Notice of Availability of Model Application Concerning Technical Specification Improvement To Modify Requirements Regarding the Addition of LCO 3.0.9 on the Unavailability of Barriers Using the Consolidated Line Item Improvement Process, 58444-58454 [06-8427]

Agencies

• NUCLEAR REGULATORY COMMISSION

[Federal Register Volume 71, Number 191 (Tuesday, October 3, 2006)]
[Notices]
[Pages 58444-58454]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 06-8427]


-----------------------------------------------------------------------

NUCLEAR REGULATORY COMMISSION


Notice of Availability of Model Application Concerning Technical 
Specification Improvement To Modify Requirements Regarding the Addition 
of LCO 3.0.9 on the Unavailability of Barriers 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 safety evaluation (SE) 
and model application relating to the modification of requirements 
regarding the impact of unavailable barriers, not explicitly addressed 
in technical specifications, but required for operability of supported 
systems in technical specifications (TS). The NRC staff has also 
prepared a model no-significant-hazards-consideration (NSHC) 
determination relating to this matter. The purpose of these models is 
to permit the NRC to efficiently process amendments that propose to add 
an LCO 3.0.9 that provides a delay time for entering a supported system 
TS when the inoperability is due solely to an unavailable barrier, if 
risk is assessed and managed. Licensees of nuclear power reactors to 
which the models apply could then request amendments utilizing the 
model application, as generically approved by this notice, and 
confirming the applicability of the SE and NSHC determination to their 
reactors.

DATES: The NRC staff issued a Federal Register notice (71 FR 32145, 
June 2, 2006) which provided a Model Safety Evaluation (SE) and model 
application relating to modification of requirements regarding the 
addition to the TS of LCO 3.0.9 the impact of unavailable barriers; 
similarly the NRC staff herein provides a Model Application, including 
a revised Model Safety Evaluation. The NRC staff can most efficiently 
consider applications based upon the Model Application, which 
references the Model Safety Evaluation, if the application is submitted 
within one year of this Federal Register notice.

FOR FURTHER INFORMATION CONTACT: T. R. Tjader, Mail Stop: O-12H4, 
Division of Inspection and Regional Support, Office

[[Page 58445]]

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 by processing 
proposed changes to the standard technical specifications (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 assessment by the NRC staff 
and finding that the change will likely be offered for adoption by 
licensees. The CLIIP directs the NRC staff to evaluate any comments 
received for a proposed change to the STS and to either reconsider the 
change or to proceed with announcing the availability of the change for 
proposed adoption by licensees. Those licensees opting to apply for the 
subject change to technical specifications 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 addition of LCO 3.0.9 to the TS which 
provides a delay time for entering a supported system TS when the 
inoperability is due solely to an unavailable barrier, if risk is 
assessed and managed. This change was proposed for incorporation into 
the standard technical specifications by the owners groups participants 
in the Technical Specification Task Force (TSTF) and is designated 
TSTF-427, Revision 2 (Rev 2). TSTF-427, Rev 2, can be viewed on the 
NRC's Web page at https://www.nrc.gov/reactors/operating/
licensing/techspecs.html.

Applicability

    This proposal to modify technical specification requirements by the 
addition of LCO 3.0.9, as proposed in TSTF-427, Rev 2, is applicable to 
all licensees.
    To efficiently process the incoming license amendment applications, 
the staff requests that each licensee applying for the changes proposed 
in TSTF-427, Rev 2, to use the CLIIP. The CLIIP does not prevent 
licensees from requesting an alternative approach or proposing the 
changes without the requested Bases and Bases control program. 
Variations 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 request to adopt TSTF-427, Rev 2, under CLIIP.

Public Notices

    The staff issued a Federal Register notice (71 FR 32145, June 2, 
2006) that requested public comment on the NRC's pending action to 
approve modification of TS requirements regarding the impact of 
unavailable barriers on supported systems in TS. In particular, 
following an assessment and draft safety evaluation by the NRC staff, 
the staff sought public comment on proposed changes to the STS, 
designated as TSTF-427. The TSTF-427 Revision 2 can be viewed on the 
NRC's Web page at https://www.nrc.gov/reactors/operating/
licensing/techspecs.html. TSTF-427 Revision 2 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) at https://www.nrc.gov/reading-rm/adams.html.
    In response to the notice soliciting comments from interested 
members of the public about modifying the TS requirements regarding the 
impact of unavailable barriers on supported systems in TS, the staff 
received one set of comments (from the TSTF Owners Groups, representing 
licensees). The specific comments are provided and discussed below:

General Comments and Comments on the Notice for Comment

    1. Comment: Throughout the notice, reference is made to TSTF-427, 
Revision 1. Revision 2 of TSTF-427 was submitted to the NRC on May 3, 
2006 (NRC accession number ML061240055). The document should be revised 
to reference Revision 2 instead of Revision 1.
    Response: This notice of availability correctly references TSTF-
427, Revision 2, which includes the addition of a discussion of 
barriers significant to Large Early Release (i.e., containment bypass 
events) and external events, consistent with the implementation 
guidance in NEI 04-08. TSTF-427, Revision 2, was provided on the Web 
site for review and comment.
    2. Comment: In the notice under ``Applicability'', the last two 
sentences state, ``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-427, Rev 1''. Should a licensee submit an 
application that requests adoption of TSTF-427 but includes significant 
variations or additional changes, it would facilitate the NRC's review 
for the licensee to acknowledge that the change is based on TSTF-427 so 
that the NRC may use the model Safety Evaluation to the extent 
possible. We recommend revising the last sentence to state, ``Instead, 
licensees desiring significant variations and/or additional changes 
should submit a LAR that does not request to adopt TSTF-427, Rev 2. 
under the Consolidate Line Item Improvement Process''.
    Response: The staff agrees and the change in wording has been made.
    3. Comment: The notice generally uses the term ``barrier'' but uses 
the term ``hazard barrier'' or ``hazard barriers'' nine times. TSTF-427 
and the associated implementation guidance, NEI-04-08, use the term 
``barriers''. We recommend that the document be revised to use the word 
``barrier'' throughout instead of the phrase ``hazard barrier'' so that 
the Traveler, the implementation guidance, the model Safety Evaluation, 
the model application, and the notice are consistent.
    Response: The staff agrees and the change in wording has been made 
for consistency.

Comments on the Model Safety Evaluation

    1. Comment: Section 1.0, first paragraph, first sentence--The 
notice states that the NEI Risk-Informed Technical Specification Task 
Force (RITSTF) submitted TSTF-427, Revision 1. That is incorrect. TSTF-
427 (including the most recent version, Revision 2) was submitted by 
the Technical Specifications Task Force (TSTF), not the NEI RITSTF. 
Note that all Travelers are submitted by the TSTF, even if the Traveler 
is risk-informed and developed with the NEI Risk Informed Technical 
Specification Task Force.

[[Page 58446]]

    Response: The staff agrees to this clarification and the change in 
wording has been made.
    2. Comment: Section 1.0--The quote of the proposed LCO 3.0.9, first 
sentence, contains an extra word not in TSTF-427, Revision 2. It 
states, ``* * * any affected supported system * * *'' The word 
``affected'' does not appear in TSTF-427 and should be removed. This 
same misquote appears in the last sentence of Section 1.
    Response: The staff agrees and the wording correction has been 
made.
    3. Comment: Section 2.0, first sentence, contains a typographical 
error. ``TX'' should be ``TS''. Note that this wording is correct on 
the NRC's Web site as ML061460020, but not in the published notice.
    Response: The staff agrees and the typographical correction has 
been made.
    4. Comment: Section 2.0, second paragraph, first sentence--the 
definition of barriers is not consistent with TSTF-427, Revision 2. 
Specifically, the notice states, ``mechanical devices'', which was 
deleted from TSTF-427, Revision 2.
    Response: The staff agrees and the term ``mechanical devices'' has 
been replaced with the term ``installed structures or components'', to 
be consistent with TSTF-427, Revision 2.
    5. Comment: Section 3.0, first paragraph, fourth sentence--The date 
given for NEI 04-08 is incorrect. The correct date is March 2006, not 
November 2005. Note that Section 7.0, ``References'', provides the 
correct date.
    Response: The date given for NEI 04-08 is corrected.
    6. Comment: Section 3.0, second paragraph, first sentence--There is 
a wording error. The sentence should state, ``* * * can be assessed 
using the same approach * * *'' instead of ``during the same 
approach''. Note that this wording is correct on the NRC's Web site as 
ML061460020, but not in the published notice.
    Response: The staff agrees and the wording correction has been 
made.
    7. Comment: Section 3.0, numbered item 2--The last sentence is 
missing the verb. It should read, ``The objective is to ensure that * * 
*'' Note that this wording is correct on the NRC's Web site as 
ML061460020, but not in the published notice.
    Response: The staff agrees and the wording correction has been 
made.
    8. Comment: Section 3.0, sixth paragraph, second sentence--There is 
a typographical error. The sentence states, ``* * * barriers that are n 
not able to perform * * *'' The extraneous ``n'' should be deleted. 
Note that this wording is correct on the NRC's Web site as ML061460020, 
but not in the published notice.
    Response: The staff agrees and the typographical error has been 
corrected.
    9. Comment: Section 3.0, third paragraph from end, last sentence--
This sentence references Section 3.3. The correct reference is Section 
3.1.3.
    Response: The staff agrees and the correction has been made.
    10. Comment: Section 3.1.1, last paragraph before Table 2--NUMARC 
93-01 is misquoted. The notice states, ``* * * configuration that is 
associated with a CDF higher than 1E-03 should not be entered 
voluntarily''. However, NUMARC 93-01, Section 11.3.7.2, states, ``* * * 
CDF in excess of 10-3/year should be carefully considered before 
voluntarily entering such conditions. If such conditions are entered, 
it should be for very short periods of time and only with a clear 
detailed understanding of which events cause the risk level''. The 
notice wording should be revised. Note that Table 2 in the notice 
correctly describes the NUMARC 93-01 guidance.
    Response: The staff agrees. To be consistent with NUMARC 93-01, the 
word ``normally'' has been added so that the phrase reads: ``* * * 
should not normally be entered voluntarily''.
    11. Comment: Section 3.1.1, Table 2--The table uses the undefined 
term ``RCDF''. This term should be defined.
    Response: The staff agrees. The term has been defined.
    12. Comment: Section 3.1.2, third paragraph--The following phrase 
is confusing, ``* * * unplanned failures or discovered conditions may 
result in the unavailability of at least one train or subsystem for a 
particular initiating event''. A clear statement of the intent is in 
Section 1.0, which states, ``* * * if the required OPERABLE train or 
subsystem becomes inoperable while this specification is in use, it 
must be restored to OPERABLE status within 24 hours or * * *'' The 
inoperability of the train that has the affected barrier is not the 
purpose of the 24-hour allowance--it is the inoperability of the 
opposite train. This phrase should be revised to be consistent with 
Section 1.0.
    Response: The staff agrees and the change in wording has been made 
for consistency.
    13. Comment: Section 3.1.2, third paragraph--The notice states, 
``Such conditions may result during application of LCO 3.0.9 from 
equipment failure on the operable train, or discovery of degraded 
barriers''. The statement is technically correct but the last phrase is 
misleading. The 24-hour allowance is only used when the redundant train 
required to be operable by LCO 3.0.9 is found to be inoperable due to 
equipment failure or the failure of a barrier that protects the train 
from the same initiating event as the unavailable barrier on the first 
train. We recommend revising the sentence by replacing the last phrase 
with ``* * * or discovery of a degraded barrier that protect all trains 
of a TS system from the same initiating event''.
    Response: The staff agrees, and the wording has been revised for 
clarification.
    14. Comment: Section 3.1.3, second paragraph, first sentence--This 
sentence is incorrect when it states, ``The implementation guidance for 
LCO 3.0.9 (Reference 2) requires that the risk determination for an 
unavailable barrier be performed per the ICCDP calculation as described 
in Section 3.1 * * *'' The implementation guidance clearly states in 
Section 6.2, Step 7, first paragraph, ``(The user is not limited by the 
example used in the TSTF-427 technical justification)''. Furthermore, 
Appendix A of the implementation guidance provides an example of a risk 
assessment program for barriers using a site-specific on-line risk 
tool. The example uses the ICCDP equation only to calculate the allowed 
time, Tc. This sentence in the notice should be revised to 
state, ``The risk determination of an unavailable barrier is to be 
performed using the plant-specific configuration''.
    Response: The staff agrees, and the wording has been revised for 
clarification.
    15. Comment: Section 3.1.3, third paragraph, second sentence--This 
sentence has a grammar error. It should state, ``The numerical guidance 
identified in Table 2 is applicable to * * * ``not'' are applicable 
to''.
    Response: The staff agrees and the correction has been made.
    16. Comment: Section 3.1.3, next to the last paragraph, last 
sentence--The sentence is not correct. The CLIIP states, ``* * * LERF, 
then the methodology requires a calculation for ICLERP similar to the 
calculations performed for ICCDP, described in Section 3.1, or the 
applicability of LCO 3.0.9 must be limited to that one barrier''. This 
is inconsistent with TSTF-427, Section 4, and NEI 04-08, Section 6.2, 
Step 7.c, which states, ``However, if the barrier protects a system 
that is significant to mitigation of containment bypass events, such as 
interfacing systems LOCA or steam generator tube rupture, assess the 
LERF impact using a qualitative, quantitative, or blended approach, * * 
*. If a quantitative assessment of the LERF impact cannot be made, the 
use of LCO 3.0.9 at a given time should be limited to a single

[[Page 58447]]

barrier protecting a system that is significant to mitigation of 
containment bypass events''. The notice should be revised to be 
consistent with the Traveler and the implementation guidance document.
    Response: The staff agrees, and the wording has been revised for 
clarification.
    17. Comment: Section 3.2, Item 3, first paragraph, last sentence--
This is an incomplete sentence. We recommend revising it to state 
``Unnecessary plant shutdowns may occur due to discovery of * * *''
    Response: The staff agrees to this clarification and change in 
wording has been made.
    18. Comment: Section 3.2, next to the last paragraph, stipulation 
item 1--Reference to NEI 04-08 should be eliminated. Commitment to NEI 
04-08 is discussed in the next paragraph. Note that the commitments in 
the Model Application do not reference NEI 04-08 in the first 
commitment.
    Response: The staff does not agree that a change is necessary. The 
purpose of item 1 is to identify both required commitments, and the 
purpose of item 2 is to address necessary related revisions to 
procedures.
    19. Comment: Section 3.2, last paragraph, stipulation item 2--The 
paragraph states, ``Licensee procedures must be revised to ensure that 
the risk assessment and management process described in NEI 04-08 is 
used whenever a barrier is considered unavailable * * *'' NEI 04-08 is 
not the only acceptable methodology that may be used to perform the 
risk assessment required by LCO 3.0.9. As stated in Section 6.0 of NEI 
04-08, the document ``* * * describes considerations for risk 
assessment and management relative to the use of LCO 3.0.9''. The 
document discusses acceptable methods of assessment in Section 6.1 and 
the general process for risk assessments in Section 6.2. We recommend 
revising the paragraph to state, ``Licensee procedures must be revised 
to ensure that the guidance on the assessment and management of risk in 
NEI 04-08 is used whenever a barrier is considered unavailable''. The 
same change should be made to commitment 2 in Section 3.2, 
``Verification and Commitments'', and in Enclosure 4 in the published 
Model Application.
    Response: The staff agrees and the change in wording has been made 
for consistency.
    20. Comment: Section 7.0, Reference 1--Revise Reference 1 to refer 
to Revision 2 of TSTF-427, dated May 3, 2006.
    Response: The staff agrees and the correction has been made.
    21. Comment: Section 7.0, Reference 7--For consistency, Reference 7 
should list the May 2000 issuance date of Regulatory Guide 1.182.
    Response: The staff agrees and the change in wording has been made 
for consistency.

Comments on the Proposed No-Significant-Hazards-Consideration 
Determination

    1. Comment: Last paragraph--The notice states, ``Based upon the 
reasoning presented above and the previous discussion of the amendment 
request, the requested change does not involve a no-significant-hazards 
consideration''. The use of the double negative is confusing. We 
recommend revising the sentence to state, ``Based upon the reasoning 
presented above and the previous discussion of the amendment request, 
the requested change presents no significant hazards considerations 
under the standards set forth in 10 CFR 50.92(c)''.
    Response: The staff agrees and this clarifying change has been 
made.
    Comments on the Model Application
    1. Comment: Enclosure 3, ``Revised Technical Specification Pages'', 
should be shown as optional. Many licensees do not provide retyped 
technical specification pages in their license amendment requests.
    Response: The staff does not agree that this proposed change is 
necessary. Submission of revised technical specification pages clearly 
identify the changes requested and enhance the staff's ability to 
conduct an efficient review, consistent with purpose of changes made in 
accordance with the Consolidated Line Item Improvement Process.
    2. Comment: We recommend adding the Technical Specifications Branch 
Chief to the cc: list on the model application as has been done in 
other CLIIP model applications.
    Response: The staff agrees and the change has been made.

    Dated at Rockville, Maryland, this 25th day of September 2006.

    For the Nuclear Regulatory Commission.
Timothy J. Kobetz,
Chief, Technical Specifications Branch, Division of Inspection and 
Regional Support, Office of Nuclear Reactor Regulation.

Model Safety Evaluation, U.S. Nuclear Regulatory Commission, Office of 
Nuclear Reactor Regulation, Consolidated Line Item Improvement, 
Technical Specification Task Force (TSTF) Change TSTF-427; The Addition 
of Limiting Condition for Operation (LCO) 3.0.9 on the Unavailability 
of Barriers

1.0 Introduction

    On May 3, 2006, the industry owners group Technical Specifications 
Task Force (TSTF) submitted a proposed change, TSTF-427, Revision 2, to 
the standard technical specifications (STS) (NUREGs 1430-1434) on 
behalf of the industry (TSTF-427, Revisions 0 and 1 were prior draft 
iterations). TSTF-427, Revision 2, is a proposal to add an STS Limiting 
Condition for Operation (LCO) 3.0.9, allowing a delay time for entering 
a supported system technical specification (TS), when the inoperability 
is due solely to an unavailable barrier, if risk is assessed and 
managed. The postulated initiating events which may require a 
functional barrier are limited to those with low frequencies of 
occurrence, and the overall TS system safety function would still be 
available for the majority of anticipated challenges.
    This proposal is one of the industry's initiatives being developed 
under the risk-informed TS 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.
    The proposed change adds a new limiting condition of operation, LCO 
3.0.9, to the TS. LCO 3.0.9 allows licensees to delay declaring an LCO 
not met for equipment supported by barriers unable to perform their 
associated support function, when risk is assessed and managed. This 
new LCO 3.0.9 states:
    ``When one or more required barriers are unable to perform their 
related support function(s), any supported system LCO(s) are not 
required to be declared not met solely for this reason for up to 30 
days provided that at least one train or subsystem of the supported 
system is OPERABLE and supported by barriers capable of providing their 
related support function(s), and risk is

[[Page 58448]]

assessed and managed. This specification may be concurrently applied to 
more than one train or subsystem of a multiple train or subsystem 
supported system provided at least one train or subsystem of the 
supported system is OPERABLE and the barriers supporting each of these 
trains or subsystems provide their related support function(s) for 
different categories of initiating events.

[BWR only: For the purposes of this specification, the [High Pressure 
Coolant Injection/High Pressure Core Spray] system, the [Reactor Core 
Isolation Cooling] system, and the [Automatic Depressurization System] 
are considered independent subsystems of a single system.]

    If the required OPERABLE train or subsystem becomes inoperable 
while this specification is in use, it must be restored to OPERABLE 
status within 24 hours or the provisions of this specification cannot 
be applied to the trains or subsystems supported by the barriers that 
cannot perform their related support function(s).
    At the end of the specified period, the required barriers must be 
able to perform their related support function(s), or the supported 
system LCO(s) shall be declared not met.''

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, 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 specification * * *.'' TS Section 3.0, on ``LCO and SR 
Applicability,'' provides details or ground rules for complying with 
the LCOs.
    Barriers are doors, walls, floor plugs, curbs, hatches, installed 
structures or components, or other devices, not explicitly described in 
TS that support the performance of the functions of systems described 
in the TS. For purposes of this TS, the term ``barrier'' refers to one 
or more devices which protect one train of a safety system from a given 
initiating event. A ``degraded barrier'' refers to a barrier that has 
been found to be degraded and must be repaired, or to a barrier that is 
purposefully removed or reconfigured to facilitate maintenance 
activities. As stated in NEI 04-08, LCO 3.0.9 specifically does not 
apply to fire barriers, snubbers, barriers which support ventilation 
systems or non-TS systems, or barriers which support TS systems where 
the unavailability of the barrier does not render the supported system 
inoperable.
    Some TS required systems may require one or more functional 
barriers in order to perform their intended function(s) for certain 
initiating events for which the barriers provide some protective 
support function. For example, there are barriers to protect systems 
from the effects of internal flooding, such as floor plugs and 
retaining walls, and barriers are used to protect equipment from steam 
impingement in case of high energy line breaks. Barriers are also used 
to protect systems against missiles, either internally generated, or 
generated by external events.
    Barriers are not explicitly described in the TS, but are required 
to be capable of performing their required support function by the 
definition of OPERABILITY for the supported system which is described 
in the TS. Therefore, under the current STS, the supported system must 
be declared inoperable when the related barrier(s) are unavailable. 
However, the magnitude of plant risk associated with the barrier which 
cannot perform its related support function is much less than the risk 
associated with direct unavailability of the supported system, since 
barriers are only required for specific, low frequency initiating 
events.
    Some potential undesirable consequences of the current TS 
requirements include:
    1. When maintenance activities on the supported TS system require 
removal and restoration of barriers, the time available to complete 
maintenance and perform system restoration and testing is reduced by 
the time spent maneuvering the barriers within the time constraints of 
the supported system LCO;
    2. Restoration of barriers following maintenance may be given a 
high priority due to time restraints of the existing supported system 
LCO, when other activities may have a greater risk impact and should 
therefore be given priority; and
    3. Unnecessary plant shutdowns may occur due to discovery of 
degraded barriers which require more time than provided by the existing 
supported system LCO to complete repairs and restoration of the 
barrier.
    To improve the treatment of unavailable barriers and enhance 
safety, the TSTF proposed a risk-informed TS change that introduces a 
delay time before entering the actions for the supported equipment, 
when one or more barriers are found to be degraded, or are removed or 
reconfigured to support maintenance activities, if risk is assessed and 
managed. Such a delay time will provide needed flexibility in the 
performance of maintenance and at the same time will enhance overall 
plant safety by:
    1. Performing system maintenance and restoration activities, 
including post-maintenance testing, within the existing TS LCO time, 
and allowing barrier removal and restoration to be performed outside of 
the TS LCO, providing more time for the safe conduct of maintenance and 
testing activities on the supported TS system;
    2. Requiring barrier removal and restoration activities to be 
assessed and prioritized based on actual plant risk impacts; and
    3. Avoiding unnecessary unscheduled plant shutdowns and thus 
minimizing plant transition and realignment risks.

3.0 Technical Evaluation

    The industry submitted TSTF-427, Revision 2 (Reference 2), 
``Allowance for Non Technical Specification Barrier Degradation on 
Supported System OPERABILITY'' in support of the proposed TS change. 
This submittal documents a risk-informed analysis of the proposed TS 
change. Probabilistic risk assessment (PRA) methods are used, in 
combination with deterministic and defense-in-depth arguments, to 
identify and justify delay times for entering the actions for the 
supported equipment associated with unavailable barriers at nuclear 
power plants. The industry also submitted implementation guidance NEI 
04-08, March 2006 (Reference 2). This submittal provides detailed 
guidance on assessing and managing risk associated with unavailable 
barriers. This is in accordance with guidance provided in Regulatory 
Guides (RGs) 1.174 (Reference 3) and 1.177 (Reference 4).
    The risk impact associated with the proposed delay times for 
entering the TS actions for the supported equipment can be assessed 
using the same approach as for allowed completion

[[Page 58449]]

time (CT) extensions. Therefore, the risk assessment was performed 
following the three-tiered approach recommended in RG 1.177 for 
evaluating proposed extensions in currently allowed CTs:
    1. The first tier involves the assessment of the change in plant 
risk due to the proposed TS change. Such risk change is expressed (1) 
by the change in the average yearly core damage frequency ([Delta]CDF) 
and the average yearly large early release frequency ([Delta]LERF) and 
(2) by the incremental conditional core damage probability (ICCDP) and 
the incremental conditional large early release probability (ICLERP). 
The assessed [Delta]CDF and [Delta]LERF values are compared to 
acceptance guidelines, consistent with the Commission's Safety Goal 
Policy Statement as documented in RG 1.174, so that the plant's average 
baseline risk is maintained within a minimal range. The assessed ICCDP 
and ICLERP values are compared to acceptance guidelines in RG 1.177, 
which provide assurance that the plant risk does not increase 
unacceptably during the period the equipment is taken out of service.
    2. The second tier involves the identification of potentially high-
risk configurations that could exist if equipment in addition to that 
associated with the change were to be taken out of service 
simultaneously, or other risk-significant operational factors such as 
concurrent equipment testing were also involved. The objective is to 
ensure that appropriate restrictions are in place to avoid any 
potential high-risk configurations.
    3. The third tier involves the establishment of an overall 
configuration risk management program (CRMP) to ensure that potentially 
risk-significant configurations resulting from maintenance and other 
operational activities are identified. The objective of the CRMP is to 
manage configuration-specific risk by appropriate scheduling of plant 
activities and/or appropriate compensatory measures.
    A simplified risk assessment was performed to justify the proposed 
addition of LCO 3.0.9 to the TS. This approach was necessitated by (1) 
the general nature of the proposed TS change (i.e., it applies to all 
plants and is associated with an undetermined number of barriers that 
are not able to perform their function), and (2) the lack of detailed 
modeling in most plant-specific PRAs which do not include passive 
structures such as barriers.
    The simplified risk assessment considers three different 
parameters:
    1. The length of time the affected barrier is unavailable,
    2. The initiating event frequency for which the affected barrier is 
designed to mitigate, and
    3. The importance to CDF (or LERF) of the TS equipment (train, 
subsystem, or component) for which the affected barrier is designed to 
protect, measured by the risk achievement worth of the equipment.
    The ICCDP can be calculated based on the following equation:
    [GRAPHIC] [TIFF OMITTED] TN03OC06.026
    
Where:

 Tc is the time the barrier is unavailable 
(hours)
 Tc/8766 is therefore the fraction of the year 
during which the barrier is unavailable,
 IEi/IET is the ratio of the 
initiating event frequency for which the affected barrier is 
designed to mitigate, IEi, and the total initiating event 
frequency, IET,
 RAWj is the risk achievement worth of the 
component(s) for which the barrier provides protection, and
 CDFbase is the baseline core damage frequency 
(per year).

    ICLERP also may be similarly determined, using baseline LERF and 
RAW values with respect to LERF. It is assumed that the magnitude of 
the LERF risk resulting from the barrier's inability to perform its 
related support function would be generally at least one order of 
magnitude less than the corresponding CDF risk. Containment bypass 
scenarios, which are typically the significant contributors to LERF, 
would not be uniquely affected by application of LCO 3.0.9, and 
initiating events which would be significant LERF contributors, such as 
steam generator tube rupture and interfacing systems LOCA, are not 
typically associated with barriers within the scope of LCO 3.0.9. 
Therefore, the assumption regarding LERF risk is reasonable and 
acceptable for the generic risk evaluation, provided that LERF risk 
impacts are considered on a plant-specific basis for unavailable 
barriers, as described in section 3.1.3.
    The relevant initiating events (i.e., events for which barriers 
subject to LCO 3.0.9 provide protection) are:
     Internal and external floods,
     High energy line breaks,
     Feedwater line breaks,
     Loss of coolant accident (small, medium, and large),
     Tornados and high winds, and
     Turbine missiles.
    Generic frequencies for most of these initiating events were 
obtained from NUREG/CR-5750 (Reference 5). For external floods, turbine 
missiles, and tornados, other industry source documents were 
referenced. The most limiting (highest frequency) initiating event was 
obtained for a high energy line break from NUREG/CR-5750, with a 
frequency of 9.1E-3 per year. The risk assessment is therefore based on 
this limiting frequency, and the proposed methodology to apply LCO 
3.0.9 is similarly restricted to barriers protecting against initiating 
events whose total frequency is no more than 9.1E-3 per year.

3.1 Risk Assessment Results and Insights

    The results and insights from the implementation of the three-
tiered approach of RG 1.177 to support the proposed addition of LCO 
3.0.9 to the TS are summarized and evaluated in the following Sections 
3.1.1 to 3.1.3.
3.1.1 Risk Impact
    The bounding risk assessment approach, described in Section 3.0, 
was developed for a range of plant baseline CDF values and for a range 
of protected component RAW values. The maximum allowable 30-day outage 
time was used. The results are summarized in Table 1.

Table 1.--Risk Assessment Results for a Postulated 30-Day Barrier Outage
------------------------------------------------------------------------
                RAW                       ICCDP              ICLERP
------------------------------------------------------------------------
                      Baseline CDF = 1E-6 per year
------------------------------------------------------------------------
2.................................  7.5E-10            7.5E-11
10................................  6.7E-09            6.7E-10
50................................  3.7E-08            3.7E-09
100...............................  7.4E-08            7.4E-09
------------------------------------------------------------------------
                      Baseline CDF = 1E-5 per year
------------------------------------------------------------------------
2.................................  7.5E-09            7.5E-10
10................................  6.7E-08            6.7E-09
50................................  3.7E-07            3.7E-08
100...............................  7.4E-07            7.4E-08
------------------------------------------------------------------------

[[Page 58450]]

 
                      Baseline CDF = 1E-4 per year
------------------------------------------------------------------------
2.................................  7.5E-08            7.5E-09
10................................  6.7E-07            6.7E-08
50................................  3.7E-06            3.7E-07
100...............................  7.4E-06            7.4E-07
------------------------------------------------------------------------

The above results represent a sensitivity analysis covering the 
expected range of plant baseline CDF values and component RAW values. 
The most limiting configurations involving very high risk components 
(RAW > 10) would not be anticipated to occur for most planned 
maintenance activities.
    The calculations conservatively assume the most limiting (highest 
frequency) initiating event and the longest allowable outage time (30 
days). Occurrence of the initiating event during unavailability of the 
barrier is conservatively assumed to directly fail the protected 
equipment; no credit is taken for event-specific circumstances which 
may result in the equipment remaining functional even with the barrier 
unavailable. (For example, a barrier required to protect equipment from 
steam impingement for high energy line breaks may only be required for 
breaks occurring in specific locations and orientations relative to the 
protected equipment, and only for large size breaks.) No credit is 
taken for avoided risk identified in Section 2.
    The risk assessment results of Table 1 were compared to guidance 
provided in the revised Section 11 of NUMARC 93-01, Revision 2 
(Reference 6), endorsed by RG 1.182 (Reference 7), for implementing the 
requirements of paragraph (a)(4) of the Maintenance Rule, 10 CFR 50.65. 
Such guidance is summarized in Table 2. Guidance regarding the 
acceptability of conditional risk increase in terms of CDF for a 
planned configuration is provided. This guidance states that a specific 
configuration that is associated with a CDF higher than 1E-3 per year 
should not normally be entered voluntarily. The staff notes that the 
higher risk configurations documented in Table 1 would exceed this 
guidance, and would therefore not be permitted to be entered 
voluntarily. For example, with a baseline CDF of 1E-4 per year, a 
component with a RAW greater than 10 would exceed the 1E-3 per year 
criteria. Therefore, the sensitivity analyses presented in Table 1 are 
understood to include higher risk configurations which would not be 
permitted under the guidance of Reference 6.

         Table 2.--Guidance for Implementing 10 CFR 50.65(a)(4)
------------------------------------------------------------------------
              [Delta]RCDF                            Guidance
------------------------------------------------------------------------
Greater than 1E-3/year.................  Configuration should not
                                          normally be entered
                                          voluntarily.
------------------------------------------------------------------------


 
             ICCDP                     Guidance              ICLERP
------------------------------------------------------------------------
Greater 1E-5..................  Configuration should    Greater than
                                 not normally be         than 1E-6.
                                 entered voluntarily.
1E-6 to 1E-5..................  Assess non-             1E-7 to 1E-6.
                                 quantifiable factors.
                                 Establish risk
                                 management actions.
Less than 1E-6................  Normal work controls..  Less than 1E-7.
------------------------------------------------------------------------

    Guidance regarding the acceptability of ICCDP and ICLERP values for 
a specific planned configuration and the establishment of risk 
management actions is also provided in NUMARC 93-01. This guidance, as 
shown in Table 2, states that a specific plant configuration that is 
associated with ICCDP and ICLERP values below 1E-6 and 1E-7, 
respectively, is considered to require ``normal work controls''. Table 
1 shows that for the majority of barrier outage configurations the 
conservatively assessed ICCDP and ICLERP values are within the limits 
for what is recommended as the threshold for the ``normal work 
controls'' region.
    As stated in the implementation guidance for LCO 3.0.9 (Reference 
2), plants are required to commit to the guidance of NUMARC 93-01 
Section 11, and therefore the above limits would be applicable. Plant 
configurations including out of service barriers may therefore be 
entered voluntarily if supported by the results of the risk assessment 
required by 10 CFR 50.65(a)(4), and by LCO 3.0.9.
    RG 1.177 (Ref. 4) provides guidance of 5E-7 ICDP and 5E-8 ILERP as 
the limit for a TS allowed outage time. As shown in Table 1, the 
guidance is met for the typically anticipated configurations, unless 
either the baseline CDF for the plant approaches 1E-4 per year or the 
RAW of the protected components is well above 10. Such configurations 
may exceed the criteria described in Ref. 6 (Table 2) and would not be 
voluntarily entered. Such configurations are not expected to be 
frequently encountered, and may be addressed on a case-by-case plant-
specific basis by limiting the allowed outage time and by implementing 
plant-specific risk management actions, as per the implementing 
guidance (Reference 2).
    RG 1.174 (Ref. 3) provides guidance of 1E-5 per year [Delta]CDF and 
1E-6 per year [Delta]LERF. The ICCDP calculations demonstrated that 
each individual 30-day barrier outage is anticipated to be low risk. 
Although there is no explicit limit on the number of times per year 
that LCO 3.0.9 may be applied, even assuming barrier outages occurred 
continuously over the entire year, the risk incurred would still be 
anticipated to be below the limits of the guidance.
    The staff finds that the risk assessment results support the 
proposed addition of LCO 3.0.9 to the TS. The risk increases associated 
with this TS change will be insignificant based on guidance provided in 
RGs 1.174 and 1.177 and within the range of risks associated with 
normal maintenance activities.
3.1.2 Identification of High-Risk Configurations
    The second tier of the three-tiered approach recommended in RG 
1.177 involves the identification of potentially high-risk 
configurations that could exist if equipment, in addition to that 
associated with the TS change, were to be taken out of service 
simultaneously. Insights from the risk assessments, in conjunction with 
important assumptions made in the analysis and defense-in-depth 
considerations, were used to identify such configurations. To avoid 
these potentially high-risk configurations, specific restrictions to 
the implementation of the proposed TS changes were identified.
    When LCO 3.0.9 is applied, at least one train or subsystem is 
required to be operable with required barriers in place, such that this 
train or subsystem would be available to provide mitigation of the 
initiating event. LCO 3.0.9 may be applied to multiple trains of the 
same system only for barriers which provide protection for different 
initiating events, such that at least one train or subsystem

[[Page 58451]]

is available to provide mitigation of the initiating event. The use of 
LCO 3.0.9 for barriers which protect all trains or subsystems from a 
particular initiating event is not permitted. Therefore, potentially 
high-risk configurations involving a loss of function required for 
mitigation of a particular initiating event are avoided by the 
restrictions imposed on applicability of LCO 3.0.9.
    LCO 3.0.9 also addresses potential emergent conditions where 
unplanned failures or discovered conditions may result in the 
unavailability of a required train or subsystem for a particular 
initiating event. Such conditions may result during application of LCO 
3.0.9 from equipment failure on the operable train, such that all 
trains of a TS system are not protected from the same initiating event. 
In such cases, a 24-hour allowed time is provided to restore the 
conditions to permit continued operation with unavailable barriers, 
after which the applicability of LCO 3.0.9 ends, and the supported 
system LCO becomes effective. This allowed time is provided so that 
emergent conditions with low risk consequences may be effectively 
managed, rather than requiring immediate exit of LCO 3.0.9 and the 
potential for an unplanned plant shutdown.
    A limit of 30 days is applied to the LCO 3.0.9 allowed outage time 
for each barrier, after which the barrier must be restored to an 
available status, or the supported system TS must be applied. This 30-
day backstop applies regardless of the risk level calculated, and 
provides assurance that installed plant barriers will be maintained 
available over long periods of time, and that the application of LCO 
3.0.9 will not result in long term degradation of plant barriers.
    The staff finds that the restrictions on the applicability of LCO 
3.0.9 assuring that one safety train remains available to mitigate the 
initiating event, along with the 30-day limit applicable to each 
barrier, assure that potentially high-risk configurations are avoided 
in accordance with the guidance provided in RGs 1.174 and 1.177.
3.1.3 Configuration Risk Management
    The third tier of the three-tiered approach recommended in RG 1.177 
involves the establishment of an overall configuration risk management 
program (CRMP) to ensure that potentially risk-significant 
configurations resulting from maintenance and other operational 
activities are identified. The objective of the CRMP is to manage 
configuration-specific risk by appropriate scheduling of plant 
activities and/or appropriate compensatory measures. This objective is 
met by licensee programs to comply with the requirements of paragraph 
(a)(4) of the Maintenance Rule (10 CFR 50.65) to assess and manage risk 
resulting from maintenance activities, and by LCO 3.0.9 requiring risk 
assessments and management using (a)(4) processes if no maintenance is 
in progress. These programs can support licensee decision making 
regarding the appropriate actions to manage risk whenever a risk-
informed TS is entered.
    The implementation guidance for LCO 3.0.9 (Reference 2) requires 
that the allowed outage time determination for an unavailable barrier 
be performed using the plant-specific configuration. Further, the risk 
determinations are to be updated whenever emergent conditions occur. 
These requirements assure that the configuration-specific risk 
associated with unavailable barriers is assessed and managed prior to 
entry into LCO 3.0.9 and during its applicability as conditions change.
    These evaluations for the unavailable barrier are performed as part 
of the assessment of plant risk required by 10 CFR 50.65(a)(4). The 
numerical guidance identified in Table 2 is applicable to 
implementation of LCO 3.0.9, using the results of the configuration-
specific risk assessment which addresses the risk impact of the 
unavailable barrier along with all other out of service components and 
plant alignments.
    Risk management actions are required to be considered when the 
calculated risk exceeds specific thresholds per NUMARC 93-01 Section 
11, as identified in Table 2. Additional guidance on risk management 
actions are provided in the implementation guidance for LCO 3.0.9.
    The allowed outage time for a barrier is calculated based on an 
ICCDP limit of 1E-6. This is the NUMARC 93-01 Section 11 guidance for 
applicability of normal work controls, and is conservatively lower than 
the guidance of 1E-5 for voluntary maintenance activities. The use of 
1E-6 will result in conservatively short allowed outage times for 
barriers compared to allowed times for other maintenance activities.
    If the scope of the PRA model used to support the plant-specific 
CRMP does not include the initiating event for which a barrier provides 
protection, then LCO 3.0.9 applicability is limited to one barrier on a 
single train. Multiple barriers for such initiating events may not be 
unavailable under LCO 3.0.9, and in such situations the LCO(s) 
associated with the protected components would be applicable. 
Applicability of LCO 3.0.9 to the single barrier for an initiating 
event that is not modeled in the plant PRA is acceptable based on the 
generic risk analysis provided by TSTF-427, as described in Section 
3.1.
    Assessment of the LERF risk impact on an unavailable barrier is 
required to be performed in accordance with NUMARC 93-01 Section 11. If 
an unavailable barrier provides protection to equipment which is 
relevant to the containment function, or which protects equipment from 
the effects of an initiating event which is a contributor to LERF, then 
applicability of LCO 3.0.9 must be limited to that one barrier unless a 
quantified assessment of LERF is performed.
    The staff finds that the risk evaluations necessary to support the 
applicability of LCO 3.0.9 appropriately consider the risk from 
unavailable barriers in an integrated manner based on the overall plant 
configuration. Therefore, potentially high-risk configurations can be 
identified and managed in accordance with the guidance provided in RGs 
1.174 and 1.177.

3.2 Summary and Conclusions

    The unavailability of barriers which protect TS required components 
from the effects of specific initiating events is typically a low risk 
configuration which should not require that the protected components be 
immediately declared inoperable. The current TS require that when such 
barriers are unavailable, the protected component LCO is immediately 
entered. Some potential undesirable consequences of the current TS 
requirements include:
    1. When maintenance activities on the supported TS system requires 
removal and restoration of barriers, the time available to complete 
maintenance and perform system restoration and testing is reduced by 
the time spent maneuvering the barriers within the time constraints of 
the supported system LCO;
    2. Restoration of barriers following maintenance must be given a 
high priority due to time restraints of the existing supported system 
LCO, when other more risk important activities may have a greater risk 
impact and should therefore be given priority; and
    3. Unnecessary plant shutdowns may occur due to discovery of 
degraded barriers which may require more than the existing supported 
system LCO time to complete repairs and restoration.
    To remove the overly restrictive requirements in the treatment of 
barriers, licensees are proposing a risk-informed TS change which 
introduces a delay time before entering the actions for the supported 
equipment when one or more barriers are found degraded or removed to 
facilitate planned

[[Page 58452]]

maintenance activities. Such a delay time will provide needed 
flexibility in the performance of maintenance during power operation 
and at the same time will enhance overall plant safety by (1) 
performing system maintenance and restoration activities, including 
post-maintenance testing, within the existing TS LCO time, and allowing 
barrier removal and restoration to be performed outside of the TS LCO, 
providing more time for the safe conduct of maintenance and testing 
activities on the supported system; (2) requiring barrier removal and 
restoration activities to be assessed and prioritized based on actual 
plant risk impacts; and (3) avoiding unnecessary unscheduled plant 
shutdowns, thus minimizing plant transition and realignment risks.
    The risk impact of the proposed TS changes was assessed following 
the three-tiered approach recommended in RG 1.177. A simplified 
bounding risk assessment was performed to justify the proposed TS 
changes. This bounding assessment was selected due to the lack of 
detailed plant-specific risk models for most plants which do not 
include failure modes of passive structures such as barriers. The 
impact from the addition of the proposed LCO 3.0.9 to the TS on 
defense-in-depth was also evaluated in conjunction with the risk 
assessment results.
    Based on this integrated evaluation, the staff concludes that the 
proposed addition of LCO 3.0.9 to the TS would lead to insignificant 
risk increases as stipulated by RG 1.177 and depicted on Table 1 above. 
This conclusion is true without taking any credit for the removal of 
potential undesirable consequences associated with the current 
conservative treatment of barriers. Therefore, the proposed change 
provides adequate protection of public health and safety and is 
acceptable provided the conditions set forth below are satisfied.
    Consistent with the staff's approval and inherent in the 
implementation of TSTF-427, licensees interested in implementing LCO 
3.0.9 must, as applicable, operate in accordance with the following 
stipulations:
    1. The licensee must commit to the guidance of NUMARC 93-01, 
Section 11 (Reference 6) and to NEI 04-08 (Reference 2); and
    2. Licensee procedures must be revised to ensure that the guidance 
on the risk assessment and management process described in NEI 04-08 is 
used whenever a barrier is considered unavailable and the requirements 
of LCO 3.0.9 are to be applied. This must be done in accordance with an 
overall CRMP to ensure that potentially risk-significant configurations 
resulting from maintenance and other operational activities are 
identified and avoided.

4.0 State Consultation

    In accordance with the Commission's regulations, the [ ] 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 a requirement with respect to the 
installation or use of a facility component located within the 
restricted area as defined in 10 CFR part 20 and change surveillance 
requirements. 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 the amendment involves no-significant-hazards 
considerations, and there has been no public comment on the finding 
[FR]. 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.

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. TSTF-427, Revision 2, ``Allowance for Non Technical 
Specification Barrier Degradation on Supported System OPERABILITY'', 
May 3, 2006.
    2. NEI 04-08, ``Allowance for Non Technical Specification Barrier 
Degradation on Supported System OPERABILITY (TSTF-427) Industry 
Implementation Guidance'', March 2006.
    3. Regulatory Guide 1.174, ``An Approach for Using Probabilistic 
Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to 
the Licensing Basis'', USNRC, August 1998.
    4. Regulatory Guide 1.177, ``An Approach for Plant-Specific, Risk-
Informed Decisionmaking: Technical Specifications'', USNRC, August 
1998.
    5. ``Rates of Initiating Events at U.S. Nuclear Power Plants'', 
NUREG/CR-5750, Idaho National Engineering and Environmental Laboratory, 
February 1999.
    6. Nuclear Energy Institute, ``Industry Guideline for Monitoring 
the Effectiveness of Maintenance at Nuclear Power Plants'', NUMARC 93-
01, Revision 2, Section 11.
    7. ``Assessing and Managing Risk Before Maintenance Activities at 
Nuclear Power Plants'', Regulatory Guide 1.182, May 2000.

Proposed No-Significant-Hazards-Consideration Determination

    Description of Amendment Request: A change is proposed to the 
standard technical specifications (STS) (NUREGs 1430 through 1434) and 
plant-specific technical specifications (TS), to allow a delay time for 
entering a supported system technical specification (TS) when the 
inoperability is due solely to an unavailable barrier, if risk is 
assessed and managed consistent with the program in place for complying 
with the requirements of 10 CFR 50.65(a)(4). LCO 3.0.9 will be added to 
individual TS providing this allowance.
    Basis for proposed no significant hazards consideration 
determination: As required by 10 CFR 50.91(a), an analysis of the issue 
of no significant hazards 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 delay time for entering a supported 
system technical specification (TS) when the inoperability is due 
solely to an unavailable barrier if risk is assessed and managed. 
The postulated initiating events which may require a functional 
barrier are limited to those with low frequencies of occurrence, and 
the overall TS system safety function would still be available for 
the majority of anticipated challenges. Therefore, the probability 
of an accident previously evaluated is not significantly increased, 
if at all. The consequences of an accident while relying on the 
allowance provided by proposed LCO 3.0.9 are no different than the 
consequences of an accident while relying on the TS required actions 
in effect without the allowance provided by proposed LCO 3.0.9. 
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

[[Page 58453]]

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.

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). 
Allowing delay times for entering supported system TS when 
inoperability is due solely to an unavailable barrier, if risk is 
assessed and managed, 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 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 a delay time for entering a supported 
system TS when the inoperability is due solely to an unavailable 
barrier, if risk is assessed and managed. The postulated initiating 
events which may require a functional barrier are limited to those 
with low frequencies of occurrence, and the overall TS system safety 
function would still be available for the majority of anticipated 
challenges. The risk impact of the proposed TS changes was assessed 
following the three-tiered approach recommended in RG 1.177. A 
bounding risk assessment was performed to justify the proposed TS 
changes. This application of LCO 3.0.9 is predicated upon the 
licensee's performance of a risk assessment and the management of 
plant risk. The net change to the margin of safety is insignificant 
as indicated by the anticipated low levels of associated risk (ICCDP 
and ICLERP) as shown in Table 1 of Section 3.1.1 in the Safety 
Evaluation. Therefore, this change does not involve a significant 
reduction in a margin of safety.

    Based upon the reasoning presented above and the previous 
discussion of the amendment request, the requested change presents no-
significant-hazards considerations per 10 CFR 50.92(c).

    Dated at Rockville, Maryland, this --day of --------.

    For the Nuclear Regulatory Commission.
Timothy J. Kobetz,
Chief, Technical Specifications Branch, Division of Inspection and 
Regional Support, Office of Nuclear Reactor Regulation.

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 REVISE TECHNICAL SPECIFICATIONS REGARDING THE 
ADDITION OF LCO 3.0.9 ON THE UNAVAILABILITY OF BARRIERS 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 Regulatory Commission
Document Control Desk
Washington, D.C. 20555

SUBJECT:
    PLANT NAME
    DOCKET NO. 50--APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TO 
ADD LCO 3.0.9 ON THE UNAVAILABILITY OF BARRIERS 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 requirements for unavailable 
barriers by adding LCO 3.0.9.
    Attachment 1 provides a description of the proposed change, the 
requested confirmation of applicability, and plant-specific 
verifications. Attachment 2 provides the exist