode 3 (hot shutdown) until the
required repairs are completed. The
reactor steam dome pressure is not
reduced to less than 150 psig.
Assessment: This change would allow
the inoperable RCIC system to be
repaired in a plant operating mode with
lower risk and without challenging the
normal shutdown systems. The BWROG
topical report did a comparative PRA
evaluation of the core damage risks of
operation in the current end state and in
the Mode 3 end state. The evaluation
indicates that the core damage risks are
lower in Mode 3 than in Mode 4. Going
to Mode 3 with reactor steam dome
pressure less than 150 psig for
inoperability of RCIC would also cause
loss of the high-pressure steam-driven
injection system HPCI and loss of the
power conversion system (condenser/
feedwater), and would require activating
the RHR system. In addition, Plant EOPs
direct the operator to take control of the
depressurization function if low
pressure injection/spray systems are
needed for RPV water makeup and
cooling. Based on the low probability of
loss of the necessary overpressure
protection function and the number of
systems available in Mode 3, the staff
concludes in the SE to the BWR topical
report that the risks of staying in Mode
3 are approximately the same as, and in
some cases lower than, the risks of going
to the Mode 4 end state.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.4 TRS 4.5.1.6 and LCO 3.6.1.6
(BWR/4); TRS 5.5.2.5 and LCO 3.6.1.6
(BWR/6), Low-Low Set (LLS) Valves.
The function of LLS is to prevent
excessive short-duration SRV cycling
during an overpressure event. This TS
provides operability requirements for
the four LLS SRVs as described below.
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14731
The TS change allows the plant to
remain in Mode 3 until the repairs are
completed.
[Note: Plant Applicability, BWR 4/6]
Conditions requiring entry into end
state: If one LLS valve is inoperable, it
must be returned to operability within
14 days. If the LLS valve cannot be
returned to operable status within the
allotted time, the plant must be placed
in Mode 3 within 12 hours and in Mode
4 within 36 hours.
Modification for end state required
actions: The TS change would keep the
plant in Mode 3 until the required
repair actions are completed. The plant
would not be taken into Mode 4 (cold
shutdown).
Assessment: The BWROG topical
report did a comparative PRA
evaluation of the core damage risks of
operation in the current end state and
the Mode 3 end state. The evaluation
indicates that the core damage risks are
lower in Mode 3 than in Mode 4, the
current end state. Going to Mode 4 for
one LLS inoperable SRV would cause
loss of the high-pressure steam-driven
injection system (RCIC/HPCI), and loss
of the power conversion system
(condenser/feedwater), and would
require activating the RHR system. With
one LLS valve inoperable, the remaining
valves are adequate to perform the
required function. EOPs direct the
operator to take control of the
depressurization function if low
pressure injection/spray systems are
needed for RPV water makeup and
cooling. Based on the low probability of
loss of the necessary overpressure
protection function during the
infrequent and limited time in Mode 3
and the number of systems available in
Mode 3, the staff concludes in the SE to
the BWR topical report that the risks of
staying in Mode 3 are approximately the
same as and in some cases lower than
the risks of going to the Mode 4 end
state. The change allows repairs of the
inoperable SRV to be performed in a
plant operating mode with lower risks.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.5 TRS 4.5.1.1, TRS 4.5.2.1 and
LCO 3.3.8.2, Reactor Protection System
(RPS) Electric Power Monitoring.
RPS Electric Power Monitoring
System is provided to isolate the RPS
bus from the motor generator (MG) set
or an alternate power supply in the
event of over voltage, under voltage, or
under frequency. This system protects
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the load connected to the RPS bus
against unacceptable voltage and
frequency conditions and forms an
important part of the primary success
path of the essential safety circuits.
Some of the essential equipment
powered from the RPS buses includes
the RPS logic, scram solenoids, and
various valve isolation logic. The TS
change allows the plant to remain in
Mode 3 until the repairs are completed.
wwhite on PROD1PC61 with NOTICES
[Note: Plant Applicability, BWR 4/6]
LCO: For Modes 1, 2, 3 and Modes 4
and 5 (with any control rod withdrawn
from a core cell containing one or more
fuel assemblies), two RPS electric power
monitoring assemblies shall be operable
for each in-service RPS motor generator
set or alternate power supply.
Condition Requiring Entry into End
State: If the LCO cannot be met, the
associated in-service power supply(s)
must be removed from service within 72
hours for one Electric Power Assembly
(EPA) inoperable or within one hour for
both EPAs inoperable. In Modes 1, 2,
and 3, if the in-service power supply(s)
cannot be removed from service within
the allotted time, the plant must be
placed in Mode 3 within 12 hours and
Mode 4 within 36 hours.
Modification: The change is to keep
the plant in Mode 3 until the repair
actions are completed. Delete required
action in C.2 which required the plant
to be in Mode 4.
Assessment: To reach Mode 3 per the
TS, there must be a functioning power
supply with degraded protective
circuitry in operation. However, the
over voltage, under voltage, or under
frequency condition must exist for an
extended time period to cause damage.
There is a low probability of this
occurring in the short period of time
that the plant would remain in Mode 3
without this protection.
The specific failure condition of
interest is not risk significant for BWR
PRAs. If the required restoration actions
cannot be completed within the
specified time, going into Mode 4 would
cause loss of the high-pressure steamdriven injection system (RCIC/HPCI)
and loss of the power conversion system
(condenser/feedwater), and would
require activating the RHR system. In
addition, EOPs direct the operator to
take control of the depressurization
function if low pressure injection/spray
systems are needed for RPV water
makeup and cooling. Based on the low
probability of loss of the RPS power
monitoring system during the infrequent
and limited time in Mode 3 and the
number of systems available in Mode 3,
the staff concludes in the SE to the BWR
topical report that the risks of staying in
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Mode 3 are approximately the same as
and in some cases lower than the risks
of going to the Mode 4 end state.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.6 TRS 4.5.1.19 and LCO
3.8.1(BWR/4); TRS 4.5.2.17 and LCO
3.8.1(BWR/6), AC Sources (Operating).
The purpose of the AC electrical
system is to provide during all
situations the power required to put and
maintain the plant in a safe condition
and prevent the release of radioactivity
to the environment.
The Class 1E electrical power
distribution system AC sources consist
of the offsite power source (preferred
power sources, normal and alternate(s)),
and the onsite standby power sources
(e.g., emergency diesel generators
(EDGs)). In addition, many sites provide
a crosstie capability between units.
As required by General Design
Criterion (GDC) 17 of 10 CFR Part 50,
Appendix A, the design of the AC
electrical system provides
independence and redundancy. The
onsite Class 1E AC distribution system
is divided into redundant divisions so
that the loss of any one division does
not prevent the minimum safety
functions from being performed. Each
division has connections to two
preferred offsite power sources and a
single EDG or other Class 1E Standby
AC power source.
Offsite power is supplied to the unit
switchyard(s) from the transmission
network by two transmission lines.
From the switchyard(s), two electrically
and physically separated circuits
provide AC power through a stepdown
transformer(s) to the 4.16-kV emergency
buses.
In the event of a loss of offsite power,
the emergency electrical loads are
automatically connected to the EDGs in
sufficient time to provide for a safe
reactor shutdown and to mitigate the
consequence of a design basis accident
(DBA) such as a LOCA.
[Note: Plant Applicability, BWR 4/6]
LCO: The following AC electrical
power sources shall be operable in
Modes 1, 2, and 3:
a. Two qualified circuits between the
offsite transmission network and the
onsite Class1E AC Electric Power
Distribution System,
b. Three EDGs,
c. Automatic Load Sequencers.
Condition requiring entry into end
state: Plant operators must bring the
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plant to Mode 4 within 36 hours
following the sustained inoperability of
one required Automatic Load
Sequencer; either or both required
offsite circuits; either one, two or three
required EDGs; or one required offsite
circuit and one, two or three required
EDGs.
Modification for end state require
actions: Delete required action G.2 to go
to Mode 4 (cold shutdown). The plant
will remain in Mode 3 (hot shutdown).
Assessment: Entry into any of the
conditions for the AC power sources
implies that the AC power sources have
been degraded and the single failure
protection for the safe shutdown
equipment may be ineffective.
Consequently, as specified in TS 3.8.1 at
present, the plant operators must bring
the plant to Mode 4 when the required
action is not completed by the specified
time for the associated action.
The BWROG topical report did a
comparative PRA evaluation of the core
damage risks of operation in the current
end state and in the Mode 3 end state.
Events initiated by the loss of offsite
power are dominant contributors to core
damage frequency in most BWR PRAs,
and the steam-driven core cooling
systems, RCIC and HPCI, play a major
role in mitigating these events. The
evaluation indicates that the core
damage risks are lower in Mode 3 than
in Mode 4 for one inoperable AC power
source. Going to Mode 4 for one
inoperable AC power source would
cause loss of the high-pressure steamdriven injection system (RCIC/HPCI),
and loss of the power conversion system
(condenser/feedwater), and require
activating the RHR system. In addition,
EOPs direct the operator to take control
of the depressurization function if low
pressure injection/spray systems are
needed for RPV water makeup and
cooling. Based on the low probability of
loss of the AC power and the number of
steam-driven systems available in Mode
3, the staff concludes in the SE to the
BWR topical report that the risks of
staying in Mode 3 are lower than going
to the Mode 4 end state.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.7 TRS 4.5.1.20 and LCO 3.8.4
(BWR/4); TRS 4.5.2.18 and LCO 3.8.4
DC Sources (Operating).
The purpose of the DC power system
is to provide a reliable source of DC
power for both normal and abnormal
conditions. It must supply power in an
emergency for an adequate length of
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time until normal supplies can be
restored.
The DC electrical system:
a. Provides the AC emergency power
system with control power,
b. Provides motive and control power
to selected safety related equipment,
and
c. Provides power to preferred AC
vital buses (via inverters).
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[Note: Plant Applicability, BWR 4/6]
LCO: For Modes 1, 2 and 3, the
following DC sources are required to be
operable: BWR/4: The (Division 1 and
Division 2 station service, and DG 1B,
2A, and 2C) DC electrical power systems
shall be operable.
BWR/6: The (Divisions 1, 2, and 3) DC
electrical power subsystems shall be
operable.
Condition requiring entry into end
state: The plant operators must bring the
plant to Mode 3 within 12 hours and
Mode 4 within 36 hours following the
sustained inoperability of one DC
electrical power subsystem for a period
of 2 hours.
Modification for end state required
actions: The TS change is to remove the
requirement to place the plant in Mode
4, Required Actions in D.2 (BWR/4) and
E.2 (BWR/6) are deleted.
Assessment: If one of the DC electrical
power subsystems is inoperable, the
remaining DC electrical power
subsystems have the capacity to support
a safe shutdown and to mitigate an
accident condition. The BWROG topical
report did a comparative PRA
evaluation of the core damage risks of
operation in the current end state and in
the Mode 3 end state, with one DC
system inoperable. Events initiated by
the loss of offsite power are dominant
contributors to core damage frequency
in most BWR PRAs, and the steamdriven core cooling systems, RCIC and
HPCI, play a major role in mitigating
these events. The evaluation indicates
that the core damage risks are lower in
Mode 3 than in Mode 4. Going to Mode
4 for one inoperable DC power source
would cause loss of the high-pressure
steam-driven injection system (RCIC/
HPCI), and loss of the power conversion
system (condenser/feedwater), and
require activating the RHR system. In
addition, EOPs direct the operator to
take control of the depressurization
function if low pressure injection/spray
systems are needed for RPV water
makeup and cooling. Based on the low
probability of loss of the DC power and
the number of systems available in
Mode 3, the staff concludes in the SE to
the BWR topical report that the risks of
staying in Mode 3 are approximately the
same as and in some cases lower than
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the risks of going to the Mode 4 end
state.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.8 TRS 4.5.1.21 and LCO 3.8.7
(BWR/4); TRS 4.5.2.19 and 3.8.7 (BWR/
6), Inverters (Operating).
In Modes 1,2,and 3, the inverters
provide the preferred source of power
for the 120-VAC vital buses which
power the reactor protection system
(RPS) and the Emergency Core Cooling
Systems (ECCS) initiation. The inverter
can be powered from an internal AC
source/rectifier or from the station
battery.
[Note: Plant Applicability, BWR 4/6]
LCO: For Modes 1, 2, and 3 the
following Inverters shall be operable:
BWR/4: The (Division 1 and Division
2) shall be operable.
BWR/6: The (Divisions 1, 2, and 3)
shall be operable.
Condition requiring entry into end
state: The plant operators must bring the
plant to Mode 3 within 12 hours and
Mode 4 within 36 hours following the
sustained inoperability of the required
inverter for a period of 24 hours.
Modification for end state required
actions: The TS change is to remove the
requirement to place the plant in Mode
4. Required Actions in B.2 (BWR/4) and
C.2 (BWR/6) are deleted.
Assessment: If one of the Inverters is
inoperable, the remaining Inverters have
the capacity to support a safe shutdown
and to mitigate an accident condition.
The BWROG topical report did a
comparative PRA evaluation of the core
damage risks of operation in the current
end state and in the Mode 3 end state,
with an inoperable Inverter. Events
initiated by the loss of offsite power are
dominant contributors to core damage
frequency in most BWR PRAs, and the
steam-driven core cooling systems, RCIC
and HPCI, play a major role in
mitigating these events. The evaluation
indicates that the core damage risks are
lower in Mode 3 than in Mode 4. Going
to Mode 4 for one inoperable Inverter
power source would cause loss of the
high-pressure steam-driven injection
system (RCIC/HPCI), and loss of the
power conversion system (condenser/
feedwater), and require activating the
RHR system. In addition, EOPs direct
the operator to take control of the
depressurization function if low
pressure injection/spray systems are
needed for RPV water makeup and
cooling. Based on the low probability of
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14733
loss of the Inverters during the
infrequent and limited time in Mode 3
and the number of systems available in
Mode 3, the staff concludes in the SE to
the BWR topical report that the risks of
staying in Mode 3 are approximately the
same as and in some cases lower than
the risks of going to the Mode 4 end
state.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.9 TRS 4.5.1.22 and LCO 3.8.9
(BWR/4); TRS 4.5.2.20 and LCO 3.8.9
(BWR/6), Distribution
Systems(Operating).
The onsite Class 1E AC and DC
electrical power distribution system is
divided into redundant and
independent AC, DC, and AC vital bus
electrical power distribution systems.
The primary AC electrical power
distribution subsystem for each division
consists of a 4.16-kV Engineered Safety
Feature (ESF) bus having an offsite
source of power as well as a dedicated
onsite EDG source. The secondary plant
distribution subsystems include 600VAC emergency buses and associated
load centers, motor control centers,
distribution panels and transformers.
The 120-VAC vital buses are arranged in
four load groups and normally powered
from DC via the inverters. There are two
independent 125/250-VDC station
service electrical power distribution
systems and three independent 125VDC DG electrical power distribution
subsystems that support the necessary
power for ESF functions. Each
subsystem consists of a 125-VDC and
250-VDC bus and associated
distribution panels.
[Note: Plant Applicability, BWR 4/6]
LCO: For Modes 1,2, and 3, the
following electrical power distribution
subsystems shall be operable:
BWR/4: The Division 1 and Division
2 AC, DC, and AC vital buses shall be
operable.
BWR/6: The Divisions 1, 2, and 3 AC,
DC, and AC vital buses shall be
operable.
Condition requiring entry into end
state: The plant operators must bring the
plant to Mode 3 within 12 hours and
Mode 4 within 36 hours following the
sustained inoperability of one AC or one
DC or one AC vital bus electrical power
subsystem for a period of 8 hours, 2
hours and 2 hours, respectively (with a
maximum 16 hour Completion Time
limit from initial discovery of failure to
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meet the LCO, to preclude being in the
LCO indefinitely).
Modification for end state required
actions: The TS change is to remove the
requirement to place the plant in Mode
4, Required Action in D.2 (BWR/4) and
D.2 (BWR/6) are deleted.
Assessment: If one of the AC/DC/AC
vital subsystems is inoperable, the
remaining AC/DC/AC vital subsystems
have the capacity to support a safe
shutdown and to mitigate an accident
condition. The BWROG topical report
did a comparative PRA evaluation of the
core damage risks of operation in the
current end state and in the Mode 3 end
state, with one of the AC/DC/AC vital
subsystems inoperable. Events initiated
by the loss of offsite power are
dominant contributors to core damage
frequency in most BWR PRAs, and the
steam-driven core cooling systems, RCIC
and HPCI, play a major role in
mitigating these events. The evaluation
indicates that the core damage risks are
lower in Mode 3 than in Mode 4. Going
to Mode 4 for one inoperable AC/DC/AC
vital subsystem would cause loss of the
high-pressure steam-driven injection
system (RCIC/HPCI), and loss of the
power conversion system (condenser/
feedwater), and require activating the
RHR system. In addition, EOPs direct
the operator to take control of the
depressurization function if low
pressure injection/spray systems are
needed for RPV water makeup and
cooling. Based on the low probability of
loss of the AC/DC/AC vital electrical
subsystems during the infrequent and
limited time in Mode 3 and the number
of systems available in Mode 3, the staff
concludes in the SE to the BWR topical
report that the risks of staying in Mode
3 are approximately the same as and in
some cases lower than the risks of going
to the Mode 4 end state.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.10 TRS 4.5.1.5 and LCO 3.6.1.1,
Primary Containment.
The function of the primary
containment is to isolate and contain
fission products released from the
Reactor Primary System following a
design basis LOCA and to confine the
postulated release of radioactivity. The
primary containment consists of a steellined, reinforced concrete vessel, which
surrounds the Reactor Primary System
and provides an essentially leak-tight
barrier against an uncontrolled release
of radioactivity to the environment.
Additionally, this structure provides
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shielding from the fission products that
may be present in the primary
containment atmosphere following
accident conditions.
[Note: Plant Applicability, BWR 4/6]
LCO: The primary containment shall
be operable.
Condition Requiring Entry into End
State: If the LCO cannot be met, the
primary containment must be returned
to operability within one hour (Required
Action A.1). If the primary containment
cannot be returned to operable status
within the allotted time, the plant must
be placed in Mode 3 within 12 hours
(Required Action B.1) and in Mode 4
within 36 hours (Required Action B.2).
Modification for End State Required
Actions: Delete Required Action B.2.
Assessment: The primary
containment is one of the three primary
boundaries to the release of
radioactivity. (The other two are the fuel
cladding and the Reactor Primary
System pressure boundary.) Compliance
with this LCO ensures that a primary
containment configuration exists,
including equipment hatches and
penetrations, that is structurally sound
and will limit leakage to those leakage
rates assumed in the safety analyses.
This LCO entry condition does not
include leakage through an unisolated
release path. The BWROG topical report
has determined that previous generic
PRA work related to Appendix J
requirements has shown that
containment leakage is not risk
significant. Should a fission product
release from the primary containment
occur, the secondary containment and
related functions would remain
operable to contain the release, and the
standby gas treatment system would
remain available to filter fission
products from being released to the
environment. By remaining in Mode 3,
HPCI, RCIC, and the power conversion
system (condensate/feedwater) remain
available for water makeup and decay
heat removal. Additionally, the EOPs
direct the operators to take control of
the depressurization function if low
pressure injection/spray are needed for
reactor coolant makeup and cooling.
Therefore, defense-in-depth is
maintained with respect to water
makeup and decay heat removal by
remaining in Mode 3.
Finding: The requested change is
acceptable. Note that the staff’s approval
relies upon the secondary containment
and the standby gas treatment system
for maintaining defense-in-depth while
in this reduced end state.
3.2.11 TRS 4.5.1.7 and LCO 3.6.1.7,
Reactor Building-to-Suppression
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Chamber Vacuum Breakers(BWR/4
only).
The reactor building-to-suppression
chamber vacuum breakers relieve
vacuum when the primary containment
depressurizes below the pressure of the
reactor building, thereby serving to
preserve the integrity of the primary
containment.
[Note: Plant Applicability, BWR/4]
LCO: Each reactor building-tosuppression chamber vacuum breaker
shall be operable.
Condition Requiring Entry into End
State: If one line has one or more reactor
building-to-suppression chamber
vacuum breakers inoperable for
opening, the breaker(s) must be returned
to operability within 72 hours (Required
Action C.1). If the vacuum breaker(s)
cannot be returned to operability within
the allotted time, the plant must be
placed in Mode 3 within 12 hours
(Required Action E.1) and in Mode 4
within 36 hours (Required Action E.2).
Modification for End State Required
Actions: Modify the Required Actions so
that if vacuum breaker(s) cannot be
returned to operable status within the
required Completion Times, the plant is
place in hot shutdown. That is, modify
Condition E to relate only to Condition
C, delete Required Action E.2, and add
Condition F, with Required Actions F.1
and F.2, shutting down the plant to
Mode 3 and then Mode 4 respectively,
to address an inability to comply with
the required actions related to the other
Conditions (i.e., Conditions A, B, and
D).
Assessment: The BWROG topical
report has determined that the specific
failure condition of interest is not risk
significant in BWR PRAs. The reduced
end state would only be applicable to
the situation where the vacuum
breaker(s) in one line are inoperable for
opening, with the remaining operable
vacuum breakers capable of providing
the necessary vacuum relief function.
The existing end state remains
unchanged, as established by new
Condition F, for conditions involving
more than one inoperable line or
vacuum breaker since they are needed
in Modes 1, 2, and 3. In Mode 3, for
other accident considerations, HPCI,
RCIC, and the power conversion system
(condensate/feedwater) remain available
for water makeup and decay heat
removal. Additionally, the EOPs direct
the operators to take control of the
depressurization function if low
pressure injection/spray are needed for
reactor coolant makeup and cooling.
Therefore, defense-in-depth is
maintained with respect to water
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makeup and decay heat removal by
remaining in Mode 3.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.12 TRS 4.5.1.8 and LCO 3.6.1.8,
Suppression Chamber-to-Drywell
Vacuum Breakers(BWR/4 only).
The function of the suppression
chamber-to-drywell vacuum breakers is
to relieve vacuum in the drywell,
thereby preventing an excessive
negative differential pressure across the
wetwell/drywell boundary.
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[Note: Plant Applicability, BWR/4]
LCO: Nine suppression chamber-todrywell vacuum breakers shall be
operable for opening.
Condition Requiring Entry into End
State: If one suppression chamber-todrywell vacuum breaker is inoperable
for opening, the breaker must be
returned to operability within 72 hours
(Required Action A.1). If the vacuum
breaker cannot be returned to
operability within the allotted time, the
plant must be placed in Mode 3 within
12 hours (Required Action C.1) and in
Mode 4 within 36 hours (Required
Action C.2).
Modification for End State Required
Actions: Modify the Required Actions so
that if vacuum breaker(s) cannot be
returned to operable status within the
required Completion Times, the plant is
placed in hot shutdown. That is, modify
Condition C to relate only to Condition
A, and delete Required Action C.2, and
add Condition D, with Required Actions
D.1 and D.2, shutting down the plant to
Mode 3 and then Mode 4 respectively,
to address an inability to comply with
the required actions related to Condition
B, to close the vacuum breaker.
Assessment: The BWROG topical
report has determined that the specific
failure of interest is not risk significant
in BWR PRAs. The reduced end state
would only be applicable to the
situation where one suppression
chamber-to-drywell vacuum breaker is
inoperable for opening, with the
remaining operable vacuum breakers
capable of providing the necessary
vacuum relief function, since they are
required in Modes 1, 2, and 3. By
remaining in Mode 3, HPCI, RCIC, and
the power conversion system
(condensate/feedwater) remain available
for water makeup and decay heat
removal. Additionally, the EOPs direct
the operators to take control of the
depressurization function if low
pressure injection/spray are needed for
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RCS makeup and cooling. Therefore,
defense-in-depth is maintained with
respect to water makeup and decay heat
removal by remaining in Mode 3. The
existing end state remains unchanged
for conditions involving any
suppression chamber-to-drywell
vacuum breakers that are stuck open, as
established by new Condition D.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.13 TRS 4.5.1.9, TRS 4.5.2.8, and
LCO 3.6.1.9, Main Steam Isolation Valve
(MSIV) Leakage Control System (LCS).
The MSIV LCS supplements the
isolation function of the MSIVs by
processing the fission products that
could leak through the closed MSIVs
after core damage, assuming leakage rate
limits which are based on a large LOCA.
[Note: Plant Applicability, BWR 4/6]
LCO: Two MSIV LCS subsystems shall
be operable.
Condition Requiring Entry into End
State: If one MSIV LCS subsystem is
inoperable, it must be restored to
operable status within 30 days
(Required Action A.1). If both MSIV
LCS subsystems are inoperable, one of
the MSIV LCS subsystems must be
restored to operable status within seven
days (Required Action B.1). If the MSIV
LCS subsystems cannot be restored to
operable status within the allotted time,
the plant must be placed in Mode 3
within 12 hours (Required Action C.1)
and in Mode 4 within 36 hours
(Required Action C.2).
Modification for End State Required
Actions: Delete Required Action C.2.
Assessment: The BWROG topical
report has determined that this system
is not significant in BWR PRAs and,
based on a BWROG program, many
plants have eliminated the system
altogether. The unavailability of one or
both MSIV LCS subsystems has no
impact on CDF or LERF, irrespective of
the mode of operation at the time of the
accident. Furthermore, the challenge
frequency of the MSIV LCS system (i.e.,
the frequency with which the system is
expected to be challenged to mitigate
offsite radiation releases resulting from
MSIV leaks above TS limits) is less than
1.0E–6/yr. Consequently, the
conditional probability that this system
will be challenged during the repair
time interval while the plant is at either
the current or the proposed end state
(i.e., Mode 4 or Mode 3, respectively) is
less than 1.0E–8. This probability is
considerably smaller than probabilities
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considered ‘‘negligible’’ in Regulatory
Guide 1.177 for much higher
consequence risks, such as large early
release.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.1.9, TRS 4.5.2.8, and LCO
3.6.1.9, ‘‘Main Steam Isolation Valve
(MSIV) Leakage Control System (LCS).’’
The argument for staying in Mode 3
instead of going to Mode 4 to repair the
MSIV LCS system (one or both trains) is
also supported by defense-in-depth
considerations. Section 6.2 makes a
comparison between the Mode 3 and the
Mode 4 end state, with respect to the
means available to perform critical
functions (i.e., functions contributing to
the defense-in-depth philosophy) whose
success is needed to prevent core
damage and containment failure and
mitigate radiation releases. The risk and
defense-in-depth arguments, used
according to the ‘‘integrated decisionmaking’’ process of Regulatory Guides
1.174 and 1.177, support the conclusion
that the plant in Mode 3 is as safe as
Mode 4 (if not safer) for repairing an
inoperable MSIV LCS system. Personnel
safety must be considered separately.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.14 TRS 4.5.1.11 and LCO 3.6.2.4,
Residual Heat Removal (RHR)
Suppression Pool Spray(BWR/4 only).
Following a DBA, the RHR
suppression pool spray system removes
heat from the suppression chamber
airspace. A minimum of one RHR
suppression pool spray subsystem is
required to mitigate potential bypass
leakage paths from drywell and
maintain the primary containment peak
pressure below the design limits.
[Note: Plant Applicability, BWR/4]
LCO: Two RHR suppression pool
spray subsystems shall be operable.
Condition Requiring Entry into End
State: If one RHR suppression pool
spray subsystem is inoperable
(Condition A), it must be restored to
operable status within seven days
(Required Action A.1). If both RHR
suppression pool spray subsystems are
inoperable (Condition B), one of them
must be restored to operable status
within eight hours (Required Action
B.1). If the RHR suppression pool spray
subsystem cannot be restored to
operable status within the allotted time,
the plant must be placed in Mode 3
within 12 hours (Required Action C.1),
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and in Mode 4 within 36 hours
(Required Action C.2).
Modification for End State Required
Actions: Delete Required Action C.2.
Assessment: The main function of the
RHR suppression spray system is to
remove heat from the suppression
chamber so that the pressure and
temperature inside primary containment
remain within analyzed design limits.
The RHR suppression spray system was
designed to mitigate potential effects of
a postulated DBA, that is, a large LOCA
which is assumed to occur concurrently
with the most limiting single failure and
conservative inputs, such as for initial
suppression pool water volume and
temperature. Under the conditions
assumed in the DBA, steam blown down
from the break could bypass the
suppression pool and end up in the
suppression chamber air space and the
RHR suppression spray system could be
needed to condense such steam so that
the pressure and temperature inside
primary containment remain within
analyzed design basis limits. However,
the frequency of a DBA is very small
and the containment has considerable
margin to failure above the design
limits. For these reasons, the
unavailability of one or both RHR
suppression spray subsystems has no
significant impact on CDF or LERF,
even for accidents initiated during
operation at power. Therefore, it is very
unlikely that the RHR suppression spray
system will be challenged to mitigate an
accident occurring during power
operation. This probability becomes
extremely unlikely for accidents that
would occur during a small fraction of
the year (less than three days) during
which the plant would be in Mode 3
(associated with lower initial energy
level and reduced decay heat load as
compared to power operation) to repair
the failed RHR suppression spray
system.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.1.11 and LCO 3.6.2.4, ‘‘Residual
Heat Removal (RHR) Suppression Pool
Spray.’’ The argument for staying in
Mode 3 instead of going to Mode 4 to
repair the RHR Suppression Pool Spray
system (one or both trains) is also
supported by defense-in-depth
considerations. Section 6.2 makes a
comparison between the Mode 3 and the
Mode 4 end state, with respect to the
means available to perform critical
functions (i.e., functions contributing to
the defense-in-depth philosophy) whose
success is needed to prevent core
damage and containment failure and
mitigate radiation releases, and
precluding the need for RHR
suppression spray subsystems.
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In addition, the probability of a DBA
(large break) is much smaller during
shutdown as compared to power
operation. A DBA in Mode 3 would be
considerably less severe than a DBA
occurring during power operation since
Mode 3 is associated with lower initial
energy level and reduced decay heat
load. Under these extremely unlikely
conditions, an alternate method that can
be used to remove heat from the primary
containment (in order to keep the
pressure and temperature within the
analyzed design basis limits) is
containment venting. For more realistic
accidents that could occur in Mode 3,
several alternate means are available to
remove heat from the primary
containment, such as the RHR system in
the suppression pool cooling mode and
the containment spray mode.
The risk and defense-in-depth
arguments, used according to the
‘‘integrated decision-making’’ process of
Regulatory Guides 1.174 and 1.177,
support the conclusion that Mode 3 is
as safe as Mode 4 (if not safer) for
repairing an inoperable RHR
suppression spray system.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.15 TRS 4.5.1.12, TRS 4.5.2.10,
and LCO 3.6.4.1, Secondary
Containment.
Following a DBA, the function of the
secondary containment is to contain,
dilute, and stop radioactivity (mostly
fission products) that may leak from
primary containment. Its leak tightness
is required to ensure that the release of
radioactivity from the primary
containment is restricted to those
leakage paths and associated leakage
rates assumed in the accident analysis
and that fission products entrapped
within the secondary containment
structure will be treated by the standby
gas treatment system prior to discharge
to the environment.
[Note: Plant Applicability, BWR 4/6]
LCO: The secondary containment
shall be operable.
Condition Requiring Entry into End
State: If the secondary containment is
inoperable, it must be restored to
operable status within four hours
(Required Action A.1). If it cannot be
restored to operable status within the
allotted time, the plant must be placed
in Mode 3 within 12 hours (Required
Action B.1), and in Mode 4 within 36
hours (Required Action B.2).
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Modification for End State Required
Actions: Delete Required Action B.2.
Assessment: This LCO entry
condition does not include gross leakage
through an unisolable release path. The
BWROG topical report has determined
that previous generic PRA work related
to Appendix J requirements has shown
that containment leakage is not risk
significant. The primary containment,
and all other primary and secondary
containment-related functions would
still be operable, including the standby
gas treatment system, thereby
minimizing the likelihood of an
unacceptable release. By remaining in
Mode 3, HPCI, RCIC, and the power
conversion system (condensate/
feedwater) remain available for water
makeup and decay heat removal.
Additionally, the EOPs direct the
operators to take control of the
depressurization function if low
pressure injection/spray are needed for
RCS makeup and cooling. Therefore,
defense-in-depth is improved with
respect to water makeup and decay heat
removal by remaining in Mode 3.
Finding: The requested change is
acceptable. Note that the staff’s approval
relies upon the primary containment,
and all other primary and secondary
containment-related functions, to still
be operable, including the standby gas
treatment system, for maintaining
defense-in-depth while in this end state.
3.2.16 TRS 4.5.1.13, TRS 4.5.2.11,
and LCO 3.6.4.3, Standby Gas
Treatment (SGT) System.
The function of the SGT system is to
ensure that radioactive materials that
leak from the primary containment into
the secondary containment following a
DBA are filtered and adsorbed prior to
exhausting to the environment.
Applicability: BWR4/6.
LCO: Two SGT subsystems shall be
operable.
Condition Requiring Entry into End
State: If one SGT subsystem is
inoperable, it must be restored to
operable status within seven days
(Required Action A.1). If the SGT
subsystem cannot be restored to
operable status within the allotted time,
the plant must be placed in Mode 3
within 12 hours (Required Action B.1)
and in Mode 4 within 36 hours
(Required Action B.2). In addition, if
two SGT subsystems are inoperable in
Mode 1, 2, or 3, LCO 3.0.3 must be
entered immediately (Required Action
D.1).
Modification for End State Required
Actions: Delete Required Action B.2.
Change Required Action D.1 to ‘‘Be in
Mode 3’’ with a Completion Time of ‘‘12
hours.’’
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Assessment: The unavailability of one
or both SGT subsystems has no impact
on CDF or LERF, irrespective of the
mode of operation at the time of the
accident. Furthermore, the challenge
frequency of the SGT system (i.e., the
frequency with which the system is
expected to be challenged to mitigate
offsite radiation releases resulting from
materials that leak from the primary to
the secondary containment above TS
limits) is less than 1.0E–6/yr.
Consequently, the conditional
probability that this system will be
challenged during the repair time
interval while the plant is at either the
current or the proposed end state (i.e.,
Mode 4 or Mode 3, respectively) is less
than 1.0E–8. This probability is
considerably smaller than probabilities
considered ‘‘negligible’’ in Regulatory
Guide 1.177 for much higher
consequence risks, such as large early
release.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.1.13, TRS 4.5.2.11, and LCO
3.6.4.3, ‘‘Standby Gas Treatment (SGT)
System.’’ The argument for staying in
Mode 3 instead of going to Mode 4 to
repair the SGT system (one or both
trains) is also supported by defense-indepth considerations. Section 6.2 makes
a comparison between the Mode 3 and
the Mode 4 end state, with respect to the
means available to perform critical
functions (i.e., functions contributing to
the defense-in-depth philosophy) whose
success is needed to prevent core
damage and containment failure and
mitigate radiation releases. The risk and
defense-in-depth arguments, used
according to the ‘‘integrated decisionmaking’’ process of Regulatory Guides
1.174 and 1.177, support the conclusion
that Mode 3 is as safe as Mode 4 (if not
safer) for repairing an inoperable SGT
system.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.17 TRS 4.5.1.14 and LCO 3.7.1,
Residual Heat Removal Service Water
(RHRSW) System (BWR/4 only).
The RHRSW system is designed to
provide cooling water for the RHR
system heat exchangers, which are
required for safe shutdown following a
normal shutdown or DBA or transient.
[Note: Plant Applicability, BWR/4]
LCO: Two RHRSW subsystems shall
be operable.
Condition Requiring Entry into End
State: If the LCO cannot be met, the
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following actions must be taken for the
listed conditions:
a. If one RHRSW pump is inoperable
(Condition A), it must be restored to
operable status within 30 days
(Required Action A.1).
b. If one RHRSW pump in each
subsystem is inoperable (Condition B),
one RHRSW pump must be restored to
operable status within seven days
(Required Action B.1).
c. If one RHRSW subsystem is
inoperable for reasons other than
Condition A (Condition C), the RHRSW
subsystem must be restored to operable
status within seven days (Required
Action C.1).
d. If the required action and
associated completion time cannot be
met within the allotted time (Condition
E), the plant must be placed in Mode 3
within 12 hours (Required Action E.1)
and in Mode 4 within 36 hours
(Required Action E.2). {Note: Condition
D addresses both RHRSW subsytems
inoperable for reason other than
Condition B, and its Required Action
D.1 is not affected by this change.
Modification for End State Required
Actions: Renumber Conditions D (and
Required Action D.1), and E (and
Required Actions E.1 and E.2), to
Conditions E (and Required Action E.1)
and F (and Required Actions F.1 and
F.2), respectively. Modify new
Condition F to address new Condition
E, which maintains the existing
requirements with respect to both RHR
subsystems being inoperable for reasons
other than Condition B. Add a new
Condition D, which establishes
requirements for existing Conditions A,
B, and C, that are similar to existing
Condition E but without Required
Action E.2.
Assessment: The BWROG topical
report performed a comparative PRA
evaluation of the core damage risks
when operating in the current end state
versus the Mode 3 end state. The results
indicated that the core damage risks
while operating in Mode 3 (assuming
the individual failure conditions) are
lower or comparable to the current end
state. By remaining in Mode 3, HPCI,
RCIC, and the power conversion system
(condensate/feedwater) remain available
for water makeup and decay heat
removal. Additionally, the EOPs direct
the operators to take control of the
depressurization function if low
pressure injection/spray are needed for
RCS makeup and cooling. Therefore,
defense-in-depth is improved with
respect to water makeup and decay heat
removal by remaining in Mode 3, and
the required safety function can still be
performed with the RHRSW subsystem
components that are still operable.
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Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.18 TRS 4.5.1.15 and LCO 3.7.2,
Plant Service Water (PSW) System and
Ultimate Heat Sink (UHS) (BWR/4 only).
The PSW system (in conjunction with
the UHS) is designed to provide cooling
water for the removal of heat from
certain safe shutdown-related
equipment heat exchangers following a
DBA or transient.
[Note: Plant Applicability, BWR/4]
LCO: Two PSW subsystems and UHS
shall be operable.
Condition Requiring Entry into End
State: If the LCO cannot be met, the
following actions must be taken for the
listed conditions:
a. If one PSW pump is inoperable
(Condition A), it must be restored to
operable status within 30 days
(Required Action A.1).
b. If one PSW pump in each
subsystem is inoperable (Condition B),
one PSW pump must be restored to
operable status within seven days
(Required Action B.1).
c. If the required action and
associated completion time cannot be
met within the allotted time, the plant
must be placed in Mode 3 within 12
hours (Required Action E.1) and in
Mode 4 within 36 hours (Required
Action E.2).
Modification: Renumber unaffected
Conditions C, D, E, and F to Conditions
D, E, F, and G respectively, and
renumber associated Required Actions
accordingly. Add a new Condition C, for
the Required Actions and associated
Completion Time of Conditions A and
B not met, with a Required Action C.1,
to be in Mode 3 in a Completion Time
of 12 hours. Change the new Condition
G to read, ‘‘Required Action and
associated Completion Time of
Condition E not met, OR Both [PSW
subsystems inoperable for reasons other
than Condition(s) B [and D], [OR [UHS]
inoperable for reasons other than
Conditions D [or E].’’
Assessment: The BWROG topical
report performed a comparative PRA
evaluation of the core damage risks
associated with operating in the current
end state versus the Mode 3 end state.
The results indicated that the core
damage risks while operating in Mode 3
(assuming the individual failure
conditions) are lower or comparable to
the current end state. With one pump
inoperable in one or more subsystems,
the remaining pumps are adequate to
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perform the PSW heat removal function.
By remaining in Mode 3, HPCI, RCIC,
and the power conversion system
(condensate/feedwater) remain available
for water makeup and decay heat
removal. Additionally, the EOPs direct
the operators to take control of the
depressurization function if low
pressure injection/spray are needed for
RCS makeup and cooling. Therefore,
defense-in-depth is improved with
respect to water makeup and decay heat
removal by remaining in Mode 3.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.19 TRS 4.5.1.16 and LCO 3.7.4,
Main Control Room Environmental
Control (MCREC) System (BWR/4 only).
The MCREC system provides a
radiologically controlled environment
from which the plant can be safely
operated following a DBA.
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[Note: Plant Applicability, BWR/4]
LCO: Two MCREC subsystems shall
be operable.
Condition Requiring Entry into End
State: If one MCREC subsystem is
inoperable, it must be restored to
operable status within seven days
(Required Action A.1). If the MCREC
subsystem cannot be restored to
operable status within the allotted time,
the plant must be placed in Mode 3
within 12 hours (Required Action B.1)
and in Mode 4 within 36 hours
(Required Action B.2). If two MCREC
subsystems are inoperable in Mode 1, 2,
or 3, LCO 3.0.3 must be entered
immediately (Required Action D.1).
Modification for End State Required
Actions: Delete Required Action B.2,
and change Required Action D.1 to ‘‘Be
in Mode 3’’ with a Completion Time of
‘‘12 hours.’’
Assessment: The unavailability of one
or both MCREC subsystems has no
significant impact on CDF or LERF,
irrespective of the mode of operation at
the time of the accident. Furthermore,
the challenge frequency of the MCREC
system (i.e., the frequency with which
the system is expected to be challenged
to provide a radiologically controlled
environment in the main control room
following a DBA which leads to core
damage and leaks of radiation from the
containment that can reach the control
room) is less than 1.0E–6/yr.
Consequently, the conditional
probability that this system will be
challenged during the repair time
interval while the plant is at either the
current or the proposed end state (i.e.,
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Mode 4 or Mode 3, respectively) is less
than 1.0E–8. This probability is
considerably smaller than probabilities
considered ‘‘negligible’’ in Regulatory
Guide 1.177 for much higher
consequence risks, such as large early
release.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.1.16, and LCO 3.7.4, ‘‘Main
Control Room Environmental Control
(MCREC) System.’’ The argument for
staying in Mode 3 instead of going to
Mode 4 to repair the MCREC system
(one or both trains) is also supported by
defense-in-depth considerations.
Section 6.2 makes a comparison
between the Mode 3 and the Mode 4
end state, with respect to the means
available to perform critical functions
(i.e., functions contributing to the
defense-in-depth philosophy) whose
success is needed to prevent core
damage and containment failure and
mitigate radiation releases. The risk and
defense-in-depth arguments, used
according to the ‘‘integrated decisionmaking’’ process of Regulatory Guides
1.174 and 1.177, support the conclusion
that Mode 3 is as safe as Mode 4 (if not
safer) for repairing an inoperable
MCREC system.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.20 TRS 4.5.1.17 and LCO 3.7.5,
Control Room Air Conditioning (AC)
System (BWR/4 only).
The Control Room AC system
provides temperature control for the
control room following control room
isolation during accident conditions.
[Note: Plant Applicability, BWR/4]
LCO: Two control room AC
subsystems shall be operable.
Condition Requiring Entry into End
State: If one control room AC subsystem
is inoperable, the subsystem must be
restored to operable status within 30
days (Required Action A.1). If the
required actions and associated
completion times cannot be met, the
plant must be placed in Mode 3 within
12 hours (Required Action B.1) and in
Mode 4 within 36 hours (Required
Action B.2). If two control room AC
subsystems are inoperable, LCO 3.0.3
must be entered immediately (Required
Action D.1).
Modification for End State Required
Actions: Delete Required Action B.2,
and change Required Action D.1 to ‘‘Be
in Mode 3’’ with a Completion Time of
‘‘12 hours.’’
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Assessment: The unavailability of one
or both AC subsystems has no
significant impact on CDF or LERF,
irrespective of the mode of operation at
the time of the accident. Furthermore,
the challenge frequency of the AC
system (i.e., the frequency with which
the system is expected to be challenged
to provide temperature control for the
control room following control room
isolation following a DBA) is less than
1.0E–6/yr. Consequently, the
conditional probability that this system
will be challenged during the repair
time interval while the plant is at either
the current or the proposed end state
(i.e., Mode 4 or Mode 3, respectively) is
less than 1.0E–8. This probability is
considerably smaller than probabilities
considered ‘‘negligible’’ in Regulatory
Guide 1.177 for much higher
consequence risks, such as large early
release.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.1.17, and LCO 3.7.5, ‘‘Control
Room Air Conditioning (AC) System.’’
The argument for staying in Mode 3
instead of going to Mode 4 to repair the
AC system (one or both trains) is also
supported by defense-in-depth
considerations. Section 6.2 makes a
comparison between the Mode 3 and the
Mode 4 end state, with respect to the
means available to perform critical
functions (i.e., functions contributing to
the defense-in-depth philosophy) whose
success is needed to prevent core
damage and containment failure and
mitigate radiation releases. The risk and
defense-in-depth arguments, used
according to the ‘‘integrated decisionmaking’’ process of Regulatory Guides
1.174 and 1.177, support the conclusion
that Mode 3 is as safe as Mode 4 (if not
safer) for repairing an inoperable AC
system.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.21 TRS 4.5.1.18 and LCO 3.7.6,
Main Condenser Off gas (BWR/4 only).
The Off gas from the main condenser
normally includes radioactive gases.
The gross gamma activity rate is
controlled to ensure that accident
analysis assumptions are satisfied and
that offsite dose limits will not be
exceeded during postulated accidents.
The main condenser Off gas (MCOG)
gross gamma activity rate is an initial
condition of a DBA which assumes a
gross failure of the MCOG system
pressure boundary.
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[Note: Plant Applicability, BWR/4]
LCO: The gross gamma activity rate of
the noble gases measured at the main
condenser evacuation system
pretreatment monitor station shall be
≤240 mCi/second after decay of 30
minutes.
Condition Requiring Entry into End
State: If the gross gamma activity rate of
the noble gases in the main condenser
Off gas (MCOG) system is not within
limits, the gross gamma activity rate of
the noble gases in the main condenser
Off gas must be restored to within limits
within 72 hours (Required Action A.1).
If the required action and associated
completion time cannot be met, one of
the following must occur:
a. All steam lines must be isolated
within 12 hours (Required Action B.1).
b. The steam jet air ejector (SJAE)
must be isolated within 12 hours
(Required Action B.2).
c. The plant must be placed in Mode
3 within 12 hours (Required Action
B.3.1) and in Mode 4 within 36 hours
(Required Action B.3.2).
Modification for End State Required
Actions: Delete Required Action B.3.2.
Assessment: The failure to maintain
the gross gamma activity rate of the
noble gases in the main condenser Off
gas (MCOG) within limits has no
significant impact on CDF or LERF,
irrespective of the mode of operation at
the time of the accident. Furthermore,
the challenge frequency of the MCOG
system (i.e., the frequency with which
the system is expected to be challenged
to mitigate offsite radiation releases
following a DBA) is less than 1.0E–6/yr.
Consequently, the conditional
probability that this system will be
challenged during the repair time
interval while the plant is at either the
current or the proposed end state (i.e.,
Mode 4 or Mode 3, respectively) is less
than 1.0E–8. This probability is
considerably smaller than probabilities
considered ‘‘negligible’’ in Regulatory
Guide 1.177 for much higher
consequence risks, such as large early
release.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.1.18 and LCO 3.7.6, ‘‘Main
Condenser Off gas.’’ The argument for
staying in Mode 3 instead of going to
Mode 4 to repair the MCOG system (one
or both trains) is also supported by
defense-in-depth considerations.
Section 6.2 makes a comparison
between the Mode 3 and the Mode 4
end state, with respect to the means
available to perform critical functions
(i.e., functions contributing to the
defense-in-depth philosophy) whose
success is needed to prevent core
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damage and containment failure and
mitigate radiation releases. The risk and
defense-in-depth arguments, used
according to the ‘‘integrated decisionmaking’’ process of Regulatory Guides
1.174 and 1.177, support the conclusion
that Mode 3 is as safe as Mode 4 (if not
safer) for repairing an inoperable MCOG
system.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.22 TRS 4.5.2.6 and LCO 3.6.1.7,
Residual Heat Removal (RHR)
Containment Spray System (BWR/6
only).
The primary containment must be
able to withstand a postulated bypass
leakage pathway that allows the passage
of steam from the drywell directly into
the primary containment airspace,
bypassing the suppression pool. The
primary containment also must be able
to withstand a low energy steam release
into the primary containment airspace.
The RHR Containment Spray System is
designed to mitigate the effects of
bypass leakage and low energy line
breaks.
[Note: Plant Applicability, BWR/6]
LCO: Two RHR containment spray
subsystems shall be operable.
Condition Requiring Entry into End
State: If one RHR Containment Spray
Subsystem is inoperable, it must be
restored to operable status within seven
days (Required Action A.1). If two RHR
Containment Spray Subsystems are
inoperable, one of them must be
restored to operable status within eight
hours (Required Action B.1). If the RHR
Containment Spray System cannot be
restored to operable status within the
allotted time, the plant must be placed
in Mode 3 within 12 hours (Required
Action C.1), and in Mode 4 within 36
hours (Required Action C.2)
Modification for End State Required
Actions: Delete Required Action C.2.
Assessment: The primary
containment is designed with a
suppression pool so that, in the event of
a LOCA, steam released from the
primary system is channeled through
the suppression pool water and
condensed without producing
significant pressurization of the primary
containment. The primary containment
is designed so that with the pool
initially at the minimum water level and
the worst single failure of the primary
containment heat removal systems,
suppression pool energy absorption
combined with subsequent operator
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14739
controlled pool cooling will prevent the
primary containment pressure from
exceeding its design value. However,
the primary containment must also
withstand a postulated bypass leakage
pathway that allows the passage of
steam from the drywell directly into the
primary containment airspace,
bypassing the suppression pool. The
primary containment also must
withstand a postulated low energy
steam release into the primary
containment airspace. The main
function of the RHR containment spray
system is to suppress steam, which is
postulated to be released into the
primary containment airspace through a
bypass leakage pathway and a low
energy line break under DBA
conditions, without producing
significant pressurization of the primary
containment (i.e., ensure that the
pressure inside primary containment
remains within analyzed design limits).
Under the conditions assumed in the
DBA, steam blown down from the break
could find its way into the primary
containment through a bypass leakage
pathway. In addition to the DBA, a
postulated low energy pipe break could
add more steam into the primary
containment airspace. Under such an
extremely unlikely scenario (very small
frequency of a DBA combined with the
likelihood of a bypass pathway and a
concurrent low energy pipe brake inside
the primary containment), the RHR
containment spray system could be
needed to condense steam so that the
pressure inside the primary
containment remains within analyzed
design limits. Furthermore,
containments have considerable margin
to failure above the design limit (it is
very likely that the containment will be
able to withstand pressures as much as
three times the design limit). For these
reasons, the unavailability of one or
both RHR containment spray
subsystems has no significant impact on
CDF or LERF, even for accidents
initiated during operation at power.
Therefore, it is very unlikely that the
RHR containment spray system will be
challenged to mitigate an accident
occurring during power operation. This
probability becomes extremely unlikely
for accidents that would occur during a
small fraction of the year (less than
three days) during which the plant
would be in Mode 3 (associated with
lower initial energy level and reduced
decay heat load as compared to power
operation) to repair the failed RHR
containment spray system.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.2.6 and LCO 3.6.1.7, ‘‘Residual
Heat Removal (RHR) Containment Spray
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System.’’ The argument for staying in
Mode 3 instead of going to Mode 4 to
repair the RHR containment spray
system (one or both trains) is also
supported by defense-in-depth
considerations. Section 6.2 makes a
comparison between the Mode 3 and the
Mode 4 end state, with respect to the
means available to perform critical
functions (i.e., functions contributing to
the defense-in-depth philosophy) whose
success is needed to prevent core
damage and containment failure and
mitigate radiation releases. The risk and
defense-in-depth arguments, used
according to the ‘‘integrated decisionmaking’’ process of Regulatory Guides
1.174 and 1.177, support the conclusion
that Mode 3 is as safe as Mode 4 (if not
safer) for repairing an inoperable RHR
containment spray system.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.23 TRS 4.5.2.7 and LCO 3.6.1.8,
Penetration Valve Leakage Control
System (PVLCS) (BWR/6 only).
The PVLCS supplements the isolation
function of primary containment
isolation valves (PCIVs) in process lines
that also penetrate the secondary
containment. These penetrations are
sealed by air from the PVLCS to prevent
fission products leaking past the
isolation valves and bypassing the
secondary containment after a design
basis loss-of-coolant accident (LOCA).
wwhite on PROD1PC61 with NOTICES
[Note: Plant Applicability, BWR/6]
LCO: Two PVLCS subsystems shall be
operable.
Condition Requiring Entry into End
State: If one PVLCS subsystem is
inoperable, it must be restored to
operable status within 30 days
(Required Action A.1). If two PVLCS
subsystems are inoperable, one of the
PVLCS subsystems must be restored to
operable status within seven days
(Required Action B.1). If the PVLCS
subsystem cannot be restored to
operable status within the allotted time,
the plant must be placed in Mode 3
within 12 hours (Required Action C.1)
and in Mode 4 within 36 hours
(Required Action C.2).
Assessment: The BWROG topical
report has determined that this system
is not significant in BWR PRAs. The
unavailability of one or both PVLCS
subsystems has no impact on CDF or
LERF, irrespective of the mode of
operation at the time of the accident.
Furthermore, the challenge frequency of
the PVLCS system (i.e., the frequency
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with which the system is expected to be
challenged to prevent fission products
leaking past the isolation valves and
bypassing the secondary containment) is
less than 1.0E–6/yr. Consequently, the
conditional probability that this system
will be challenged during the repair
time interval while the plant is at either
the current or the proposed end state
(i.e., Mode 4 or Mode 3, respectively) is
less than 1.0E–8. This probability is
considerably smaller than probabilities
considered ‘‘negligible’’ in Regulatory
Guide 1.177 for much higher
consequence risks, such as large early
release.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.2.7 and LCO 3.6.1.8,
‘‘Penetration Valve Leakage Control
System (PVLCS).’’ The argument for
staying in Mode 3 instead of going to
Mode 4 to repair the PVLCS system (one
or both trains) is also supported by
defense-in-depth considerations.
Section 6.2 makes a comparison
between the Mode 3 and the Mode 4
end state, with respect to the means
available to perform critical functions
(i.e., functions contributing to the
defense-in-depth philosophy) whose
success is needed to prevent core
damage and containment failure and
mitigate radiation releases. The risk and
defense-in-depth arguments, used
according to the ‘‘integrated decisionmaking’’ process of Regulatory Guides
1.174 and 1.177, support the conclusion
that Mode 3 is as safe as Mode 4 (if not
safer) for repairing an inoperable PVLCS
system.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.24 TRS 4.5.1.10, TRS 4.5.2.9 and
LCO 3.6.2.3, Residual Heat Removal
(RHR) Suppression Pool Cooling.
Some means must be provided to
remove heat from the suppression pool
so that the temperature inside the
primary containment remains within
design limits. This function is provided
by two redundant RHR suppression
pool cooling subsystems.
[Note: Plant Applicability, BWR 4/6]
LCO: Two RHR suppression pool
cooling subsystems shall be operable.
Condition Requiring Entry into End
State: If one RHR suppression pool
cooling subsystem is inoperable
(Condition A), it must be restored to
operable status within seven days
(Required Action A.1). If the RHR
suppression pool spray subsystem
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cannot be restored to operable status
within the allotted time (Condition B),
the plant must be placed in Mode 3
within 12 hours (Required Action B.1),
and in Mode 4 within 36 hours
(Required Action B.2).
Modification for End State Required
Actions: Delete Required Action B.2,
and retain Condition B and Required
Action B.1 for one RHR suppression
pool spray subsystem inoperable. Add
Condition C, with Required Actions C.1
and C.2, identical to existing Condition
B, with Required Actions B.1 and B.2,
to maintain existing requirements
unchanged for two RHR suppression
pool subsystems inoperable.
Assessment: The BWROG topical
report has completed a comparative
PRA evaluation of the core damage risks
of operation in the current end state
versus operation in the Mode 3 end
state. The results indicated that the core
damage risks while operating in Mode 3
(assuming the individual failure
conditions) are lower or comparable to
the current end state. One loop of the
RHR suppression pool cooling system is
sufficient to accomplish the required
safety function. By remaining in Mode
3, HPCS, RCIC, and the power
conversion system (condensate/
feedwater) remain available for water
makeup and decay heat removal.
Additionally, the EOPs direct the
operators to take control of the
depressurization function if low
pressure injection/spray are needed for
RCS makeup and cooling. Therefore,
defense-in-depth is improved with
respect to water makeup and decay heat
removal by remaining in Mode 3.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.25 TRS 4.5.2.12 and LCO 3.6.5.6,
Drywell Vacuum Relief System (BWR/6
only).
The Mark III pressure suppression
containment is designed to condense, in
the suppression pool, the steam released
into the drywell in the event of a lossof-coolant accident (LOCA). The steam
discharging to the pool carries the noncondensibles from the drywell.
Therefore, the drywell atmosphere
changes from low humidity air to nearly
100% steam (no air) as the event
progresses. When the drywell
subsequently cools and depressurizes,
non-condensibles in the drywell must
be replaced to avoid excessive weir wall
overflow into the drywell. Rapid weir
wall overflow must be controlled in a
large break LOCA, so that essential
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equipment and systems located above
the weir wall in the drywell are not
subjected to excessive drag and impact
loads. The drywell post-LOCA and the
drywell purge vacuum relief subsystems
are the means by which noncondensibles are transferred from the
primary containment back to the
drywell.
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[Note: Plant Applicability, BWR/6]
LCO: Two drywell post-LOCA and
two drywell purge vacuum relief
subsystems shall be operable.
Condition Requiring Entry into End
State: If one or two drywell post-LOCA
vacuum relief subsystems are inoperable
(Condition A), or if one drywell purge
vacuum relief subsystem is inoperable
(Condition B), for reasons other than
being not closed, the subsystem(s) must
be restored to operable status within 30
days (Required Actions B.1 and C.1,
respectively). If the required actions
cannot be completed within the allotted
time, the plant must be placed in Mode
3 within 12 hours and in Mode 4 within
36 hours.
Modification for End State Required
Actions: Renumber Conditions D, E, F
and G, to Conditions E, F, G, and H
respectively, and renumber associated
Required Actions accordingly. Add a
new Condition D for when Required
Action and associated Completion Time
of Condition B or C not met, with
Required Action D.1 to be in Mode 3 in
a Completion Time of 12 hours. Change
new Condition G to read, ‘‘Required
Action and associated Completion Time
of Condition A, E or F not met.’’
Assessment: The BWROG topical
report has determined that the specific
failure conditions of interest are not risk
significant in BWR PRAs. With one or
two drywell post-LOCA vacuum relief
subsystems inoperable or one drywell
purge vacuum relief subsystem
inoperable, for reasons other than not
being closed, the remaining operable
vacuum relief subsystems are adequate
to perform the depressurization
mitigation function. By remaining in
Mode 3, HPCS, RCIC, and the power
conversion system (condensate/
feedwater) remain available for water
makeup and decay heat removal.
Additionally, the EOPs direct the
operators to take control of the
depressurization function if low
pressure injection/spray are needed for
RCS makeup and cooling. Therefore,
defense-in-depth is improved with
respect to water makeup and decay heat
removal by remaining in Mode 3.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
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defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.26 TRS 4.5.2.13 and LCO 3.7.1,
Standby Service Water (SSW) System
and Ultimate Heat Sink (UHS) (BWR/6
only).
The SSW system (in conjunction with
the UHS) is designed to provide cooling
water for the removal of heat from
certain safe shutdown-related
equipment heat exchangers following a
DBA or transient.
[Note: Plant Applicability, BWR/6]
LCO: Division 1 and 2 SSW
subsystems and UHS shall be operable.
Condition Requiring Entry into End
State: If one or more cooling towers
with one cooling tower fan is inoperable
(Condition A), the cooling tower fan(s)
must be restored to operable status
within seven days (Required Action
A.1). If one SSW subsystem is
inoperable for reasons other than
Condition A (Condition C), the SSW
subsystem must be restored to operable
status within 72 hours (Required Action
C.1). If the required action(s) and
associated completion time(s) (of
Conditions A or C) cannot be met
(Condition D), the plant must be placed
in Mode 3 within 12 hours (Required
Action D.1) and in Mode 4 within 36
hours (Required Action D.2).
Modification: The existing second and
third conditions of existing Condition D
have been transferred to a new
Condition E in an unchanged form (with
Required Actions E.1 and E.2 identical
to existing Required Actions D.1 and
D.2). Existing Condition B with its
associated Required Actions and
Associated Completion Times, has been
transferred to a new Condition D in an
unchanged form. Existing Condition C,
with its associated Required Action and
Associated Completion Time, has been
moved to a new Condition B in
unchanged form. A new Condition C
has been created. If the Required
Actions and Associated Completion
Times for new Condition A or B are not
met (new Condition C), then the plant
must be placed in Mode 3 in 12 hours
(new Required Action C.1).
Assessment: The BWROG topical
report determined that the specific
failure condition of interest is not risk
significant in BWR PRAs. With the
specified inoperable components/
subsystems, a sufficient number of
operable components/subsystems are
still available to perform the heat
removal function. By remaining in
Mode 3, HPCS, RCIC, and the power
conversion system (condensate/
feedwater) remain available for water
makeup and decay heat removal.
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14741
Additionally, the EOPs direct the
operators to take control of the
depressurization function if low
pressure injection/spray are needed for
RCS makeup and cooling. Therefore,
defense-in-depth is improved with
respect to water makeup and decay heat
removal by remaining in Mode 3.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.27 TRS 4.5.2.14 and LCO 3.7.3,
Control Room Fresh Air (CRFA) System
(BWR/6 only).
The CRFA system provides a
radiologically controlled environment
from which the unit can be safely
operated following a DBA. The CRFA
system consists of two independent and
redundant high efficiency air filtration
subsystems for treatment of recirculated
air or outside supply air. Each
subsystem consists of a demister, an
electric heater, a prefilter, a high
efficiency particulate air (HEPA) filter,
an activated charcoal adsorber section, a
second HEPA filter, a fan, and the
associated ductwork and dampers.
Demisters remove water droplets from
the airstream. Prefilters and HEPA
filters remove particulate matter that
may be radioactive. The charcoal
adsorbers provide a holdup period for
gaseous iodine, allowing time for decay.
[Note: Plant Applicability, BWR/6]
LCO: Two CRFA subsystems shall be
operable.
Condition Requiring Entry into End
State: If one CRFA subsystem is
inoperable (Condition A), it must be
restored to operable status within seven
days (Required Action A.1). If two
CRFA subsystems are inoperable
(Condition B for control room boundary
and Condition E for reasons for
inoperability), one CRFA subsystem
must be restored to operable status in 24
hours (Required Action B.1) or enter
LCO 3.0.3 (Required Action E.1). If
Conditions A or B, and associated
Required Actions A.1 and B.1) cannot
be met in the required Completion Time
(Condition C), the plant must be placed
in Mode 3 within 12 hours (Required
Action C.1) and in Mode 4 within 36
hours (Required Action C.2).
Modification for End State Required
Actions: Delete Required Action C.2,
and change Required Action E.1 to ‘‘Be
in Mode 3’’ within a Completion Time
of ‘‘12 hours.’’
Assessment: The unavailability of one
or both CRFA subsystems has no
significant impact on CDF or LERF,
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irrespective of the mode of operation at
the time of the accident. Furthermore,
the challenge frequency of the CRFA
system (i.e., the frequency with which
the system is expected to be challenged
to provide a radiologically controlled
environment in the main control room
following a DBA which leads to core
damage and leaks of radiation from the
containment that can reach the control
room) is less than 1.0E–6/yr.
Consequently, the conditional
probability that this system will be
challenged during the repair time
interval while the plant is at either the
current or the proposed end state (i.e.,
Mode 4 or Mode 3, respectively) is less
than 1.0E–8. This probability is
considerably smaller than probabilities
considered ‘‘negligible’’ in Regulatory
Guide 1.177 for much higher
consequence risks, such as large early
release.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.2.14 and LCO 3.7.3, ‘‘Control
Room Fresh Air (CRFA) System.’’ The
argument for staying in Mode 3 instead
of going to Mode 4 to repair the CRFA
system (one or both trains) is also
supported by defense-in-depth
considerations. Section 6.2 makes a
comparison between the Mode 3 and the
Mode 4 end state, with respect to the
means available to perform critical
functions (i.e., functions contributing to
the defense-in-depth philosophy) whose
success is needed to prevent core
damage and containment failure and
mitigate radiation releases. The risk and
defense-in-depth arguments, used
according to the ‘‘integrated decisionmaking’’ process of Regulatory Guides
1.174 and 1.177, support the conclusion
that Mode 3 is as safe as Mode 4 (if not
safer) for repairing an inoperable CRFA
system.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.28 TRS 4.5.2.15 and LCO 3.7.4,
Control Room Air Conditioning (CRAC)
System (BWR/6 only).
The control room AC system provides
temperature control for the control room
following control room isolation. The
control room AC system consists of two
independent, redundant subsystems
that provide cooling and heating of
recirculated control room air. Each
subsystem consists of heating coils,
cooling coils, fans, chillers,
compressors, ductwork, dampers, and
instrumentation and controls to provide
for control room temperature control.
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Jkt 208001
The control room AC system is designed
to provide a controlled environment
under both normal and accident
conditions. A single subsystem provides
the required temperature control to
maintain a suitable control room
environment for a sustained occupancy
of 12 persons.
[Note: Plant Applicability, BWR/6]
LCO: Two control room AC
subsystems shall be operable.
Condition Requiring Entry into End
State: If one control room AC subsystem
is inoperable, it must be restored to
operable status within 30 days
(Required Action A.1). If the required
actions and associated completion times
cannot be met, the plant must be placed
in Mode 3 within 12 hours (Required
Action B.1) and in Mode 4 within 36
hours (Required Action B.2). If two
control room AC subsystems are
inoperable, LCO 3.0.3 must be entered
immediately (Condition D).
Modification for End State Required
Actions: Delete Required Action B.2,
and change Required Action D.1 to ‘‘Be
in Mode 3’’ with a Completion Time of
‘‘12 hours.’’
Assessment: The unavailability of one
or both AC subsystems has no
significant impact on CDF or LERF,
irrespective of the mode of operation at
the time of the accident. Furthermore,
the challenge frequency of the AC
system (i.e., the frequency with which
the system is expected to be challenged
to provide temperature control for the
control room following control room
isolation following a DBA which leads
to core damage) is less than 1.0E–6/yr.
Consequently, the conditional
probability that this system will be
challenged during the repair time
interval while the plant is at either the
current or the proposed end state (i.e.,
Mode 4 or Mode 3, respectively) is less
than 1.0E–8. This probability is
considerably smaller than probabilities
considered ‘‘negligible’’ in Regulatory
Guide 1.177 for much higher
consequence risks, such as large early
release.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.2.15 and LCO 3.7.4, ‘‘Control
Room Air Conditioning (AC) System.’’
The argument for staying in Mode 3
instead of going to Mode 4 to repair the
CRAC system (one or both trains) is also
supported by defense-in-depth
considerations. Section 6.2 makes a
comparison between the Mode 3 and the
Mode 4 end state, with respect to the
means available to perform critical
functions (i.e., functions contributing to
the defense-in-depth philosophy) whose
success is needed to prevent core
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damage and containment failure and
mitigate radiation releases. The risk and
defense-in-depth arguments, used
according to the ‘‘integrated decisionmaking’’ process of Regulatory Guides
1.174 and 1.177, support the conclusion
that Mode 3 is as safe as Mode 4 (if not
safer) for repairing an inoperable CRAC
system.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
3.2.29 TRS 4.5.2.16 and LCO 3.7.5,
Main Condenser Off gas (BWR/6 only).
The Off gas from the main condenser
normally includes radioactive gases.
The gross gamma activity rate is
controlled to ensure that accident
analysis assumptions are satisfied and
that offsite dose limits will not be
exceeded during postulated accidents.
[Note: Plant Applicability, BWR/6]
LCO: The gross gamma activity rate of
the noble gases measured at the Off gas
recombiner effluent shall be ≤380 mCi/
second after decay of 30 minutes.
Condition Requiring Entry into End
State: If the gross gamma activity rate of
the noble gases in the main condenser
Off gas is not within limits (Condition
A), the gross gamma activity rate of the
noble gases in the main condenser Off
gas must be restored to within limits
within 72 hours (Required Action A.1).
If the required action and associated
completion time cannot be met, one of
the following must occur:
a. All steam lines must be isolated
within 12 hours (Required Action B.1).
b. The steam jet air ejector (SJAE)
must be isolated within 12 hours
(Required Action B.2).
c. The plant must be placed in Mode
3 within 12 hours (Required Action
B.3.1) and in Mode 4 within 36 hours
(Required Action B.3.2).
Modification for End State Required
Actions: Delete Required Action B.3.2.
Assessment: The failure to maintain
the gross gamma activity rate of the
noble gases in the main condenser Off
gas (MCOG) within limits has no
significant impact on CDF or LERF,
irrespective of the mode of operation at
the time of the accident. Furthermore,
the challenge frequency of the MCOG
system (i.e., the frequency with which
the system is expected to be challenged
to mitigate offsite radiation releases
following a DBA) is less than 1.0E–6/yr.
Consequently, the conditional
probability that this system will be
challenged during the repair time
interval while the plant is at either the
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current or the proposed end state (i.e.,
Mode 4 or Mode 3, respectively) is less
than 1.0E–8. This probability is
considerably smaller than probabilities
considered ‘‘negligible’’ in Regulatory
Guide 1.177 for much higher
consequence risks, such as large early
release.
Section 6 of reference 6 summarizes
the staff’s risk argument for approval of
TRS 4.5.2.16 and LCO 3.7.5, ‘‘Main
Condenser Off gas.’’ The argument for
staying in Mode 3 instead of going to
Mode 4 to repair the MCOG system (one
or both trains) is also supported by
defense-in-depth considerations.
Section 6.2 makes a comparison
between the Mode 3 and the Mode 4
end state, with respect to the means
available to perform critical functions
(i.e., functions contributing to the
defense-in-depth philosophy) whose
success is needed to prevent core
damage and containment failure and
mitigate radiation releases. The risk and
defense-in-depth arguments, used
according to the ‘‘integrated decisionmaking’’ process of Regulatory Guides
1.174 and 1.177, support the conclusion
that Mode 3 is as safe as Mode 4 (if not
safer) for repairing an inoperable MCOG
system.
Finding: Based upon the above
assessment, and because the time spent
in Mode 3 to perform the repair is
infrequent and limited, and in light of
defense-in-depth considerations
(discussed in Reference 1), the change is
acceptable.
wwhite on PROD1PC61 with NOTICES
4.0 State Consultation
In accordance with the Commission’s
regulations, the [llll] State official
was notified of the proposed issuance of
the amendment. The State official had
[(1) no comments or (2) the following
comments—with subsequent
disposition by the staff].
5.0 Environmental Consideration
The amendment changes
requirements with respect to the
installation or use of a facility
component located within the restricted
area as defined in 10 CFR Part 20. The
NRC staff has determined that the
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 that adopting TSTF–
423, Rev 0, involves no significant
hazards considerations, and there has
been no public comment on the finding
in Federal Register Notice 70 FR 74037,
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16:54 Mar 22, 2006
Jkt 208001
December 14, 2005. Accordingly, the
amendments meet the eligibility criteria
for categorical exclusion set forth in 10
CFR 51.22(c)(9). Pursuant to 10 CFR
51.22(b), no environmental impact
statement or environmental assessment
need be prepared in connection with the
issuance of the amendment.
6.0
Conclusion
The Commission has concluded, on
the basis of the considerations discussed
above, that (1) there is reasonable
assurance that the health and safety of
the public will not be endangered by
operation in the proposed manner, (2)
such activities will be conducted in
compliance with the Commission’s
regulations, and (3) the issuance of the
amendments will not be inimical to the
common defense and security or to the
health and safety of the public.
7.0
References
1. NEDC–32988–A, Revision 2,
‘‘Technical Justification to Support
Risk-Informed Modification to Selected
Required Action End States for BWR
Plants,’’ December 2002.
2. Federal Register, Vol. 58, No. 139,
p. 39136, ‘‘Final Policy Statement on
Technical Specifications Improvements
for Nuclear Power Plants,’’ July 22,
1993.
3. 10 CFR 50.65, Requirements for
Monitoring the Effectiveness of
Maintenance at Nuclear Power Plants.’’
4. Regulatory Guide 1.182, ‘‘Assessing
and Managing Risk Before Maintenance
Activities at Nuclear Power Plants,’’
May 2000. (ML003699426)
5. NUMARC 93–01, ‘‘Industry
Guideline for Monitoring the
Effectiveness of Maintenance at Nuclear
Power Plants,’’ Nuclear Management
and Resource Council, Revision 3, July
2000.
6. NRC Safety Evaluation for Topical
Report NEDC–32988, Revision 2,
September 27, 2002. (ML022700603)
7. TSTF–423, Revision 0, ‘‘Technical
Specifications End States, NEDC–
32988–A.’’
8. TSTF–IG–05–02, Implementation
Guidance for TSTF–423, Revision 0,
‘‘Technical Specifications End States,
NEDC–32988–A,’’ September 2005.
9. Regulatory Guide 1.174, ‘‘An
Approach for Using Probabilistic Risk
Assessment in Risk-Informed Decision
Making on Plant Specific Changes to the
Licensing Basis,’’ USNRC, August 1998.
(ML003740133)
10. Regulatory Guide 1.177, ‘‘An
Approach for Pant Specific RiskInformed Decision Making: Technical
Specifications,’’ USNRC, August 1998.
(ML003740176)
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14743
Proposed No Significant Hazards
Consideration Determination
Description of Amendment Request: A
change is proposed to the technical
specifications (TS) of [plant name],
consistent with Technical Specifications
Task Force (TSTF) change TSTF–423 to
the standard technical specifications
(STS) for BWR Plants (NUREG 1433 and
NUREG 1434) to allow, for some
systems, entry into hot shutdown rather
than cold shutdown to repair
equipment, if risk is assessed and
managed consistent with the program in
place for complying with the
requirements of 10 CFR 50.65(a)(4).
Changes proposed in will be made to
the [plant name] TS for selected
Required Action end states providing
this allowance.
Basis for proposed no-significanthazards-consideration determination:
As required by 10 CFR 50.91(a), an
analysis of the issue of no-significanthazards-consideration is presented
below:
Criterion 1—The Proposed Change Does
Not Involve a Significant Increase in the
Probability or Consequences of an
Accident Previously Evaluated
The proposed change allows a change
to certain required end states when the
TS Completion Times for remaining in
power operation will be exceeded. Most
of the requested technical specification
(TS) changes are to permit an end state
of hot shutdown (Mode 3) rather than an
end state of cold shutdown (Mode 4)
contained in the current TS. The request
was limited to: (1) Those end states
where entry into the shutdown mode is
for a short interval, (2) entry is initiated
by inoperability of a single train of
equipment or a restriction on a plant
operational parameter, unless otherwise
stated in the applicable technical
specification, and (3) the primary
purpose is to correct the initiating
condition and return to power operation
as soon as is practical. Risk insights
from both the qualitative and
quantitative risk assessments were used
in specific TS assessments. Such
assessments are documented in Section
6 of GE NEDC–32988, Revision 2,
‘‘Technical Justification to Support Risk
Informed Modification to Selected
Required Action End States for BWR
Plants.’’ They provide an integrated
discussion of deterministic and
probabilistic issues, focusing on specific
technical specifications, which are used
to support the proposed TS end state
and associated restrictions. The staff
finds that the risk insights support the
conclusions of the specific TS
assessments. Therefore, the probability
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of an accident previously evaluated is
not significantly increased, if at all. The
consequences of an accident after
adopting proposed TSTF–423, are no
different than the consequences of an
accident prior to adopting TSTF–423.
Therefore, the consequences of an
accident previously evaluated are not
significantly affected by this change.
The addition of a requirement to assess
and manage the risk introduced by this
change will further minimize possible
concerns. Therefore, this change does
not involve a significant increase in the
probability or consequences of an
accident previously evaluated.
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Criterion 2—The Proposed Change Does
Not Create the Possibility of a New or
Different Kind of Accident From Any
Previously Evaluated
The proposed change does not
involve a physical alteration of the plant
(no new or different type of equipment
will be installed). If risk is assessed and
managed, allowing a change to certain
required end states when the TS
Completion Times for remaining in
power operation are exceeded, i.e., entry
into hot shutdown rather than cold
shutdown to repair equipment, will not
introduce new failure modes or effects
and will not, in the absence of other
unrelated failures, lead to an accident
whose consequences exceed the
consequences of accidents previously
evaluated. The addition of a
requirement to assess and manage the
risk introduced by this change and the
commitment by the licensee to adhere to
the guidance in TSTF–IG–05–02,
Implementation Guidance for TSTF–
423, Revision 0, ‘‘Technical
Specifications End States, NEDC–
32988–A,’’ will further minimize
possible concerns. Thus, this change
does not create the possibility of a new
or different kind of accident from an
accident previously evaluated.
Criterion 3—The Proposed Change Does
Not Involve a Significant Reduction in
the Margin of Safety
The proposed change allows, for some
systems, entry into hot shutdown rather
than cold shutdown to repair
equipment, if risk is assessed and
managed. The BWROG’s risk assessment
approach is comprehensive and follows
staff guidance as documented in RGs
1.174 and 1.177. In addition, the
analyses show that the criteria of the
three-tiered approach for allowing TS
changes are met. The risk impact of the
proposed TS changes was assessed
following the three-tiered approach
recommended in RG 1.177. A risk
assessment was performed to justify the
proposed TS changes. The net change to
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the margin of safety is insignificant.
Therefore, this change does not involve
a significant reduction in a margin of
safety.
The Following Example of an
Application Was Prepared by the NRC
Staff To Facilitate Use of the
Consolidated Line Item Improvement
Process (CLIIP). The Model Provides the
Expected Level of Detail and Content for
an Application To Adopt TSTF–423,
Revisions 0, ‘‘Risk-Informed
Modifications to Selected Required
Action End States,’’ for BWR Plants (and
Adoption of a Technical Specification
Bases Control Program)* Using CLIIP.
Licensees Remain Responsible for
Ensuring That Their Actual Application
Fulfills Their Administrative
Requirements as Well as Nuclear
Regulatory Commission Regulations.
U.S. Nuclear Regular Commission,
Document Control Desk,
Washington, DC 20555.
Subject: Plant Name, Docket No. 50—
Application for Technical Specification
Change TSTF–423, Risk Informed
Modification To Selected Required Action
End States for BWR Plants, (and Adoption
of a Technical Specifications Bases Control
Program)* Using the Consolidated Line
Item Improvement Process
Gentleman: In accordance with the
provisions of 10 CFR 50.90 [Licensee] is
submitting a request for an amendment to the
technical specifications (TS) for [Plant Name,
Unit Nos.].
The proposed amendment would modify
TS to risk-inform requirements regarding
selected Required Action End States, (and, in
conjunction with the proposed change, TS
requirements for a Bases control program
consistent with TS Bases Control Program
described in Section 5.5 of the BWR Standard
Technical Specifications.)*
Enclosure 1 provides a description of the
proposed change, the requested confirmation
of applicability, and plant-specific
verifications. Enclosure 2 provides the
existing TS pages marked up to show the
proposed change. Enclosure 3 provides
revised (clean) TS pages. Enclosure 4
provides a summary of the regulatory
commitments made in this submittal.
Enclosure 5 provides the existing TS Bases
pages marked up to show the proposed
change (for information only).)
[Licensee] requests approval of the
proposed license amendment by [Date], with
the amendment being implemented [by Date
or Within X Days].
In accordance with 10 CFR 50.91, a copy
of this application, with enclosures, is being
provided to the designated [State] Official.
* If not already in the facility Technical
Specifications.
I declare under penalty of perjury under
the laws of the United States of America that
I am authorized by [Licensee] to make this
request and that the foregoing is true and
correct. (Note that request may be notarized
in lieu of using this oath or affirmation
statement).
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If you should have any questions regarding
this submittal, please contact [Name,
Telephone Number]
Sincerely,
[Name, Title]
Enclosures:
1. Description and Assessment
2. Proposed Technical Specification Changes
3. Revised Technical Specification Pages
4. Regulatory Commitments
5. Proposed Technical Specification Bases
Changes
cc: NRC Project Manager
NRC Regional Office
NRC Resident Inspector
State Contact
ENCLOSURE 1
Description and Assessment
1.0 Description
The proposed amendment would modify
technical specifications to risk-inform
requirements regarding selected Required
Action End States.1
The changes are consistent with Nuclear
Regulatory Commission (NRC) approved
Industry/Technical Specification Task Force
(TSTF) TSTF–423 Revision 0. The
availability of this TS improvement was
published in the Federal Register on [Date]
as part of the consolidated line item
improvement process (CLIIP).
2.0 Assessment
2.1 Applicability of Topical Report, TSTF–
423, and Published Safety Evaluation
[Licensee] has reviewed GE topical report
(Reference 1), TSTF–423 (Reference 2), and
the NRC model safety evaluation (Reference
3) as part of the CLIIP. [Licensee] has
concluded that the information in the GE
topical report and TSTF–423, as well as 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. [Note: Only
those changes proposed in TSTF–423 are
addressed in the model SE. The model SE
and associated topical report address the
entire fleet of BWR plants, and the plants
adopting TSTF–423 must confirm the
applicability of the changes to their plant.]
2.2 Optional Changes and Variations
[Licensee] is not proposing any variations
or deviations from the GE topical report and
the TS changes described in the TSTF–423
Revision 0 or the NRC staff’s model safety
evaluation dated [Date]. [Note: The CLIIP
does not prevent licensees from requesting an
alternate approach or proposing changes
without the requested Bases or Bases control
program. However, deviations from the
approach recommended in this notice may
require additional review by the NRC staff
and may increase the time and resources
needed for the review. Significant variations
1 [In conjunction with the proposed change,
technical specifications (TS) requirements for a
Bases Control Program, consistent with the TS
Bases Control Program described in Section 5.5 of
the applicable vendor’s standard TS (STS), shall be
incorporated into the licensee’s TS, if not already
in the TS.]
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Federal Register / Vol. 71, No. 56 / Thursday, March 23, 2006 / Notices
from the approach, or inclusion of additional
changes to the license, will result in staff
rejection of the submittal. Instead, licensees
desiring significant variations and/or
additional changes should submit a LAR that
does not claim to adopt TSTF–423.]
and components when one or more systems
are not able to perform their associated
function. Finally, [Licensee] has a Bases
Control Program consistent with Section 5.5
of the Standard Technical Specifications
(STS).
3.0 Regulatory Analysis
3.1 No Significant Hazards Consideration
Determination
[Licensee] has reviewed the proposed no
significant hazards consideration
determination (NSHCD) published in the
Federal Register as part of the CLIIP.
[Licensee] has concluded that the proposed
NSHCD presented in the Federal Register
notice is applicable to [Plant] and is hereby
incorporated by reference to satisfy the
requirements of 10 CFR 50.91(a).
3.2 Verification and Commitments
As discussed in the notice of availability
published in the Federal Register on [Date]
for this TS improvement, plant-specific
verifications were performed as follows:
[Licensee] commits to the regulatory
commitments in Enclosure 4. In addition,
[Licensee] has proposed TS Bases consistent
with the GE topical report and TSTF–423,
which provide guidance and details on how
to implement the new requirements.
Implementation of TSTF–423 requires that
risk be managed and assessed, and the
licensee’s configuration risk management
program is adequate to satisfy this
requirement. The risk assessment need not be
quantified, but may be a qualitative
assessment of the vulnerability of systems
4.0
Environmental Evaluation
The amendment changes requirements
with respect to the installation or use of a
facility component located within the
restricted area as defined in 10 CFR Part 20.
The NRC staff has determined that the
amendment adopting TSTF–423, Rev 0,
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 that TSTF–423, Rev 0,
involves no significant hazards
considerations, and there has been no public
comment on the finding in Federal Register
Notice 70 FR 74037, December 14, 2005.
Accordingly, the amendment meets the
eligibility criteria for categorical exclusion
set forth in 10 CFR 51.22(c)(9). Pursuant to
10 CFR 51.22(b), no environmental impact
statement or environmental assessment need
be prepared in connection with the issuance
of the amendment.
5.0
References
1. NEDC–32988–A, Revision 2, ‘‘Technical
Justification to Support Risk-Informed
14745
Modification to Selected Required Action
End States for BWR Plants,’’ December 2002.
2. TSTF–423, Revision 0, ‘‘Technical
Specifications End States, NEDC–32988–A.’’
3. Federal Register, Vol. XX, No. XX, p.
XXXXX, ‘‘Notice of Availability of Model
Application Concerning Technical
Specifications for Boiling Water Reactor
Plants to Risk-Inform Requirements
Regarding Selected Required Action End
States Using the Consolidated Line Item
Improvement Process, and NRC Model Safety
Evaluation,’’ [Date].
Enclosure 2
Proposed Technical Specification Changes
(Mark-up)
Enclosure 3
Proposed Technical Specification Pages
[Clean copies of Licensee specific
Technical Specification (TS) pages,
corresponding to the TS pages changed by
TSTF–423, Rev 0, are to be included in
Enclosure 3]
Enclosure 4
List of Regulatory Commitments
The following table identifies those actions
committed to by [Licensee] in this document.
Any other statements in this submittal are
provided for information purposes and are
not considered to be regulatory
commitments. Please direct questions
regarding these commitments to [Contact
Name].
Regulatory committments
Due date/event
[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 3, July 2000.
[Licensee] will follow the guidance established in TSTF–IG–05–02, Implementation Guidance
for TSTF–423, Revision 0, ‘‘Technical Specifications End States, NEDC–32988–A,’’ September 2005.
[Ongoing, or implement with amendment].
Enclsoure 5
initial public offerings and 460 other
offerings. Please note that an agency
may not conduct or sponsor, and a
person is not required to respond to, a
collection of information unless it
displays a currently valid control
number.
Written comments regarding the
above information should be directed to
the following persons: (i) Desk Officer
for the Securities and Exchange
Commission, Office of Information and
Regulatory Affairs, Office of
Management and Budget, Room 10102,
New Executive Office Building,
Washington, DC 20503 or by sending an
e-mail to David_Rostker@omb.eop.gov;
and (ii) R. Corey Booth, Director/Chief
Information Officer, Securities and
Exchange Commission, C/O Shirley
Martinson, 6432 General Green Way,
Alexandria, Virginia 22312; or send an
e-mail to: PRA_Mailbox@sec.gov.
Proposed Changes to Technical Specification
Bases Pages
[FR Doc. 06–2803 Filed 3–22–06; 8:45 am]
BILLING CODE 7590–01–P
• Rule 15c2–8 Delivery of Prospectus
SECURITIES AND EXCHANGE
COMMISSION
Submission for OMB Review;
Comment Request
wwhite on PROD1PC61 with NOTICES
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of Filings and
Information Services, Washington, DC
20549.
Extension:
Rule 15c2–8, SEC File No. 270–421, OMB
Control No. 3235–0481.
Notice is hereby given that pursuant
to the Paperwork Reduction Act of 1995
VerDate Aug<31>2005
16:54 Mar 22, 2006
Jkt 208001
(44 U.S.C. 3501 et seq.), the Securities
and Exchange Commission
(‘‘Commission’’) has submitted to the
Office of Management and Budget
(‘‘OMB’’) a request for extension of the
previously approved collection of
information discussed below.
Rule 15c2–8 under the Securities
Exchange Act of 1934 requires brokerdealers to deliver preliminary or final
prospectuses to specified persons in
association with securities offerings.
This requirement ensures that
information concerning issuers flows to
purchasers of the issuers’ securities in a
timely fashion. It is estimated that there
are approximately 8,000 broker-dealers,
any of which potentially may
participate in an offering subject to Rule
15c2–8. The Commission estimates that
Rule 15c2–8 creates approximately
10,600 burden hours with respect to 120
PO 00000
Frm 00069
Fmt 4703
Sfmt 4703
[Implement with amendment, when TS Required Action End State remains within the
Applicability of TS].
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Agencies
[Federal Register Volume 71, Number 56 (Thursday, March 23, 2006)]
[Notices]
[Pages 14726-14745]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 06-2803]
-----------------------------------------------------------------------
NUCLEAR REGULATORY COMMISSION
Notice of Availability of Model Application Concerning Technical
Specifications for Boiling Water Reactor Plants to Risk-Inform
Requirements Regarding Selected Required Action End States Using the
Consolidated Line Item Improvement Process
AGENCY: Nuclear Regulatory Commission.
ACTION: Notice of availability.
-----------------------------------------------------------------------
SUMMARY: Notice is hereby given that the staff of the Nuclear
Regulatory Commission (NRC) has prepared a model application related to
the revision of Boiling Water Reactor (BWR) plant required action end
state requirements in technical specifications (TS). The purpose of
this model is to permit the NRC to efficiently process amendments that
propose to revise BWR TS required action end state requirements.
Licensees of nuclear power reactors to which the model applies may
request amendments utilizing the model application.
DATES: The NRC staff issued a Federal Register Notice (70 FR 74037,
December 14, 2005) that provided a model safety evaluation (SE) and a
model no significant hazards consideration (NSHC) determination
relating to changing BWR TS required action end state requirements. The
NRC staff hereby announces that the model SE and NSHC determination may
be referenced in plant-specific applications to adopt the changes. The
staff has posted a model application on the NRC Web site to assist
licensees in using the consolidated line item improvement process
(CLIIP) to revise the BWR TS required action end state requirements.
The NRC staff can most efficiently consider applications based upon the
model application if the application is submitted within a year of this
Federal Register Notice.
FOR FURTHER INFORMATION CONTACT: T. R. Tjader, Mail Stop: O12H2,
Division of Inspection and Regional Support, Office of Nuclear Reactor
Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555-
0001, telephone 301-415-1187.
SUPPLEMENTARY INFORMATION:
Background
Regulatory Issue Summary 2000-06, ``Consolidated Line Item
Improvement Process for Adopting Standard Technical Specification
Changes for Power Reactors,'' was issued on March 20, 2000. The
Consolidated Line Item Improvement Process (CLIIP) is intended to
improve the efficiency of NRC licensing processes. This is accomplished
by processing changes to the standard TS (STS) in a manner that
supports subsequent license amendment applications. The CLIIP includes
an opportunity for the public to comment on proposed changes to the STS
following a preliminary safety assessment by the NRC staff and finding
that the change will likely be offered for adoption by licensees. The
CLIIP includes NRC staff evaluation of any comments received for a
proposed change to the STS, and either a reconsideration of the change
or an announcement of the availability of the change for adoption by
licensees. Those licensees opting to apply for the subject change to
their TS are responsible for reviewing the staff's evaluation,
referencing the applicable technical justifications, and providing any
necessary plant-specific information. Each amendment application made
in response to the notice of availability will be processed and noticed
in accordance with applicable rules and NRC procedures.
This notice involves the revision of BWR TS required action end
state requirements. This change was proposed for incorporation into the
STS by participants in the Owners Groups Technical Specification Task
Force (TSTF) and is designated TSTF-423, Revision 0. TSTF-423, as well
as the NRC staff's safety evaluation and model application, may be
examined, and/or copied for a fee, at the NRC's Public Document Room,
located at One White Flint North, 11555 Rockville Pike (first floor),
Rockville, Maryland. Publicly available records are accessible
electronically from the ADAMS Public Library component on the NRC Web
site, (the Electronic Reading Room). TSTF-423, the NRC staff's safety
evaluation, and the model application, can be viewed on the NRC Web
site at: (https://www.nrc.gov/reactors/operating/licensing/
techspecs.html).
Applicability
This proposal to modify technical specification requirements by the
adoption of TSTF-423 is applicable to all licensees of BWR plants who
have adopted or will adopt, in conjunction with the change, technical
specification requirements for a Bases control program consistent with
the TS Bases Control Program described in Section 5.5 of the BWR STS.
Licensees that have not adopted requirements for a Bases control
program by converting to the improved STS or by other means, are
requested to include the requirements
[[Page 14727]]
for a Bases control program consistent with the STS in their
application for the change. The need for a Bases control program stems
from the need for adequate regulatory control of some key elements of
the proposal that are contained in the Bases in TSTF-423. The staff is
requesting that the Bases changes be included with the proposed license
amendments consistent with the Bases in TSTF-423, prior to implementing
TSTF-423. To ensure that the overall change, including the Bases,
includes appropriate regulatory controls, the staff plans to condition
the issuance of each license amendment on the licensee's incorporation
of the changes into the Bases document and on requiring the licensee to
control the changes in accordance with the Bases Control Program. The
CLIIP does not prevent licensees from requesting an alternative
approach or proposing the changes without the requested Bases and Bases
control program. However, deviations from the approach recommended in
this notice may require additional review by the NRC staff and may
increase the time and resources needed for the review. Significant
variations from the approach, or inclusion of additional changes to the
license, will result in staff rejection of the submittal. Instead,
licensees desiring significant variations and/or additional changes
should submit a LAR that does not claim to adopt TSTF-423.
Public Notices
In a notice in the Federal Register dated December 14, 2005 (70 FR
74037), the staff requested comment on the use of the CLIIP to process
requests to revise the BWR TS regarding required action end state
requirements, designated as TSTF-423.
In response to the notice soliciting comments from interested
members of the public about modifying the TS requirements regarding
revising required action end state requirements, the staff received one
set of comments (from the Owners Groups TSTF, representing licensees).
Specific comments on the model SE were offered, and are summarized and
discussed below:
1. Comment: We commend the staff for adopting a draft Safety
Evaluation format that simplifies the application of the model Safety
Evaluation for TSTF-423 to individual licensees. For example, providing
blanks for plant name, operating license number, etc. We encourage the
staff to follow this example for future CLIIP model Safety Evaluations.
Response: The NRC staff acknowledges the comment; no action taken.
2. Comment: The ``Applicability'' portion of the notice states that
each licensee applying for the changes proposed in TSTF-423 should
include Bases for the proposed Technical Specifications (TS) consistent
with the Bases proposed in TSTF-423. We request that the section be
revised to not require licensees to submit Bases changes. The Bases
changes in TSTF-423 are not integral to the change and both licensee
and NRC resources could be saved by allowing licensees to adopt the
necessary Bases changes using the Technical Specifications Bases
Control Program. As a precedent, the CLIIP for TSTF-460 (Notice of
Availability published in the Federal Register on August 23, 2004)
allowed licensees to commit to updating their TS Bases under the TS
Bases Control Program instead of requiring licensees to submit their
Bases changes for NRC review. We propose that the TSTF-423 CLIIP take a
similar approach.
Response: The NRC staff does not agree with the comment. The
associated TS Bases changes are an essential and integral element of
the change, must be consistent with the Bases in TSTF-423, and should
be submitted by the licensees with the license amendment request for
adoption of TSTF-423.
3. Comment: Section 1.0 of the model Safety Evaluation, in the
first paragraph, states that TSTF-423 was proposed by the Nuclear
Energy Institute Risk Informed Technical Specification Task Force. That
is incorrect. TSTF-423, Revision 0, was submitted by the Owners Group
Technical Specifications Task Force in a letter to the NRC dated August
12, 2003.
Response: The NRC staff agrees with the comment. The correction has
been made.
4. Comment: Section 1.0 of the model Safety Evaluation, the last
sentence of section, states, ``Short duration repairs are on the order
of 2-to-3 days, but not more than a week.'' We recommend replacing this
sentence with the statement from the Implementation Guidance (TSTF-IG-
05-02), which states, ``A `short duration' is envisioned to be the
duration that boiling water reactors (BWRs) are most physically and
practicably able to remain in the hot shutdown condition (i.e., from a
few days to approximately one week).'' This clarifies that the time
frames are a statement of fact rather than a restriction which must be
incorporated in plant operating controls.
Response: The NRC staff does not agree with the comment. This issue
was discussed thoroughly and the one week limit was determined
appropriate. The one week limit is explicitly stated in the
Implementation Guidance (Reference 8 to the SE) submitted by industry,
agreed to by the NRC staff, and to which the licensees must commit.
Section 1 paragraph 6 of the Implementation Guidance (TSTF-IG-05-02)
states, ``Any entry into Mode 3 using this TS allowance must be limited
to no more than seven days.'' No action has been taken.
5. Comment: In Section 3.2, ``Assessment of TS Changes,'' of the
model Safety Evaluation, each subsection is titled with the applicable
Topical Report section number and the ITS LCO number. The abbreviation
``TS'' is used to indicate the Topical Report section number (e.g.,
``TS 4.5.1.2 and LCO 3.4.3 (BWR/4); TS 4.5.2.2 and LCO 3.4.4 (BWR/6),
Safety/Relief Valves (SRVs).'' The labels ``4.5.1.2'' and ``4.5.2.2''
are the Topical Report sections associated with these LCO changes.
These references also appear in the text of Section 3.2. This
presentation is confusing as ``TS'' is defined in the model Safety
Evaluation as ``Technical Specifications'' and non-ITS plants have
Technical Specification requirements with numbers similar to the
Topical Report numbers. We recommend replacing this use of the
abbreviation ``TS'' with either ``Topical Report section'' or defining
another acronym, such as ``TR.''
Response: The NRC staff agrees with the comment. The abbreviation
for the Topical Report Section was poorly chosen, in that it was easily
confused with the abbreviation for Technical Specification. The Topical
Report Section abbreviation has been changed to ``TRS.''
6. Comment: In Section 3.2.4 of the model Safety Evaluation, in the
title and in the first paragraph, the LCO name ``Low-Low Set Logic
(LLS) Valves'' is used. The word ``logic'' should not appear in the LCO
name. The document should be revised to state ``Low-Low Set (LLS)
Valves.''
Response: The NRC staff agrees with the comment. The correction has
been made.
7. Comment: Section 5.0, ``Environmental Consideration,'' of the
model Safety Evaluation states that the amendments meet the eligibility
criteria for categorical exclusion set forth in ``10 CFR 51.22(c)(9)
[and (c)(10)].'' 10 CFR 51.22(c)(10) pertains to issuance of an
amendment pursuant to ``parts 30, 31, 32, 33, 34, 35, 36, 39, 40, 50,
60, 61, 70 or part 72 of this chapter which (i) changes surety,
insurance and/or indemnity requirements, or (ii) changes
[[Page 14728]]
recordkeeping, reporting, or administrative procedures or
requirements.'' Paragraph (c)(10) is not applicable to this change and
the reference should be deleted.
Response: The NRC staff agrees with the comment. The correction has
been made.
8. Comment: Section 7.0, ``References,'' of the model Safety
Evaluation, Reference 1, states the date of NEDC-32988-A, Revision 2,
as September 2005. The correct date of the document is December 2002.
Response: The NRC staff agrees with the comment. The correction has
been made.
The NRC staff has made editorial changes to the previously
published model SE related to TSTF-423 resulting from the disposition
of comments 3, 5, 6, 7, and 8. The staff finds that technically the
previously published SE remains unaltered. Below are the republished
model SE and model NSHC determination (previously published in the
Federal Register; 70 FR 23238, December 14, 2005), and the model
application prepared by the staff that licensees may reference in their
plant-specific applications.
Dated at Rockville, Maryland, this 16th day of March 2006.
For the Nuclear Regulatory Commission.
Thomas H. Boyce,
Branch Chief, Technical Specifications Branch, Division of Inspection
and Regional Support, Office of Nuclear Reactor Regulation.
Model Plant Specific Safety Evaluation for Technical Specification Task
Force (TSTF) Change TSTF-423, Risk Informed Modification to Selected
Required Action End States, a Consolidated Line Item Improvement
U.S. Nuclear Regulatory Commission, Safety Evaluation by the Office of
Nuclear Reactor Regulation Related to Amendment No. [------] to
Facility Operating License NFP-[----[lowbarm]] [Utility Name] [Plant
Name], [Unit ------] Docket No. -[----]
1.0 Introduction
By letter dated ----------, 20--, [Utility Name] (the licensee)
proposed changes to the technical specifications (TS) for [plant name].
The requested changes are the adoption of TSTF-423, Revision 0, to the
Boiling Water Reactor (BWR) Standard Technical Specifications (STS)
(NUREG 1433 and NUREG 1434), which was proposed by the Owners Groups
Technical Specifications Task Force (TSTF) on August 12, 2003, on
behalf of the industry. TSTF-423, Revision 0, incorporates the BWR
Owners Group (BWROG) approved Topical Report NEDC-32988, Revision 2,
``Technical Justification to Support Risk Informed Modification to
Selected Required Action End States for BWR Plants'' (Reference 1),
into the BWR STS (NOTE: The changes in TSTF-423 are made with respect
to Revision 2 of the BWR STS NUREGs).
TSTF-423 is one of the industry's initiatives developed under the
Risk Management Technical Specifications (RMTS) program. These
initiatives are intended to maintain or improve safety through the
incorporation of risk assessment and management techniques in TS, while
reducing unnecessary burden and making TS requirements consistent with
the Commission's other risk-informed regulatory requirements, in
particular the maintenance rule.
The Code of Federal Regulations, 10 CFR 50.36, ``Technical
Specifications,'' states: ``When a limiting condition for operation of
a nuclear reactor is not met, the licensee shall shut down the reactor
or follow the remedial action permitted by the technical specification
until the condition can be met.'' The STS and most plant TS provide a
completion time (CT) for the plant to meet the limiting condition for
operation (LCO). If the LCO or the remedial action cannot be met, then
the reactor is required to be shut down. When the STS and individual
plant technical specifications were written, the shutdown condition or
end state specified was usually cold shutdown.
Topical Report NEDC-32988, Revision 2, provides the technical basis
to change certain required end states when the TS Actions for remaining
in power operation cannot be met within the CTs. Most of the requested
TS changes permit an end state of hot shutdown (Mode 3), if risk is
assessed and managed, rather than an end state of cold shutdown (Mode
4) contained in the current TS. The request was limited to those end
states where: (1) entry into the shutdown mode is for a short interval,
(2) entry is initiated by inoperability of a single train of equipment
or a restriction on a plant operational parameter, unless otherwise
stated in the applicable TS, and (3) the primary purpose is to correct
the initiating condition and return to power operation as soon as is
practical.
The STS for BWR plants define five operational modes. In general,
they are:
Mode 1--Power Operation. The reactor mode switch is in run
position.
Mode 2--Reactor Startup. The reactor mode switch is in
refuel position (with all reactor vessel head closure bolts fully
tensioned) or in startup/hot standby position.
Mode 3--Hot Shutdown. The reactor coolant system (RCS)
temperature is above 200 degrees F (TS specific) and the reactor mode
switch is in shutdown position (with all reactor vessel head closure
bolts fully tensioned).
Mode 4--Cold Shutdown. The RCS temperature is equal to or
less than 200 degrees F and the reactor mode switch is in shutdown
position (with all reactor vessel head closure bolts fully tensioned).
Mode 5--Refueling. The reactor mode switch is in shutdown
or refuel position, and one or more reactor vessel head closure bolts
are less than fully tensioned.
Criticality is not allowed in Modes 3 through 5.
TSTF-423 generally allows a Mode 3 end state rather than a Mode 4
end state for selected initiating conditions in order to perform short-
duration repairs which necessitate exiting the original Mode of
operation. Short duration repairs are on the order of 2-to-3 days, but
not more than a week.
2.0 Regulatory Evaluation
In 10 CFR 50.36, the Commission established its regulatory
requirements related to the content of TS. Pursuant to 10 CFR 50.36(c),
TS are required to include items in the following five specific
categories related to station operation: (1) Safety limits, limiting
safety system settings, and limiting control settings; (2) limiting
conditions for operation (LCOs); (3) surveillance requirements (SRs);
(4) design features; and (5) administrative controls. The rule does not
specify the particular requirements to be included in a plant's TS. As
stated in 10 CFR 50.36(c)(2)(i), the ``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 of a nuclear reactor is not met, the licensee
shall shut down the reactor or follow any remedial action permitted by
the technical specifications * * *.''
Reference 1 states: ``Cold shutdown is normally required when an
inoperable system or train cannot be restored to an operable status
within the allowed time. Going to cold shutdown results in the loss of
steam-driven systems, challenges the shutdown heat removal systems, and
requires restarting the plant. A more preferred operational mode is one
that maintains adequate risk levels while repairs are completed without
causing unnecessary challenges to plant equipment during shutdown and
startup transitions.'' In the end state changes under consideration
here, a problem
[[Page 14729]]
with a component or train has or will result in a failure to meet a TS,
and a controlled shutdown has begun because a TS Action requirement
cannot be met within the TS CT.
Most of today's TS and the design basis analyses were developed
under the perception that putting a plant in cold shutdown would result
in the safest condition and the design basis analyses would bound
credible shutdown accidents. In the late 1980s and early 1990s, the NRC
and licensees recognized that this perception was incorrect and took
corrective actions to improve shutdown operation. At the same time,
standard TS were developed and many licensees improved their TS. Since
enactment of a shutdown rule was expected, almost all TS changes
involving power operation, including a revised end state requirement,
were postponed (see, for example the Final Policy Statement on TS
Improvements, Reference 2). However, in the mid 1990s, the Commission
decided a shutdown rule was not necessary in light of industry
improvements.
Controlling shutdown risk encompasses control of conditions that
can cause potential initiating events and responses to those initiating
events that do occur. Initiating events are a function of equipment
malfunctions and human error. Responses to events are a function of
plant sensitivity, ongoing activities, human error, defense-in-depth,
and additional equipment malfunctions.
In practice, the risk during shutdown operations is often addressed
via voluntary actions and application of 10 CFR 50.65 (Reference 3),
the maintenance rule. Section 50.65(a)(4) states: ``Before performing
maintenance activities * * * the licensee shall assess and manage the
increase in risk that may result from the proposed maintenance
activities. The scope of the assessment may be limited to structures,
systems, and components that a risk-informed evaluation process has
shown to be significant to public health and safety.'' Regulatory Guide
(RG) 1.182 (Reference 4) provides guidance on implementing the
provisions of 10 CFR 50.65(a)(4) by endorsing the revised Section 11
(published separately) to NUMARC 93-01, Revision 2. The revised Section
11 of NUMARC 93-01, Revision 2, was subsequently incorporated into
Revision 3 of NUMARC 93-01 (Reference 5). However, Revision 3 has not
yet been formally endorsed by the NRC. The changes in TSTF-423 are
consistent with the rules, regulations and associated regulatory
guidance, as noted above.
3.0 Technical Evaluation
The changes proposed in TSTF-423 are consistent with the changes
proposed and justified in Topical Report GE NEDC-32988-A, Revision 2,
(Reference 1) and approved by the associated NRC SE (Reference 6). The
evaluation included in Reference 6, as appropriate and applicable to
the changes of TSTF-423 (Reference 7), is reiterated here and
differences from the SE are justified. In its application the licensee
commits to TSTF-IG-05-02, Implementation Guidance for TSTF-423,
Revision 0, ``Technical Specifications End States, NEDC-32988-A,''
(Reference 8), which addresses a variety of issues such as
considerations and compensatory actions for risk-significant plant
configurations. An overview of the generic evaluation and associated
risk assessment is provided below, along with a summary of the
associated TS changes justified by Reference 1.
3.1 Risk Assessment
The objective of the BWROG topical report (Reference 1) risk
assessment was to show that any risk increases associated with the
changes in TS end states are either negligible or negative (i.e., a net
decrease in risk).
The BWROG topical report documents a risk-informed analysis of the
proposed TS change. Probabilistic Risk Assessment (PRA) results and
insights are used, in combination with results of deterministic
assessments, to identify and propose changes in ``end states'' for all
BWR plants. This is in accordance with guidance provided in RG 1.174
(Reference 9) and RG 1.177 (Reference 10). The three-tiered approach
documented in RG 1.177, ``An Approach for Plant-Specific, Risk-Informed
Decision Making: Technical Specifications,'' was followed. The first
tier of the three-tiered approach includes the assessment of the risk
impact of the proposed change for comparison to acceptance guidelines
consistent with the Commission's Safety Goal Policy Statement, as
documented in RG 1.174. The first tier aims at ensuring that there are
no unacceptable temporary risk increases as a result of the TS change,
such as when equipment is taken out of service. The second tier
addresses the need to preclude potentially high-risk configurations
which could result if equipment is taken out of service concurrently
with the equipment out of service as allowed by this TS change. The
third tier addresses the application of 10 CFR 50.65(a)(4) of the
Maintenance Rule for identifying risk-significant configurations
resulting from maintenance related activities and taking appropriate
compensatory measures to avoid such configurations. This TS invokes a
risk assessment because 10 CFR 50.65(a)(4) is applicable to maintenance
related activities and does not cover other operational activities
beyond the effect they may have on existing maintenance related risk.
BWROG's risk assessment approach was found comprehensive and
acceptable in the SE for the topical report. In addition, the analyses
show that the three-tiered approach criteria for allowing TS changes
are met as follows:
Risk Impact of the Proposed Change (Tier 1). The risk
changes associated with the TS changes in TSTF-423, in terms of mean
yearly increases in core damage frequency (CDF) and large early release
frequency (LERF), are risk neutral or risk beneficial. In addition,
there are no significant temporary risk increases, as defined by RG
1.177 criteria, associated with the implementation of the TS end state
changes.
Avoidance of Risk-Significant Configurations (Tier 2). The
performed risk analyses, which are based on single LCOs, shows that
there are no high-risk configurations associated with the TS end state
changes. The reliability of redundant trains is normally covered by a
single LCO. When multiple LCOs occur, which affect trains in several
systems, the plant's risk-informed configuration risk management
program (CRMP), or the risk assessment and management program
implemented in response to the Maintenance Rule 10 CFR 50.65(a)(4),
shall ensure that high-risk configurations are avoided. As part of the
implementation of TSTF-423, the licensee has committed to follow
Section 11 of NUMARC 93-01, Revision 3, and include guidance in
appropriate plant procedures and/or administrative controls to preclude
high-risk plant configurations when the plant is at the proposed end
state. The staff finds that such guidance is adequate for preventing
risk-significant plant configurations.
Configuration Risk Management (Tier 3). The licensee has a
program, as described above, in place to comply with 10 CFR 50.65(a)(4)
to assess and manage the risk from maintenance activities. This program
can support a licensee decision in selecting the appropriate actions to
control risk for most cases in which a risk-informed TS is entered.
The generic risk impact of the end state mode change was evaluated
subject to the following assumptions
[[Page 14730]]
which are incorporated into the TS, TS Bases, and TSTF-IG-05-02
(Reference 8):
1. The entry into the end state is initiated by the inoperability
of a single train of equipment or a restriction on a plant operational
parameter, unless otherwise stated in the applicable technical
specification.
2. The primary purpose of entering the end state is to correct the
initiating condition and return to power as soon as is practical.
3. When Mode 3 is entered as the repair end state, the time the
reactor coolant pressure is above 500 psig will be minimized. If
reactor coolant pressure is above 500 psig for more than 12 hours, the
associated plant risk will be assessed and managed.
These assumptions are consistent with typical entries into Mode 3
for short duration repairs, which is the intended use of the TS end
state changes.
The staff concludes that, in general, going to Mode 3 (hot
shutdown) instead of going to Mode 4 (cold shutdown) to carry out
equipment repairs that are of short duration, does not have any adverse
effect on plant risk.
3.2 Assessment of TS Changes
The changes proposed by the licensee and in TSTF-423 are consistent
with the changes in topical report GE NEDC-32988 (Reference 1), and
approved by the NRC SE (Reference 6). The following are the changes,
including a synopsis of the STS LCO, and a conclusion of acceptability.
3.2.1 Topical Report Section (TRS) 4.5.1.2 and LCO 3.4.3 (BWR/4);
TRS 4.5.2.2 and LCO 3.4.4 (BWR/6), Safety/Relief Valves (SRVs).
The function of the SRVs is to protect the plant against severe
overpressurization events. These TS provide the operability
requirements for the SRVs as described below. The TS change allows the
plant to remain in Mode 3 until the repairs are completed.
[Note:
Plant Applicability, BWR4/6]
LCO: The safety function of 11 SRVs must be operable (BWR/4
plants). The safety function of seven SRVs must be operable and the
relief function of seven additional SRVs must be operable (BWR/6
plants).
Condition requiring entry into end state: If the LCO cannot be met
with one or two SRVs inoperable, the inoperable valves must be returned
to operability within 14 days. If the SRVs cannot be returned to
operable status within that time, the plant must be placed in Mode 3
within 12 hours and in Mode 4 within 36 hours.
Modification for end state required actions: If the LCO cannot be
met with one or two SRVs inoperable, the inoperable valves must be
returned to operability within 14 days. If the one or two inoperable
SRVs cannot be returned to operable status within 14 days, the plant
must be placed in Mode 3 within 12 hours. If three or more SRVs become
inoperable, the plant must be placed in Mode 4 within 36 hours.
Assessment: The BWROG topical report did a comparative PRA
evaluation of the core damage risks of operation in the current end
state and in the Mode 3 end state. The evaluation indicates that the
core damage risks are lower in Mode 3 than in Mode 4. Going to Mode 4
for one inoperable SRV would cause loss of the high-pressure steam-
driven injection system (reactor core isolation cooling (RCIC)/high
pressure coolant injection (HPCI)), and loss of the power conversion
system (condenser/feedwater), and require activating the residual heat
removal (RHR) system. In addition, emergency operating procedures
(EOPs) direct the operator to take control of the depressurization
function if low pressure injection/spray systems are needed for reactor
pressure vessel (RPV) water makeup and cooling. Based on the low
probability of loss of the necessary overpressure protection function
and the number of systems available in Mode 3, the staff concluded in
the SE (reference 6) for the BWROG topical report that the risks of
staying in Mode 3 are approximately the same as, and in some cases
lower than, the risks of going to the Mode 4 end state. The change
allows the inoperable SRV to be repaired in a plant operating mode with
lower risks. After repairs are made, the plant can be brought to full-
power operation with less potential for transients and errors. The
plant is taken into cold shutdown only when three or more SRVs are
inoperable.
Finding: Based on the above assessment, and because the time spent
in Mode 3 to perform the repair is infrequent and limited, and in light
of defense-in-depth considerations (discussed in Reference 1), the
staff finds that the requested change to allow operation in Mode 3 with
a minimum number of SRVs inoperable, after plant risk has been assessed
and managed, is acceptable.
3.2.2 TRS 4.5.1.3 and LCO 3.5.1(BWR/4); TRS 4.5.2.3 and LCO 3.5.1
(BWR/6), Emergency Core Cooling Systems (ECCS) (Operating).
The ECCS systems provide cooling water to the core in the event of
a loss-of-coolant accident (LOCA). This set of ECCS TS provide the
operability requirements for the various ECCS subsystems as described
below. This TS change would delete the secondary actions. The plant can
remain in Mode 3 until the required repair actions are completed. The
reactor is not depressurized.
[Note:
Plant Applicability, BWR4/6]
LCO: Each ECCS injection/spray subsystem and the automatic
depressurization system (ADS) function of seven BWR/4, or eight BWR/6,
SRVs must be operable.
Conditions requiring entry into end state: If the LCO cannot be
met, the following actions must be taken for the listed conditions:
a. If one low-pressure ECCS injection/spray subsystem is
inoperable, the subsystem must be restored to operable status in 7
days.
b. If the inoperable ECCS injection/core spray cannot be restored
to operable status, the plant must be placed in Mode 3 within 12 hours
and Mode 4 within 36 hours (BWR/4 plants only).
c. If two ECCS injection subsystems are inoperable or one ECCS
injection subsystem and one ECCS spray system are inoperable, one ECCS
injection/spray subsystem must be restored to operable status within 72
hours. If this required action cannot be met, the plant must be placed
in Mode 3 within 12 hours and in Mode 4 within 36 hours (BWR/6 plants
only).
d. If the HPCI/High Pressure Core Spray (HPCS) system is
inoperable, the RCIC system must be verified to be operable by
administrative means within 1 hour and the HPCI/HPCS system restored to
operable status within 14 days.
e. If one ADS valve is inoperable, it must be restored to operable
status within 14 days.
f. If one ADS valve is inoperable and one low-pressure ECCS
injection/spray subsystem is inoperable, the ADS valve must be restored
to operable status within 72 hours or the low-pressure ECCS injection/
spray subsystem must be restored to operable status within 72 hours.
g. If two or more ADS valves become inoperable, or the required
actions described in items e and/or f cannot be met, the plant must be
placed in Mode 3 within 12 hours and the reactor steam dome pressure
reduced to less than 150 psig within 36 hours.
Modification for End State Required Actions:
a. No change
b. If the ECCS injection or spray system is inoperable, the plant
must be
[[Page 14731]]
restored to operable status within 12 hours. The plant is not taken
into Mode 4 (cold shutdown).
c. If two ECCS injection subsystems are inoperable or one ECCS
injection subsystem and one ECCS spray system are inoperable, one ECCS
injection/spray subsystem must be restored to operable status within 72
hours. If this required action cannot be met, the plant must be placed
in Mode 3 within 12 hours. The plant is not taken into Mode 4 (BWR/6
plants only).
d. No change
e. No change
f. No change
g. If two or more ADS valves become inoperable or the required
actions described in item e and/or f cannot be met, the plant must be
placed in Mode 3 within 12 hours. The reactor is not depressurized and
not taken to Mode 4.
Assessment: The BWROG topical report did a comparative PRA
evaluation of the core damage risks of operation in the current end
state and the Mode 3 end state. The evaluation indicates that the core
damage risks are lower in Mode 3 than in the current end state Mode 4.
Going to Mode 4 for one ECCS subsystem or one ADS valve would cause
loss of the high-pressure steam-driven injection system (RCIC/HPCI),
and loss of the power conversion system (condenser/feedwater), and
require activating the RHR system. In addition, Plant Emergency
Operating Procedures (EOPs) direct the operator to take control of the
depressurization function if low-pressure injection/spray systems are
needed for RPV water makeup and cooling. Based on the low probability
of loss of the reactor coolant inventory and the number of systems
available in Mode 3, the staff concludes in the SE to the BWR topical
report that the risks of staying in Mode 3 are approximately the same
as, and in some cases lower than, the risks of going to the Mode 4 end
state.
Finding: Based on the above assessment, and because the time spent
in Mode 3 to perform the repair is infrequent and limited, and in light
of defense-in-depth considerations (discussed in Reference 1), the
change is acceptable.
3.2.3 TRS 4.5.1.4 and LCO 3.5.3 (BWR/4 only), Reactor Core
Isolation Cooling (RCIC) System.
The function of the RCIC system is to provide reactor coolant
makeup during loss of feedwater and other transient events. This TS
provides the operability requirements for the RCIC system as described
below. The TS change allows the plant to remain in Mode 3 until the
repairs are completed.
[Note:
Plant Applicability, BWR/4]
LCO: The RCIC system must be operable during Modes 1, 2 and 3 when
the reactor steam dome pressure is greater than 150 psig.
Condition requiring entry into end state: If the LCO cannot be met,
the following actions must be taken: (a) Verify by administrative means
within 1 hour that the HPCI system is operable, (b) restore the RCIC
system to operable status within 14 days. If either or both actions
cannot be completed within the allotted time, the plant must be placed
in Mode 3 within 12 hours and the reactor steam dome pressure reduced
to less than 150 psig within 36 hours.
Modification for end state required actions: This TS change keeps
the plant in Mode 3 (hot shutdown) until the required repairs are
completed. The reactor steam dome pressure is not reduced to less than
150 psig.
Assessment: This change would allow the inoperable RCIC system to
be repaired in a plant operating mode with lower risk and without
challenging the normal shutdown systems. The BWROG topical report did a
comparative PRA evaluation of the core damage risks of operation in the
current end state and in the Mode 3 end state. The evaluation indicates
that the core damage risks are lower in Mode 3 than in Mode 4. Going to
Mode 3 with reactor steam dome pressure less than 150 psig for
inoperability of RCIC would also cause loss of the high-pressure steam-
driven injection system HPCI and loss of the power conversion system
(condenser/ feedwater), and would require activating the RHR system. In
addition, Plant EOPs direct the operator to take control of the
depressurization function if low pressure injection/spray systems are
needed for RPV water makeup and cooling. Based on the low probability
of loss of the necessary overpressure protection function and the
number of systems available in Mode 3, the staff concludes in the SE to
the BWR topical report that the risks of staying in Mode 3 are
approximately the same as, and in some cases lower than, the risks of
going to the Mode 4 end state.
Finding: Based upon the above assessment, and because the time
spent in Mode 3 to perform the repair is infrequent and limited, and in
light of defense-in-depth considerations (discussed in Reference 1),
the change is acceptable.
3.2.4 TRS 4.5.1.6 and LCO 3.6.1.6 (BWR/4); TRS 5.5.2.5 and LCO
3.6.1.6 (BWR/6), Low-Low Set (LLS) Valves.
The function of LLS is to prevent excessive short-duration SRV
cycling during an overpressure event. This TS provides operability
requirements for the four LLS SRVs as described below. The TS change
allows the plant to remain in Mode 3 until the repairs are completed.
[Note:
Plant Applicability, BWR 4/6]
Conditions requiring entry into end state: If one LLS valve is
inoperable, it must be returned to operability within 14 days. If the
LLS valve cannot be returned to operable status within the allotted
time, the plant must be placed in Mode 3 within 12 hours and in Mode 4
within 36 hours.
Modification for end state required actions: The TS change would
keep the plant in Mode 3 until the required repair actions are
completed. The plant would not be taken into Mode 4 (cold shutdown).
Assessment: The BWROG topical report did a comparative PRA
evaluation of the core damage risks of operation in the current end
state and the Mode 3 end state. The evaluation indicates that the core
damage risks are lower in Mode 3 than in Mode 4, the current end state.
Going to Mode 4 for one LLS inoperable SRV would cause loss of the
high-pressure steam-driven injection system (RCIC/HPCI), and loss of
the power conversion system (condenser/feedwater), and would require
activating the RHR system. With one LLS valve inoperable, the remaining
valves are adequate to perform the required function. EOPs direct the
operator to take control of the depressurization function if low
pressure injection/spray systems are needed for RPV water makeup and
cooling. Based on the low probability of loss of the necessary
overpressure protection function during the infrequent and limited time
in Mode 3 and the number of systems available in Mode 3, the staff
concludes in the SE to the BWR topical report that the risks of staying
in Mode 3 are approximately the same as and in some cases lower than
the risks of going to the Mode 4 end state. The change allows repairs
of the inoperable SRV to be performed in a plant operating mode with
lower risks.
Finding: Based upon the above assessment, and because the time
spent in Mode 3 to perform the repair is infrequent and limited, and in
light of defense-in-depth considerations (discussed in Reference 1),
the change is acceptable.
3.2.5 TRS 4.5.1.1, TRS 4.5.2.1 and LCO 3.3.8.2, Reactor Protection
System (RPS) Electric Power Monitoring.
RPS Electric Power Monitoring System is provided to isolate the RPS
bus from the motor generator (MG) set or an alternate power supply in
the event of over voltage, under voltage, or under frequency. This
system protects
[[Page 14732]]
the load connected to the RPS bus against unacceptable voltage and
frequency conditions and forms an important part of the primary success
path of the essential safety circuits. Some of the essential equipment
powered from the RPS buses includes the RPS logic, scram solenoids, and
various valve isolation logic. The TS change allows the plant to remain
in Mode 3 until the repairs are completed.
[Note:
Plant Applicability, BWR 4/6]
LCO: For Modes 1, 2, 3 and Modes 4 and 5 (with any control rod
withdrawn from a core cell containing one or more fuel assemblies), two
RPS electric power monitoring assemblies shall be operable for each in-
service RPS motor generator set or alternate power supply.
Condition Requiring Entry into End State: If the LCO cannot be met,
the associated in-service power supply(s) must be removed from service
within 72 hours for one Electric Power Assembly (EPA) inoperable or
within one hour for both EPAs inoperable. In Modes 1, 2, and 3, if the
in-service power supply(s) cannot be removed from service within the
allotted time, the plant must be placed in Mode 3 within 12 hours and
Mode 4 within 36 hours.
Modification: The change is to keep the plant in Mode 3 until the
repair actions are completed. Delete required action in C.2 which
required the plant to be in Mode 4.
Assessment: To reach Mode 3 per the TS, there must be a functioning
power supply with degraded protective circuitry in operation. However,
the over voltage, under voltage, or under frequency condition must
exist for an extended time period to cause damage. There is a low
probability of this occurring in the short period of time that the
plant would remain in Mode 3 without this protection.
The specific failure condition of interest is not risk significant
for BWR PRAs. If the required restoration actions cannot be completed
within the specified time, going into Mode 4 would cause loss of the
high-pressure steam-driven injection system (RCIC/HPCI) and loss of the
power conversion system (condenser/feedwater), and would require
activating the RHR system. In addition, EOPs direct the operator to
take control of the depressurization function if low pressure
injection/spray systems are needed for RPV water makeup and cooling.
Based on the low probability of loss of the RPS power monitoring system
during the infrequent and limited time in Mode 3 and the number of
systems available in Mode 3, the staff concludes in the SE to the BWR
topical report that the risks of staying in Mode 3 are approximately
the same as and in some cases lower than the risks of going to the Mode
4 end state.
Finding: Based upon the above assessment, and because the time
spent in Mode 3 to perform the repair is infrequent and limited, and in
light of defense-in-depth considerations (discussed in Reference 1),
the change is acceptable.
3.2.6 TRS 4.5.1.19 and LCO 3.8.1(BWR/4); TRS 4.5.2.17 and LCO
3.8.1(BWR/6), AC Sources (Operating).
The purpose of the AC electrical system is to provide during all
situations the power required to put and maintain the plant in a safe
condition and prevent the release of radioactivity to the environment.
The Class 1E electrical power distribution system AC sources
consist of the offsite power source (preferred power sources, normal
and alternate(s)), and the onsite standby power sources (e.g.,
emergency diesel generators (EDGs)). In addition, many sites provide a
crosstie capability between units.
As required by General Design Criterion (GDC) 17 of 10 CFR Part 50,
Appendix A, the design of the AC electrical system provides
independence and redundancy. The onsite Class 1E AC distribution system
is divided into redundant divisions so that the loss of any one
division does not prevent the minimum safety functions from being
performed. Each division has connections to two preferred offsite power
sources and a single EDG or other Class 1E Standby AC power source.
Offsite power is supplied to the unit switchyard(s) from the
transmission network by two transmission lines. From the switchyard(s),
two electrically and physically separated circuits provide AC power
through a stepdown transformer(s) to the 4.16-kV emergency buses.
In the event of a loss of offsite power, the emergency electrical
loads are automatically connected to the EDGs in sufficient time to
provide for a safe reactor shutdown and to mitigate the consequence of
a design basis accident (DBA) such as a LOCA.
[Note:
Plant Applicability, BWR 4/6]
LCO: The following AC electrical power sources shall be operable in
Modes 1, 2, and 3:
a. Two qualified circuits between the offsite transmission network
and the onsite Class1E AC Electric Power Distribution System,
b. Three EDGs,
c. Automatic Load Sequencers.
Condition requiring entry into end state: Plant operators must
bring the plant to Mode 4 within 36 hours following the sustained
inoperability of one required Automatic Load Sequencer; either or both
required offsite circuits; either one, two or three required EDGs; or
one required offsite circuit and one, two or three required EDGs.
Modification for end state require actions: Delete required action
G.2 to go to Mode 4 (cold shutdown). The plant will remain in Mode 3
(hot shutdown).
Assessment: Entry into any of the conditions for the AC power
sources implies that the AC power sources have been degraded and the
single failure protection for the safe shutdown equipment may be
ineffective. Consequently, as specified in TS 3.8.1 at present, the
plant operators must bring the plant to Mode 4 when the required action
is not completed by the specified time for the associated action.
The BWROG topical report did a comparative PRA evaluation of the
core damage risks of operation in the current end state and in the Mode
3 end state. Events initiated by the loss of offsite power are dominant
contributors to core damage frequency in most BWR PRAs, and the steam-
driven core cooling systems, RCIC and HPCI, play a major role in
mitigating these events. The evaluation indicates that the core damage
risks are lower in Mode 3 than in Mode 4 for one inoperable AC power
source. Going to Mode 4 for one inoperable AC power source would cause
loss of the high-pressure steam-driven injection system (RCIC/HPCI),
and loss of the power conversion system (condenser/feedwater), and
require activating the RHR system. In addition, EOPs direct the
operator to take control of the depressurization function if low
pressure injection/spray systems are needed for RPV water makeup and
cooling. Based on the low probability of loss of the AC power and the
number of steam-driven systems available in Mode 3, the staff concludes
in the SE to the BWR topical report that the risks of staying in Mode 3
are lower than going to the Mode 4 end state.
Finding: Based upon the above assessment, and because the time
spent in Mode 3 to perform the repair is infrequent and limited, and in
light of defense-in-depth considerations (discussed in Reference 1),
the change is acceptable.
3.2.7 TRS 4.5.1.20 and LCO 3.8.4 (BWR/4); TRS 4.5.2.18 and LCO
3.8.4 DC Sources (Operating).
The purpose of the DC power system is to provide a reliable source
of DC power for both normal and abnormal conditions. It must supply
power in an emergency for an adequate length of
[[Page 14733]]
time until normal supplies can be restored.
The DC electrical system:
a. Provides the AC emergency power system with control power,
b. Provides motive and control power to selected safety related
equipment, and
c. Provides power to preferred AC vital buses (via inverters).
[Note:
Plant Applicability, BWR 4/6]
LCO: For Modes 1, 2 and 3, the following DC sources are required to
be operable: BWR/4: The (Division 1 and Division 2 station service, and
DG 1B, 2A, and 2C) DC electrical power systems shall be operable.
BWR/6: The (Divisions 1, 2, and 3) DC electrical power subsystems
shall be operable.
Condition requiring entry into end state: The plant operators must
bring the plant to Mode 3 within 12 hours and Mode 4 within 36 hours
following the sustained inoperability of one DC electrical power
subsystem for a period of 2 hours.
Modification for end state required actions: The TS change is to
remove the requirement to place the plant in Mode 4, Required Actions
in D.2 (BWR/4) and E.2 (BWR/6) are deleted.
Assessment: If one of the DC electrical power subsystems is
inoperable, the remaining DC electrical power subsystems have the
capacity to support a safe shutdown and to mitigate an accident
condition. The BWROG topical report did a comparative PRA evaluation of
the core damage risks of operation in the current end state and in the
Mode 3 end state, with one DC system inoperable. Events initiated by
the loss of offsite power are dominant contributors to core damage
frequency in most BWR PRAs, and the steam-driven core cooling systems,
RCIC and HPCI, play a major role in mitigating these events. The
evaluation indicates that the core damage risks are lower in Mode 3
than in Mode 4. Going to Mode 4 for one inoperable DC power source
would cause loss of the high-pressure steam-driven injection system
(RCIC/HPCI), and loss of the power conversion system (condenser/
feedwater), and require activating the RHR system. In addition, EOPs
direct the operator to take control of the depressurization function if
low pressure injection/spray systems are needed for RPV water makeup
and cooling. Based on the low probability of loss of the DC power and
the number of systems available in Mode 3, the staff concludes in the
SE to the BWR topical report that the risks of staying in Mode 3 are
approximately the same as and in some cases lower than the risks of
going to the Mode 4 end state.
Finding: Based upon the above assessment, and because the time
spent in Mode 3 to perform the repair is infrequent and limited, and in
light of defense-in-depth considerations (discussed in Reference 1),
the change is acceptable.
3.2.8 TRS 4.5.1.21 and LCO 3.8.7 (BWR/4); TRS 4.5.2.19 and 3.8.7
(BWR/6), Inverters (Operating).
In Modes 1,2,and 3, the inverters provide the preferred source of
power for the 120-VAC vital buses which power the reactor protection
system (RPS) and the Emergency Core Cooling Systems (ECCS) initiation.
The inverter can be powered from an internal AC source/rectifier or
from the station battery.
[Note:
Plant Applicability, BWR 4/6]
LCO: For Modes 1, 2, and 3 the following Inverters shall be
operable:
BWR/4: The (Division 1 and Division 2) shall be operable.
BWR/6: The (Divisions 1, 2, and 3) shall be operable.
Condition requiring entry into end state: The plant operators must
bring the plant to Mode 3 within 12 hours and Mode 4 within 36 hours
following the sustained inoperability of the required inverter for a
period of 24 hours.
Modification for end state required actions: The TS change is to
remove the requirement to place the plant in Mode 4. Required Actions
in B.2 (BWR/4) and C.2 (BWR/6) are deleted.
Assessment: If one of the Inverters is inoperable, the remaining
Inverters have the capacity to support a safe shutdown and to mitigate
an accident condition. The BWROG topical report did a comparative PRA
evaluation of the core damage risks of operation in the current end
state and in the Mode 3 end state, with an inoperable Inverter. Events
initiated by the loss of offsite power are dominant contributors to
core damage frequency in most BWR PRAs, and the steam-driven core
cooling systems, RCIC and HPCI, play a major role in mitigating these
events. The evaluation indicates that the core damage risks are lower
in Mode 3 than in Mode 4. Going to Mode 4 for one inoperable Inverter
power source would cause loss of the high-pressure steam-driven
injection system (RCIC/HPCI), and loss of the power conversion system
(condenser/feedwater), and require activating the RHR system. In
addition, EOPs direct the operator to take control of the
depressurization function if low pressure injection/spray systems are
needed for RPV water makeup and cooling. Based on the low probability
of loss of the Inverters during the infrequent and limited time in Mode
3 and the number of systems available in Mode 3, the staff concludes in
the SE to the BWR topical report that the risks of staying in Mode 3
are approximately the same as and in some cases lower than the risks of
going to the Mode 4 end state.
Finding: Based upon the above assessment, and because the time
spent in Mode 3 to perform the repair is infrequent and limited, and in
light of defense-in-depth considerations (discussed in Reference 1),
the change is acceptable.
3.2.9 TRS 4.5.1.22 and LCO 3.8.9 (BWR/4); TRS 4.5.2.20 and LCO
3.8.9 (BWR/6), Distribution Systems(Operating).
The onsite Class 1E AC and DC electrical power distribution system
is divided into redundant and independent AC, DC, and AC vital bus
electrical power distribution systems. The primary AC electrical power
distribution subsystem for each division consists of a 4.16-kV
Engineered Safety Feature (ESF) bus having an offsite source of power
as well as a dedicated onsite EDG source. The secondary plant
distribution subsystems include 600-VAC emergency buses and associated
load centers, motor control centers, distribution panels and
transformers. The 120-VAC vital buses are arranged in four load groups
and normally powered from DC via the inverters. There are two
independent 125/250-VDC station service electrical power distribution
systems and three independent 125-VDC DG electrical power distribution
subsystems that support the necessary power for ESF functions. Each
subsystem consists of a 125-VDC and 250-VDC bus and associated
distribution panels.
[Note:
Plant Applicability, BWR 4/6]
LCO: For Modes 1,2, and 3, the following electrical power
distribution subsystems shall be operable:
BWR/4: The Division 1 and Division 2 AC, DC, and AC vital buses
shall be operable.
BWR/6: The Divisions 1, 2, and 3 AC, DC, and AC vital buses shall
be operable.
Condition requiring entry into end state: The plant operators must
bring the plant to Mode 3 within 12 hours and Mode 4 within 36 hours
following the sustained inoperability of one AC or one DC or one AC
vital bus electrical power subsystem for a period of 8 hours, 2 hours
and 2 hours, respectively (with a maximum 16 hour Completion Time limit
from initial discovery of failure to
[[Page 14734]]
meet the LCO, to preclude being in the LCO indefinitely).
Modification for end state required actions: The TS change is to
remove the requirement to place the plant in Mode 4, Required Action in
D.2 (BWR/4) and D.2 (BWR/6) are deleted.
Assessment: If one of the AC/DC/AC vital subsystems is inoperable,
the remaining AC/DC/AC vital subsystems have the capacity to support a
safe shutdown and to mitigate an accident condition. The BWROG topical
report did a comparative PRA evaluation of the core damage risks of
operation in the current end state and in the Mode 3 end state, with
one of the AC/DC/AC vital subsystems inoperable. Events initiated by
the loss of offsite power are dominant contributors to core damage
frequency in most BWR PRAs, and the steam-driven core cooling systems,
RCIC and HPCI, play a major role in mitigating these events. The
evaluation indicates that the core damage risks are lower in Mode 3
than in Mode 4. Going to Mode 4 for one inoperable AC/DC/AC vital
subsystem would cause loss of the high-pressure steam-driven injection
system (RCIC/HPCI), and loss of the power conversion system (condenser/
feedwater), and require activating the RHR system. In addition, EOPs
direct the operator to take control of the depressurization function if
low pressure injection/spray systems are needed for RPV water makeup
and cooling. Based on the low probability of loss of the AC/DC/AC vital
electrical subsystems during the infrequent and limited time in Mode 3
and the number of systems available in Mode 3, the staff concludes in
the SE to the BWR topical report that the risks of staying in Mode 3
are approximately the same as and in some cases lower than the risks of
going to the Mode 4 end state.
Finding: Based upon the above assessment, and because the time
spent in Mode 3 to perform the repair is infrequent and limited, and in
light of defense-in-depth considerations (discussed in Reference 1),
the change is acceptable.
3.2.10 TRS 4.5.1.5 and LCO 3.6.1.1, Primary Containment.
The function of the primary containment is to isolate and contain
fission products released from the Reactor Primary System following a
design basis LOCA and to confine the postulated release of
radioactivity. The primary containment consists of a steel-lined,
reinforced concrete vessel, which surrounds the Reactor Primary System
and provides an essentially leak-tight barrier against an uncontrolled
release of radioactivity to the environment. Additionally, this
structure provides shielding from the fission products that may be
present in the primary containment atmosphere following accident
conditions.
[Note:
Plant Applicability, BWR 4/6]
LCO: The primary containment shall be operable.
Condition Requiring Entry into End State: If the LCO cannot be met,
the primary containment must be returned to operability within one hour
(Required Action A.1). If the primary containment cannot be returned to
operable status within the allotted time, the plant must be placed in
Mode 3 within 12 hours (Required Action B.1) and in Mode 4 within 36
hours (Required Action B.2).
Modification for End State Required Actions: Delete Required Action
B.2.
Assessment: The primary containment is one of the three primary
boundaries to the release of radioactivity. (The other two are the fuel
cladding and the Reactor Primary System pressure boundary.) Compliance
with this LCO ensures that a primary containment configuration exists,
including equipment hatches and penetrations, that is structurally
sound and will limit leakage to those leakage rates assumed in the
safety analyses. This LCO entry condition does not include leakage
through an unisolated release path. The BWROG topical report has
determined that previous generic PRA work related to Appendix J
requirements has shown that containment leakage is not risk
significant. Should a fission product release from the primary
containment occur, the secondary containment and related functions
would remain operable to contain the release, and the standby gas
treatment system would remain available to filter fission products from
being released to the environment. By remaining in Mode 3, HPCI, RCIC,
and the power conversion system (condensate/feedwater) remain available
for water makeup and decay heat removal. Additionally, the EOPs direct
the operators to take control of the depressurization function if low
pressure injection/spray are needed for reactor coolant makeup and
cooling. Therefore, defense-in-depth is maintained with respect to
water makeup and decay heat removal by remaining in Mode 3.
Finding: The requested change is acceptable. Note that the staff's
approval relies upon the secondary containment and the standby gas
treatment system for maintaining defense-in-depth while in this reduced
end state.
3.2.11 TRS 4.5.1.7 and LCO 3.6.1.7, Reactor Building-to-Suppression
Chamber Vacuum Breakers(BWR/4 only).
The reactor building-to-suppression chamber vacuum breakers relieve
vacuum when the primary containment depressurizes below the pressure of
the reactor building, thereby serving to preserve the integrity of the
primary containment.
[Note:
Plant Applicability, BWR/4]
LCO: Each reactor building-to-suppression chamber vacuum breaker
shall be operable.
Condition Requiring Entry into End State: If one line has one or
more reactor building-to-suppression chamber vacuum breakers inoperable
for opening, the breaker(s) must be returned to operability within 72
hours (Required Action C.1). If the vacuum breaker(s) cannot be
returned to operability within the allotted time, the plant must be
placed in Mode 3 within 12 hours (Required Action E.1) and in Mode 4
within 36 hours (Required Action E.2).
Modification for End State Required Actions: Modify the Required
Actions so that if vacuum breaker(s) cannot be returned to operable
status within the required Completion Times, the plant is place in hot
shutdown. That is, modify Condition E to relate only to Condition C,
delete Required Action E.2, and add Condition F, with Required Actions
F.1 and F.2, shutting down the plant to Mode 3 and then Mode 4
respectively, to address an inability to comply with the required
actions related to the other Conditions (i.e., Conditions A, B, and D).
Assessment: The BWROG topical report has determined that the
specific failure condition of interest is not risk significant in BWR
PRAs. The reduced end state would only be applicable to the situation
where the vacuum breaker(s) in one line are inoperable for opening,
with the remaining operable vacuum breakers capable of providing the
necessary vacuum relief function. The existing end state remains
unchanged, as established by new Condition F, for conditions involving
more than one inoperable line or vacuum breaker since they are needed
in Modes 1, 2, and 3. In Mode 3, for other accident considerations,
HPCI, RCIC, and the power conversion system (condensate/feedwater)
remain available for water makeup and decay heat removal. Additionally,
the EOPs direct the operators to take control of the depressurization
function if low pressure injection/spray are needed for reactor coolant
makeup and cooling. Therefore, defense-in-depth is maintained with
respect to water
[[Page 14735]]
makeup and decay heat removal by remaining in Mode 3.
Finding: Based upon the above assessment, and because the time
spent in Mode 3 to perform the repair is infrequent and limited, and in
light of defense-in-depth considerations (discussed in Reference 1),
the change is acceptable.
3.2.12 TRS 4.5.1.8 and LCO 3.6.1.8, Suppression Chamber-to-Drywell
Vacuum Breakers(BWR/4 only).
The function of the suppression chamber-to-drywell vacuum breakers
is to relieve vacuum in the drywell, thereby preventing an excessive
negative differential pressure across the wetwell/drywell boundary.
[Note:
Plant Applicability, BWR/4]
LCO: Nine suppression chamber-to-drywell vacuum breakers shall be
operable for opening.
Condition Requiring Entry into End State: If one suppression
chamber-to-drywell vacuum breaker is inoperable for opening, the
breaker must be returned to operability within 72 hours (Required
Action A.1). If the vacuum breaker cannot be returned to operability
within the allotted time, the plant must be placed in Mode 3 within 12
hours (Required