Notice of Opportunity To Comment on Model Safety Evaluation on Technical Specification Improvement To Relocate Surveillance Frequencies to Licensee Control-Risk-Informed Technical Specification Task Force (RITSTF) Initiative 5b, Technical Specification Task Force-425, Revision 2, 74202-74210 [E8-28850]
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Federal Register / Vol. 73, No. 235 / Friday, December 5, 2008 / Notices
Dated: December 2, 2008.
R. Michelle Schroll,
Office of the Secretary.
[FR Doc. E8–28934 Filed 12–3–08; 4:15 pm]
BILLING CODE 7590–01–P
NUCLEAR REGULATORY
COMMISSION
Notice of Opportunity To Comment on
Model Safety Evaluation on Technical
Specification Improvement To
Relocate Surveillance Frequencies to
Licensee Control—Risk-Informed
Technical Specification Task Force
(RITSTF) Initiative 5b, Technical
Specification Task Force—425,
Revision 2
dwashington3 on PROD1PC60 with NOTICES
Background
SUMMARY: The U. S. Nuclear Regulatory
Commission (NRC) has prepared a
model license amendment request
(LAR), model safety evaluation (SE), and
model no significant hazards
consideration (NSHC) determination.
These are related to changes to standard
technical specifications (STS) for
Technical Specification Task Force
(TSTF)—425, Rev. 2, ‘‘Relocate
Surveillance Frequencies to Licensee
Control—RITSTF Initiative 5b,’’
(Agencywide Documents Access
Management System (ADAMS)
Accession No. ML080280275). The
purpose of these models is to permit the
NRC to efficiently process amendments
that propose to relocate TS surveillance
frequencies. Licensees of nuclear power
reactors could then request
amendments, confirming the
applicability of the safety evaluation
and NSHC determination to their
reactors. The NRC staff is requesting
comment on the model safety evaluation
and model NSHC determination prior to
announcing their availability for
referencing in license amendment
applications.
DATES: The comment period expires
January 5, 2009. Comments received
after this date will be considered if it is
practical to do so. However, the
Commission can only ensure
consideration for comments received on
or before this date.
ADDRESSES: Please submit comments
either electronically or through U.S.
mail. E-mail comments to
CLIIP@nrc.gov. Mail comments to the
Chief, Rulemaking, Directives, and
Editing Branch, Division of
Administrative Services, Office of
Administration, Mail Stop: T–6 D59,
U.S. Nuclear Regulatory Commission,
15:27 Dec 04, 2008
Jkt 217001
FOR FURTHER INFORMATION CONTACT:
Robert Elliott, Mail Stop: O–12H2,
Technical Specifications Branch,
Division of Inspection & Regional
Support, Office of Nuclear Reactor
Regulation, U.S. Nuclear Regulatory
Commission, Washington, DC 20555–
0001, telephone 301–415–8585.
SUPPLEMENTARY INFORMATION:
AGENCY: Nuclear Regulatory
Commission.
ACTION: Request for comment.
VerDate Aug<31>2005
Washington, DC 20555–0001. Handdeliver comments to: 11545 Rockville
Pike, Rockville, MD between 7:45 a.m.
and 4:15 p.m. on Federal workdays.
Copies of comments received may be
examined at the NRC’s Public Document
Room, 11555 Rockville Pike (Room O–
1F21), Rockville, MD. You can submit
comments electronically to
CLIIP@nrc.gov.
This notice provides an opportunity
for the public to comment on proposed
changes to the STS after a preliminary
assessment and finding by the NRC staff
that the NRC will likely offer the change
for adoption by licensees. This notice
solicits comment on a proposed change
to the STS that modify surveillance
frequencies. NRC staff will evaluate any
comments received for the proposed
change to the STS and reconsider the
change or announce the availability of
the change for adoption by licensees.
Licensees opting to apply for this
change are responsible for reviewing the
staff’s evaluation, referencing the
applicable technical justifications, and
providing any necessary plant-specific
information. The NRC will process and
note each amendment application
responding to the notice of availability
according to applicable NRC rules and
procedures.
This notice involves the relocation of
most time-based surveillance
frequencies to a licensee-controlled
program, the Surveillance Frequency
Control Program (SFCP), and provides a
reference to the SFCP in the
administrative controls section of TS.
Exceptions to surveillance frequency
relocation are those surveillances
frequencies that are event driven, event
driven with a time component,
reference another established licensee
program, or condition-based
surveillance frequencies. Revision 2 of
TSTF–425 addresses all four reactor
vendor types. The owners groups
participants proposed this change for
incorporation into the standard
technical specifications in the technical
specification task force (TSTF) and is
designated TSTF–425, Rev. 2. TSTF–
425, Rev. 2 (ADAMS Accession No.
ML080280275), can be viewed on the
PO 00000
Frm 00073
Fmt 4703
Sfmt 4703
NRC’s Web page at https://www.nrc.gov/
reading-rm/adams.html.
Applicability
TSTF–425, Rev 2, is applicable to all
nuclear power reactors and requires the
application of the Nuclear Energy
Institute (NEI) 04–10, Rev. 1, ‘‘Riskinformed Technical Specifications
Initiative 5B, Risk-Informed Method for
Control of Surveillance Frequencies,’’
(ADAMS Accession No. ML071360456).
The NRC staff reviewed and approved
NEI 04–10, Revision 1 (Rev. 1), by letter
dated September 19, 2007 (ADAMS
Accession No. ML072570267). To
efficiently process the incoming license
amendment applications, the NRC staff
requests that each licensee applying for
the changes proposed in TSTF–425
include documentation regarding the
probabilistic risk assessment (PRA)
technical adequacy consistent with the
requirements of Section 4.2 Regulatory
Guide (RG) 1.200, ‘‘An Approach for
Determining the Technical Adequacy of
Probabilistic Risk Assessment Results
for Risk-Informed Activities’’ (ADAMS
Accession No. ML070240001).
Applicants proposing to use PRA
models for which NRC-endorsed
standards do not exist must submit
documentation that identifies
characteristics of those models
consistent with Sections 1.2 and 1.3 of
RG–1.200 or identify and justify the
methods to be applied for assessing the
risk contribution for those sources of
risk not addressed by PRA models.
The proposed change to adopt TSTF–
425 does not prevent licensees from
requesting an alternate approach or
proposing changes other than those
proposed in TSTF–425, Rev. 2.
Significant deviations from the
approach recommended in this notice,
or inclusion of additional changes to the
license, however, require additional
review by the NRC staff. This may
increase the time and resources needed
for the review or result in staff rejection
of the LAR. Licensees desiring
significant deviations or additional
changes should instead submit a license
amendment request that does not claim
to adopt TSTF–425, Rev 2.
Public Notices
This notice requests comments from
interested members of the public within
30 days of the date of publication in the
Federal Register. After evaluating the
comments received as a result of this
notice, the NRC staff will either
reconsider the proposed change or
announce the availability of the change
in a subsequent notice (with possible
changes to the safety evaluation or the
proposed no significant hazards
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Federal Register / Vol. 73, No. 235 / Friday, December 5, 2008 / Notices
consideration determination as a result
of public comments). If NRC staff
announces the availability of the
change, licensees wishing to adopt the
change must submit an application in
accordance with applicable rules and
other regulatory requirements.
For each application the NRC staff
will publish a notice of consideration of
issuance of amendment to facility
operating licenses, a proposed no
significant hazards consideration
determination, and a notice of
opportunity for a hearing. The staff will
also publish a notice of issuance of an
amendment to the operating license to
announce the relocation of surveillance
frequencies to licensee-controlled
document for each plant that receives
the requested change.
dwashington3 on PROD1PC60 with NOTICES
Dated at Rockville, MD, this 24th day of
November 2008.
For the Nuclear Regulatory Commission.
Robert Elliott,
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. THE MODEL
PROVIDES THE EXPECTED LEVEL OF
DETAIL AND CONTENT FOR AN
APPLICATION TO REVISE TECHNICAL
SPECIFICATIONS REGARDING RISKINFORMED JUSTIFICATION FOR
RELOCATION OF SPECIFIC TS
SURVEILLANCE FREQUENCIES TO A
LICENSEE CONTROLLED PROGRAM
CHANGE. LICENSEES REMAIN
RESPONSIBLE FOR ENSURING THAT
THEIR ACTUAL APPLICATION
FULFILLS THEIR ADMINISTRATIVE
REQUIREMENTS AS WELL AS NRC
REGULATIONS.
U.S. Nuclear Regulatory Commission
Document Control Desk
Washington, DC 20555
SUBJECT: PLANT NAME
DOCKET NO. 50—APPLICATION FOR
TECHNICAL SPECIFICATION
CHANGE REGARDING RISKINFORMED JUSTIFICATION FOR
THE RELOCATION OF SPECIFIC
SURVEILLANCE FREQUENCY
REQUIREMENTS TO A LICENSEE
CONTROLLED PROGRAM
Dear Sir or Madam:
In accordance with the provisions of
Title 10 of the Code of Federal
Regulations (10 CFR Part 50.90),
‘‘Application for Amendment License
Construction Permit at Request of
Holder,’’ [LICENSEE] is submitting a
request for an amendment to the
technical specifications (TS) for [PLANT
NAME, UNIT NOS.].
The proposed amendment would
modify [LICENSEE] technical
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15:27 Dec 04, 2008
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specifications by relocating specific
surveillance frequencies to a licenseecontrolled program with the
implementation of Nuclear Energy
Institute (NEI) 04–10, ‘‘Risk-Informed
Technical Specification Initiative 5B,
Risk-Informed Method for Control of
Surveillance Frequencies.’’
Attachment 1 provides a description
of the proposed change, the requested
confirmation of applicability, and plantspecific verifications. Attachment 2
provides the existing TS pages marked
up to show the proposed change.
Attachment 3 provides revised (clean)
TS pages. Attachment 4 provides a
summary of the regulatory commitments
made in this submittal. Attachment 5
provides the proposed TS Bases
changes.
[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,
‘‘Notice for Public Comment; State
Consultation,’’ a copy of this
application, with attachments, is being
provided to the designated [STATE]
Official.
I declare [or certify, verify, state]
under penalty of perjury that the
foregoing is correct and true. Executed
on [Date] [Signature]
If you should have any questions
regarding this submittal, please contact
[NAME, TELEPHONE NUMBER].
Sincerely,
[Name, Title]
Attachments:
1. Description and Assessment
2. Proposed Technical Specification
Changes
3. Revised Technical Specification
Pages
4. Regulatory Commitments
5. Proposed Technical Specification
Bases Changes
cc: U.S. Nuclear Regulatory Commission
Regional Office
NRC Resident Inspector
Frequency Control Program, to TS
Section [5], Administrative Controls.
The changes are consistent with NRC
approved Industry/TSTF STS change
TSTF–425, Revision 2, (Rev. 2) (ADAMS
Accession No. ML080280275). The
Federal Register notice published on
[DATE] announced the availability of
this TS improvement.
Attachment 1—Description and
Assessment
3.0
1.0
Description
The proposed amendment would
modify technical specifications by
relocating specific surveillance
frequencies to a licensee-controlled
program with the adoption of Technical
Specification Task Force (TSTF)–425,
Revision 2, ‘‘Relocate Surveillance
Frequencies to Licensee Control—Risk
Informed Technical Specification Task
Force (RITSTF) Initiative 5.’’
Additionally, the change would add a
new program, the Surveillance
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2.0
Assessment
2.1 Applicability of Published Safety
Evaluation
[LICENSEE] has reviewed the safety
evaluation dated [DATE]. This review
included a review of the NRC staff’s
evaluation, the supporting information
provided to support TSTF–425, Rev. 2,
and the requirements specified in NEI
04–10, Rev. 1, (ADAMS Accession No.
ML071360456).
1. [LICENSEE] LAR submittal
includes documentation with regards to
PRA technical adequacy consistent with
the requirements of RG 1.200 (ADAMS
Accession No. ML070240001) Section
4.2., and
2. [LICENSEE] proposes to use PRA
models without NRC-endorsed
standards. The licensee has submitted
documentation which identifies the
quality characteristics of those models,
as described in RG 1.200 (ADAMS
Accession No. ML070240001).
[LICENSEE] has concluded that the
justifications presented in the TSTF
proposal and the safety evaluation
prepared by the NRC staff are applicable
to [PLANT, UNIT NOS.] and justify this
amendment to incorporate the changes
to the [PLANT] TS.
2.2
Optional Changes and Variations
[LICENSEE] is not proposing any
variations or deviations from the TS
changes described in TSTF–425, Rev. 2,
and the NRC staff’s model safety
evaluation dated [DATE].
Regulatory Analysis
3.1 No Significant Hazards
Consideration Determination
[LICENSEE] has reviewed the
proposed no significant hazards
consideration determination (NSHCD)
published in the Federal Register.
[LICENSEE] has concluded that the
proposed NSHCD presented in the
Federal Register notice is applicable to
[PLANT] and has found it acceptable to
incorporate into the amendment request
that satisfies the requirements of 10 CFR
50.91(a).
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Attachment 2—Proposed Technical
Specification Changes (Mark-Up)
document. Any other statements in this
submittal are provided for information
purposes and are not considered
regulatory commitments. Please direct
questions regarding these commitments
to [CONTACT NAME].
Attachment 3—Proposed Technical
Specification Pages
Attachment 4—List of Regulatory
Commitments
The following table identifies the
[LICENSEE] commitments in this
Regulatory commitments
Due date
[LICENSEE] commits to implement NEI 04–10, Revision 1, as identified by reference in new TS Administrative Control, ‘‘Surveillance Frequency Control Program (SFCP)’’.
[Complete,
implemented
with
amendment OR within X days of
implementation of amendment].
Attachment 5—Proposed Changes to
Technical Specification Bases Pages
dwashington3 on PROD1PC60 with NOTICES
Proposed No Significant Hazards
Consideration Determination
Description of Amendment Request:
The change requests the adoption of an
approved change to the standard
technical specifications (STS) for
[Babcock and Wilcox (B&W) Plants
(NUREG–1430), Westinghouse Plants
(NUREG–1431), Combustion
Engineering Plants (NUREG–1432),
General Electric Plants, BWR/4
(NUREG–1433), and General Electric
Plants, BWR/6 (NUREG–1334)], to allow
relocation of specific TS surveillance
frequencies to a licensee-controlled
program. The proposed change is
described in Technical Specification
Task Force (TSTF) Traveler, TSTF–425,
Revision 2 (Rev. 2) (ADAMS Accession
No. ML080280275) related to the
Relocation of Surveillance Frequencies
to Licensee Control—RITSTF Initiative
5b and was described in the Notice of
Availability published in the Federal
Register on [Date] ([xx FR xxxxx]).
The proposed changes are consistent
with NRC-approved Industry/Technical
Specification Task Force (TSTF)
Traveler, TSTF–425, Rev. 2, ‘‘Relocate
Surveillance Frequencies to Licensee
Control—RITSTF Initiative 5b.’’ The
proposed change relocates surveillance
frequencies to a licensee-controlled
program, the Surveillance Frequency
Control Program (SFCP). This change is
applicable to licensees using
probabilistic risk guidelines contained
in NRC-approved NEI 04–10, ‘‘RiskInformed Technical Specifications
Initiative 5b, Risk-Informed Method for
Control of Surveillance Frequencies,’’
(ADAMS Accession No. 071360456).
Basis for proposed no significant
hazards consideration determination: As
required by 10 CFR 50.91(a), the
[LICENSEE] analysis of the issue of no
significant hazards consideration is
presented below:
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15:27 Dec 04, 2008
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1. Does the proposed change involve a
significant increase in the probability or
consequences of any accident previously
evaluated?
Response: No.
The proposed change relocates the
specified frequencies for periodic
surveillance requirements to licensee control
under a new Surveillance Frequency Control
Program. Surveillance frequencies are not an
initiator to any accident previously
evaluated. As a result, the probability of any
accident previously evaluated is not
significantly increased. The systems and
components required by the technical
specifications for which the surveillance
frequencies are relocated are still required to
be operable, meet the acceptance criteria for
the surveillance requirements, and be
capable of performing any mitigation
function assumed in the accident analysis.
As a result, the consequences of any accident
previously evaluated are not significantly
increased.
Therefore, the proposed change does not
involve a significant increase in the
probability or consequences of an accident
previously evaluated.
2. Does the proposed change create the
possibility of a new or different kind of
accident from any previously evaluated?
Response: No.
No new or different accidents result from
utilizing the proposed change. The changes
do not involve a physical alteration of the
plant (i.e., no new or different type of
equipment will be installed) or a change in
the methods governing normal plant
operation. In addition, the changes do not
impose any new or different requirements.
The changes do not alter assumptions made
in the safety analysis. The proposed changes
are consistent with the safety analysis
assumptions and current plant operating
practice.
Therefore, the proposed changes do not
create the possibility of a new or different
kind of accident from any accident
previously evaluated.
3. Does the proposed change involve a
significant reduction in the margin of safety?
Response: No.
The design, operation, testing methods,
and acceptance criteria for systems,
structures, and components (SSCs), specified
in applicable codes and standards (or
alternatives approved for use by the NRC)
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Fmt 4703
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will continue to be met as described in the
plant licensing basis (including the final
safety analysis report and bases to TS), since
these are not affected by changes to the
surveillance frequencies. Similarly, there is
no impact to safety analysis acceptance
criteria as described in the plant licensing
basis. To evaluate a change in the relocated
surveillance frequency, [LICENSEE]
performed a probabilistic risk evaluation
using the guidance contained in NRC
approved NEI 04–10, Rev. 1. NEI 04–10, Rev.
1 methodology provides reasonable
acceptance guidelines and methods for
evaluating the risk increase of proposed
changes to surveillance frequencies
consistent with Regulatory Guide 1.177.
Therefore, the proposed changes do 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 does not involve a significant
hazards consideration as set forth in 10
CFR 50.92(c), Issuance of Amendment,’’
and therefore, [LICENSEE] finding of
‘‘no significant hazards consideration’’
is justified.
Proposed Safety Evaluation
U.S. Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
Technical Specification Task Force
(TSTF) Change TSTF–425
Relocate Surveillance Frequencies to
Licensee Control
1.0 Introduction
By letter dated [llll, 20ll],
[LICENSEE] (the licensee) proposed
changes to the technical specifications
(TS) for [PLANT NAME]. The requested
change is the adoption of NRC-approved
TSTF–425, Revision 2, ‘‘Relocate
Surveillance Frequencies to Licensee
Control—RITSTF Initiative 5b’’
(Reference 1). When implemented,
TSTF–425, Revision 2 (Rev. 2) relocates
most periodic frequencies of technical
specifications (TS) surveillances to a
licensee controlled program, the
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Surveillance Frequency Control
Program (SFCP), and provides
requirements for the new program in the
administrative controls section of TS.
All surveillance frequencies can be
relocated except:
• Frequencies that reference other
approved programs for the specific
interval (such as the Inservice Testing
Program or the Primary Containment
Leakage Rate Testing Program),
• Frequencies that are purely event
driven (e.g., ‘‘Each time the control rod
is withdrawn to the ‘full out’ position’’).
• Frequencies that are event-driven
but have a time component for
performing the surveillance on a onetime basis once the event occurs (e.g.,
‘‘within 24 hours after thermal power
reaching ≥ 95% RTP’’)
• Frequencies that are related to
specific conditions (e.g., battery
degradation, age, and capacity) or
conditions for the performance of a
surveillance requirement (e.g., ‘‘drywell
to suppression chamber differential
pressure decrease’’).
The definition of ‘‘Staggered Test
Basis’’ in TS Section 1.1, ‘‘Definitions,’’
is placed in brackets. Plants that adopt
TSTF–425, Rev. 2, and no longer use
this defined term in the technical
specifications may remove it from
Section 1.1. A new Administrative
Controls Program is added to TS section
5 as [Specification 5.5.15 (NUREG–1433
and –1434) or Specification 5.5.18
(NUREG–1430, 1431, and 1432)]. The
new program is called the Surveillance
Frequency Control Program (SFCP) and
describes the requirements for the
program to control changes to the
relocated surveillance frequencies. The
TS Bases for each affected surveillance
is revised to state that the frequency is
set in accordance with the Surveillance
Frequency Control Program. Various
editorial changes may be made to the
Bases as needed to facilitate the
addition of the Bases changes. Some
surveillance Bases do not contain a
discussion of the frequency. In these
cases, Bases describing the current
frequency were added to maintain
consistency with the Bases for similar
surveillances. These instances are noted
in the markup along with the source of
the text. The proposed changes to the
administrative controls of TS to
incorporate the SFCP includes a specific
reference to NEI 04–10, ‘‘Risk-Informed
Technical Specifications Initiative 5B,
Risk-Informed Method for Control of
Surveillance Frequencies,’’ Revision 1
(Rev. 1), (Reference 2) as the basis for
making any changes to the surveillance
frequencies once they are relocated out
of TS.
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In a letter dated September 19, 2007,
the NRC staff approved Nuclear Energy
Institute (NEI) Topical Report (TR) 04–
10, Rev. 1, ‘‘Risk-Informed Technical
Specification initiative 5B, Risk
Informed Method for Control of
Surveillance Frequencies’’ (ADAMS
Accession No. 072570267), as
acceptable for referencing in licensing
actions to the extent specified and
under the limitations delineated in NEI
04–10, Rev. 1, and the final acceptance
SE providing the basis for NRC
acceptance of NEI 04–10, Rev 1.
2.0 Regulatory Evaluation
In the ‘‘Final Policy Statement:
Technical Specifications for Nuclear
Power Plants’’ published in the Federal
Register (FR) (58 FR 39132, 7/22/93) the
NRC addressed the use of Probabilistic
Safety Analysis (PSA, currently referred
to as Probabilistic Risk Analysis or PRA)
in STS. In this 1993 FR publication, the
NRC states, in part, ‘‘The Commission
believes that it would be inappropriate
at this time to allow requirements which
meet one or more of the first three
criteria [of 10 CFR 50.36] to be deleted
from technical specifications based
solely on PSA (Criterion 4). However, if
the results of PSA indicate that
technical specifications can be relaxed
or removed, a deterministic review will
be performed.’’ Additionally, the NRC
states in this publication, ‘‘The
Commission Policy in this regard is
consistent with its Policy Statement on
‘Safety Goals for the operation of
Nuclear Power Plants,’ 51 FR 30028,
published on August 21, 1986. The
Policy Statement on Safety Goals states
in part, * * * probabilistic results
should also be reasonably balanced and
supported through use of deterministic
arguments. In this way, judgments can
be made * * * about the degree of
confidence to be given these
[probabilistic] estimates and
assumptions. This is a key part of the
process for determining the degree of
regulatory conservatism that may be
warranted for particular decisions. This
‘defense-in-depth’ approach is expected
to continue to ensure the protection of
public health and safety.’’ The NRC
further states in the 1993 publication,
‘‘The Commission will continue to use
PSA, consistent with its policy on
Safety Goals, as a tool in evaluating
specific line-item improvements to
Technical Specifications, new
requirements, and industry proposals
for risk-based Technical Specification
changes.’’
Approximately two years later the
NRC provided additional detail
concerning the use of PRA in the ‘‘Final
Policy Statement: Use of Probabilistic
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Risk Assessment in Nuclear Regulatory
Activities’’ published in the Federal
Register (FR) (60 FR 42622, August 16,
1995) the NRC addressed the use of
Probabilistic Risk Assessment. In this
FR publication, the NRC’S opening
statement states, in-part, ‘‘The
Commission believes that an overall
policy on the use of PRA methods in
nuclear regulatory activities should be
established so that the many potential
applications of PRA can be
implemented in a consistent and
predictable manner that would promote
regulatory stability and efficiency. In
addition, the Commission believes that
the use of PRA technology in NRC
regulatory activities should be increased
to the extent supported by the state-ofthe-art in PRA methods and data and in
a manner that complements the NRC’s
deterministic approach.’’
The following excerpts are taken, in
part, from the 1995 Commission Policy
Statement: ‘‘PRA addresses a broad
spectrum of initiating events by
assessing the event frequency.
Mitigating system reliability is then
assessed, including the potential for
multiple and common-cause failures.
The treatment, therefore, goes beyond
the single failure requirements in the
deterministic approach. The
probabilistic approach to regulation is,
therefore, considered an extension and
enhancement of traditional regulation
by considering risk in a more coherent
and complete manner.
‘‘Therefore, the Commission believes
that an overall policy on the use of PRA
in nuclear regulatory activities should
be established so that the many
potential applications of PRA can be
implemented in a consistent and
predictable manner that promotes
regulatory stability and efficiency. This
policy statement sets forth the
Commission’s intention to encourage
the use of PRA and to expand the scope
of PRA applications in all nuclear
regulatory matters to the extent
supported by the state-of-the-art in
terms of methods and data.
‘Therefore, the Commission adopts
the following policy statement regarding
the expanded NRC use of PRA:
(1) The use of PRA technology should
be increased in all regulatory matters to
the extent supported by the state-of-theart in PRA methods and data and in a
manner that complements the NRC’s
deterministic approach and supports the
NRC’s traditional defense-in-depth
philosophy.
(2) PRA and associated analyses (e.g.,
sensitivity studies, uncertainty analyses,
and importance measures) should be
used in regulatory matters, where
practical within the bounds of the state-
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of-the-art, to reduce unnecessary
conservatism associated with current
regulatory requirements, regulatory
guides, license commitments, and staff
practices. Where appropriate, PRA
should be used to support the proposal
for additional regulatory requirements
in accordance with 10 CFR 50.109
(Backfit Rule). Appropriate procedures
for including PRA in the process should
be developed and followed. It is, of
course, understood that the intent of
this policy is that existing rules and
regulations shall be complied with
unless these rules and regulations are
revised.
(3) PRA evaluations in support of
regulatory decisions should be as
realistic as practicable and appropriate
supporting data should be publicly
available for review.
(4) The Commission’s safety goals for
nuclear power plants and subsidiary
numerical objectives are to be used with
appropriate consideration of
uncertainties in making regulatory
judgments on the need for proposing
and backfitting new generic
requirements on nuclear power plant
licensees.’’
In 10 CFR 50.36, the NRC 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; (3)
surveillance requirements; (4) design
features; and (5) administrative controls.
As stated in 10 CFR 50.36(c)(3),
‘‘Surveillance requirements are
requirements relating to test, calibration,
or inspection to assure that the
necessary quality of systems and
components is maintained, that facility
operation will be within safety limits,
and that the limiting conditions for
operation will be met.’’ The surveillance
requirements are required by 10 CFR
50.36(c)(3) to reside in TS and will
remain in TS. The new TS SFCP will
provide the necessary surveillance
frequency programmatic controls and is
located in the TS Administrative
Controls Section (STS Section 5.0).
Changes to surveillance frequencies in
the SFCP are made using the
methodology contained in NEI 04–10,
Rev. 1, including qualitative
considerations, results of risk analyses,
sensitivity studies and any bounding
analyses, and recommended monitoring
of SSCs, are required to be documented.
Changes to frequencies are subject to
regulatory review and oversight of the
SFCP implementation through the
rigorous NRC review of safety related
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SSC performance provided by the
reactor oversight program (ROP).
[LICENSEE] SFCP ensures that
surveillance requirements specified in
the TS are performed at intervals
sufficient to assure the above regulatory
requirements are met. Existing
regulatory requirements, such as 10 CFR
50.65, ‘‘Requirements for Monitoring the
Effectiveness of Maintenance at Nuclear
Power Plants’’ and 10 CFR 50 Appendix
B (corrective action program), require
licensee monitoring of surveillance test
failures and implementing corrective
actions to address such failures. One of
these actions may be to consider
increasing the frequency at which a
surveillance test is performed. In
addition, the SFCP implementation
guidance in NEI 04–10, Rev. 1, requires
monitoring of the performance of
structures, systems, and components
(SSCs) for which surveillance
frequencies are decreased to assure
reduced testing does not adversely
impact the SSCs.
This change is analogous with other
NRC-approved TS changes in which the
surveillance requirements are retained
in technical specifications but the
related surveillance frequencies are
relocated to licensee-controlled
documents, such as surveillances
performed in accordance with the InService Testing Program and the
Primary Containment Leakage Rate
Testing Program. Thus, this proposed
change complies with 10 CFR
50.36(c)(3) by retaining the
requirements relating to test, calibration,
or inspection to assure that the
necessary quality of systems and
components is maintained, that facility
operation will be within safety limits,
and that the limiting conditions for
operation will be met and meets the first
key safety principle articulated in
Regulatory Guide (RG) 1.177 (Reference
3) for plant-specific, risk-informed TS
changes by complying with current
regulations.
Licensees are required by TS to
perform surveillance test, calibration, or
inspection on specific safety related
system equipment such as reactivity
control, power distribution, electrical,
instrumentation, and others to verify
system operability. Surveillance
frequencies, currently identified in TS,
are based primarily upon deterministic
methods such as engineering judgment,
operating experience, and
manufacturer’s recommendations. The
licensee’s use of NRC-approved PRA
methodologies identified in NEI 04–10,
Rev. 1, provides a way to establish riskinformed Surveillance frequencies that
complements the deterministic
approach and supports the NRC’s
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traditional defense-in-Depth
philosophy.
These regulatory requirements, and
the monitoring required by NEI 04–10,
Rev. 1, ensure that surveillance
frequencies are sufficient to assure that
the requirements of 10 CFR 50.36 are
satisfied and that any performance
deficiencies will be identified and
appropriate corrective actions taken.
3.0 Technical Evaluation
[LICENSEE] adoption of TSTF–425,
Rev. 2, provides for administrative
relocation of applicable surveillance
frequencies, and provides for the
addition of the SFCP to the
administrative controls of TS. TSTF–
425, Rev. 2, also requires the application
of NEI 04–10, Rev. 1, for any changes to
surveillance frequencies within the
SFCP. The licensee’s application for the
changes proposed in TSTF–425, Rev 2,
included documentation regarding the
probabilistic risk assessment (PRA)
technical adequacy consistent with the
requirements of Regulatory Guide 1.200
(RG–1.200) (Reference 4), ‘‘An
Approach for Determining the Technical
Adequacy of Probabilistic Risk
Assessment Results for Risk-Informed
Activities’’, Section 4.2. In accordance
with NEI 04–10, Rev. 1, probabilistic
risk assessment (PRA) methods are
used, in combination with plant
performance data and other
considerations, to identify and justify
modifications to the surveillance
frequencies of equipment at nuclear
power plants. This is in accordance
with guidance provided in RG 1.174
(Reference 5) and RG 1.177 in support
of changes to surveillance test intervals.
RG 1.177 identifies five key safety
principles required for risk-informed
changes to TS. Each of these principles
is addressed by the industry
methodology document, NEI 04–10,
Rev. 1. Four of the five principles,
which relate to the technical aspects of
the proposed change, are discussed
below in Sections 3.1 through 3.4.
3.1 The Proposed Change Is Consistent
With the Defense-in-Depth Philosophy
Consistency with the defense-indepth philosophy is maintained if:
• A reasonable balance is preserved
among prevention of core damage,
prevention of containment failure, and
consequence mitigation.
• Over-reliance on programmatic
activities to compensate for weaknesses
in plant design is avoided.
• System redundancy, independence,
and diversity are preserved
commensurate with the expected
frequency, consequences of challenges
to the system, and uncertainties (e.g., no
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risk outliers). Because the scope of the
proposed methodology is limited to
revision of surveillance frequencies, the
redundancy, independence, and
diversity of plant systems are not
impacted.
• Defenses against potential common
cause failures are preserved, and the
potential for the introduction of new
common cause failure mechanisms is
assessed.
• Independence of barriers is not
degraded.
• Defenses against human errors are
preserved.
• The intent of the General Design
Criteria in 10 CFR Part 50, Appendix A,
is maintained.
TSTF–425, Rev. 2, requires the
application of NEI 04–10, Rev. 1, for any
changes to surveillance frequencies
within the SFCP. NEI 04–10, Rev. 1,
uses both the core damage frequency
(CDF) and the large early release
frequency (LERF) metrics to evaluate the
impact of proposed changes to
surveillance frequencies. The guidance
of RG 1.174 and RG 1.177 for changes
to CDF and LERF is achieved by
evaluation using a comprehensive risk
analysis, which assesses the impact of
proposed changes including
contributions from human errors and
common cause failures. Defense-indepth is also included in the
methodology explicitly as a qualitative
consideration outside of the risk
analysis, as is the potential impact on
detection of component degradation that
could lead to increased likelihood of
common cause failures. Both the
quantitative risk analysis and the
qualitative considerations assure a
reasonable balance of defense-in-depth
is maintained to ensure protection of
public health and safety, satisfying the
second key safety principle of RG 1.177.
3.2 The Proposed Change Maintains
Sufficient Safety Margins
The engineering evaluation conducted
by the licensee assessed the impact of
the proposed TS change with the
principle that sufficient safety margins
are maintained. The guidelines used for
making that assessment included
ensuring the proposed TS Surveillance
test frequency change is not in conflict
with approved industry codes and
standards or adversely affects any
assumptions or inputs to the safety
analysis, or, if such inputs are affected,
justification is provided to ensure
sufficient safety margin will continue to
exist.
The design, operation, testing
methods, and acceptance criteria for
SSCs, specified in applicable codes and
standards (or alternatives approved for
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use by the NRC) will continue to be met
as described in the plant licensing basis
(including the Final Safety Analysis
Report and bases to TS), since these are
not affected by changes to the
surveillance frequencies. Similarly,
there is no impact to safety analysis
acceptance criteria as described in the
plant licensing basis.
Thus, safety margins are maintained
by the proposed methodology, and the
third key safety principle of RG 1.177 is
satisfied.
3.3 When Proposed Changes Result in
an Increase in Core Damage Frequency
or Risk, the Increases Should Be Small
and Consistent With the Intent of the
Commission’s Safety Goal Policy
Statement
RG 1.177 provides a framework for
risk evaluation of proposed changes to
surveillance frequencies, which requires
identification of the risk contribution
from impacted surveillances,
determination of the risk impact from
the change to the proposed surveillance
frequency, and performance of
sensitivity and uncertainty evaluations.
TSTF–425, Rev. 2, requires application
of NEI 04–10, Rev. 1, in the SFCP. NEI
04–10, Rev. 1, satisfies the intent of RG
1.177 requirements for evaluation of the
change in risk, and for assuring that
such changes are small by providing the
technical methodology to support risk
informed technical specifications for
control of surveillance frequencies.
3.4.1 Quality of the PRA
The quality of the [LICENSEE] PRA is
compatible with the safety implications
of the proposed TS change and the role
the PRA plays in justifying the change.
That is, the more the potential change
in risk or the greater the uncertainty in
that risk from the requested TS change,
or both, the more rigor that must go into
ensuring the quality of the PRA.
[LICENSEE] used RG 1.200 to address
the plant PRA technical adequacy. RG
1.200 is NRC developed regulatory
guidance, which addresses the use of
the American Society of Mechanical
Engineers (ASME) RA–Sb–2005,
Addenda to ASME RA–S–2002
Standard for Probabilistic Risk
Assessment for Nuclear Power Plant
Applications (Reference 6), and the NEI
peer review process NEI 00–02, PRA
Peer Review Process Guidance
(Reference 7). The licensee has
performed an assessment of the PRA
models used to support the SFCP
against the requirements of RG 1.200 to
assure that the PRA models are capable
of determining the change in risk due to
changes to surveillance frequencies of
SSCs, using plant specific data and
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models. Capability category II of ASME
RA–Sb–2005 is applied as the standard,
and any identified deficiencies to those
requirements are assessed further in
sensitivity studies to determine any
impacts to proposed decreases to
surveillance frequencies. This level of
PRA quality, combined with the
proposed sensitivity studies, is
sufficient to support the evaluation of
changes proposed to surveillance
frequencies within the SFCP, and is
consistent with regulatory position 2.3.1
of RG 1.177.
3.4.2 Scope of the PRA
[LICENSEE] is required to evaluate
each proposed change to a relocated
surveillance frequency using the
guidance contained in NEI 04–10, Rev.
1, to determine its potential impact on
risk, due to impacts from internal
events, fires, seismic, other external
events, and from shutdown conditions.
Consideration is made of both CDF and
LERF metrics. In cases where a PRA of
sufficient scope or where quantitative
risk models were unavailable,
[LICENSEE] uses bounding analyses, or
other conservative quantitative
evaluations. A qualitative screening
analysis may be used when the
surveillance frequency impact on plant
risk is shown to be negligible or zero.
The licensee’s evaluation methodology
is sufficient to ensure the scope of the
risk contribution of each surveillance
frequency change is properly identified
for evaluation, and is consistent with
regulatory position 2.3.2 of RG 1.177.
3.4.3 PRA Modeling
The [LICENSEE] determines whether
the SSCs affected by a proposed change
to a surveillance frequency are modeled
in the PRA. Where the SSC is directly
or implicitly modeled, a quantitative
evaluation of the risk impact may be
carried out. The methodology adjusts
the failure probability of the impacted
SSCs, including any impacted common
cause failure modes, based on the
proposed change to the surveillance
frequency. Where the SSC is not
modeled in the PRA, bounding analyses
are performed to characterize the impact
of the proposed change to surveillance
frequency. Potential impacts on the risk
analyses due to screening criteria and
truncation levels are addressed by the
requirements for PRA technical
adequacy consistent with guidance
contained in RG 1.200, and by
sensitivity studies identified in NEI 04–
10, Rev. 1.
The licensee performs quantitative
evaluations of the impact of selected
testing strategy (i.e., staggered testing or
sequential testing) consistent with the
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guidance of NUREG/CR–6141 and
NUREG/CR–5497, as discussed in NEI
04–10 Rev. 1.
Thus, through the application of NEI
04–10, Rev. 1, the [LICENSEE] PRA
modeling is sufficient to ensure an
acceptable evaluation of risk for the
proposed changes in surveillance
frequency, and is consistent with
regulatory position 2.3.3 of RG 1.177.
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3.4.4 Assumptions for Time Related
Failure Contributions
The failure probabilities of SSCs
modeled in the [LICENSEE] PRA
[include] a standby time-related
contribution and a cyclic demandrelated contribution. NEI 04–10, Rev. 1,
criteria adjust the time-related failure
contribution of SSCs affected by the
proposed change to surveillance
frequency. This is consistent with RG
1.177 Section 2.3.3 which permits
separation of the failure rate
contributions into demand and standby
for evaluation of surveillance
requirements. If the available data do
not support distinguishing between the
time-related failures and demand
failures, then the change to surveillance
frequency is conservatively assumed to
impact the total failure probability of
the SSC, including both standby and
demand contributions. The SSC failure
rate (per unit time) is assumed to be
unaffected by the change in test
frequency, and will be confirmed by the
required monitoring and feedback
implemented after the change in
surveillance frequency is implemented.
The process requires consideration of
qualitative sources of information with
regards to potential impacts of test
frequency on SSC performance,
including industry and plant-specific
operating experience, vendor
recommendations, industry standards,
and code-specified test intervals. Thus
the process is not reliant upon risk
analyses as the sole basis for the
proposed changes.
The potential beneficial risk impacts
of reduced surveillance frequency,
including reduced downtime, lesser
potential for restoration errors,
reduction of potential for test caused
transients, and reduced test-caused wear
of equipment, are identified
qualitatively, but are conservatively not
required to be quantitatively assessed.
Thus, through the application of NEI
04–10, Rev. 1, [LICENSEE] has
employed reasonable assumptions with
regard to extensions of surveillance test
intervals, and is consistent with
regulatory position 2.3.4 of RG 1.177.
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3.4.5 Sensitivity and Uncertainty
Analyses
NEI 04–10, Rev. 1, requires sensitivity
studies to assess the impact of
uncertainties from key assumptions of
the PRA, uncertainty in the failure
probabilities of the affected SSCs,
impact to the frequency of initiating
events, and of any identified deviations
from capability category II of ASME
PRA Standard (ASME RA–Sb–2005)
(Reference 4). Where the sensitivity
analyses identify a potential impact on
the proposed change, revised
surveillance frequencies are considered,
along with any qualitative
considerations that may bear on the
results of such sensitivity studies.
Required monitoring and feedback of
SSC performance once the revised
surveillance frequencies are
implemented will also be performed.
Thus, through the application of NEI
04–10, Rev. 1, [LICENSEE] has
appropriately considered the possible
impact of PRA model uncertainty and
sensitivity to key assumptions and
model limitations, consistent with
regulatory position 2.3.5 of RG 1.177.
3.4.6 Acceptance Guidelines
[LICENSEE] quantitatively evaluates
the change in total risk (including
internal and external events
contributions) in terms of core damage
frequency (CDF) and large early release
fraction (LERF) for both the individual
risk impact of a proposed change in
surveillance frequency and the
cumulative impact from all individual
changes to surveillance frequencies.
Each individual change to surveillance
frequency must show a risk impact
below 1E–6 per year for change to CDF,
and below 1E–7 per year for change to
LERF. These are consistent with the
limits of RG 1.174 for very small
changes in risk. Where the RG 1.174
limits are not met, the process either
considers revised surveillance
frequencies which are consistent with
RG 1.174, or the process terminates
without permitting the proposed
changes. Where quantitative results are
unavailable to permit comparison to
acceptance guidelines, appropriate
qualitative analyses are required to
demonstrate that the associated risk
impact of a proposed change to
surveillance frequency is negligible or
zero. Otherwise, bounding quantitative
analyses are required which
demonstrate the risk impact is at least
one order of magnitude lower than the
RG 1.174 acceptance guidelines for very
small changes in risk. In addition to
assessing each individual SSC
surveillance frequency change, the
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cumulative impact of all changes must
result in a risk impact below 1E–5 per
year for change to CDF, and below 1E–
6 per year for change to LERF, and the
total CDF and total LERF must be
reasonably shown to be less than 1E–4
per year and 1E–5 per year, respectively.
These are consistent with the limits of
RG 1.174 for acceptable changes in risk,
as referenced by RG 1.177 for changes
to surveillance frequencies. The staff
interprets this assessment of cumulative
risk as a requirement to calculate the
change in risk from a baseline model
utilizing failure probabilities based on
the surveillance frequencies prior to
implementation of the SFCP, compared
to a revised model with failure
probabilities based on changed
surveillance frequencies. The staff
further notes that [LICENSEE] includes
a provision to exclude the contribution
to cumulative risk from individual
changes to surveillance frequencies
associated with small risk increases
(less than 5E–8 CDF and 5E–9 LERF)
once the baseline PRA models are
updated to include the effects of the
revised surveillance frequencies.
The quantitative acceptance guidance
of RG 1.174 is necessary but not
sufficient to accept decreases in
surveillance frequencies. The process
also considers qualitative information to
evaluate the proposed changes to
surveillance frequencies, including
industry and plant-specific operating
experience, vendor recommendations,
industry standards, the results of
sensitivity studies, and SSC
performance data and test history.
The final acceptability of the
proposed change is based on all of these
considerations and not solely on the
PRA results compared to numerical
acceptance guidelines. Post
implementation performance
monitoring and feedback are also
required to assure continued reliability
of the components. The licensee’s
application of NEI 04–10, Rev. 1,
provides reasonable acceptance
guidelines and methods for evaluating
the risk increase of proposed changes to
surveillance frequencies, consistent
with Regulatory Position 2.4 of RG
1.177. Therefore, the proposed
[LICENSEE] methodology satisfies the
fourth key safety principle of RG 1.177
by assuring any increase in risk is small
consistent with the intent of the
Commission’s Safety Goal Policy
Statement.
3.4.7 The Impact of the Proposed
Change Should Be Monitored Using
Performance Measurement Strategies
[LICENSEE] adoption of TSTF–425,
Rev. 2, requires application of NEI 04–
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10, Rev. 1, in the SFCP. NEI 04–10, Rev.
1, requires performance monitoring of
SSCs whose surveillance frequency has
been revised as part of a feedback
process to assure that the change in test
frequency has not resulted in
degradation of equipment performance
and operational safety. The monitoring
and feedback includes consideration of
maintenance rule monitoring of
equipment performance. In the event of
degradation of SSC performance, the
surveillance frequency will be
reassessed in accordance with the
methodology, in addition to any
corrective actions which may apply as
part of the maintenance rule
requirements. The performance
monitoring and feedback specified in
NEI 04–10, Rev. 1, is sufficient to
reasonably assure acceptable SSC
performance and is consistent with
regulatory position 3.2 of RG 1.177.
Thus, the fifth key safety principle of
RG 1.177 is satisfied.
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3.4.8 Addition of Surveillance
Frequency Control Program to TS
Section 5
[LICENSEE] has included the SFCP
and specific requirements into TS
Section [5.5.15 or 5.5.18], administrative
controls, as follows:
This program provides controls for
surveillance frequencies. The program
ensures that surveillance requirements
specified in the technical specifications
are performed at intervals (frequencies)
sufficient to assure that the associated
limiting conditions for operation are
met.
a. The Surveillance Frequency
Control Program contains a list of
frequencies of those surveillance
requirements for which the frequency is
controlled by the program.
b. Changes to the frequencies listed in
the Surveillance Frequency Control
Program shall be made in accordance
with NEI 04–10, ‘‘Risk-Informed Method
for Control of Surveillance
Frequencies,’’ Revision 1.
c. The provisions of surveillance
requirements 3.0.2 and 3.0.3 are
applicable to the frequencies established
in the Surveillance Frequency Control
Program.
Summary and Conclusions
The staff has reviewed the
[LICENSEE] proposed relocation of
surveillance frequencies to a licensee
controlled document, and controlling
changes to surveillance frequencies in
accordance with a new program, the
SFCP, identified in the administrative
controls of TS. The SFCP and TS
Section [5.5.15, 5.5.18] references NEI
04–10, Rev. 1, which provides a risk-
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informed methodology using plantspecific risk insights and performance
data to revise surveillance frequencies
within the SFCP. This methodology
supports relocating surveillance
frequencies from TS to a licenseecontrolled document, provided those
frequencies are changed in accordance
with NEI 04–10, Rev. 1, as referenced in
the administrative controls of the TS.
The proposed [LICENSEE] adoption of
TSTF–425, Rev. 2, and risk-informed
methodology of NEI 04–10, Rev. 1, as
referenced in the administrative
controls of TS, satisfies the key
principles of risk-informed decision
making applied to changes to TS as
delineated in RG 1.177 and RG 1.174, in
that:
• The proposed change meets current
regulations;
• The proposed change is consistent
with defense-in-depth philosophy;
• The proposed change maintains
sufficient safety margins;
• Increases in risk resulting from the
proposed change are small and
consistent with the Commission’s Safety
Goal Policy Statement; and
• The impact of the proposed change
is monitored with performance
measurement strategies.
10 CFR 50.36(c)(3) states ‘‘Technical
specifications will include items in the
following categories: Surveillance
Requirements. Surveillance
Requirements are requirements relating
to test, calibration, or inspection to
assure that the necessary quality of
systems and components is maintained,
that facility operation will be within
safety limits, and that the limiting
conditions for operation will be met.’’
The NRC staff finds that with the
proposed relocation of surveillance
frequencies to an owner-controlled
document and administratively
controlled in accordance with the TS
SFCP, [LICENSEE] continues to meet
the regulatory requirement of 10 CFR
50.36, and specifically, 10 CFR
50.36(c)(3), surveillance requirements.
The NRC 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 NRC’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.
4.0 State Consultation
In accordance with the NRC’s
regulations, the [ ] State official was
notified of the proposed issuance of the
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74209
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[s] change[s] 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 or
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
NRC has previously issued a proposed
finding that the amendment involves no
significant hazards consideration and
there has been no public comment on
such finding published [DATE] ([] 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
References
1. TSTF–425, Revision 2, ‘‘Relocate
Surveillance Frequencies to Licensee
Control—RITSTF Initiative 5b,’’ January
17, 2008 (ADAMS Accession Number:
ML080280275).
2. NEI 04–10, ‘‘Risk-Informed Technical
Specifications Initiative 5B, RiskInformed Method for Control of
Surveillance Frequencies,’’ April 2007
(ADAMS Accession Number:
ML071360456).
3. Regulatory Guide 1.177, ‘‘An Approach for
Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications,’’
August 1998 (ADAMS Accession
Number: ML003740176).
4. Regulatory Guide 1.200, Rev. 1 ‘‘An
Approach for Determining the Technical
Adequacy of Probabilistic Risk
Assessment Results for Risk-Informed
Activities,’’ Revision 1, January 2007
(ADAMS Accession Number:
ML070240001).
5. Regulatory Guide 1.174, ‘‘An Approach for
Using Probabilistic Risk Assessment in
Risk-Informed Decisions on PlantSpecific Changes to the Licensing Basis,’’
NRC, August 1998 (ADAMS Accession
Number: ML003740133).
6. ASME PRA Standard ASME RA–Sb–2005,
Addenda to ASME RA–S–2002,
‘‘Standard for Probabilistic Risk
Assessment for Nuclear Power Plant
Application.’’
7. NEI 00–02, Rev. 1 ‘‘Probabilistic Risk
Assessment (PRA) Peer Review Process
Guidance, Rev. 1, May 2006 (ADAMS
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Accession Number: ML061510621).
[FR Doc. E8–28850 Filed 12–4–08; 8:45 am]
BILLING CODE 7590–01–P
NUCLEAR REGULATORY
COMMISSION
[Docket No. 50–285]
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Omaha Public Power District, Fort
Calhoun Station, Unit No. 1; Notice of
Withdrawal of Application for
Amendment to Facility Operating
License
The U.S. Nuclear Regulatory
Commission (the Commission) has
granted the request of Omaha Public
Power District (the licensee) to
withdraw its February 5, 2008,
application for proposed amendment to
Facility Operating License No. DPR–40
for the Fort Calhoun Station, Unit No.
1, located in Washington County,
Nebraska.
The proposed amendment would
have revised the Technical
Specifications (TS) to eliminate the
second condition of Limiting Conditions
for Operation from (LCO) 2.5(1)A. The
current LCO 2.5(1)A. states, ‘‘With one
steam supply to the turbine driven AFW
[auxiliary feedwater] pump inoperable,
restore the steam supply to OPERABLE
status within 7 days and within 8 days
from discovery of the failure to meet the
LCO.’’ The amendment would have
eliminated the second condition that
states, ‘‘and within 8 days from
discovery of failure to meet the LCO.’’
The licensee stated that the proposed
change would have been consistent with
the objective of Technical Specification
Task Force (TSTF) Traveler TSTF–439,
Revision 2, ‘‘Eliminate Second
Completion Times Limiting Time From
Discovery of Failure to Meet an LCO.’’
The Commission had previously
issued a Notice of Consideration of
Issuance of Amendment published in
the Federal Register on June 3, 2008 (73
FR 31722). However, by letter dated
November 10, 2008, the licensee
withdrew the proposed change.
For further details with respect to this
action, see the application for
amendment dated February 5, 2008, and
the licensee’s letter dated November 10,
2008, which withdrew the application
for license amendment. Documents may
be examined, and/or copied for a fee, at
the NRC’s Public Document Room
(PDR), located at One White Flint North,
Public File Area O1 F21, 11555
Rockville Pike (first floor), Rockville,
Maryland. Publicly available records
will be accessible electronically from
the Agencywide Documents Access and
VerDate Aug<31>2005
15:27 Dec 04, 2008
Jkt 217001
Management System (ADAMS) Public
Electronic Reading Room on the Internet
at the NRC Web site, https://
www.nrc.gov/reading-rm.html. Persons
who do not have access to ADAMS or
who encounter problems in accessing
the documents located in ADAMS
should contact the NRC PDR Reference
staff by telephone at 1–800–397–4209,
or 301–415–4737 or by e-mail to
pdr.resource@nrc.gov.
Dated at Rockville, Maryland, this 26th day
of November 2008.
For the Nuclear Regulatory Commission.
Alan B. Wang,
Project Manager, Plant Licensing Branch IV,
Division of Operating Reactor Licensing,
Office of Nuclear Reactor Regulation.
[FR Doc. E8–28846 Filed 12–4–08; 8:45 am]
BILLING CODE 7590–01–P
OFFICE OF PERSONNEL
MANAGEMENT
Federal Prevailing Rate Advisory
Committee; Open Committee Meetings
According to the provisions of section
10 of the Federal Advisory Committee
Act (Pub. L. 92–463), notice is hereby
given that a meeting of the Federal
Prevailing Rate Advisory Committee
will be held on Thursday, January 8,
2009.
The meeting will start at 10 a.m. and
will be held in Room 5A06A, U.S.
Office of Personnel Management
Building, 1900 E Street, NW.,
Washington, DC.
The Federal Prevailing Rate Advisory
Committee is composed of a Chair, five
representatives from labor unions
holding exclusive bargaining rights for
Federal blue-collar employees, and five
representatives from Federal agencies.
Entitlement to membership on the
Committee is provided for in 5 U.S.C.
5347.
The Committee’s primary
responsibility is to review the Prevailing
Rate System and other matters pertinent
to establishing prevailing rates under
subchapter IV, chapter 53, 5 U.S.C., as
amended, and from time to time advise
the U.S. Office of Personnel
Management.
This scheduled meeting will start in
open session with both labor and
management representatives attending.
During the meeting either the labor
members or the management members
may caucus separately with the Chair to
devise strategy and formulate positions.
Premature disclosure of the matters
discussed in these caucuses would
unacceptably impair the ability of the
Committee to reach a consensus on the
matters being considered and would
PO 00000
Frm 00081
Fmt 4703
Sfmt 4703
disrupt substantially the disposition of
its business. Therefore, these caucuses
will be closed to the public because of
a determination made by the Director of
the U.S. Office of Personnel
Management under the provisions of
section 10(d) of the Federal Advisory
Committee Act (Pub. L. 92–463) and 5
U.S.C. 552b(c)(9)(B). These caucuses
may, depending on the issues involved,
constitute a substantial portion of a
meeting.
Annually, the Chair compiles a report
of pay issues discussed and concluded
recommendations. These reports are
available to the public, upon written
request to the Committee.
The public is invited to submit
material in writing to the Chair on
Federal Wage System pay matters felt to
be deserving of the Committee’s
attention. Additional information on
this meeting may be obtained by
contacting the Committee at U.S. Office
of Personnel Management, Federal
Prevailing Rate Advisory Committee,
Room 5526, 1900 E Street, NW.,
Washington, DC 20415, (202) 606–2838.
Dated: December 1, 2008.
Charles E. Brooks,
Chairman, Federal Prevailing Rate Advisory
Committee.
[FR Doc. E8–28835 Filed 12–4–08; 8:45 am]
BILLING CODE 6325–49–P
OFFICE OF THE UNITED STATES
TRADE REPRESENTATIVE
Determination of Trade Surplus in
Certain Sugar and Syrup Goods and
Sugar Containing Products of Chile,
Morocco, the Dominican Republic, El
Salvador, Guatemala, Honduras, and
Nicaragua
AGENCY: Office of the United States
Trade Representative.
ACTION: Notice.
SUMMARY: In accordance with relevant
provisions of the Harmonized Tariff
Schedule of the United States (HTS), the
Office of the United States Trade
Representative (USTR) is providing
notice of its determination of the trade
surplus in certain sugar and syrup goods
and sugar-containing products of Chile,
Morocco, the Dominican Republic, El
Salvador, Guatemala, Honduras, and
Nicaragua. As described below, the level
of a country’s trade surplus in these
goods relates to the quantity of sugar
and syrup goods and sugar-containing
products for which the United States
grants preferential tariff treatment under
(i) the United States—Chile Free Trade
Agreement (Chile FTA), in the case of
Chile; (ii) the United States—Morocco
E:\FR\FM\05DEN1.SGM
05DEN1
Agencies
[Federal Register Volume 73, Number 235 (Friday, December 5, 2008)]
[Notices]
[Pages 74202-74210]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-28850]
-----------------------------------------------------------------------
NUCLEAR REGULATORY COMMISSION
Notice of Opportunity To Comment on Model Safety Evaluation on
Technical Specification Improvement To Relocate Surveillance
Frequencies to Licensee Control--Risk-Informed Technical Specification
Task Force (RITSTF) Initiative 5b, Technical Specification Task Force--
425, Revision 2
AGENCY: Nuclear Regulatory Commission.
ACTION: Request for comment.
-----------------------------------------------------------------------
SUMMARY: The U. S. Nuclear Regulatory Commission (NRC) has prepared a
model license amendment request (LAR), model safety evaluation (SE),
and model no significant hazards consideration (NSHC) determination.
These are related to changes to standard technical specifications (STS)
for Technical Specification Task Force (TSTF)--425, Rev. 2, ``Relocate
Surveillance Frequencies to Licensee Control--RITSTF Initiative 5b,''
(Agencywide Documents Access Management System (ADAMS) Accession No.
ML080280275). The purpose of these models is to permit the NRC to
efficiently process amendments that propose to relocate TS surveillance
frequencies. Licensees of nuclear power reactors could then request
amendments, confirming the applicability of the safety evaluation and
NSHC determination to their reactors. The NRC staff is requesting
comment on the model safety evaluation and model NSHC determination
prior to announcing their availability for referencing in license
amendment applications.
DATES: The comment period expires January 5, 2009. Comments received
after this date will be considered if it is practical to do so.
However, the Commission can only ensure consideration for comments
received on or before this date.
ADDRESSES: Please submit comments either electronically or through U.S.
mail. E-mail comments to CLIIP@nrc.gov. Mail comments to the Chief,
Rulemaking, Directives, and Editing Branch, Division of Administrative
Services, Office of Administration, Mail Stop: T-6 D59, U.S. Nuclear
Regulatory Commission, Washington, DC 20555-0001. Hand-deliver comments
to: 11545 Rockville Pike, Rockville, MD between 7:45 a.m. and 4:15 p.m.
on Federal workdays. Copies of comments received may be examined at the
NRC's Public Document Room, 11555 Rockville Pike (Room O-1F21),
Rockville, MD. You can submit comments electronically to CLIIP@nrc.gov.
FOR FURTHER INFORMATION CONTACT: Robert Elliott, Mail Stop: O-12H2,
Technical Specifications Branch, Division of Inspection & Regional
Support, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001, telephone 301-415-8585.
SUPPLEMENTARY INFORMATION:
Background
This notice provides an opportunity for the public to comment on
proposed changes to the STS after a preliminary assessment and finding
by the NRC staff that the NRC will likely offer the change for adoption
by licensees. This notice solicits comment on a proposed change to the
STS that modify surveillance frequencies. NRC staff will evaluate any
comments received for the proposed change to the STS and reconsider the
change or announce the availability of the change for adoption by
licensees. Licensees opting to apply for this change are responsible
for reviewing the staff's evaluation, referencing the applicable
technical justifications, and providing any necessary plant-specific
information. The NRC will process and note each amendment application
responding to the notice of availability according to applicable NRC
rules and procedures.
This notice involves the relocation of most time-based surveillance
frequencies to a licensee-controlled program, the Surveillance
Frequency Control Program (SFCP), and provides a reference to the SFCP
in the administrative controls section of TS. Exceptions to
surveillance frequency relocation are those surveillances frequencies
that are event driven, event driven with a time component, reference
another established licensee program, or condition-based surveillance
frequencies. Revision 2 of TSTF-425 addresses all four reactor vendor
types. The owners groups participants proposed this change for
incorporation into the standard technical specifications in the
technical specification task force (TSTF) and is designated TSTF-425,
Rev. 2. TSTF-425, Rev. 2 (ADAMS Accession No. ML080280275), can be
viewed on the NRC's Web page at https://www.nrc.gov/reading-rm/
adams.html.
Applicability
TSTF-425, Rev 2, is applicable to all nuclear power reactors and
requires the application of the Nuclear Energy Institute (NEI) 04-10,
Rev. 1, ``Risk-informed Technical Specifications Initiative 5B, Risk-
Informed Method for Control of Surveillance Frequencies,'' (ADAMS
Accession No. ML071360456). The NRC staff reviewed and approved NEI 04-
10, Revision 1 (Rev. 1), by letter dated September 19, 2007 (ADAMS
Accession No. ML072570267). To efficiently process the incoming license
amendment applications, the NRC staff requests that each licensee
applying for the changes proposed in TSTF-425 include documentation
regarding the probabilistic risk assessment (PRA) technical adequacy
consistent with the requirements of Section 4.2 Regulatory Guide (RG)
1.200, ``An Approach for Determining the Technical Adequacy of
Probabilistic Risk Assessment Results for Risk-Informed Activities''
(ADAMS Accession No. ML070240001). Applicants proposing to use PRA
models for which NRC-endorsed standards do not exist must submit
documentation that identifies characteristics of those models
consistent with Sections 1.2 and 1.3 of RG-1.200 or identify and
justify the methods to be applied for assessing the risk contribution
for those sources of risk not addressed by PRA models.
The proposed change to adopt TSTF-425 does not prevent licensees
from requesting an alternate approach or proposing changes other than
those proposed in TSTF-425, Rev. 2. Significant deviations from the
approach recommended in this notice, or inclusion of additional changes
to the license, however, require additional review by the NRC staff.
This may increase the time and resources needed for the review or
result in staff rejection of the LAR. Licensees desiring significant
deviations or additional changes should instead submit a license
amendment request that does not claim to adopt TSTF-425, Rev 2.
Public Notices
This notice requests comments from interested members of the public
within 30 days of the date of publication in the Federal Register.
After evaluating the comments received as a result of this notice, the
NRC staff will either reconsider the proposed change or announce the
availability of the change in a subsequent notice (with possible
changes to the safety evaluation or the proposed no significant hazards
[[Page 74203]]
consideration determination as a result of public comments). If NRC
staff announces the availability of the change, licensees wishing to
adopt the change must submit an application in accordance with
applicable rules and other regulatory requirements.
For each application the NRC staff will publish a notice of
consideration of issuance of amendment to facility operating licenses,
a proposed no significant hazards consideration determination, and a
notice of opportunity for a hearing. The staff will also publish a
notice of issuance of an amendment to the operating license to announce
the relocation of surveillance frequencies to licensee-controlled
document for each plant that receives the requested change.
Dated at Rockville, MD, this 24th day of November 2008.
For the Nuclear Regulatory Commission.
Robert Elliott,
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. THE MODEL PROVIDES THE EXPECTED LEVEL OF DETAIL AND CONTENT FOR
AN APPLICATION TO REVISE TECHNICAL SPECIFICATIONS REGARDING RISK-
INFORMED JUSTIFICATION FOR RELOCATION OF SPECIFIC TS SURVEILLANCE
FREQUENCIES TO A LICENSEE CONTROLLED PROGRAM CHANGE. LICENSEES REMAIN
RESPONSIBLE FOR ENSURING THAT THEIR ACTUAL APPLICATION FULFILLS THEIR
ADMINISTRATIVE REQUIREMENTS AS WELL AS NRC REGULATIONS.
U.S. Nuclear Regulatory Commission
Document Control Desk
Washington, DC 20555
SUBJECT: PLANT NAME
DOCKET NO. 50--APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING
RISK-INFORMED JUSTIFICATION FOR THE RELOCATION OF SPECIFIC SURVEILLANCE
FREQUENCY REQUIREMENTS TO A LICENSEE CONTROLLED PROGRAM
Dear Sir or Madam:
In accordance with the provisions of Title 10 of the Code of
Federal Regulations (10 CFR Part 50.90), ``Application for Amendment
License Construction Permit at Request of Holder,'' [LICENSEE] is
submitting a request for an amendment to the technical specifications
(TS) for [PLANT NAME, UNIT NOS.].
The proposed amendment would modify [LICENSEE] technical
specifications by relocating specific surveillance frequencies to a
licensee-controlled program with the implementation of Nuclear Energy
Institute (NEI) 04-10, ``Risk-Informed Technical Specification
Initiative 5B, Risk-Informed Method for Control of Surveillance
Frequencies.''
Attachment 1 provides a description of the proposed change, the
requested confirmation of applicability, and plant-specific
verifications. Attachment 2 provides the existing TS pages marked up to
show the proposed change. Attachment 3 provides revised (clean) TS
pages. Attachment 4 provides a summary of the regulatory commitments
made in this submittal. Attachment 5 provides the proposed TS Bases
changes.
[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, ``Notice for Public Comment; State
Consultation,'' a copy of this application, with attachments, is being
provided to the designated [STATE] Official.
I declare [or certify, verify, state] under penalty of perjury that
the foregoing is correct and true. Executed on [Date] [Signature]
If you should have any questions regarding this submittal, please
contact [NAME, TELEPHONE NUMBER].
Sincerely,
[Name, Title]
Attachments:
1. Description and Assessment
2. Proposed Technical Specification Changes
3. Revised Technical Specification Pages
4. Regulatory Commitments
5. Proposed Technical Specification Bases Changes
cc: U.S. Nuclear Regulatory Commission
Regional Office
NRC Resident Inspector
Attachment 1--Description and Assessment
1.0 Description
The proposed amendment would modify technical specifications by
relocating specific surveillance frequencies to a licensee-controlled
program with the adoption of Technical Specification Task Force (TSTF)-
425, Revision 2, ``Relocate Surveillance Frequencies to Licensee
Control--Risk Informed Technical Specification Task Force (RITSTF)
Initiative 5.'' Additionally, the change would add a new program, the
Surveillance Frequency Control Program, to TS Section [5],
Administrative Controls.
The changes are consistent with NRC approved Industry/TSTF STS
change TSTF-425, Revision 2, (Rev. 2) (ADAMS Accession No.
ML080280275). The Federal Register notice published on [DATE] announced
the availability of this TS improvement.
2.0 Assessment
2.1 Applicability of Published Safety Evaluation
[LICENSEE] has reviewed the safety evaluation dated [DATE]. This
review included a review of the NRC staff's evaluation, the supporting
information provided to support TSTF-425, Rev. 2, and the requirements
specified in NEI 04-10, Rev. 1, (ADAMS Accession No. ML071360456).
1. [LICENSEE] LAR submittal includes documentation with regards to
PRA technical adequacy consistent with the requirements of RG 1.200
(ADAMS Accession No. ML070240001) Section 4.2., and
2. [LICENSEE] proposes to use PRA models without NRC-endorsed
standards. The licensee has submitted documentation which identifies
the quality characteristics of those models, as described in RG 1.200
(ADAMS Accession No. ML070240001).
[LICENSEE] has concluded that the justifications presented in the
TSTF proposal and the safety evaluation prepared by the NRC staff are
applicable to [PLANT, UNIT NOS.] and justify this amendment to
incorporate the changes to the [PLANT] TS.
2.2 Optional Changes and Variations
[LICENSEE] is not proposing any variations or deviations from the
TS changes described in TSTF-425, Rev. 2, and the NRC staff's model
safety evaluation dated [DATE].
3.0 Regulatory Analysis
3.1 No Significant Hazards Consideration Determination
[LICENSEE] has reviewed the proposed no significant hazards
consideration determination (NSHCD) published in the Federal Register.
[LICENSEE] has concluded that the proposed NSHCD presented in the
Federal Register notice is applicable to [PLANT] and has found it
acceptable to incorporate into the amendment request that satisfies the
requirements of 10 CFR 50.91(a).
[[Page 74204]]
Attachment 2--Proposed Technical Specification Changes (Mark-Up)
Attachment 3--Proposed Technical Specification Pages
Attachment 4--List of Regulatory Commitments
The following table identifies the [LICENSEE] commitments in this
document. Any other statements in this submittal are provided for
information purposes and are not considered regulatory commitments.
Please direct questions regarding these commitments to [CONTACT NAME].
------------------------------------------------------------------------
Regulatory commitments Due date
------------------------------------------------------------------------
[LICENSEE] commits to implement NEI 04-10, [Complete, implemented with
Revision 1, as identified by reference in amendment OR within X days
new TS Administrative Control, of implementation of
``Surveillance Frequency Control Program amendment].
(SFCP)''.
------------------------------------------------------------------------
Attachment 5--Proposed Changes to Technical Specification Bases Pages
Proposed No Significant Hazards Consideration Determination
Description of Amendment Request: The change requests the adoption
of an approved change to the standard technical specifications (STS)
for [Babcock and Wilcox (B&W) Plants (NUREG-1430), Westinghouse Plants
(NUREG-1431), Combustion Engineering Plants (NUREG-1432), General
Electric Plants, BWR/4 (NUREG-1433), and General Electric Plants, BWR/6
(NUREG-1334)], to allow relocation of specific TS surveillance
frequencies to a licensee-controlled program. The proposed change is
described in Technical Specification Task Force (TSTF) Traveler, TSTF-
425, Revision 2 (Rev. 2) (ADAMS Accession No. ML080280275) related to
the Relocation of Surveillance Frequencies to Licensee Control--RITSTF
Initiative 5b and was described in the Notice of Availability published
in the Federal Register on [Date] ([xx FR xxxxx]).
The proposed changes are consistent with NRC-approved Industry/
Technical Specification Task Force (TSTF) Traveler, TSTF-425, Rev. 2,
``Relocate Surveillance Frequencies to Licensee Control--RITSTF
Initiative 5b.'' The proposed change relocates surveillance frequencies
to a licensee-controlled program, the Surveillance Frequency Control
Program (SFCP). This change is applicable to licensees using
probabilistic risk guidelines contained in NRC-approved NEI 04-10,
``Risk-Informed Technical Specifications Initiative 5b, Risk-Informed
Method for Control of Surveillance Frequencies,'' (ADAMS Accession No.
071360456).
Basis for proposed no significant hazards consideration
determination: As required by 10 CFR 50.91(a), the [LICENSEE] analysis
of the issue of no significant hazards consideration is presented
below:
1. Does the proposed change involve a significant increase in
the probability or consequences of any accident previously
evaluated?
Response: No.
The proposed change relocates the specified frequencies for
periodic surveillance requirements to licensee control under a new
Surveillance Frequency Control Program. Surveillance frequencies are
not an initiator to any accident previously evaluated. As a result,
the probability of any accident previously evaluated is not
significantly increased. The systems and components required by the
technical specifications for which the surveillance frequencies are
relocated are still required to be operable, meet the acceptance
criteria for the surveillance requirements, and be capable of
performing any mitigation function assumed in the accident analysis.
As a result, the consequences of any accident previously evaluated
are not significantly increased.
Therefore, the proposed change does not involve a significant
increase in the probability or consequences of an accident
previously evaluated.
2. Does the proposed change create the possibility of a new or
different kind of accident from any previously evaluated?
Response: No.
No new or different accidents result from utilizing the proposed
change. The changes do not involve a physical alteration of the
plant (i.e., no new or different type of equipment will be
installed) or a change in the methods governing normal plant
operation. In addition, the changes do not impose any new or
different requirements. The changes do not alter assumptions made in
the safety analysis. The proposed changes are consistent with the
safety analysis assumptions and current plant operating practice.
Therefore, the proposed changes do not create the possibility of
a new or different kind of accident from any accident previously
evaluated.
3. Does the proposed change involve a significant reduction in
the margin of safety?
Response: No.
The design, operation, testing methods, and acceptance criteria
for systems, structures, and components (SSCs), specified in
applicable codes and standards (or alternatives approved for use by
the NRC) will continue to be met as described in the plant licensing
basis (including the final safety analysis report and bases to TS),
since these are not affected by changes to the surveillance
frequencies. Similarly, there is no impact to safety analysis
acceptance criteria as described in the plant licensing basis. To
evaluate a change in the relocated surveillance frequency,
[LICENSEE] performed a probabilistic risk evaluation using the
guidance contained in NRC approved NEI 04-10, Rev. 1. NEI 04-10,
Rev. 1 methodology provides reasonable acceptance guidelines and
methods for evaluating the risk increase of proposed changes to
surveillance frequencies consistent with Regulatory Guide 1.177.
Therefore, the proposed changes do 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 does not
involve a significant hazards consideration as set forth in 10 CFR
50.92(c), Issuance of Amendment,'' and therefore, [LICENSEE] finding of
``no significant hazards consideration'' is justified.
Proposed Safety Evaluation
U.S. Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
Technical Specification Task Force (TSTF) Change TSTF-425
Relocate Surveillance Frequencies to Licensee Control
1.0 Introduction
By letter dated [--------, 20----], [LICENSEE] (the licensee)
proposed changes to the technical specifications (TS) for [PLANT NAME].
The requested change is the adoption of NRC-approved TSTF-425, Revision
2, ``Relocate Surveillance Frequencies to Licensee Control--RITSTF
Initiative 5b'' (Reference 1). When implemented, TSTF-425, Revision 2
(Rev. 2) relocates most periodic frequencies of technical
specifications (TS) surveillances to a licensee controlled program, the
[[Page 74205]]
Surveillance Frequency Control Program (SFCP), and provides
requirements for the new program in the administrative controls section
of TS. All surveillance frequencies can be relocated except:
Frequencies that reference other approved programs for the
specific interval (such as the Inservice Testing Program or the Primary
Containment Leakage Rate Testing Program),
Frequencies that are purely event driven (e.g., ``Each
time the control rod is withdrawn to the `full out' position'').
Frequencies that are event-driven but have a time
component for performing the surveillance on a one-time basis once the
event occurs (e.g., ``within 24 hours after thermal power reaching
[gteqt] 95% RTP'')
Frequencies that are related to specific conditions (e.g.,
battery degradation, age, and capacity) or conditions for the
performance of a surveillance requirement (e.g., ``drywell to
suppression chamber differential pressure decrease'').
The definition of ``Staggered Test Basis'' in TS Section 1.1,
``Definitions,'' is placed in brackets. Plants that adopt TSTF-425,
Rev. 2, and no longer use this defined term in the technical
specifications may remove it from Section 1.1. A new Administrative
Controls Program is added to TS section 5 as [Specification 5.5.15
(NUREG-1433 and -1434) or Specification 5.5.18 (NUREG-1430, 1431, and
1432)]. The new program is called the Surveillance Frequency Control
Program (SFCP) and describes the requirements for the program to
control changes to the relocated surveillance frequencies. The TS Bases
for each affected surveillance is revised to state that the frequency
is set in accordance with the Surveillance Frequency Control Program.
Various editorial changes may be made to the Bases as needed to
facilitate the addition of the Bases changes. Some surveillance Bases
do not contain a discussion of the frequency. In these cases, Bases
describing the current frequency were added to maintain consistency
with the Bases for similar surveillances. These instances are noted in
the markup along with the source of the text. The proposed changes to
the administrative controls of TS to incorporate the SFCP includes a
specific reference to NEI 04-10, ``Risk-Informed Technical
Specifications Initiative 5B, Risk-Informed Method for Control of
Surveillance Frequencies,'' Revision 1 (Rev. 1), (Reference 2) as the
basis for making any changes to the surveillance frequencies once they
are relocated out of TS.
In a letter dated September 19, 2007, the NRC staff approved
Nuclear Energy Institute (NEI) Topical Report (TR) 04-10, Rev. 1,
``Risk-Informed Technical Specification initiative 5B, Risk Informed
Method for Control of Surveillance Frequencies'' (ADAMS Accession No.
072570267), as acceptable for referencing in licensing actions to the
extent specified and under the limitations delineated in NEI 04-10,
Rev. 1, and the final acceptance SE providing the basis for NRC
acceptance of NEI 04-10, Rev 1.
2.0 Regulatory Evaluation
In the ``Final Policy Statement: Technical Specifications for
Nuclear Power Plants'' published in the Federal Register (FR) (58 FR
39132, 7/22/93) the NRC addressed the use of Probabilistic Safety
Analysis (PSA, currently referred to as Probabilistic Risk Analysis or
PRA) in STS. In this 1993 FR publication, the NRC states, in part,
``The Commission believes that it would be inappropriate at this time
to allow requirements which meet one or more of the first three
criteria [of 10 CFR 50.36] to be deleted from technical specifications
based solely on PSA (Criterion 4). However, if the results of PSA
indicate that technical specifications can be relaxed or removed, a
deterministic review will be performed.'' Additionally, the NRC states
in this publication, ``The Commission Policy in this regard is
consistent with its Policy Statement on `Safety Goals for the operation
of Nuclear Power Plants,' 51 FR 30028, published on August 21, 1986.
The Policy Statement on Safety Goals states in part, * * *
probabilistic results should also be reasonably balanced and supported
through use of deterministic arguments. In this way, judgments can be
made * * * about the degree of confidence to be given these
[probabilistic] estimates and assumptions. This is a key part of the
process for determining the degree of regulatory conservatism that may
be warranted for particular decisions. This `defense-in-depth' approach
is expected to continue to ensure the protection of public health and
safety.'' The NRC further states in the 1993 publication, ``The
Commission will continue to use PSA, consistent with its policy on
Safety Goals, as a tool in evaluating specific line-item improvements
to Technical Specifications, new requirements, and industry proposals
for risk-based Technical Specification changes.''
Approximately two years later the NRC provided additional detail
concerning the use of PRA in the ``Final Policy Statement: Use of
Probabilistic Risk Assessment in Nuclear Regulatory Activities''
published in the Federal Register (FR) (60 FR 42622, August 16, 1995)
the NRC addressed the use of Probabilistic Risk Assessment. In this FR
publication, the NRC'S opening statement states, in-part, ``The
Commission believes that an overall policy on the use of PRA methods in
nuclear regulatory activities should be established so that the many
potential applications of PRA can be implemented in a consistent and
predictable manner that would promote regulatory stability and
efficiency. In addition, the Commission believes that the use of PRA
technology in NRC regulatory activities should be increased to the
extent supported by the state-of-the-art in PRA methods and data and in
a manner that complements the NRC's deterministic approach.''
The following excerpts are taken, in part, from the 1995 Commission
Policy Statement: ``PRA addresses a broad spectrum of initiating events
by assessing the event frequency. Mitigating system reliability is then
assessed, including the potential for multiple and common-cause
failures. The treatment, therefore, goes beyond the single failure
requirements in the deterministic approach. The probabilistic approach
to regulation is, therefore, considered an extension and enhancement of
traditional regulation by considering risk in a more coherent and
complete manner.
``Therefore, the Commission believes that an overall policy on the
use of PRA in nuclear regulatory activities should be established so
that the many potential applications of PRA can be implemented in a
consistent and predictable manner that promotes regulatory stability
and efficiency. This policy statement sets forth the Commission's
intention to encourage the use of PRA and to expand the scope of PRA
applications in all nuclear regulatory matters to the extent supported
by the state-of-the-art in terms of methods and data.
`Therefore, the Commission adopts the following policy statement
regarding the expanded NRC use of PRA:
(1) The use of PRA technology should be increased in all regulatory
matters to the extent supported by the state-of-the-art in PRA methods
and data and in a manner that complements the NRC's deterministic
approach and supports the NRC's traditional defense-in-depth
philosophy.
(2) PRA and associated analyses (e.g., sensitivity studies,
uncertainty analyses, and importance measures) should be used in
regulatory matters, where practical within the bounds of the state-
[[Page 74206]]
of-the-art, to reduce unnecessary conservatism associated with current
regulatory requirements, regulatory guides, license commitments, and
staff practices. Where appropriate, PRA should be used to support the
proposal for additional regulatory requirements in accordance with 10
CFR 50.109 (Backfit Rule). Appropriate procedures for including PRA in
the process should be developed and followed. It is, of course,
understood that the intent of this policy is that existing rules and
regulations shall be complied with unless these rules and regulations
are revised.
(3) PRA evaluations in support of regulatory decisions should be as
realistic as practicable and appropriate supporting data should be
publicly available for review.
(4) The Commission's safety goals for nuclear power plants and
subsidiary numerical objectives are to be used with appropriate
consideration of uncertainties in making regulatory judgments on the
need for proposing and backfitting new generic requirements on nuclear
power plant licensees.''
In 10 CFR 50.36, the NRC 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;
(3) surveillance requirements; (4) design features; and (5)
administrative controls. As stated in 10 CFR 50.36(c)(3),
``Surveillance requirements are requirements relating to test,
calibration, or inspection to assure that the necessary quality of
systems and components is maintained, that facility operation will be
within safety limits, and that the limiting conditions for operation
will be met.'' The surveillance requirements are required by 10 CFR
50.36(c)(3) to reside in TS and will remain in TS. The new TS SFCP will
provide the necessary surveillance frequency programmatic controls and
is located in the TS Administrative Controls Section (STS Section 5.0).
Changes to surveillance frequencies in the SFCP are made using the
methodology contained in NEI 04-10, Rev. 1, including qualitative
considerations, results of risk analyses, sensitivity studies and any
bounding analyses, and recommended monitoring of SSCs, are required to
be documented. Changes to frequencies are subject to regulatory review
and oversight of the SFCP implementation through the rigorous NRC
review of safety related SSC performance provided by the reactor
oversight program (ROP).
[LICENSEE] SFCP ensures that surveillance requirements specified in
the TS are performed at intervals sufficient to assure the above
regulatory requirements are met. Existing regulatory requirements, such
as 10 CFR 50.65, ``Requirements for Monitoring the Effectiveness of
Maintenance at Nuclear Power Plants'' and 10 CFR 50 Appendix B
(corrective action program), require licensee monitoring of
surveillance test failures and implementing corrective actions to
address such failures. One of these actions may be to consider
increasing the frequency at which a surveillance test is performed. In
addition, the SFCP implementation guidance in NEI 04-10, Rev. 1,
requires monitoring of the performance of structures, systems, and
components (SSCs) for which surveillance frequencies are decreased to
assure reduced testing does not adversely impact the SSCs.
This change is analogous with other NRC-approved TS changes in
which the surveillance requirements are retained in technical
specifications but the related surveillance frequencies are relocated
to licensee-controlled documents, such as surveillances performed in
accordance with the In-Service Testing Program and the Primary
Containment Leakage Rate Testing Program. Thus, this proposed change
complies with 10 CFR 50.36(c)(3) by retaining the requirements relating
to test, calibration, or inspection to assure that the necessary
quality of systems and components is maintained, that facility
operation will be within safety limits, and that the limiting
conditions for operation will be met and meets the first key safety
principle articulated in Regulatory Guide (RG) 1.177 (Reference 3) for
plant-specific, risk-informed TS changes by complying with current
regulations.
Licensees are required by TS to perform surveillance test,
calibration, or inspection on specific safety related system equipment
such as reactivity control, power distribution, electrical,
instrumentation, and others to verify system operability. Surveillance
frequencies, currently identified in TS, are based primarily upon
deterministic methods such as engineering judgment, operating
experience, and manufacturer's recommendations. The licensee's use of
NRC-approved PRA methodologies identified in NEI 04-10, Rev. 1,
provides a way to establish risk-informed Surveillance frequencies that
complements the deterministic approach and supports the NRC's
traditional defense-in-Depth philosophy.
These regulatory requirements, and the monitoring required by NEI
04-10, Rev. 1, ensure that surveillance frequencies are sufficient to
assure that the requirements of 10 CFR 50.36 are satisfied and that any
performance deficiencies will be identified and appropriate corrective
actions taken.
3.0 Technical Evaluation
[LICENSEE] adoption of TSTF-425, Rev. 2, provides for
administrative relocation of applicable surveillance frequencies, and
provides for the addition of the SFCP to the administrative controls of
TS. TSTF-425, Rev. 2, also requires the application of NEI 04-10, Rev.
1, for any changes to surveillance frequencies within the SFCP. The
licensee's application for the changes proposed in TSTF-425, Rev 2,
included documentation regarding the probabilistic risk assessment
(PRA) technical adequacy consistent with the requirements of Regulatory
Guide 1.200 (RG-1.200) (Reference 4), ``An Approach for Determining the
Technical Adequacy of Probabilistic Risk Assessment Results for Risk-
Informed Activities'', Section 4.2. In accordance with NEI 04-10, Rev.
1, probabilistic risk assessment (PRA) methods are used, in combination
with plant performance data and other considerations, to identify and
justify modifications to the surveillance frequencies of equipment at
nuclear power plants. This is in accordance with guidance provided in
RG 1.174 (Reference 5) and RG 1.177 in support of changes to
surveillance test intervals.
RG 1.177 identifies five key safety principles required for risk-
informed changes to TS. Each of these principles is addressed by the
industry methodology document, NEI 04-10, Rev. 1. Four of the five
principles, which relate to the technical aspects of the proposed
change, are discussed below in Sections 3.1 through 3.4.
3.1 The Proposed Change Is Consistent With the Defense-in-Depth
Philosophy
Consistency with the defense-in-depth philosophy is maintained if:
A reasonable balance is preserved among prevention of core
damage, prevention of containment failure, and consequence mitigation.
Over-reliance on programmatic activities to compensate for
weaknesses in plant design is avoided.
System redundancy, independence, and diversity are
preserved commensurate with the expected frequency, consequences of
challenges to the system, and uncertainties (e.g., no
[[Page 74207]]
risk outliers). Because the scope of the proposed methodology is
limited to revision of surveillance frequencies, the redundancy,
independence, and diversity of plant systems are not impacted.
Defenses against potential common cause failures are
preserved, and the potential for the introduction of new common cause
failure mechanisms is assessed.
Independence of barriers is not degraded.
Defenses against human errors are preserved.
The intent of the General Design Criteria in 10 CFR Part
50, Appendix A, is maintained.
TSTF-425, Rev. 2, requires the application of NEI 04-10, Rev. 1,
for any changes to surveillance frequencies within the SFCP. NEI 04-10,
Rev. 1, uses both the core damage frequency (CDF) and the large early
release frequency (LERF) metrics to evaluate the impact of proposed
changes to surveillance frequencies. The guidance of RG 1.174 and RG
1.177 for changes to CDF and LERF is achieved by evaluation using a
comprehensive risk analysis, which assesses the impact of proposed
changes including contributions from human errors and common cause
failures. Defense-in-depth is also included in the methodology
explicitly as a qualitative consideration outside of the risk analysis,
as is the potential impact on detection of component degradation that
could lead to increased likelihood of common cause failures. Both the
quantitative risk analysis and the qualitative considerations assure a
reasonable balance of defense-in-depth is maintained to ensure
protection of public health and safety, satisfying the second key
safety principle of RG 1.177.
3.2 The Proposed Change Maintains Sufficient Safety Margins
The engineering evaluation conducted by the licensee assessed the
impact of the proposed TS change with the principle that sufficient
safety margins are maintained. The guidelines used for making that
assessment included ensuring the proposed TS Surveillance test
frequency change is not in conflict with approved industry codes and
standards or adversely affects any assumptions or inputs to the safety
analysis, or, if such inputs are affected, justification is provided to
ensure sufficient safety margin will continue to exist.
The design, operation, testing methods, and acceptance criteria for
SSCs, specified in applicable codes and standards (or alternatives
approved for use by the NRC) will continue to be met as described in
the plant licensing basis (including the Final Safety Analysis Report
and bases to TS), since these are not affected by changes to the
surveillance frequencies. Similarly, there is no impact to safety
analysis acceptance criteria as described in the plant licensing basis.
Thus, safety margins are maintained by the proposed methodology,
and the third key safety principle of RG 1.177 is satisfied.
3.3 When Proposed Changes Result in an Increase in Core Damage
Frequency or Risk, the Increases Should Be Small and Consistent With
the Intent of the Commission's Safety Goal Policy Statement
RG 1.177 provides a framework for risk evaluation of proposed
changes to surveillance frequencies, which requires identification of
the risk contribution from impacted surveillances, determination of the
risk impact from the change to the proposed surveillance frequency, and
performance of sensitivity and uncertainty evaluations. TSTF-425, Rev.
2, requires application of NEI 04-10, Rev. 1, in the SFCP. NEI 04-10,
Rev. 1, satisfies the intent of RG 1.177 requirements for evaluation of
the change in risk, and for assuring that such changes are small by
providing the technical methodology to support risk informed technical
specifications for control of surveillance frequencies.
3.4.1 Quality of the PRA
The quality of the [LICENSEE] PRA is compatible with the safety
implications of the proposed TS change and the role the PRA plays in
justifying the change. That is, the more the potential change in risk
or the greater the uncertainty in that risk from the requested TS
change, or both, the more rigor that must go into ensuring the quality
of the PRA.
[LICENSEE] used RG 1.200 to address the plant PRA technical
adequacy. RG 1.200 is NRC developed regulatory guidance, which
addresses the use of the American Society of Mechanical Engineers
(ASME) RA-Sb-2005, Addenda to ASME RA-S-2002 Standard for Probabilistic
Risk Assessment for Nuclear Power Plant Applications (Reference 6), and
the NEI peer review process NEI 00-02, PRA Peer Review Process Guidance
(Reference 7). The licensee has performed an assessment of the PRA
models used to support the SFCP against the requirements of RG 1.200 to
assure that the PRA models are capable of determining the change in
risk due to changes to surveillance frequencies of SSCs, using plant
specific data and models. Capability category II of ASME RA-Sb-2005 is
applied as the standard, and any identified deficiencies to those
requirements are assessed further in sensitivity studies to determine
any impacts to proposed decreases to surveillance frequencies. This
level of PRA quality, combined with the proposed sensitivity studies,
is sufficient to support the evaluation of changes proposed to
surveillance frequencies within the SFCP, and is consistent with
regulatory position 2.3.1 of RG 1.177.
3.4.2 Scope of the PRA
[LICENSEE] is required to evaluate each proposed change to a
relocated surveillance frequency using the guidance contained in NEI
04-10, Rev. 1, to determine its potential impact on risk, due to
impacts from internal events, fires, seismic, other external events,
and from shutdown conditions. Consideration is made of both CDF and
LERF metrics. In cases where a PRA of sufficient scope or where
quantitative risk models were unavailable, [LICENSEE] uses bounding
analyses, or other conservative quantitative evaluations. A qualitative
screening analysis may be used when the surveillance frequency impact
on plant risk is shown to be negligible or zero. The licensee's
evaluation methodology is sufficient to ensure the scope of the risk
contribution of each surveillance frequency change is properly
identified for evaluation, and is consistent with regulatory position
2.3.2 of RG 1.177.
3.4.3 PRA Modeling
The [LICENSEE] determines whether the SSCs affected by a proposed
change to a surveillance frequency are modeled in the PRA. Where the
SSC is directly or implicitly modeled, a quantitative evaluation of the
risk impact may be carried out. The methodology adjusts the failure
probability of the impacted SSCs, including any impacted common cause
failure modes, based on the proposed change to the surveillance
frequency. Where the SSC is not modeled in the PRA, bounding analyses
are performed to characterize the impact of the proposed change to
surveillance frequency. Potential impacts on the risk analyses due to
screening criteria and truncation levels are addressed by the
requirements for PRA technical adequacy consistent with guidance
contained in RG 1.200, and by sensitivity studies identified in NEI 04-
10, Rev. 1.
The licensee performs quantitative evaluations of the impact of
selected testing strategy (i.e., staggered testing or sequential
testing) consistent with the
[[Page 74208]]
guidance of NUREG/CR-6141 and NUREG/CR-5497, as discussed in NEI 04-10
Rev. 1.
Thus, through the application of NEI 04-10, Rev. 1, the [LICENSEE]
PRA modeling is sufficient to ensure an acceptable evaluation of risk
for the proposed changes in surveillance frequency, and is consistent
with regulatory position 2.3.3 of RG 1.177.
3.4.4 Assumptions for Time Related Failure Contributions
The failure probabilities of SSCs modeled in the [LICENSEE] PRA
[include] a standby time-related contribution and a cyclic demand-
related contribution. NEI 04-10, Rev. 1, criteria adjust the time-
related failure contribution of SSCs affected by the proposed change to
surveillance frequency. This is consistent with RG 1.177 Section 2.3.3
which permits separation of the failure rate contributions into demand
and standby for evaluation of surveillance requirements. If the
available data do not support distinguishing between the time-related
failures and demand failures, then the change to surveillance frequency
is conservatively assumed to impact the total failure probability of
the SSC, including both standby and demand contributions. The SSC
failure rate (per unit time) is assumed to be unaffected by the change
in test frequency, and will be confirmed by the required monitoring and
feedback implemented after the change in surveillance frequency is
implemented. The process requires consideration of qualitative sources
of information with regards to potential impacts of test frequency on
SSC performance, including industry and plant-specific operating
experience, vendor recommendations, industry standards, and code-
specified test intervals. Thus the process is not reliant upon risk
analyses as the sole basis for the proposed changes.
The potential beneficial risk impacts of reduced surveillance
frequency, including reduced downtime, lesser potential for restoration
errors, reduction of potential for test caused transients, and reduced
test-caused wear of equipment, are identified qualitatively, but are
conservatively not required to be quantitatively assessed. Thus,
through the application of NEI 04-10, Rev. 1, [LICENSEE] has employed
reasonable assumptions with regard to extensions of surveillance test
intervals, and is consistent with regulatory position 2.3.4 of RG
1.177.
3.4.5 Sensitivity and Uncertainty Analyses
NEI 04-10, Rev. 1, requires sensitivity studies to assess the
impact of uncertainties from key assumptions of the PRA, uncertainty in
the failure probabilities of the affected SSCs, impact to the frequency
of initiating events, and of any identified deviations from capability
category II of ASME PRA Standard (ASME RA-Sb-2005) (Reference 4). Where
the sensitivity analyses identify a potential impact on the proposed
change, revised surveillance frequencies are considered, along with any
qualitative considerations that may bear on the results of such
sensitivity studies. Required monitoring and feedback of SSC
performance once the revised surveillance frequencies are implemented
will also be performed. Thus, through the application of NEI 04-10,
Rev. 1, [LICENSEE] has appropriately considered the possible impact of
PRA model uncertainty and sensitivity to key assumptions and model
limitations, consistent with regulatory position 2.3.5 of RG 1.177.
3.4.6 Acceptance Guidelines
[LICENSEE] quantitatively evaluates the change in total risk
(including internal and external events contributions) in terms of core
damage frequency (CDF) and large early release fraction (LERF) for both
the individual risk impact of a proposed change in surveillance
frequency and the cumulative impact from all individual changes to
surveillance frequencies. Each individual change to surveillance
frequency must show a risk impact below 1E-6 per year for change to
CDF, and below 1E-7 per year for change to LERF. These are consistent
with the limits of RG 1.174 for very small changes in risk. Where the
RG 1.174 limits are not met, the process either considers revised
surveillance frequencies which are consistent with RG 1.174, or the
process terminates without permitting the proposed changes. Where
quantitative results are unavailable to permit comparison to acceptance
guidelines, appropriate qualitative analyses are required to
demonstrate that the associated risk impact of a proposed change to
surveillance frequency is negligible or zero. Otherwise, bounding
quantitative analyses are required which demonstrate the risk impact is
at least one order of magnitude lower than the RG 1.174 acceptance
guidelines for very small changes in risk. In addition to assessing
each individual SSC surveillance frequency change, the cumulative
impact of all changes must result in a risk impact below 1E-5 per year
for change to CDF, and below 1E-6 per year for change to LERF, and the
total CDF and total LERF must be reasonably shown to be less than 1E-4
per year and 1E-5 per year, respectively. These are consistent with the
limits of RG 1.174 for acceptable changes in risk, as referenced by RG
1.177 for changes to surveillance frequencies. The staff interprets
this assessment of cumulative risk as a requirement to calculate the
change in risk from a baseline model utilizing failure probabilities
based on the surveillance frequencies prior to implementation of the
SFCP, compared to a revised model with failure probabilities based on
changed surveillance frequencies. The staff further notes that
[LICENSEE] includes a provision to exclude the contribution to
cumulative risk from individual changes to surveillance frequencies
associated with small risk increases (less than 5E-8 CDF and 5E-9 LERF)
once the baseline PRA models are updated to include the effects of the
revised surveillance frequencies.
The quantitative acceptance guidance of RG 1.174 is necessary but
not sufficient to accept decreases in surveillance frequencies. The
process also considers qualitative information to evaluate the proposed
changes to surveillance frequencies, including industry and plant-
specific operating experience, vendor recommendations, industry
standards, the results of sensitivity studies, and SSC performance data
and test history.
The final acceptability of the proposed change is based on all of
these considerations and not solely on the PRA results compared to
numerical acceptance guidelines. Post implementation performance
monitoring and feedback are also required to assure continued
reliability of the components. The licensee's application of NEI 04-10,
Rev. 1, provides reasonable acceptance guidelines and methods for
evaluating the risk increase of proposed changes to surveillance
frequencies, consistent with Regulatory Position 2.4 of RG 1.177.
Therefore, the proposed [LICENSEE] methodology satisfies the fourth key
safety principle of RG 1.177 by assuring any increase in risk is small
consistent with the intent of the Commission's Safety Goal Policy
Statement.
3.4.7 The Impact of the Proposed Change Should Be Monitored Using
Performance Measurement Strategies
[LICENSEE] adoption of TSTF-425, Rev. 2, requires application of
NEI 04-
[[Page 74209]]
10, Rev. 1, in the SFCP. NEI 04-10, Rev. 1, requires performance
monitoring of SSCs whose surveillance frequency has been revised as
part of a feedback process to assure that the change in test frequency
has not resulted in degradation of equipment performance and
operational safety. The monitoring and feedback includes consideration
of maintenance rule monitoring of equipment performance. In the event
of degradation of SSC performance, the surveillance frequency will be
reassessed in accordance with the methodology, in addition to any
corrective actions which may apply as part of the maintenance rule
requirements. The performance monitoring and feedback specified in NEI
04-10, Rev. 1, is sufficient to reasonably assure acceptable SSC
performance and is consistent with regulatory position 3.2 of RG 1.177.
Thus, the fifth key safety principle of RG 1.177 is satisfied.
3.4.8 Addition of Surveillance Frequency Control Program to TS Section
5
[LICENSEE] has included the SFCP and specific requirements into TS
Section [5.5.15 or 5.5.18], administrative controls, as follows:
This program provides controls for surveillance frequencies. The
program ensures that surveillance requirements specified in the
technical specifications are performed at intervals (frequencies)
sufficient to assure that the associated limiting conditions for
operation are met.
a. The Surveillance Frequency Control Program contains a list of
frequencies of those surveillance requirements for which the frequency
is controlled by the program.
b. Changes to the frequencies listed in the Surveillance Frequency
Control Program shall be made in accordance with NEI 04-10, ``Risk-
Informed Method for Control of Surveillance Frequencies,'' Revision 1.
c. The provisions of surveillance requirements 3.0.2 and 3.0.3 are
applicable to the frequencies established in the Surveillance Frequency
Control Program.
Summary and Conclusions
The staff has reviewed the [LICENSEE] proposed relocation of
surveillance frequencies to a licensee controlled document, and
controlling changes to surveillance frequencies in accordance with a
new program, the SFCP, identified in the administrative controls of TS.
The SFCP and TS Section [5.5.15, 5.5.18] references NEI 04-10, Rev. 1,
which provides a risk-informed methodology using plant-specific risk
insights and performance data to revise surveillance frequencies within
the SFCP. This methodology supports relocating surveillance frequencies
from TS to a licensee-controlled document, provided those frequencies
are changed in accordance with NEI 04-10, Rev. 1, as referenced in the
administrative controls of the TS.
The proposed [LICENSEE] adoption of TSTF-425, Rev. 2, and risk-
informed methodology of NEI 04-10, Rev. 1, as referenced in the
administrative controls of TS, satisfies the key principles of risk-
informed decision making applied to changes to TS as delineated in RG
1.177 and RG 1.174, in that:
The proposed change meets current regulations;
The proposed change is consistent with defense-in-depth
philosophy;
The proposed change maintains sufficient safety margins;
Increases in risk resulting from the proposed change are
small and consistent with the Commission's Safety Goal Policy
Statement; and
The impact of the proposed change is monitored with
performance measurement strategies.
10 CFR 50.36(c)(3) states ``Technical specifications will include
items in the following categories: Surveillance Requirements.
Surveillance Requirements are requirements relating to test,
calibration, or inspection to assure that the necessary quality of
systems and components is maintained, that facility operation will be
within safety limits, and that the limiting conditions for operation
will be met.'' The NRC staff finds that with the proposed relocation of
surveillance frequencies to an owner-controlled document and
administratively controlled in accordance with the TS SFCP, [LICENSEE]
continues to meet the regulatory requirement of 10 CFR 50.36, and
specifically, 10 CFR 50.36(c)(3), surveillance requirements.
The NRC 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 NRC'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.
4.0 State Consultation
In accordance with the NRC'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[s] change[s] 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 or 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 NRC has previously issued a
proposed finding that the amendment involves no significant hazards
consideration and there has been no public comment on such finding
published [DATE] ([] 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 References
1. TSTF-425, Revision 2, ``Relocate Surveillance Frequencies to
Licensee Control--RITSTF Initiative 5b,'' January 17, 2008 (ADAMS
Accession Number: ML080280275).
2. NEI 04-10, ``Risk-Informed Technical Specifications Initiative
5B, Risk-Informed Method for Control of Surveillance Frequencies,''
April 2007 (ADAMS Accession Number: ML071360456).
3. Regulatory Guide 1.177, ``An Approach for Plant-Specific, Risk-
Informed Decision-making: Technical Specifications,'' August 1998
(ADAMS Accession Number: ML003740176).
4. Regulatory Guide 1.200, Rev. 1 ``An Approach for Determining the
Technical Adequacy of Probabilistic Risk Assessment Results for
Risk-Informed Activities,'' Revision 1, January 2007 (ADAMS
Accession Number: ML070240001).
5. Regulatory Guide 1.174, ``An Approach for Using Probabilistic
Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes
to the Licensing Basis,'' NRC, August 1998 (ADAMS Accession Number:
ML003740133).
6. ASME PRA Standard ASME RA-Sb-2005, Addenda to ASME RA-S-2002,
``Standard for Probabilistic Risk Assessment for Nuclear Power Plant
Application.''
7. NEI 00-02, Rev. 1 ``Probabilistic Risk Assessment (PRA) Peer
Review Process Guidance, Rev. 1, May 2006 (ADAMS
[[Page 74210]]
Accession Number: ML061510621).
[FR Doc. E8-28850 Filed 12-4-08; 8:45 am]
BILLING CODE 7590-01-P