Notice of Availability of Model License Amendment Request and Safety Evaluation on Technical Specification Improvement Regarding Revision to the Completion Time in STS 3.6.6A, “Containment Spray and Cooling Systems” for Combustion Engineering Pressurized Water Reactors Using the Consolidated Line Item Improvement Process, 65148-65160 [06-9094]

Agencies

• NUCLEAR REGULATORY COMMISSION

[Federal Register Volume 71, Number 215 (Tuesday, November 7, 2006)]
[Notices]
[Pages 65148-65160]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 06-9094]


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NUCLEAR REGULATORY COMMISSION


Notice of Availability of Model License Amendment Request and 
Safety Evaluation on Technical Specification Improvement Regarding 
Revision to the Completion Time in STS 3.6.6A, ``Containment Spray and 
Cooling Systems'' for Combustion Engineering Pressurized Water Reactors 
Using the Consolidated Line Item Improvement Process

AGENCY: Nuclear Regulatory Commission.

ACTION: Notice of availability.

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SUMMARY: Notice is hereby given that the staff of the U.S. Nuclear 
Regulatory Commission (NRC) has prepared a model license amendment 
request (LAR), model safety evaluation (SE), and model proposed no 
significant hazards consideration (NSHC) determination related to 
changes to the completion times (CT) in Standard Technical 
Specification (STS) 3.6.6A, ``Containment Spray and Cooling Systems,'' 
contained in NUREG-1432 (Standard Technical Specifications for 
Combustion Engineering Plants, Rev. 3.0). The proposed changes would 
revise STS 3.6.6A by extending the CT for one containment spray system 
(CSS) train inoperable from 72 hours to seven days, and add a 
Condition, Required Actions and associated CT when one CSS train and 
one containment cooling system (CCS) train are inoperable. These 
changes are based on analyses provided in a joint applications report 
submitted by the Combustion Engineering Owner's Group (CEOG). The CEOG 
participants in the Technical Specifications Task Force (TSTF) proposed 
these changes to the STS in Change Traveler No. TSTF-409, Revision 2.
    The purpose of these models is to permit the NRC to efficiently 
process amendments to incorporate these changes into plant-specific STS 
for Combustion Engineering pressurized water reactors (PWRs). Since 
TSTF-409 involves a risk-informed approach to extending the CT for one 
CSS inoperable, the NRC staff must verify that licensees who apply for 
this TS change have a valid, up-to-date probabilistic risk assessment 
(PRA) model that employs PRA principles to ensure that public health 
and safety are maintained when the CSS CT of 7 days is implemented. 
Therefore, the model LAR contains several conditions requiring 
licensees to make specific validations of their plant PRA quality and 
methods. The intent of using the CLIIP to adopt TSTF-409 is to 
eliminate

[[Page 65149]]

the need for additional technical review and requests for additional 
information (RAIs) on plant-specific amendments. Licensees of nuclear 
power reactors to which the models apply can request amendments 
conforming to the models. In such a request, a licensee should confirm 
the applicability of the model SE and NSHC determination to its plant, 
and provide the expected supplemental information requested in the 
model LAR.

DATES: The NRC staff issued a Federal Register Notice (71 FR 18380, 
April 11, 2006) which provided for public comment a model SE, model 
LAR, and NSHC determination related to changes to the CT for one CSS 
train inoperable in STS 3.6.6A. The NRC staff herein provides a revised 
model SE, revised model LAR, and NSHC determination. The NRC staff can 
most efficiently consider applications based upon the model LAR, which 
references the Model SE, if the application is submitted within one 
year of this Federal Register Notice.

FOR FURTHER INFORMATION CONTACT: Tim Kobetz, Mail Stop: O-12H2, 
Division of Inspection Program Management, Office of Nuclear Reactor 
Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555-
0001, telephone 301-415-1932.

SUPPLEMENTARY INFORMATION:

Background

    Regulatory Issue Summary 2000-06, ``Consolidated Line Item 
Improvement Process [CLIIP] for Adopting Standard Technical 
Specifications Changes for Power Reactors,'' was issued on March 20, 
2000. The CLIIP is intended to improve the efficiency and transparency 
of NRC licensing processes. This is accomplished by processing proposed 
changes to the 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 includes 
NRC staff evaluation of any comments received for a proposed change to 
the STS. In several instances, the staff's evaluation did result in 
changes to the model LAR and/or model SE. Those licensees opting to 
apply for the subject changes to TSs are responsible for reviewing the 
staff's evaluation, referencing the applicable technical 
justifications, and providing any necessary plant-specific information. 
The model LAR shows licensees the expected level of detail that needs 
to be included in order to adopt TSTF-409, Rev. 2, as well as 
guidelines for staff review. The NRC has established an internal review 
plan that designates the appropriate staff and approximate timelines to 
review plant-specific LARs that reference TSTF-409, Rev. 2. Each 
amendment application made in response to the notice of availability 
will be processed and noticed in accordance with applicable NRC rules 
and procedures.
    This notice involves an increase in the allowed CT to restore an 
inoperable CSS train on Combustion Engineering PWRs. By letter dated 
November 10, 2003, the CEOG proposed this change for incorporation into 
the STS as TSTF-409, Revision 2. This change is based on the NRC staff-
approved analyses contained in CE NPSD-1045-A, ``Joint Applications 
Report: Modification to the Containment Spray System, and Low Pressure 
Safety Injection System Technical Specifications,'' dated March 2000, 
as approved by the NRC in a SE dated December 21, 1999, accessible 
electronically from the Agencywide Documents Access and Management 
System's (ADAMS) Public Electronic Reading Room on the Internet (ADAMS 
Accession No. ML993620241) at the NRC Web site https://www.nrc.gov/
reading-rm/adams.html. Persons who do not have access to ADAMS or who 
encounter problems in accessing the documents located in ADAMS, should 
contact the NRC Public Document Room Reference staff by telephone at 1-
800-397-4209, 301-415-4737, or by e-mail to pdr@nrc.gov.
    This notice, along with TSTF-409, Rev. 2, will be posted on the NRC 
Web site at https://www.nrc.gov/reactors/operating/licensing/techspecs/
changes-issued-for-adoption.html.

Applicability

    This proposed change to revise the Technical Specification (TS) CT 
for one inoperable CSS train is applicable to Combustion engineering 
PWRs.
    To efficiently process the incoming license amendment applications, 
the NRC staff requests that each licensee applying for the changes 
addressed by TSTF-409, Revision 2, use the CLIIP to submit a LAR that 
adheres to the following model. Any deviations from the model LAR 
should be explained in the licensee's submittal. When applying, 
licensees should ensure they address the eight conditions and one 
regulatory commitment listed in the model LAR and model SE.
    The CLIIP does not prevent licensees from requesting an alternative 
approach, proposing changes without providing the information described 
in the eight model LAR conditions, or making the requested commitment. 
Variations from the approach recommended in this notice may, however, 
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 in the LAR, will result in 
staff rejection of the submittal under the CLIIP. Instead, licensees 
desiring significant variations and/or additional changes should either 
submit a LAR that does not claim to adopt TSTF-409, or specifically 
state in their LAR that they are adopting TSTF-409 without using the 
CLIIP.

Public Notices

    In a notice in the Federal Register dated April 11, 2006 (71 FR 
18380), the staff requested comment on the use of the CLIIP to process 
requests to revise the CE PWR TS regarding Containment Spray System 
completion time extensions as discussed in TSTF-409. In response to 
this notice, the staff received one set of comments (developed by the 
PWR Owners Group, and submitted by the Nuclear Energy Institute in a 
letter dating May 10, 2006 (ADAMs Accession No. ML061570029)). Specific 
comments on the model LAR and model SE were offered. These comments, 
along with the NRC staff's responses, are summarized and discussed 
below.
    1. Comment: Based on discussions with the author regarding the 
intent of the ``Model SE,'' [i.e., to allow acceptance review without 
RAIs while satisfying the CLIIP] it is recommended that additional 
explanatory information be included. * * * At the very minimum, a clear 
preamble to the FRN should be provided that places the scope of the FRN 
in perspective.
    Response: The following preamble has been inserted after the first 
sentence of the second paragraph of the FRN.

    ``Since TSTF-409 involves a risk-informed approach to extending 
the CT for one CSS inoperable, the NRC staff must verify that 
licensees who apply for this TS change have a valid, up to date 
probabilistic risk assessment (PRA) model that employs PRA 
principles to ensure that public health and safety are maintained 
when the CSS CT of 7 days is implemented. Therefore, the model LAR 
contains several conditions requiring licensees to make specific 
validations of their plant PRA quality and methods. The intent of 
using the CLIIP to adopt TSTF-409 is to eliminate the need for 
additional technical review and requests for additional information 
(RAIs) on plant-specific amendments.''

    2. Comment: [The FRN] should equally note that existing strategies 
for

[[Page 65150]]

approval are valid and may also be used.
    Response: The second to last paragraph of the FRN discusses how a 
licensee should proceed if it desires to deviate from the approach 
outlined in the CLIIP. The NRC's position is that, if a licensee is 
going to submit a LAR that adopts TSTF-409 using the CLIIP, then the 
plant-specific LAR should provide all the information requested in the 
model LAR. Any variations/deviations should be explained, and may 
require additional review by the staff (including issuance of RAIs). 
Significant variations from the CLIIP methodology should be submitted 
as normal license amendment requests. The staff has changed the last 
sentence of second to last paragraph of the FRN to read:

    ``Instead, licensees desiring significant variations and/or 
additional changes should either submit a LAR that does not claim to 
adopt TSTF-409, or specifically state in their LAR that they are 
adopting TSTF-409 without using the CLIIP.''

    This will correctly define the scope of the review for the staff 
when processing an incoming LAR that does not conform to the CLIIP.
    3. Comment: The essence of the proposed CSS TS change focuses on a 
single CSS train. Thus, the mention of ACTION G (regarding two CSS 
trains out-of-service) seems unnecessary.
    Response: The staff agrees with this comment. Mention of ACTION G 
has been removed from Section 4.1 of the model LAR, and Section 3.1 of 
the model SE.
    4. Comment: The last paragraph of section 4.2.1 item 1 notes that 
``If a zero maintenance PRA model is used * * * in performing these 
calculations, then the licensee must commit to performing no other 
maintenance during the extended CSS CT * * *''. This restriction has no 
technical merit. The risk of maintenance is generated as incremental 
risks from the baseline. The initial submittal noted that for plants 
with emergency grade fan coolers (most of the applicants), the actual 
risk increases as a result of removing a CSS out of service is very 
low. Furthermore, CSS have very little (if any) overlap with other 
systems. Because the risk important function of CSSs is to maintain the 
containment pressure within acceptable limits (and control sump 
temperature to ensure adequate NPSH for ECCS equipment--a function left 
out of FRN Section 3), those functions can be accommodated by the 
redundant CS train or the fan coolers. Furthermore, by using RG 1.177 
to support low risk, the risk impact of removal of the CSS for the 
duration of the 7 day AOT is small. Because plants perform maintenance 
on a frequent basis, not allowing repair or maintenance on another 
system (which is likely to be of greater risk importance than the CSS) 
is unnecessary and likely to have worse risk.
    Another unusual aspect of the restriction implies that the 
incremental risk calculated using zero maintenance conditions is 
significantly different from that calculated using annualized plant-
wide system out-of-service values. While the baseline PRA for zero 
maintenance is less than the baseline PRA value for nominal 
maintenance, its impact on incremental risk will be small.
    Response: The staff accepts NEI's comment in that it creates a 
regulatory condition that is overly restrictive to plants using a zero 
maintenance PRA model. The staff has inserted alternate wording (from 
RG 1.177 Section 2.3.4. 2) to the last sentence of condition 1 
in Section 4.2.1 of the model LAR as follows:

    If the licensee utilizes a ``zero maintenance'' PRA model for 
the assessment, they should state they are using a ``zero 
maintenance'' model in the evaluation, and provide a discussion as 
to the ability of that model to produce comparable results to the 
``average maintenance'' assessment.

    5. Comment: It is understood that documented quantitative external 
event information for the plants may be limited. However, reference to 
plant individual plant examination (IPE) and individual plant 
examination for external events (IPEEE) and the requirements to explain 
the evolution of the PRA since 1988 as identified in Section in item 
4.2.1 part 2.b is unnecessary. Item 2.c requires that the peer review 
results be discussed along with the overall disposition of relevant 
facts and observations (F&Os) and item e (which includes an overall 
determination of the adequacy of the plant specific PRA with respect to 
this application). These assessment[s] are current and of more 
importance to the application. Where external events rely on IPEEE 
vintage information, a discussion/statement of the risk significance of 
the spray system in mitigating external events should be performed.
    Response: The staff agrees that peer reviews of plant-specific PRA 
are important. However, it is equally important to have an 
understanding of PRA updates and upgrades since the IPE, IPEEE, and 
peer reviews were conducted, especially if plant improvements and/or 
commitments are cited and credited in the analyses as being 
implemented. Licensees who have given this information in prior 
submittals may incorporate the information by reference.
    6. Comment: Section 4.2.1 item 3 requirements on consideration of 
fire and external events and the associated EXPECTATIONS are too 
restrictive and do not correspond to safety benefits. The CSS has 
limited risk overlap with fires or external initiating events. 
Challenges to power induced by tornadoes, high winds or seismic events 
have limited importance to the spray system and [are] more appropriate 
with AOTs associated with AC-power related components. It was our 
understanding that the intent of this restriction was to assure the 
regulator that the overall combined plant risk remains below a CDF of 
10 -4 per year (per requirements of RG 1.174). The intent of 
this section should be clarified. This requirement should be reduced to 
providing information regarding the reasons underlying low risk 
associated with this system.
    Response: The staff acknowledges that, for many plants, the impact 
of the CT extension on external event risk will be minimal. If this is 
the case, the licensee needs to confirm this in its submittal and 
explain why there is limited overlap.
    7. Comment: Section 4.2.1 item 3 ACCEPTANCE CRITERIA requires 
``combining internal events, internal flooding, external events and 
shutdown PRA results.'' The requirements for the combination of events 
should be modified to have the utility provide a technical basis for 
demonstrating the plant CDF to be less than 10 -4 per year 
or has no plant specific vulnerabilities (per SECY-88-20). Requirements 
for a fully quantified external events (including fire) PRA and 
shutdown PRA [are] beyond the state of the art. Few plants have all the 
above. The Fire PRA standard is just undergoing peer review and no 
shutdown PRA standard has been written. Methods for combining these PRA 
results [are] also not defined (particularly merging shutdown and ``at 
power'' PRA results). Instead, it should be noted that the utility may 
use existing external event evaluations including IPEEE results and 
qualitative external event assessments, where appropriate, to provide 
confidence that the overall plant CDF is not within RG 1.174 risk 
region 1.
    Response: The staff is requesting that licensees provide [Delta]CDF 
and [Delta]LERF calculations for those external events for which the 
licensee has a PRA. For external events for which the licensee does not 
have a PRA, the licensee will need to confirm there are no 
vulnerabilities that would indicate that

[[Page 65151]]

the total CDF is >10-4 or the total LERF is 
>10-\5\ yr. this stipulation allows the staff to ensure that 
plans whose [Delta]CDF or [Delta]LERF calculation puts them in Region 
II of either Figure 3 or Figure 4 of RG 1.174 are still within the RG 
1.174 Section 2.2.4 acceptance guidelines for total plant risk (CDF and 
LERF).
    With regard to NEI's comments on a fully-quantified external events 
(including fire) PRA and shutdown PRA being beyond state-of-the-art, 
the staff believes the wording in the EXPECTATIONS for Section 4.2.1 
condition 3 was misinterpreted. The wording has been revised to read 
``(quantitatively and/or qualitatively, as appropriate).'' However, the 
staff notes that while fire and shutdown PRA standards have not yet 
been endorsed, there are available methods to quantify fire and 
shutdown PRA. Therefore, the staff does not believe such evaluations 
are beyond the state of the art. Rather, they are areas where some 
evaluation is still ongoing.
    8. Comment: EXPECTATIONS supporting 4.2.1 item 4. The TS is 
structured to have a revised CT. Once the new CT is adopted the old CT 
will disappear as a regulatory item. Thus, there is no entry into an 
extended CSS CT. It is simply an entry into the CT. There are no 
significant external event interactions and the outage is limited to a 
single spray train. Therefore, The Tier 2 requirement should be limited 
to one CSS out of service, which is already governed in the TS with a 
cautionary note that Maintenance rule or tier 3 guidance to not 
simultaneously disable both the emergency grade fan coolers and the 
sprays.
    Response: The staff agrees that ``extended CT'' should not be used 
in the model LAR. Appropriate changes will be made here and in other 
sections of the FRN where appropriate.
    The staff believes that a tier 2 justification by the licensee is 
warranted with regard to removing one CSS train from service due to 
scheduled ``preventive'' maintenance for the 7-day period. If there are 
no risk-significant configurations or risk-significant external event 
conditions identified in the tier 2 evaluation, then the licensee 
should include a statement that there are no risk-significant 
configurations or external event conditions that would preclude them 
from using the 7-day CT.
    9. Comment: End of [Section 4.2.1 item 7]. Note that the RGs 
provide guidelines. Risk values are not rigid thresholds. Thus small 
deviations to the guidance can be and are somewhat fuzzy to allow for 
the mathematical uncertainties inherent in these studies.
    Response: The staff agrees that RG 1.174 and 1.177 guidelines are 
not rigid standards, and has revised condition 7 to delete the second 
paragraph of the EXPECTATIONS section. Note that Condition 5 of the 
model LAR requires licensees to confirm that their CRMP or associated 
(a)(4) program meets all aspects of Section 2.3.7.2 or RG 1.177.

    Dated at Rockville, Maryland; this 19th day of October 2006.

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

    FOR INCLUSION ON THE TECHNICAL SPECIFICATION WEB PAGE THE FOLLOWING 
EXAMPLE OF A LICENSE AMENDMENT REQUEST (LAR) WAS PREPARED BY THE NRC 
STAFF TO FACILITATE THE ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE 
(TSTF) TRAVELER TSTF-409, REVISION 2 ``CONTAINMENT SPRAY SYSTEM 
COMPLETION TIME EXTENSION (CE NPSD-1045-A).'' THE MODEL PROVIDES THE 
EXPECTED LEVEL OF DETAIL AND CONTENT FOR A LAR TO ADOPT TSTF-409, 
REVISION 2. LICENSEES REMAIN RESPONSIBLE FOR ENSURING THAT THEIR PLANT-
SPECIFIC LAR FULFILLS THEIR ADMINISTRATIVE REQUIREMENTS AS WELL AS NRC 
REGULATIONS.
----------------------------------------------------------------
U.S. Nuclear Regulatory Commission
Document Control Desk
Washington, DC 20555

SUBJECT: [PLANT NAME] APPLICATION FOR TECHNICAL SPECIFICATION 
IMPROVEMENT TO EXTEND THE COMPLETION TIME FOR CONTAINMENT SPRAY SYSTEM 
INOPERABILITY IN ACCORDANCE WITH TSTF-409, REVISION 2

Dear Sir or Madam:

    In accordance with the provisions of Section 50.90 of Title 10 of 
the Code of Federal Regulations (10 CFR 50.90), [LICENSEE] is 
submitting a request for an amendment to the technical specifications 
(TS) for [PLANT NAME, UNIT NOS.].
    The proposed changes would revise TS 3.6.6A, ``Containment Spray 
and Cooling Systems,'' by extending from 72 hours to seven days the 
completion time (CT) to restore an inoperable containment spray system 
(CSS) train. In addition, a Condition would be added to the TS to allow 
one CSS train and one containment cooling system (CCS) train to be 
inoperable for a period of 72 hours.
    The changes are consistent with NRC-approved Industry Technical 
Specification Task Force (TSTF) Standard Technical Specification Change 
Traveler, TSTF-409, Revision 2, ``Containment Spray System Completion 
Time Extension (CE NPSD-1045-A).''
    Enclosure 1 provides a description and assessment of the proposed 
changes and confirmation of applicability. Enclosure 2 provides the 
existing TS pages marked-up to show the proposed changes. Enclosure 3 
provides the existing TS Bases marked-up to reflect the proposed 
changes (for information only). Final TS Bases will be provided in a 
future update to the Updated Final Safety Analysis Report (UFSAR) in 
accordance with the Bases Control Program. Attachments 1 through 8 
provide the discussions of [LICENSEE'S] evaluations and supporting 
information with regard to the conditions stipulated in Section 4.2.1 
of Enclosure 1.
    [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.
    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]. 
If you should have any questions regarding this submittal, please 
contact [ ].

 Sincerely,

 Name, Title

Enclosures:
    1. Description and Assessment of Proposed Changes
    2. Proposed Technical Specification Changes
    3. Proposed Technical Specification Bases Changes (if applicable)

Attachments:
    1. Licensee's supporting information for condition 1
    2. Licensee's supporting information for condition 2
    3. Licensee's supporting information for condition 3
    4. Licensee's supporting information for condition 4
    5. Licensee's supporting information for condition 5
    6. Licensee's supporting information

[[Page 65152]]

for condition 6
    7. Licensee's supporting information for condition 7
    8. Licensee's supporting information for condition 8

cc:
    NRR Project Manager
    Regional Office
    Resident Inspector
    State Contact
    ITSB Branch Chief

1.0 Description

    The letter is a request to amend Operating License(s) [LICENSE 
NUMBER(S)] for [PLANT/UNIT NAME(S)].
    The proposed changes would revise Technical Specification (TS) 
3.6.6A, ``Containment Spray and Cooling Systems,'' by extending from 72 
hours to seven days the completion time (CT) to restore an inoperable 
containment spray system (CSS) train to operable status, and would add 
a Condition describing the required action and CT when one CSS train 
and one containment cooling system (CCS) train are inoperable.
    The changes are consistent with NRC approved Industry Owner's Group 
Technical Specification Task Force (TSTF) Standard Technical 
Specification Change Traveler TSTF-409, Revision 2 (Rev. 2), 
``Containment Spray System Completion Time Extension (CE NPSD-1045-
A).'' TSTF-409, Rev. 2 was approved by the NRC on [DATE].

2.0 Proposed Change

    Specifically, the proposed revision extends the CT (or allowed 
outage time) that one CSS train is permitted to remain inoperable from 
72 hours to seven days based on Reference 1, as accepted by, and 
subject to the limitations specified in, Reference 2. TSTF-409, Rev. 2 
states that the longer CT will enhance overall plant safety by avoiding 
potential unscheduled plant shutdowns and allowing greater availability 
of safety significant components during shutdown. In addition, TSTF-
409, Rev. 2 states that this extension provides for increased 
flexibility in scheduling and performing maintenance and surveillance 
activities in order to enhance plant safety and operational flexibility 
during lower modes of operation.
    The revision also adds a Condition to allow one CSS train and one 
CCS train to be inoperable for up to 72 hours. Since Reference 1 did 
not evaluate the concurrent inoperabilities of one CSS train and one 
CCS train, the CT for this Condition was limited to 72 hours.
    [LICENSEE] also proposes to make changes to the supporting TS Bases 
in accordance with TSTF-409, Rev. 2. Changes to the Bases include 
supporting information justifying the addition of the Condition for one 
CSS train and one CCS train inoperable. The Bases changes also include 
a reviewer's note that requires [LICENSEE] to adopt Reference 1 and 
meet the requirements of References 1 and 2 prior to utilizing the 7-
day CT for one inoperable CSS. Finally, a reference to Reference 1 is 
added to the Bases. Markups of the TS Bases are provided in enclosure 
3. Changes to the Bases will be implemented in accordance with 
[LICENSEE's] bases control program.
    In summary, [LICENSEE] proposes to extend the CT for one inoperable 
CSS train from 72 hours to 7 days based on Reference 1, and add a 
Condition to allow one CSS train and one CCS train to be inoperable for 
up to 72 hours.

3.0 Background

    The function of the containment heat removal systems under accident 
conditions is to remove heat from the containment atmosphere, thus 
maintaining the containment pressure and temperature at acceptably low 
levels. The systems also serve to limit offsite radiation levels by 
reducing the pressure differential between the containment atmosphere 
and the external environment, thereby decreasing the driving force for 
fission product leakage across the containment. The two containment 
heat removal systems are the CCS and the CSS. The CCS fan coolers are 
designed to operate during both normal plant operations and under loss-
of-coolant accident [LOCA] or main steam line break (MSLB) conditions. 
The CSS is designed to operate during accident conditions only.
    The heat removal capacity of the CCS and CSS is sufficient to keep 
the containment temperature and pressure below design conditions for 
any size break, up to and including a double-ended break of the largest 
reactor coolant pipe. The systems are also designed to mitigate the 
consequences of any size break, up to and including a double-ended 
break of a main stream line. The CCS and CSS continue to reduce 
containment pressure and temperature and maintain them at acceptable 
levels post-accident.
    The CCS and CSS at [PLANT NAME] each consist of [Substitute plant-
specific configuration if it differs from the following description] 
two redundant loops and are designed such that a single failure does 
not degrade their ability to provide the required heat removal 
capability. Two of four containment fan coolers and one CSS loop are 
powered from one safety-related bus. The other two containment fan 
coolers and CSS loop are powered from another independent safety-
related bus. The loss of one bus does not affect the ability of the 
containment heat removal systems to maintain containment temperature 
and pressure below the design values in a post-accident mode.
    The [PLANT NAME] CSS consists of [Substitute plant-specific 
configuration if it differs from the following description] two 
independent and redundant loops each containing a spray pump, shutdown 
heat exchanger, piping, valves, spray headers, and spray nozzles. It 
has two modes of operation, which are:
    1. The injection mode, during which the system sprays borated water 
from the refueling water tank (RWT) into the containment, and
    2. The recirculation mode, which is automatically initiated by the 
recirculation actuation signal (RAS) after low level is reached in the 
RWT. During this mode of operation, the safety injection system (SIS) 
sump provides suction for the spray pumps.
    Containment spray is automatically initiated by the containment 
spray actuation signal coincident with the safety injection actuation 
signal and high containment pressure signal. If required, the operator 
can manually activate the system from the main control room.
    Each CSS pump, together with a CCS loop, provides the flow 
necessary to remove the heat generated inside the containment following 
a LOCA or MSLB. Upon system activation, the pumps are started and the 
borated water flows into the containment spray headers. When low level 
is reached in the RWT, sufficient water has been transferred to the 
containment to allow for the recirculation mode of operation. Spray 
pump suction is automatically realigned to the SIS sump upon a RAS.
    During the recirculation mode, the spray water is cooled by the 
shutdown heat exchangers prior to discharge into the containment. The 
shutdown heat exchangers are cooled by the component cooling water 
system. Post-LOCA pH control is provided by [Substitute plant-specific 
configuration if it differs from the following description] trisodium 
phosphate dodecahydrate, which is stored in stainless steel baskets 
located in the containment near the SIS sump intake.
    The longer CT for an inoperable CSS train will enhance overall 
plant safety by avoiding potential unscheduled plant

[[Page 65153]]

shutdowns and allowing greater availability of safety significant 
components during shutdown. In addition, this extension provides for 
increased flexibility in scheduling and performing maintenance and 
surveillance activities in order to enhance plant safety and 
operational flexibility during lower modes of operation.

4.0 Technical analysis

    [LICENSEE] has reviewed References 1 and 2, as well as TSTF-409, 
Rev. 2, and the model SE published on [DATE] ([] FR []) as part of the 
CLIIP Notice of Availability. [LICENSEE] has applied the methodology in 
Reference 1 to develop the proposed TS changes. [LICENSEE] has also 
concluded that the justifications presented in TSTF-409, Rev. 2 and the 
model SE prepared by the NRC staff are applicable to [PLANT NAME], and 
justify this amendment for the incorporation of changes to the [PLANT 
NAME] TS.
    In determining the suitability and safety impact of its adoption of 
TSTF-409, Rev. 2, [LICENSEE] analyzed the effect of increasing the CT 
for one CSS train to remain out of service using both traditional 
engineering considerations and probabilistic risk assessment (PRA) 
methods.

4.1 Traditional (Deterministic) Engineering Analysis

    The functions and operation of the CSS and CCS were described in 
Section 3.0 of this application. Based on a review of the design-basis 
requirements for the CSS, [LICENSEE] concluded that the loss of one CSS 
train is well within the design-basis analyses. This conclusion is 
based on the fact that each CSS pump, together with a CCS loop, 
provides the flow necessary to remove the heat generated inside the 
containment following a LOCA or MSLB. Therefore, the combination of one 
CSS pump and one CCS loop can carry out the design functions of 
maintaining the containment pressure and temperature at acceptably low 
levels following a design-basis accident (DBA), and limiting offsite 
radiation levels by reducing the pressure differential between the 
containment atmosphere and the external environment, thereby decreasing 
the driving force for fission product leakage across the containment.
    The plant status with one CSS train and one CCS train inoperable is 
covered by TS 3.6.6A, ACTION [D], which states:

    ``[With] one containment spray and one containment cooling train 
inoperable, restore containment spray train to OPERABLE status 
within 72 hours, or restore containment cooling train to OPERABLE 
status within 72 hours.''

    ACTION [D] ensures that the iodine removal capabilities of the CSS 
are available, along with 100 percent of the heat removal needs after 
an accident. The supporting analyses performed in Reference 1 did not 
evaluate the concurrent inoperabilities of one CSS train and one CCS 
train, therefore, the current CT of 72 hours is retained in Condition 
[D]. The 72 hour Completion Time was developed taking into account the 
redundant heat removal capabilities afforded by combinations of the CSS 
and CCS, the iodine removal function of the CSS, and the low 
probability of a DBA occurring during this period.

4.2 Probabilistic Risk Assessment Evaluation

    [LICENSEE] evaluated the proposed CT extension for the CSS using 
Reference 3 and Reference 4. This is the same methodology that the NRC 
staff used in Reference 2. The Key Principles of A Risk-Informed 
Integrated Decisionmaking Process listed in Reference 3 are as follows:

Principle I: The proposed change meets the current regulations.
Principle II: The proposed change is consistent with the defense-in-
depth philosophy.
Principle III: The proposed change maintains sufficient safety margin.
Principle IV: When the proposed change results in an increase in core 
damage frequency or risk, the increase should be small and consistent 
with the Commission's Safety Goal Policy Statement.
Principle V: The impact of the proposed change should be monitored 
using performance measurement strategies.

    In Reference 2, the NRC staff found, and [LICENSEE] agrees, that in 
risk-informed TS CT applications, Principle I is met, since regulations 
do not require specific CTs, but, rather, require ``remedial actions'' 
when an LCO cannot be met. Additionally, in its analysis of Principle 
III, the NRC staff found, and [LICENSEE] agrees, that the proposed CT 
extension maintains sufficient safety margins, For [PLANT NAME], the 
loss of one CSS train is well within the plant's design basis.
    In Reference 2, the NRC staff determined that the intent of 
Principles II, IV, and V would be met by a three-tiered approach to 
evaluate the plant-specific risk impact associated with the proposed TS 
changes, consistent with the requirements of Reference 4. The first 
tier evaluates the plant-specific PRA model and the impact of the 
proposed CT extension on plant operational risk. The second tier 
addresses the need to preclude potentially high risk configurations by 
identifying the need for any additional constraints or compensatory 
actions that, if implemented, would avoid or reduce the probability of 
a risk-significant configuration during the time when one CSS train is 
out of service. The third tier evaluates [LICENSEE'S] proposed 
Configuration Risk Management Program (CRMP) to ensure that the 
applicable plant configuration will be appropriately assessed from a 
risk perspective before entering into or during the proposed CT.
    In addition, the NRC staff determined in Reference 2, that the risk 
analysis methodology and approach used by the CEOG to estimate the risk 
impact of increasing the CT were reasonable. For most plants that 
participated in the joint application report, the NRC staff found that 
the risk impact was shown to be consistent with the acceptance 
guidelines for change in core damage frequency ([Delta]CDF), change in 
large early release frequency ([Delta]LERF), incremental conditional 
core damage probability (ICCDP), and incremental conditional large 
early release probability (ICLERP) specified in References 3 and 4 and 
Chapters 19.0 and 16.1 of Reference 5. However, not all Combustion 
Engineering (CE) plants participated in the joint application report, 
and the estimated risk impacts for some plans exceeded the Reference 3 
and/or Reference 4 acceptance guidelines, which would require 
additional justifications and/or compensatory measures to be provided 
for these plants to be determined to have acceptable risk impacts.
    In addition, the NRC staff found that the Tier 2 and Tier 3 
evaluations, as described in Reference 4, could not be approved 
generically since they were not complete, which would require that each 
individual plant-specific license amendment seeking adoption of TSTF-
409, Rev. 2 would need to include an assessment with respect to the 
Tier 2 and Tier 3 principles of Reference 4.
4.2.1 Conditions and Supporting Information
    The following conditions are provided to support adoption of TSTF-
409, Rev. 2 by [PLANT NAME]. Responses to the conditions are contained 
in Attachments 1 through 8 to this application: [NOTE: Licensees who 
cannot meet the Expectation and Acceptance Criteria listed in these 
conditions, or choose not to submit the associated information, should 
not

[[Page 65154]]

submit an application to adopt TSTF-409, Rev. 2 under the CLIIP.]
    1. As shown in Attachment 1, the plant-specific Tier 1 information 
associated with extending the CSS CT meets the acceptance guidelines of 
References 3 and 4 associated with [Delta]CDF, [Delta]LERF, ICCDP, and 
ICLERP.
    [EXPECTATIONS/ACCEPTANCE CRITERIA: the licensee's submittal must 
provide the [Delta]CDF, [Delta]LERF, ICCDP, and ICLERP values related 
to the CSS 7-day CT and confirm that these values meet the associated 
acceptance guidelines of References 3 and 4 as no more than a small 
risk increase (i.e., are in Region II or III of the acceptance 
guidelines figures). The licensee should utilize an ``average 
maintenance'' PRA model for this assessment. If the licensee utilizes a 
``zero maintenance'' PRA model for the assessment, they should state 
they are using a ``zero maintenance'' model in the evaluation, and 
provide a discussion as to the ability of that model to produce 
comparable results to the ``average maintenance'' assessment.]
    2. As shown in Attachment 2, the technical adequacy (quality) of 
[PLANT NAME'S] plant-specific PRA is acceptable for this application in 
accordance with the guidance provided in Reference 3. Specifically, the 
supporting information addresses the following areas:
    a. Justification that the plant-specific PRA reflects the as-built, 
as-operated plant.
    b. Discussion of plant-specific PRA updates and upgrades since the 
individual plant examination (IPE), individual plant examination of 
external events (IPEEE), and subsequent peer reviews and self-
assessment. Reference to past submittals discussing this information is 
acceptable.
    c. Discussion of plant-specific PRA peer reviews and/or self-
assessments performed, their overall conclusions, any facts and 
observations (F&Os) applicable to this application, and the licensee 
evaluation and resolution (e.g., by implementing model changes and/or 
sensitivity studies) of these F&Os to demonstrate the conclusions of 
the plant-specific analyses for this application are not adversely 
impacted (i.e., continued acceptability of the proposed extension of 
the CSS CT).
    d. Description of the licensee's plant-specific PRA configuration 
control (quality assurance) program and associated procedures.
    e. Overall determination of the adequacy of the plant-specific PRA 
with respect to this application.
    [EXPECTATION: The licensee's submittal must describe the scope of 
the plant-specific PRA and must justify its technical adequacy 
(quality) for this application in accordance with the guidance provided 
in Reference 3. Specifically, the supporting information must address 
each area in sufficient detail as shown in the following ACCEPTANCE 
CRITERIA:
    a. The licensee must provide a justification that confirms that the 
plant-specific PRA reflects the as-built, as-operated plant. This 
should include a description of the licensee's data and model update 
process, and the frequency of these activities. The licensee should 
also describe how the plant/corporate PRA staff are involved in (and/or 
made aware of) plant and operational/procedural modifications.
    b. The licensee must provide a summary description of the plant-
specific PRA updates and upgrades since the IPE and peer review of 
their plant and confirm that the changes identified during the IPEEE 
have been implemented or otherwise dispositioned.
    c. The licensee must discuss their plant-specific PRA peer reviews 
and/or any self-assessments performed (especially noting those 
conducted per the Nuclear Energy Institute (NEI) industry peer review 
guidelines and American Society of Mechanical Engineers (ASME) PRA 
Standard), their overall conclusions, any A&B level F&Os applicable to 
this application, and the licensee's evaluation and resolution (e.g., 
by implementing model changes and/or sensitivity studies) of these A&B 
level F&Os to demonstrate the conclusions of the plant-specific 
analyses for this application are not adversely impacted (i.e., 
continued acceptability of the proposed extension of the CSS CT).
    d. The licensee must describe their plant-specific PRA 
configuration control (quality assurance) program and associated 
procedures.
    e. The licensee must make an overall determination of the adequacy 
of their plant-specific PRA, confirming it is adequate with respect to 
this application.]
    3. Attachment 3 provides supporting information verifying that the 
plant risk impact associated with external events (e.g., fires, 
seismic, tornados, high winds, etc.) does not adversely impact or has 
no impact on the conclusions of the plant-specific analyses for this 
application and that the overall combined plant CDF and LERF are 
expected to be within the acceptance guidelines as identified in 
References 3 and Reference 4 (i.e., total CDF <1E-4/year and total LERF 
<1E-5/year)
    [EXPECTATIONS: The licensee's submittal must discuss the plant 
risks associated with external events and specifically identify 
(quantitatively and/or qualitatively, as appropriate) that the impact 
of CSS train CT extension on the risks associated with external events 
is small. The NRC staff acknowledges that any increase in the external 
event risk associated with the CSS train CT extension should be 
minimal. The licensee must address this impact and discuss why the risk 
overlap with external events (including internal fires) is negligible. 
Key insights from the IPEEE screening or quantitative approaches may be 
used to support qualitative arguments.
    If the licensee has performed updated analyses of an external event 
since the staff review and acceptance of their IPEEE, and a 
quantitative PRA demonstration is used to support the submittal, the 
licensee must describe the significant changes involved in their 
updated analyses and the impact of these changes on plant risk 
associated with this external event and with respect to this 
application.
    ACCEPTANCE CRITERIA: For the NRC staff to conclude the quantified 
risk associated with the extension request is acceptable, the total CDF 
and LERF values must meet Reference 3 and Reference 4 acceptance 
guidelines. For external events for which the licensee has a PRA, and 
the licensee provides those risk values (i.e., CDF and LERF) and risk 
metrics (i.e., [Delta]CDF, [Delta]LERF, ICCDP, and ICLERP) associated 
with the specifically analyzed external events, the licensee must also 
provide the total ``at-power'' plant risk and total ``at-power'' change 
in risk due to all PRA-analyzed contributors (combining internal 
events, internal flooding, internal fires, and external events. Results 
may be provided as a summation of values from separate PRA analyses or 
as a result of an integrated analysis (using a common PRA model for all 
contributors) or a combination of the above.
    For external events for which the licensee does not have a PRA (and 
it is not screened out as above), but rather relies on a non-PRA method 
(e.g., seismic margins analysis (SMA) or fire-induced vulnerability 
evaluation (FIVE)), to determine if the plant risk is acceptable, the 
licensee must confirm for this application that there were and still 
are either no vulnerabilities or outliers associated with these 
external events, or confirm that any vulnerabilities or outliers that 
were identified in their documented analyses (most likely in their 
IPEEE) have been resolved and, as needed, the appropriate

[[Page 65155]]

plant/procedural modifications have been implemented as described in 
their documented analyses.]
    4. Supporting information is provided in Attachment 4, consistent 
with the evaluation summary and conclusions (Sections 7 and 8) provided 
in Reference 2, in which licensees discuss implementation of procedures 
that prohibited entry into a 7-day CSS CT for scheduled maintenance 
purposes if external event conditions or warnings (e.g., severe weather 
warnings for ice, tornados, high winds, etc.) are in effect or confirm 
that these external events do not impact the submittal. [LICENSEE'S] 
discussion confirms that [PLANT NAME'S] procedures include compensatory 
measures and normal plant practices that help avoid potentially high 
risk configurations during the proposed extension of the CSS CT. This 
supporting information must also address the Tier 2 aspects of 
Reference 4.
    [EXPECTATIONS: The licensee's submittal must discuss (including 
licensee commitments related to) implementation of procedures that 
prohibit entry into a 7-day CSS CT for scheduled maintenance purposes 
if external event conditions or warnings are in effect. If the licensee 
does not want to implement this prohibition for specific severe weather 
conditions or warnings, the licensee must explicitly identify these 
event conditions/warnings and provide a justification for not including 
them. If there are no risk significant configurations or risk 
significant external event conditions identified in the Tier 2 
evaluation, then the licensee should include a statement that there are 
no risk significant configurations that would preclude them from using 
a 7-day CT.
    The licensee must also confirm that its procedures include 
compensatory measures and normal plant practices that help avoid 
potentially high risk configurations during the proposed extension of 
the CSS train CT. This supporting information must also address the 
Tier 2 aspects of Reference 4. The Tier 2 evaluation is meant to be an 
early evaluation (at the license submittal stage) to identify and 
preclude potentially high-risk plan configurations that could result if 
equipment, in addition to that associated with the proposed license 
amendment, is taken out of service simultaneously, or if other risk-
significant operational factors, such as concurrent system or equipment 
testing, are also involved.
    ACCEPTANCE CRITERIA: The Tier 2 evaluation needs to identify, as 
part of the licensee's submittal, potentially high-risk plant 
configurations associated with the CSS train CT extension that need to 
be precluded, if any, and identify how this is implemented (i.e., 
typically these aspects result in licensees establishing compensatory 
measures/commitments to ensure these configurations are precluded). If, 
in conducting the evaluation, the licensee identifies no high-risk 
plant configurations, then the licensee needs to explicitly state this 
fact.]
    5. Attachment 5 provides supporting information, consistent with 
the evaluation summary and conclusions (Sections 7 and 8) provided in 
Reference 2, that describes the plant-specific risk-informed CRMP to 
assess the risk associated with the removal of equipment from service 
during the 7-day CSS CT. If the licensee utilizes the Maintenance Rule 
(a)(4) program to evaluate the risk significance of configurations, it 
should state so in its submittal. In this description, [LICENSEE] 
confirms that the program provides the necessary assurances that 
appropriate assessments of plant risk configurations are sufficient to 
support the proposed CSS CT extension request. This supporting 
information also addresses the Tier 3 aspects of Reference 4.
    [EXPECTATIONS/ACCEPTANCE CRITERIA: The licensee's submittal must 
describe its CRMP or associated (a)(4) program (as appropriate), 
including how it reflects the current plant PRA model (specifically 
identifying any deviations and simplifications in the CRMP model from 
the plant-specific PRA model) and how the CRMP is updated to remain 
consistent with the plant-specific PRA.
    The licensee's submittal must also describe how the CRMP or 
associated (a)(4) program provides the necessary assurances that 
appropriate assessments of plant risk configurations are sufficient to 
support the proposed CT extension request for the CSS.
    Finally, the licensee's submittal must address the Tier 3 aspects 
of Reference 4, including he description of the CRMP, and must confirm 
that its CRMP or associated (a)(4) program meets all aspects of Section 
2.3.7.2 of Reference 4, specifically describing how its program meets 
each of the four Key Components identified in this Section. The Tier 3 
evaluation ensures that the CRMP or associated (a)(4) program is 
adequate when maintenance is about to commence, as opposed to the early 
(submittal stage) evaluation performed for Tier 2.]
    6. Attachment 6 provides supporting information, consistent with 
the evaluation summary (Section 7) provided in Reference 2, describing 
the relationship between components of the CSS and the shutdown cooling 
system (SDCS). For plants where components of the two systems may be 
used as backup to the other, the licensee must either confirm that Tier 
2 conditions exist in the licensee's CRMP or associated (a)(4) program 
that will not allow ``at power'' maintenance of the CSS and SDCS at the 
same time or that the risk significance of such maintenance 
configurations is low. If the CSS and SDCS have backup components, the 
plant should also describe how this backup capability is considered as 
part of the plant's shutdown operations program (SOP). If this backup 
feature is not considered when one train of the SDCS is in maintenance 
or otherwise unavailable, it should be stated in the licensee's 
application.
    [EXPECTATION: The licensee's submittal must describe the 
relationship/interfaces between the CSS and SDCS.
    ACCEPTANCE CRITERIA: If the SDCS can be used as a backup to the 
CSS, then the licensee must confirm that ``at power'' maintenance of 
the CSS and SDCS will not be allowed at the same time and describe how 
this is controlled (e.g., specifically identified in the CRMP as a 
configuration that is not allowed) or provide justification that the 
risks associated with a simultaneous ``at-power'' outage of one SDCS 
train and one CSS train is small. If the SDCS cannot be used (and is 
not credited) as a backup to CSS, then the licensee needs to explicitly 
state this fact.
    If CSS pumps can be used as a backup to the SDCS pumps, then the 
licensee must confirm that at least one CSS pump is required to be 
operable when maintenance of the CSS is performed in lower modes of 
operation (consistent with the plant's Technical Specifications) and 
must describe how this is controlled or demonstrate that the SOP 
provides adequate risk management for that configuration. If CSS pumps 
cannot be used (and are not credited) as a backup to SDCS pumps in 
lower modes of operation, then the licensee needs to explicitly state 
this fact.]
    7. Attachment 7 provides supporting information confirming that the 
licensee's Maintenance Rule program includes the ability to compute 
ICDP (incremental core damage probability), and ILERP (incremental 
large early release probability).
    [EXPECTATIONS/ACCEPTANCE CRITERIA: The licensee must confirm that 
their CRMP quantitative model (e.g., model used to provide quantitative 
assessments in support of 10 CFR 50.65 (a)(4)) calculates ICDP and 
ILERP, and

[[Page 65156]]

that their CRMP quantitative model (e.g., model used to provide 
quantitative assessment in support of 10 CFR 50.65 (a)(4)) explicitly 
models the CSS or has been modified to include the CSS, which will be 
used whenever CSS components are made unavailable.
    8. Attachment 8 provides information addressing how plant-specific 
systems, structures and components (SSC) are monitored and assessed at 
the plant under the Maintenance Rule (i.e. 10 CFR 50.65). Maintenance 
Rule unavailability and unreliability targets for CSS are also 
provided. These targets will be monitored in accordance with provisions 
of the Maintenance Rule.
    [EXPECTATIONS/ACCEPTANCE CRITERIA: The licensee must describe how 
plant-specific SSC reliability and availability are monitored and 
assessed at the plant under the Maintenance Rule (i.e., 10 CFR 50.65) 
to confirm that performance continues to be consistent with the 
analyses used to justify the 7-day CT. In providing this description, 
the licensee should also indicate how it periodically assesses previous 
risk-informed licensing action decisions to ensure that these decisions 
remain valid (i.e., continue to meet the Reference 3 and Reference 4 
acceptance guidelines) for the current plant operations and plant-
specific PRA and what actions it takes if a previously-approved risk-
informed licensing action decision is determined to no longer meet 
these acceptance guidelines.]
4.2.2 Regulatory Commitment
    The Reference 4 Tier 3 program ensures that, while the plant is 
following the TS ACTIONS associated with a 7-day CT for restoring an 
inoperable CSS to operable status, additional activities will not be 
performed that could further degrade the capabilities of the plant to 
respond to a condition that the inoperable CSS is designed to mitigate 
and, as a result, increase plant risk beyond that determined by the 
Reference 1 analyses. [LICENSEE's] implementation of Reference 4 Tier 3 
guidelines generally implies the assessment of risk with respect to 
CDF. However, the proposed CSS 7-day CT impacts accident sequences that 
can be mitigated following core damage and, consequently, impacts LERF 
as well as CDF. Therefore, [LICENSEE] has enhanced its CRMP, [OPTIONAL: 
as implemented under 10 CFR 50.65(a)(4), the Maintenance Rule,] to 
include a LERF assessment to support this application.

5.0 Regulatory Analysis

5.1 No Significant Hazards Consideration

    [LICENSEE] has reviewed the proposed no significant hazards 
consideration determination published in the Federal Register on [DATE] 
([ ] FR [ ]) as part of the CLIP. [LICENSEE] has concluded that the 
proposed determination presented in the notice is applicable to [PLANT 
NAME] and the determination is hereby incorporated by reference to 
satisfy the requirements of 10 CFR 50.91(a).

5.2 Applicable Regulatory Requirements/Criteria

    Based on its answers to the Section 4.2.1 questions provided in 
Attachments 1 through 8 to this application [LICENSEE] determines is 
based on the following:
    1. The traditional engineering evaluation reveals that the loss of 
one CSS train is well within [PLANT NAME's] design basis analyses. Key 
principles 1,2,3, and 5 in Section 2 of Reference 3 are met.
    2. By meeting the conditions identified in Section 4.2.1, 
[LICENSEE] believes that its PRA model is acceptable for this 
application and also concludes that there is minimal impact of the CT 
extensions for the CSS system on plant operational risk (Tier 1 
evaluation).
    3. By meeting the conditions identified in Section 4.2.1, 
[LICENSEE] will ensure that its implementation will identify 
potentially high risk configurations and the need for any additional 
constraints or compensatory actions that, if implemented, would avoid 
or reduce the probability of a risk-significant configuration (Tier 2 
evaluation), or state that no Tier 2 limitations have been identified.
    4. By meeting the conditions identified in Section 4.2.1, [PLANT 
NAME] will ensure that its risk-informed CRMP will satisfactorily 
assess the risk associated with the removal of equipment from service 
during the proposed CSS CT (Tier 3 evaluation) and the CRMP and plant 
risk will be managed by plant procedures, including implementation and 
monitoring of SSCs (CSS).
    In conclusion, based on the consideration discussed above, (1) 
there is reasonable assurance that the health and safety of the public 
will not be endangered by operation in the proposed manner, (2) such 
activities will be conducted in compliance with the Commission's 
regulations, and (3) the issuance of the amendment will not be inimical 
to the common defense and security or to the health and safety of the 
public.

6.0 Environmental Consideration

    [LICENSEE] has reviewed the environmental evaluation included in 
the model safety evaluation as pat of the CLIIP. [LICENSEE] concluded 
that the staff's findings presented in that the evaluation are 
applicable to [PLANT NAME] and the evaluation is hereby incorporated by 
reference for this application.

7.0 References

    [Licensee should include an applicable list of references, 
including but not limited to]
    1. Joint Applications Report: Modification to the Containment Spray 
System, and Low Pressure Safety Injection System Technical, CE Owners 
Group, CE NPSD-1045, March 2000.
    2. Safety Evaluation by the Office of Nuclear Reactor Regulation 
Related to CE Owners Group CE-NPSD-1045, ``Joint Application Report, 
Modification to the Containment Spray System, and the Low Pressure 
Safety Injection System Technical Specifications, December 21, 1999.''
    3. USNRC Regulatory Guide 1.174, ``An Approach for Using 
Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-
Specific Changes to the Licensing Basis,'' Revision 1, November 2002.
    4. USNRC Regulatory Guide 1.177, ``An Approach for Plant-Specific, 
Risk-Informed Decisionmaking: Technical Specifications,'' August 1998.
    5. NUREG-0800, ``Standard Review Plan for the Review of Safety 
Analysis Reports for Nuclear Power Plants,'' June 1996.

----------------------------------------------------------------------------------------------------------------
 
----------------------------------------------------------------------------------------------------------------
PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)
                                                                                                     Enclosure 2
----------------------------------------------------------------------------------------------------------------
CHANGES TO TS BASES
                                                                                                     Enclosure 3
----------------------------------------------------------------------------------------------------------------
CONDITION (1)
[LICENSEE'S] EVALUATION AND SUPPORTING INFORMATION

[[Page 65157]]

 
                                                                                                    Attachemnt 1
----------------------------------------------------------------------------------------------------------------
CONDITION (2)
[LICENSEE'S] EVALUATION AND SUPPORTING INFORMATION
                                                                                                    Attachemnt 2
----------------------------------------------------------------------------------------------------------------
CONDITION (3)
[LICENSEE'S] EVALUATION AND SUPPORTING INFORMATION
                                                                                                    Attachemnt 3
----------------------------------------------------------------------------------------------------------------
CONDITION (4)
[LICENSEE'S] EVALUATION AND SUPPORTING INFORMATION
                                                                                                    Attachemnt 4
----------------------------------------------------------------------------------------------------------------
CONDITION (5)
[LICENSEE'S] EVALUATION AND SUPPORTING INFORMATION
                                                                                                    Attachemnt 5
----------------------------------------------------------------------------------------------------------------
CONDITION (6)
[LICENSEE'S] EVALUATION AND SUPPORTING INFORMATION
                                                                                                    Attachemnt 6
----------------------------------------------------------------------------------------------------------------
CONDITION (7)
[LICENSEE'S] EVALUATION AND SUPPORTING INFORMATION
                                                                                                    Attachemnt 7
----------------------------------------------------------------------------------------------------------------
CONDITION (8)
[LICENSEE'S] EVALUATION AND SUPPORTING INFORMATION
                                                                                                    Attachemnt 8
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------

MODEL SAFETY EVALUATION
U.S. Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
Consolidated Line Item Improvement
Technical Specification Task Force TSTF-409, Revision 2
``Containment Spray System Completion Time Extension''

1.0 Introduction

    By letter to the Nuclear Regulatory Commission (NRC, Commission) 
dated [DATE] (Agencywide Documents Access and Management System (ADAMS) 
Accession Number MLXXXXXXXXX), [LICENSEE] (the licensee) requested 
changes to the Technical Specifications (TSs) for [PLANT NAME]. The 
proposed changes would revise TS 3.6.6A, ``Containment Spray and 
Cooling Systems,'' by extending from 72 hours to seven days the 
completion time (CT) to restore an inoperable containment spray system 
(CSS) train to operable status, and would add a Condition describing 
the required action and CT when one CSS train and one containment 
cooling system (CCS) train are inoperable.
    The changes are based on Technical Specification Task Force (TSTF) 
Change Traveler, TSTF-409, Revision 2 (Rev.), ``Containment Spray 
System Completion Time Extension (CE NPSD-2045-A)'' and associated TS 
Bases. TSTF-409, Rev. 2, submitted to the NRC by the TSTF in a letter 
dated November 10, 2003 (ADMS Accession Number MLO33280006), was 
approved by the NRC on [DATE].
    TSTF-409, Rev. 2 is based on Combustion Engineering Owner's Group 
(CEOG) Joint Application Report CE NPSD-1045-A, ``Joint Applications 
Report for Modifications to the Containment Spray System Technical 
Specifications,'' dated March 2000 (Reference 1), as accepted by, and 
subject to the limitations specified in, the associated NRC safety 
evaluation (SE), dated December 212, 1999 (ADMS Accession Number 
ML993620241) (Reference 2).
    In TSTF-409, Rev. 2, the CEOG states that the longer CT for 
restoring an inoperable CSS train to operable status will enhance 
ov