Notice of Availability of Model Application Concerning Technical Specification Improvement To Revise Containment Isolation Valve Completion Times (TSTF-498, Revision 1, for Babcock & Wilcox Plants), 1252-1262 [E9-345]

Agencies

• NUCLEAR REGULATORY COMMISSION

[Federal Register Volume 74, Number 7 (Monday, January 12, 2009)]
[Notices]
[Pages 1252-1262]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-345]


=======================================================================
-----------------------------------------------------------------------

NUCLEAR REGULATORY COMMISSION

[NRC-2008-0065]


Notice of Availability of Model Application Concerning Technical 
Specification Improvement To Revise Containment Isolation Valve 
Completion Times (TSTF-498, Revision 1, for Babcock & Wilcox Plants)

AGENCY: Nuclear Regulatory Commission.

ACTION: Notice of Availability.

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

SUMMARY: Notice is hereby given that the staff of the Nuclear 
Regulatory Commission (NRC) has prepared a model safety evaluation (SE) 
relating to the modification of technical specification (TS) 3.6.3, 
Containment Isolation Valves associated with implementation of BAW-
2461-A, ``Risk-Informed Justification for Containment Isolation Valve 
Allowed Outage Time Change.'' The NRC staff has also prepared a model 
license amendment request and a model no-significant-hazards 
consideration (NSHC) determination relating to this matter. The purpose 
of these models is to permit the NRC to efficiently process amendments 
that propose to modify TS Completion Times (CTs) for CIVs. Licensees of 
nuclear power reactors to which the models apply can then request 
amendments after confirming

[[Page 1253]]

the applicability of the SE and NSHC determination to their reactors. 
Licensees of nuclear power reactors to which the model applies may 
request amendments using the model application.

DATES: The NRC staff issued a Federal Register (FR) notice (73 FR 6529-
6537; February 4, 2008), which provided an opportunity for comment on a 
model SE, model application, and model NSHC determination relating to 
the CT extension for TS actions related to inoperable CIVs at Babcock & 
Wilcox (B&W) plants. Similarly, the NRC staff herein provides a revised 
model SE, revised model LAR, and model NSHC determination incorporating 
changes based on the public comments received. The NRC staff can most 
efficiently consider applications based on the model LAR, which 
references the model SE, if the LAR is submitted within one year of 
this Federal Register notice.

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 involves the modification of TS Containment Isolation 
Valve Completion Times. This change was proposed for incorporation into 
the standard technical specifications by the Owners Groups participants 
in the Technical Specification Task Force (TSTF) and is designated 
TSTF-498.

    Note: This notice was published in the NRC's Federal Register 
(Vol. 73 FR 6529-6537, dated 02/04/2008) as ``Notice of Opportunity 
to Comment'' stating that the subject TSTF is available for adoption 
using the NRC's Consolidated Line Item Improvement Process (CLIIP). 
The NRC has determined that this TSTF does not qualify for the CLIIP 
process.

    Those licensees opting to apply for the subject change to TSs are 
responsible for reviewing the staff's evaluation, referencing the 
applicable technical justifications, and providing any necessary plant-
specific information. Each amendment application made in response to 
the notice of availability will be processed and noticed in accordance 
with applicable rules and NRC procedures. Note that containment 
isolation valve (CIV) configurations and extended completion times 
(CTs) not specifically evaluated by TR BAW-2461, or non-bounding risk 
parameter values outside the scope of the TR, will require NRC staff's 
review and licensee development of the specific penetrations and 
related justifications for the proposed CTs.
    TSTF-498 can be viewed on the NRC's Web page at: https://
www.nrc.gov/reactors/operating/licensing/techspecs.html.

Applicability

    The staff is requesting that the methodologies for assessing large 
early release frequency (LERF) and incremental conditional large early 
release probability (ICLERP) are to be documented in the plant-specific 
application as a regulatory commitment (i.e., included in the 
licensee's commitment tracking system in accordance with NEI 99-04, 
Revision 0, ``Guidelines for Managing NRC Commitment Changes'') 
(Reference 5) in the licensees' plant-specific applications referencing 
TR BAW-2461-A. The staff is requesting this regulatory commitment 
because a licensee's implementation of Regulatory Guide (RG) 1.177 Tier 
3 guidelines generally implies the assessment of risk with respect to 
core damage frequency (CDF). However, the proposed containment 
isolation valve (CIV) completion time (CT) impacts containment 
isolation and consequently LERF and ICLERP, as well as CDF. Because the 
extended CIV CTs are also based on the LERF and ICLERP metrics, the 
management of risk in accordance with 10 CFR 50.65(a)(4) for these 
extended CIV CTs must also assess LERF and ICLERP.

Public Notices

    The staff issued a Federal Register notice (73 FR 6529-6537, 
February 4, 2008) that requested public comment on the NRC's pending 
action to revise the TS completion times for selected CIVs at B&W 
plants as proposed in TSTF-498, Revision 1. TSTF-498, Revision 1, may 
be examined, and/or copied for a fee, at the NRC's Public Document 
Room, located at One White Flint North, 11555 Rockville Pike (first 
floor), Rockville, Maryland. Publicly available records are accessible 
electronically from the ADAMS Public Library component on the NRC Web 
site (the Electronic Reading Room) at https://www.nrc.gov/reading-rm/
adams.html.
    In response to the notice soliciting comments from interested 
members of the public about the proposed changes to TS regarding CIV 
completion times, the staff received one set of comments (from the TSTF 
Owners Groups, representing licensees). The specific comments are 
provided and discussed below. Note that some of the public comments 
pertain to the NRC's CLIIP process. As stated previously, the NRC has 
determined that the subject TSTF does not qualify for the CLIIP 
process.
    1. Comment: Model SE, Section 2.0, ``Regulatory Evaluation,'' 
second paragraph, of the proposed Safety Evaluation states, 
``Therefore, the NRC staff must be able to conclude that there is 
reasonable assurance that the safety functions affected by the proposed 
TS CT changes will be performed in accordance with the design basis 
accidents (DBAs) identified in Chapter 15 of the licensee's final 
safety analysis report (FSAR).'' The TSTF disagrees with the technical 
accuracy of this statement. The Technical Specification Limiting 
Conditions for Operation (LCOs) are based on providing ``reasonable 
assurance that the safety functions * * * will be performed in 
accordance with the design basis accidents (DBAs) identified in Chapter 
15 of the licensee's final safety analysis report (FSAR).'' When an LCO 
is not met, the Required Actions are required to be followed within the 
specified Completion Times. By definition, when an LCO is not met, the 
safety functions cannot be performed as identified in Chapter 15 of the 
FSAR. We recommend that the sentence be deleted. This sentence is 
unnecessary as it only expands on a previous statement that there must 
be reasonable protection of public health and safety during the 
proposed Completion Times.
    Response: The NRC agrees with the comment and the referenced 
sentence has been deleted. Additionally, wording has been added which 
describes the function of CTs.
    2. Comment: Section 3.2 of the Model Application, ``Verification 
and Commitments,'' first paragraph, of the model application states, 
``[LICENSEE] verifies the applicability of TSTF-498, Revision 1, to 
[PLANT], and commits to adopting the requirements specified in BAW-
2461-A which includes the following Limitations and Conditions 
specified in Section 4.1, Staff Findings and Conditions and 
Limitations, of the NRC's Safety Evaluation for BAW-2461 
(ML072330227).'' The section then repeats the eleven conditions in the 
NRC's Safety Evaluation for BAW-2461.
    This approach is inconsistent with previous CLIIP model 
applications and other license amendments that are based on the 
technical justification provided in a Topical Report. Licensees do not 
typically repeat, verbatim, conditions on NRC approval of a Topical 
Report in a license amendment request. Furthermore, the proposed text 
adds no value as it states the conditions without addressing how the 
conditions are

[[Page 1254]]

satisfied by the license amendment request.
    The TSTF recommends that the quoted sentence, above, be revised to 
delete the word ``following'' in the phrase ``the following Limitations 
and Conditions,'' and that the listing of the eleven conditions be 
removed from the model application.
    We recommend that the discussion of the eleven conditions in the 
model Safety Evaluation be expanded to include a discussion of how each 
Limitation and Condition is addressed.
     For those Limitations and Conditions that require 
verification of the applicability of information in the Topical Report 
and the Safety Evaluation (i.e., Conditions 1, 2, 3, 4, 5, 7, 9, 10, 
11), the revised sentence provides the necessary affirmative statement.
     For those Limitations and Conditions addressed by the 
Technical Specification provisions in TSTF-498 (i.e., Condition 4, 
bullets 1 and 3, Condition 6), the model Safety Evaluation should 
discuss how the Condition is satisfied by the proposed Technical 
Specification requirements.
     For those Limitations and Conditions that state that the 
licensee must discuss a topic in their submittal (i.e., Conditions 5, 
8), either an affirmative statement should be added to the model 
application confirming that the Limitation and Condition is met or 
guidance should be provided on what information must be included. Note 
that Limitation and
    Condition 5 is addressed below by a proposed commitment.
    Particular attention should be paid to ensuring that the model 
application, when used as the basis for a plant-specific license 
amendment request, can be processed by the NRC under the CLIIP.
    Response: The NRC agrees with the comment that the current wording 
which repeats the Limitations and Conditions from the staff's Safety 
Evaluation for Topical Report BAW-2461-A does not address how the 
conditions are satisfied. The model application has been revised to 
require a specific verification by the licensee that each of the 11 
Limitations and Conditions have been met. This change ensures that each 
licensee adopting TSTF-498 has met all the Limitations and Conditions 
without relying exclusively on cross-referencing another document. 
Additionally, Limitation and Condition 3, as specified in 
section 3.2, Verification and Commitments, of the Model Application has 
been revised such that the specific details describing what must be 
submitted in the application regarding external events, fire risk and 
seismic evaluations has been deleted. This was necessary to maintain 
consistency with the staff's resolution of comments on the draft safety 
evaluation for TR BAW-2461 by the Pressurized Water Reactor Owners 
Group (PWROG) (ADAMS ML072330227). Furthermore, the word ``following'' 
has been deleted from the phrase ``the following Limitations and 
Conditions,'' since it is no longer required.
    3. Comment: Section 4, ``Environmental Evaluation,'' of the model 
application states that the NRC staff's environmental evaluation is 
applicable and is submitted as an attachment to the application. 
Submitting a copy of the NRC staff's environmental evaluation as an 
attachment to the license amendment request is inconsistent with 
previous CLIIP items and serves no purpose since the amendment request 
has already stated that the environmental evaluation is applicable.
    The TSTF recommends that Section 4 be revised to be consistent with 
earlier CLIIP model applications, similar to, ``[LICENSEE] has reviewed 
the environmental evaluation included in the safety evaluation (SE) 
published on [DATE]([ ] FR [ ]) as part of the CLIIP Notice of 
Availability. [LICENSEE] has concluded that the staff's findings 
presented in that evaluation are applicable to [PLANT, NO.] and the 
evaluation is hereby incorporated by reference for this application.
    Response: The NRC disagrees with the comment and the model 
application has been revised to clearly state that the Environmental 
Evaluation must be attached to the amendment request to satisfy the 
requirements of 10 CFR 50.91(a). Additionally, section 3.1, No 
Significant Hazards Determination (NSHD), has been revised to state 
that the NSHD must be attached to the amendment request to meet the 
requirements of 10 CFR 50.91(a).
    4. Comment: Attachment 4, ``List of Regulatory Commitments,'' 
contains an example table with no commitments listed. This is 
inconsistent with other CLIIP model applications, which list any needed 
commitments. By not specifying whether any commitments are needed or 
what those commitments might be, the NRC is making it unlikely that any 
application submitted following the model application can be processed 
by the NRC under the CLIIP. The TSTF identified the following 
commitments that are appropriate to include in the model application. 
This is consistent with previous CLIIP model applications for risk 
informed Completion Times and with the proposed Safety Evaluation.
     [LICENSEE] commits to implement Bases consistent with the 
Bases provided in TSTF-498 under the Technical Specification Bases 
Control Program with a Due Date concurrent with the implementation of a 
license amendment based on TSTF-498.
     [LICENSEE] commits to implementing a methodology for 
assessing the effect on large early release frequency (LERF) and 
incremental conditional large early release probability (ICLERP) when 
utilizing the extended CIV CTs in the program for managing risk in 
accordance with 10 CFR 50.65(a)(4) with a Due Date concurrent with the 
implementation of a license amendment based on TSTF-498.
     [LICENSEE] commits to the guidance of NUMARC 93-01, 
Revision 2, section 11, which provides guidance and details on the 
assessment and management of risk during maintenance as an ongoing 
commitment.
    Response: The NRC agrees with the comment with the exception of the 
first commitment concerning bases implementation. The bases are 
required to be submitted per the 10 CFR 50.36(a) criteria. The 10 CFR 
50.36(a) states that a summary statement of the bases or reasons for 
such specifications, other than those covering administrative controls, 
shall also be included in the application, but shall not become part of 
the technical specifications. After the NRC approves the Technical 
Specifications, the licensee can revise bases under its Bases Control 
Program or/and 10 CFR 50.59 process. The remaining suggested 
commitments have been added to the model application. Additionally, as 
stated before, this is not a CLIIP model application.
    Additional changes to the proposed Safety Evaluation:
     Editorial changes have been made to correct spelling and 
grammar errors.
     Wording has been removed from the Applicability statement 
related to the requirement for licensees to submit Technical 
Specification Bases along with the application. This statement was 
unnecessary since 10 CFR 50.36(a) requires the application for a 
Technical Specification change to include Technical Specification 
Bases.
     Per the Commission's Final Policy Statement on Technical 
Specifications Improvements for Nuclear Power Reactors (58 FR 39132-
39134, July 22, 1993), the Commission expects improved Bases to 
accompany requests for improved Technical specifications. Safety 
Evaluation section 3.0, Technical Evaluation, has been revised to 
clarify

[[Page 1255]]

that the TS Bases are not part of the Technical Specifications but must 
be submitted as required by 10 CFR 50.36(a).
     Wording has been added to the Summary that states the 
changes are consistent with the staff's Safety Evaluation for BAW-2461-
A and are therefore acceptable.

    Dated at Rockville, Maryland, this 5th day of January 2009.

    For the Nuclear Regulatory Commission.
Robert B. 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 CONTAINMENT ISOLATION VALVE ALLOWED OUTAGE TIME 
CHANGE. LICENSEES REMAIN RESPONSIBLE FOR ENSURING THAT THEIR ACTUAL 
APPLICATION FULFILLS THEIR ADMINISTRATIVE REQUIREMENTS AS WELL AS 
NUCLEAR REGULATORY COMMISSION REGULATIONS.

U.S. Nuclear Regulatory Commission
Document Control Desk
Washington, DC 20555

SUBJECT:
    PLANT NAME
    DOCKET NO. 50-
    APPLICATION FOR TECHNICAL SPECIFICATION CHANGE REGARDING RISK-
INFORMED JUSTIFICATION FOR CONTAINMENT ISOLATION VALVE ALLOWED 
OUTAGE TIME CHANGE

    Dear Sir/Madam: In accordance with the provisions of 10 CFR 
50.90 [LICENSEE] is submitting a request for an amendment to the 
technical specifications (TS) for [PLANT NAME, UNIT NOS.].
    The proposed amendment would modify TS requirements for 
containment isolation valve (CIV) allowed outage time changes with 
implementation of BAW-2461-A, ``Risk-Informed Justification for 
Containment Isolation Valve Allowed Outage Time Change.''
    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. Attachment 6 provides No Significant 
Hazards Consideration Determination. Attachment 7 provides 
Environmental Evaluation.
    [LICENSEE] requests approval of the proposed License Amendment 
by [DATE], with the amendment being implemented [BY DATE OR WITHIN X 
DAYS].
    In accordance with 10 CFR 50.91, a copy of this application, 
with attachments, is being provided to the designated [STATE] 
Official.
    I declare [or certify, verify, state] under penalty of perjury 
that the foregoing is true and correct.
    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
    6. No Significant Hazards Consideration Determination
    7. Environmental Evaluation

cc: NRC Regional Office
    NRC Resident Inspector

ATTACHMENT 1--Description and Assessment

1.0 DESCRIPTION

    The proposed amendment would modify TS requirements for 
containment isolation valve allowed outage times associated with 
implementation of BAW-2461-A, ``Risk-Informed Justification for 
Containment Isolation Valve Allowed Outage Time Change.''
    The changes are consistent with Nuclear Regulatory Commission 
(NRC) approved Industry/Technical Specification Task Force (TSTF) 
STS change TSTF-498, Revision 1, (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, as well as 
the supporting information provided to support TSTF-498, Revision 1. 
[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 for 
the incorporation of the changes to the [PLANT NAME, UNIT NOS.] TS.

2.2 Optional Changes and Variations

    [LICENSEE] is not proposing any variations or deviations from 
the TS changes described in TSTF-498, Revision 1, 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 [DATE]([ ] FR [ ]). [LICENSEE] has concluded that the 
proposed NSHCD presented in the Federal Register notice is 
applicable to [PLANT NAME, UNIT NOS.] and is provided as an 
attachment to this amendment request which satisfies the 
requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments

    As discussed in the notice of availability published in the 
Federal Register on [DATE] for this TS improvement, [LICENSEE] 
verifies the applicability of TSTF-498, Revision 1, to [PLANT NAME, 
UNIT NOS.], and commits to adopting the requirements specified in 
BAW-2461-A. Additionally, [LICENSEE] verifies that each of the 
Limitations and Conditions specified in Section 4.1, Staff Findings 
and Conditions and Limitations, of the NRC's Safety Evaluation for 
BAW-2461 (ML072330227) as noted below for items (1) through (11), 
also apply.
    (1) Based on TR BAW-2461, the CIV methodology, PRA parameters, 
configurations, and data used to evaluate an extended CIV CT to 168 
hours is limited to the following plants:
     Davis-Besse
     Oconee Units 1, 2, and 3
     Crystal River 3
Other licensees of B&W designed PWRs requesting to use the TR 
methodology must provide the same level of information provided by 
these demonstration plants to ensure that TR BAW-2461 is applicable 
to their plant.
    [LICENSEE] confirms that the information provided supports the 
applicability of TR BAW-2461 to be used to evaluate an extended CIV 
CT to 168 hours.
    (2) Because not all penetrations have the same impact on 
[Delta]CDF, [Delta]LERF, ICCDP, or ICLERP, verify the applicability 
of TR BAW-2461 to the specific plant, including verification that: 
(a) The CIV configurations for the specific plant match the 
configurations in TR BAW-2461, and (b) the risk-parameter values 
used in TR BAW-2461, including the sensitivity studies contained in 
the RAIs, are representative or bounding for the specific plant. Any 
additional CIV configurations, CT extensions, or non-bounding risk 
parameter values not evaluated by TR BAW-2461 should be addressed in 
the plant-specific analyses. [Note that CIV configurations and 
extended CTs not specifically evaluated by TR BAW-2461, or non-
bounding risk parameter values outside the scope of the TR, will 
require NRC staff review and licensee development of the specific 
penetrations and related justifications for the proposed 
CTs].[LICENSEE] confirms that TR BAW-2461 is applicable to [PLANT 
NAME, UNIT NOS.]. This confirmation includes verification that: (a) 
The CIV configurations for [PLANT NAME, UNIT NOS.] match the 
configurations in TR BAW-2461, and (b) the risk-parameter values 
used in TR BAW-2461, including the sensitivity studies contained in 
the RAIs, are representative or bounding for [PLANT NAME, UNIT 
NOS.].
    [[LICENSEE] has provided additional information to support 
additional CIV configurations, CT extensions, or non-bounding risk 
parameter values not evaluated by TR BAW-2461].

[[Page 1256]]

    (3) Each licensee adopting TR BAW-2461 will need to confirm that 
the plant-specific risk assessment including both internal and 
external events is within the assumptions of TR BAW-2461 and the 
acceptance guidelines of RG 1.174 and 1.177. The licensee's 
application verifies that external event risk, including seismic, 
fires, floods, and high winds, either through quantitative or 
qualitative evaluation, is shown to not have an adverse impact on 
the conclusions of the plant-specific analysis for extending the CIV 
CTs.
    [LICENSEE] confirms that the plant-specific risk assessment, 
both internal and external events, is within the assumptions of TR 
BAW-2461 and the acceptance guidelines of RG 1.174 and 1.177. 
Additionally, [LICENSEE] verifies that external event risk, 
including seismic, fires, floods, and high winds, either through 
quantitative or qualitative evaluation, is shown to not have an 
adverse impact on the conclusions of the plant-specific analysis for 
extending the CIV CTs.
    (4) For licensees adopting TR BAW-2461, confirmation should be 
provided that the Tier 2 and Tier 3 conclusions of the TR are 
applicable to the licensee's plant and that plant-specific Tier 2 
evaluations including CCF and risk-significant configurations 
including interfacing-system LOCA have been evaluated and included 
under Tier 2 and Tier 3 including the CRMP as applicable.
     The proposed 168-hour CIV CT will not be applied to 
CIVs in penetrations connected to the RCS that have two NC CIVs if 
there are no other valves between the RCS and the environment (i.e., 
low pressure piping, or opening) that may be used for backup 
isolation and cannot be confirmed closed. In that case, the operable 
CIV will be verified closed within the original 4-hour CT, thus 
satisfying the TS Required Action. See Section 3.3.4 of the staff's 
SE for BAW-2461. The specific penetrations where this is applicable 
or where interfacing-system LOCA is shown to be risk-significant (as 
determined by the plant-specific risk-informed process including 
plant-specific LOCA analysis) will be identified on a plant-specific 
basis prior to implementation of the proposed TS change. They will 
be listed explicitly in the proposed TS revision and the current CT 
will be retained. TR BAW-2461 stated that an interfacing-system LOCA 
is assumed to lead to core damage and large early release, the 
effectiveness of mitigation systems besides containment isolation is 
not considered significant. All failed open penetration flow paths 
with an RCS connection were assumed to have CDF and LERF 
contributions in TR BAW-2461. Licensees incorporating TR BAW-2461 
will need to confirm the above assumption for their plant specific 
implementation of BAW-2461.
     The specific penetrations with CCF potential will be 
identified by the licensee on a plant-specific basis. Upon entry 
into TS LCO 3.6.3, Condition A, the utility will confirm that the 
redundant similarly-designed CIV has not been affected by the same 
failure mode as the inoperable CIV. This verification will be 
performed before entering into the extended portion of the CT (i.e., 
within 4 hours). The specific penetrations with CCF potential will 
be identified on a plant-specific basis and listed in a plant-
specific TS document or other administrative source. See Section 
3.4.1.2 of the staff's SE for BAW-2461.
     No action or maintenance activity is performed that 
will remove equipment that is functionally redundant to the 
inoperable CIV, including the redundant CIV(s) on the same 
penetration and support systems for the redundant CIV. See Section 
3.3 of TR BAW-2461.
     No action or maintenance activity is performed that 
will significantly increase the likelihood of challenge to the CIVs. 
Challenges to the CIVs include DBAs that result in a release of 
radioactive material within containment (LOCA, main steam line 
break, and rod ejection accident). Also included is the removal of 
equipment from service that may cause a significant increase in the 
likelihood of core damage while in the proposed CT, which may 
increase the large early release via the inoperable CIV. See Section 
3.4 of TR BAW-2461.
     No action or maintenance activity is performed that 
will remove equipment that supports success paths credited in the CT 
risk evaluation. This includes the other series valves, if any, 
credited in the risk assessment for RCS penetrations that otherwise 
would be risk-significant (i.e., interfacing-system LOCA). See 
Section 3.4 of TR BAW-2461.
    [LICENSEE] confirms that the Tier 2 and Tier 3 conclusions of 
the TR are applicable to [PLANT NAME, UNIT NOS.] and that plant-
specific Tier 2 evaluations including CCF and risk-significant 
configurations including interfacing-system LOCA have been evaluated 
and included under Tier 2 and Tier 3 including the CRMP as 
applicable. Additionally, [LICENSEE] confirms that processes or 
procedures are in place to ensure the above items are met.
    (5) TR BAW-2461 was based on generic-plant characteristics. Each 
licensee adopting TR BAW-2461 must confirm plant-specific Tier 3 
information in their individual submittals. The licensee must 
discuss conformance to the requirements of the maintenance rule (10 
CFR 50.65(a)(4)), as they relate to the proposed CIV CTs and the 
guidance contained in NUMARC 93.01, Section 11, as endorsed by RG 
1.182, including verification that the licensee's maintenance rule 
program, with respect to CIVs, includes a LERF/ICLERP assessment 
(i.e., CRMP). See Section 3.4.3 of the staff's SE for BAW-2461. 
[LICENSEE] has confirmed that the plant-specific Tier 3 information 
for [PLANT NAME, UNIT NOS.] is consistent with the generic plant 
characteristics used in TR BAW-2461. Also, [LICENSEE] has confirmed 
that [PLANT NAME, UNIT NOS.] conforms to the requirements of the 
maintenance rule (10 CFR 50.65(a)(4)), as they relate to the 
proposed CIV CTs and the guidance contained in NUMARC 93-01, Section 
11, as endorsed by RG 1.182, including verification that the 
maintenance rule program, with respect to CIVs, includes a LERF and 
ICLERP assessment as part of the maintenance rule process.
    (6) TS LCO 3.6.3, Note 2, allows separate condition entry for 
each penetration flow path. Therefore, each licensee adopting TR 
BAW-2461 will address the simultaneous LCO entry of an inoperable 
CIV in separate penetration flow paths such that the proposed 168-
hour CIV CT LCO will be limited to no more than one CIV at any given 
time. In addition, the licensee must confirm that its Tier 3 CRMP 
addresses simultaneous inoperable CIV LCOs (i.e., separate condition 
entry) such that the cumulative CIV risk, including LERF, are 
maintained consistent with the assumptions and conclusions of TR 
BAW-2461. See Section 3.4.1.2 of the staff's SE for BAW-2461.
    [LICENSEE] confirms that the Technical Specification Required 
Actions as proposed by adoption of TSTF-498 provides a requirement 
to isolate all but one penetration flow path within 4 hours if there 
are two or more penetration flow paths with one CIV inoperable.
    (7) The licensee shall verify that the plant-specific PRA 
quality is acceptable with respect to its use for Tier 3 for this 
application in accordance with the guidelines given in RG 1.174 and 
as discussed in Section 3.4.1.1 of the staff's SE for BAW-2461.
    [LICENSEE] confirms that [PLANT NAME, UNIT NOS.] PRA quality is 
acceptable with respect to its use for Tier 3 in accordance with the 
guidelines given in RG 1.174. Additionally, [LICENSEE] confirms 
additional information on PRA quality with respect to Tier 3 
identified in Section 3.4.1.1 of the staff's SE for BAW-2461 has 
been provided.
    (8) With respect to past plant-specific license amendments or 
additional plant-specific applications for a TS change under NRC 
review that have not been incorporated into the baseline PRA used to 
evaluate the proposed change, the cumulative risk must be evaluated 
on a plant-specific basis consistent with the guidance given in RG 
1.174, Section 2.2.6 and 3.3.2, and addressed in a licensee's plant-
specific application. See Section 3.4.1.5 of the staff's SE for BAW-
2461.
    [LICENSEE] confirms that the cumulative risk has been evaluated 
for [PLANT NAME, UNIT NOS.] in accordance with guidance in RG 1.174, 
Section 2.2.6 and 3.3.2, with respect to past [PLANT NAME, UNIT 
NOS.] license amendments or additional [PLANT NAME, UNIT NOS.] 
applications for a TS change under NRC review that have not been 
incorporated into the baseline PRA used to evaluate the proposed 
change. This evaluation is provided in this application.
    (9) Closed systems inside and outside containment, which are 
considered to be containment isolation barriers, must meet the 
provisions outlined in NUREG-0800, Section 6.2.4, (Containment 
Isolation System. (See Section 2.2 of the staff's SE for BAW-2461.
    [LICENSEE] verifies that all closed systems inside and outside 
containment, which are considered to be containment isolation 
barriers, meet the provisions of NUREG-0800, Section 6.2.4, 
``Containment Isolation System.''
    (10) With an extended CIV CT, the possibility exists that the 
CIV unavailability will be impacted. Depending on the penetration 
risk significance and the

[[Page 1257]]

frequency and length of time of the CIV CT, the unavailability of 
the containment isolation function may also be impacted. Therefore, 
licensee's adopting TR BAW-2461 will need to establish an 
Implementation and monitoring program for CIVs, including 
performance criteria, on a plant-specific basis. See Sections 
3.4.1.2 and 3.4.4 of the staff's SE for BAW-2461.
    [LICENSEE] confirms that [PLANT NAME, UNIT NOS.] has established 
performance criteria and tracks maintenance unavailability in 
accordance with the maintenance rule program, 10 CFR 50.65.
    (11) The PWROG did not specifically address [Delta]CDF and 
[Delta]LERF in TR BAW-2461 regarding the acceptance guidelines of RG 
1.174. The PWROG stated that it is not expecting that online CIV 
preventive maintenance will increase with the proposed 168-hour CIV. 
To address this, licensee's adopting TR BAW-2461 will need to 
assess, on a plant-specific basis, the [Delta]CDF and [Delta]LERF 
acceptance guidance of RG 1.174 including the expected frequency of 
entering the proposed CT and the expected mean CT for CIV 
maintenance. See Section 3.4.1.2 of the staff's SE for BAW-2461.
    [LICENSEE] has assessed the [Delta]CDF and [Delta]LERF 
acceptance guidance for [PLANT NAME, UNIT NOS.] in accordance with 
RG 1.174 and provided information pertaining to the expected 
frequency of entering the proposed CT and the expected mean CT for 
CIV maintenance. This assessment and information is provided in this 
application.

4.0 ENVIRONMENTAL EVALUATION

    [LICENSEE] has reviewed the environmental evaluation included in 
the model safety evaluation dated [DATE]. [LICENSEE] has concluded 
that the proposed determination presented in the notice is 
applicable to [PLANT NAME, UNIT NOS.] and the determination is 
provided as an attachment to this amendment request to satisfy the 
requirements of 10 CFR 50.91(a).

ATTACHMENT 2--PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

ATTACHMENT 3--PROPOSED TECHNICAL SPECIFICATION PAGES

ATTACHMENT 4--LIST OF REGULATORY COMMITMENTS

    The following table identifies those actions committed to by 
[LICENSEE] in this document. Any other statements in this submittal 
are provided for information purposes and are not considered to be 
regulatory commitments. Please direct questions regarding these 
commitments to [CONTACT NAME].

----------------------------------------------------------------------------------------------------------------
                   Regulatory commitments                                          Due date
----------------------------------------------------------------------------------------------------------------
[LICENSEE] commits to implementing a methodology for         Concurrently with the implementation of a license
 assessing the effect on large early release frequency        amendment based on TSTF-498.
 (LERF) and incremental conditional large early release
 probability (ICLERP) when utilizing the extended CIV CTs
 in the program for managing risk in accordance with 10 CFR
 50.65(a)(4).
[LICENSEE] commits to the guidance of NUMARC 93-01,          Ongoing commitment.
 ``Industry Guideline for monitoring the effectiveness of
 maintenance at nuclear power plants,'' Revision 2, Section
 11, which provides guidance and details on the assessment
 and management of risk during maintenance.
----------------------------------------------------------------------------------------------------------------

ATTACHMENT 5--PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES

ATTACHMENT 6--NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

ATTACHMENT 7--ENVIRONMENTAL EVALUATION

Proposed No Significant Hazards Consideration Determination

    Description of Amendment Request: [PLANT NAME, UNIT NOS.] requests 
adoption of an approved change to the standard technical specifications 
(STS) for Babcock and Wilcox (B&W) Plants (NUREG-1430) and plant 
specific technical specifications (TS), to allow modification of 
containment isolation valve completion times associated with 
implementation of BAW-2461-A, ``Risk-Informed Justification for 
Containment Isolation Valve Allowed Outage Time Change,'' dated October 
2007. The changes are consistent with NRC approved Industry/Technical 
Specification Task Force (TSTF) STS Traveler, TSTF-498, Revision 1, 
``Risk-Informed Containment Isolation Valve Completion Times (BAW-
2461).'' The proposed change extends the Completion Times for 
containment penetration flow paths with one containment isolation valve 
inoperable from 4 hours up to 7 days for Babcock & Wilcox (B&W) NSSS 
plants. This change is applicable to containment penetrations with one 
or more containment isolation valves in which one containment isolation 
valve is inoperable [for reasons other than purge valve [shield 
building bypass] leakage not within limit]. The extended Completion 
Time is not applicable to containment isolation valves in the main 
steam lines or those identified by plant-specific analysis as having 
high risk significance for interfacing systems loss of coolant 
accidents (ISLOCAs) and the existing 4 hour Completion Time applies.
    Basis for proposed no significant hazards consideration 
determination: As required by 10 CFR 50.91(a), an analysis of the issue 
of no significant hazards consideration is presented below:
    1. Does the Proposed Change Involve a Significant Increase in the 
Probability or Consequences of an Accident Previously Evaluated?
    Response: No.
    The proposed changes revise the Completion Times for restoring an 
inoperable containment isolation valve (or isolating the affected 
penetration) within the scope of Topical Report BAW-2461-A, ``Risk-
Informed Justification for Containment Isolation Valve Allowed Outage 
Time Change.'' The Completion Times are extended from 4 hours up to 7 
days. Containment isolation valves are not accident initiators in any 
accident previously evaluated. Consequently, the probability of an 
accident previously evaluated is not significantly increased. 
Containment isolation valves control the extent of leakage from the 
containment following an accident. As such, containment isolation 
valves are instrumental in controlling the consequences of an accident. 
However, the consequences of any accident previously evaluated are no 
different during the proposed extended Completion Times than during the 
existing Completion Times. As a result, the consequences of any 
accident previously evaluated are not significantly increased. 
Therefore, the proposed changes do 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 Accident Previously Evaluated?
    Response: No.
    The proposed changes revise the Completion Times for restoring an 
inoperable containment isolation valve (or isolating the affected 
penetration) within the scope of Topical Report BAW-2461-A, ``Risk-
Informed Justification for Containment Isolation Valve Allowed Outage 
Time Change.'' The proposed changes do not change the design, 
configuration, or method of operation of the plant. The proposed 
changes do not involve a physical alteration of the plant (no new or 
different kind of equipment will be installed). Therefore, the proposed 
changes do not create the possibility of

[[Page 1258]]

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 proposed changes revise the Completion Times for restoring an 
inoperable containment isolation valve (or isolating the affected 
penetration) within the scope of Topical Report BAW-2461-A, ``Risk-
Informed Justification for Containment Isolation Valve Allowed Outage 
Time Change.'' In order to evaluate the proposed Completion Time 
extensions, a probabilistic risk evaluation was performed as documented 
in Topical Report BAW-2461-A. The risk evaluation concluded that the 
proposed increase in the Completion Times does not result in an 
unacceptable incremental conditional core damage probability or 
incremental conditional large early release probability according to 
the guidelines of 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).

Model Safety Evaluation

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Technical Specification Task Force (TSTF) Change TSTF-498, Revision 1, 
Modification of Technical Specification Containment Isolation Valve 
Completion Times

1.0 Introduction

    By letter dated December 20, 2006, (Reference 1) the Technical 
Specifications Task Force (TSTF), a joint owners group activity, 
submitted TSTF-498, ``Risk-Informed Containment Isolation Valve 
Completion Times (BAW-2461),'' Revision 0, for NRC review. By letter 
dated October 10, 2007 (Reference 2) the TSTF submitted Revision 1 to 
TSTF-498 based on responses to Requests for Additional Information 
(RAI) that resulted in not adopting certain provisions provided by BAW-
2461-A, ``Risk-Informed Justification for Containment Isolation Valve 
Allowed Outage Time Change'' (Reference 3). TSTF-498 is proposing to 
change NUREG 1430, ``Standard Technical Specifications Babcock and 
Wilcox Plants,'' (BAW STS) Revision 3.0 (Reference 4), to generically 
implement containment isolation valve completion time (CT) changes 
associated with implementation of BAW-2461-A.
    BAW-2461-A and TSTF-498 support extending CTs for CIVs in a 
penetration flow path with two [or more] containment isolation valves 
from 4 hours to 168 hours (7 days). The proposed change revises the TS 
for B&W Plants, NUREG-1430, Revision 3, Limiting Condition for 
Operation (LCO), Section 3.6.3, ``Containment Isolation Valves,'' 
Condition A from 4 hours to 7 days. Additionally, a new Required Action 
is added (Required Action A.1) which requires verification that the 
Operable containment isolation valve in the penetration is not 
inoperable due to common cause failure and also results in Required 
Actions A.1 and A.2 being relabeled as A.2 and A.3. No change is 
proposed by the Pressurized Water Reactor Owners Group (PWROG) for 
Condition B (relabeled Condition D) (i.e., a penetration flow path with 
two inoperable CIVs). A new Condition, Condition B, is added which is 
similar to the existing Condition A. It contains a 4 hour Completion 
Time to isolate the affected flow path and is only applicable to the 
containment isolation valves excluded from Condition A (e.g., 
containment isolation valves in the main steam lines or (as described 
in a Reviewer's Note) those identified by plant-specific analysis as 
having high risk significance for interfacing systems loss of coolant 
accidents (ISLOCAs). A new Condition, Condition C, is added which is 
applicable when two or more penetrations have one inoperable 
containment isolation valve. This Condition requires isolating all but 
one of the affected penetrations within 4 hours (the existing 
Completion Time for Condition A). This condition limits the 7 day 
Completion Time in Condition A to a single penetration. The extended 
Completion Time is not applicable to containment isolation valves in 
the main steam lines or those identified by plant-specific analysis as 
having high risk significance for ISLOCAs and the existing 4 hour 
Completion Time applies. BAW-2461-A is only applicable to Davis Besse, 
Oconee Nuclear Station Units 1, 2, and 3, and Crystal River Unit 3. 
Other licensees of B&W designed PWRs requesting to use the Topical 
Report (TR) methodology must provide the same level of information 
provided by these demonstration plants to ensure that TR BAW-2461-A is 
applicable to their plant. TSTF-498 will provide standardized wording 
in the B&W STS for plants implementing the changes specified in BAW-
2461-A related to extending AOTs for applicable inoperable CIVs from 4 
hours to 168 hours.

2.0 Regulatory Evaluation

    In 10 CFR 50.36, the Commission established its regulatory 
requirements related to the content of TS. Pursuant to 10 CFR 50.36, TS 
are required to include items in the following five specific categories 
related to station operation: (1) Safety limits, limiting safety system 
settings, and limiting control settings; (2) limiting conditions for 
operation (LCOs); (3) surveillance requirements (SRs); (4) design 
features; and (5) administrative controls. However, the regulation does 
not specify the particular TSs to be included in a plant's license. 
TSTF-498 is proposing changes to the TSs that involve category 2 above. 
The LCOs are the lowest functional capability, or performance levels, 
of equipment required for safe operation of the facility. When an LCO 
of a nuclear reactor is not met, the licensee shall shut down the 
reactor, or follow any remedial actions permitted by the TS until the 
condition can be met.
    Furthermore, the CTs specified in the TSs must be based on 
reasonable protection of the public health and safety. As set forth in 
10 CFR 50.36, a licensee's TS must establish the LCOs that are the 
lowest functional capability or performance levels of equipment 
required for safe operation of the facility. This requirement includes 
CTs for structures, systems, and components (SSCs), such as CIVs. These 
CTs allow a certain amount of time to correct the condition for not 
meeting the LCO until the reactor must be brought to a condition which 
exits the mode of applicability, in most cases resulting in the reactor 
being shutdown.
    The Maintenance Rule, 10 CFR 50.65, ``Requirements for monitoring 
the effectiveness of maintenance at nuclear power plants,'' requires 
licensees to monitor the performance, or condition, of SSCs against 
licensee-established goals in a manner sufficient to provide reasonable 
assurance that SSCs are capable of fulfilling their intended functions. 
The implementation and monitoring program guidance of Regulatory Guide 
(RG) 1.174, Section 2.3, and RG 1.177, Section 3, states that 
monitoring performed in conformance with the Maintenance Rule can be 
used when such monitoring is sufficient for the SSCs affected by the 
risk-informed application.
    In addition, 10 CFR 50.65(a)(4), as it relates to the proposed CIV 
CT extension, requires the assessment and management of the increase in 
risk that

[[Page 1259]]

may result from the proposed maintenance activity.
    Appendix A of 10 CFR Part 50, GDC-54, ``Piping systems penetrating 
containment,'' requires those piping systems that penetrate primary 
containment be provided with leak detection, isolation, and containment 
capabilities having redundancy, reliability, and performance 
capabilities that reflect the importance to safety of isolating these 
piping systems.
    Appendix A of 10 CFR Part 50, GDC-55, ``Reactor coolant pressure 
boundary penetrating containment,'' requires that each line that is 
part of the reactor coolant pressure boundary and that penetrates the 
primary containment shall be provided with CIVs.
    Appendix A of 10 CFR Part 50, GDC-56, ``Primary containment 
isolation,'' requires that each line that connects directly to the 
containment atmosphere and penetrates the primary reactor containment 
shall be provided with CIVs.
    The CIVs help ensure that adequate primary containment boundaries 
are maintained during and after accidents by minimizing potential 
pathways to the environment and help ensure that the primary 
containment function assumed in the safety analysis is maintained.

2.1 Proposed Change

    TSTF-498 would make the following changes to the B&W STS contained 
in NUREG-1430 associated with TS 3.6.3 Containment Isolation Valves 
(CIVs):
     The proposed change adds a Reviewer's Note prior to 
Condition A which states ``The Condition A Note should list the 
specific penetrations (if any) identified by the plant specific risk 
analysis as having high risk significance for an interfacing systems 
loss of coolant accident (ISLOCA).''
     The proposed change revises the Condition A NOTE to add 
``except containment isolation valves in the main steam lines and [ 
].''
     The proposed change adds the new Required Action A.1, 
``Determine the OPERABLE containment isolation valve in the affected 
penetration is not inoperable due to common cause failure'' with a 
Completion Time of 4 hours. This new Required Action is connected by an 
AND statement to the other applicable Required Actions.
     The proposed change revises the previous Required Action 
A.1 to be A.2 with the completion time changed from 4 hours to 7 days.
     The proposed change revises the previous Required Action 
A.2 to be A.3.
     The proposed change adds a new Condition B for one or more 
penetration flow paths with one containment isolation valve inoperable 
[for reasons other than purge valve leakage not within limit] with a 
NOTE stating (Only applicable to penetration flow paths with two [or 
more] containment isolation valves in the main steam lines and [ ]. 
(There is also a Reviewers NOTE similar to Condition A.
     The proposed change provides new Required Action B.1 to 
isolate the affected penetration flow path with a completion time of 4 
hours AND Required Action B.2 to verify the affected penetration flow 
path is isolated once per 31 days for isolation devices outside 
containment and Prior to entering Mode 4 from Mode 5 if not performed 
within the previous 92 days for isolation devices inside containment. 
Furthermore, new Required Action B.2 has two notes which state (1) 
Isolation devices in high radiation areas may be verified by use of 
administrative means and (2) Isolation devices that are locked, sealed, 
or otherwise secured may be verified by use of administrative means.
     The proposed change adds a new Condition C for two or more 
penetration flow paths with one containment isolation valve inoperable 
[for reasons other than Condition[s] [E and F]] with a NOTE stating 
``Only applicable to penetration flow paths with two [or more] 
containment isolation valves.
     The proposed change provides new Required Action C.1 to 
isolate all but one of the affected penetration flow paths by use of at 
least one closed and de-activated automatic valve, closed manual valve, 
or blind flange with a completion time of 4 hours.
     The proposed change revises the previous Condition B and 
Required Action B.1 to be new Condition D and Required Action D.1.
     The proposed change revises the previous Condition C and 
Required Action C.1 and C.2 to be new Condition E and Required Action 
E.1 and E.2.
     The proposed change revises the previous Condition D and 
Required Action D.1, D.2 and D.3 to be new Condition F and Required 
Action F.1, F.2 and F.3.
     The proposed change revises the previous reference to 
Required Action D.1 for performance of SR 3.6.3.6 within Required 
Action D.3 to Required Action F.1.
     The proposed change revises the previous Condition E and 
Required Action E.1 and E.2 to be new Condition G and Required Action 
G.1 and G.2.
    TSTF-498 includes changes to the B&W STS Bases B 3.6.3 contained in 
NUREG-1430.
     Condition A has been modified by a Note indicating this 
Condition is only applicable to those penetration flow paths with two 
[or more] containment isolation valves. The Note also states that the 
Condition is not applicable to containment isolation valves in the main 
steam lines and [any specific penetrations identified by the plant-
specific risk analysis as having high risk significance for an ISLOCA]. 
The previous discussion about the Note has been deleted. Additionally, 
a new Required Action A.1 has been added to determine that the OPERABLE 
containment isolation valve in the affected penetration is not 
inoperable due to a common cause failure with a completion time of 4 
hours. The other Condition A Required Actions have been re-numbered and 
Required Action A.2 Completion Time has been changed from 4 hours to 7 
days.
     The bases has been revised to update Required Action A.2 
from 4 hours to 7 days based on an analysis of plant risk and the 
discussion on considering the time required to isolate the penetration 
and the relative importance of supporting containment OPERABILITY has 
been deleted.
     A new Condition B has been added with a Note indicating 
this Condition is only applicable to those penetration flow paths with 
two [or more] containment isolation valves that are containment 
isolation valves in the main steam lines or are [any specific 
penetrations identified by the plant-specific risk analysis as having 
high risk significance for an interfacing systems loss of coolant 
accident (ISLOCA)]. Condition B is entered if one containment isolation 
valve in one or more penetration flow paths is inoperable, [except for 
purge valve leakage not within limit]. The Bases describes Required 
Actions B.1 and B.2 Completion Times and Notes as specified in the TS 
section.
     A new Condition C as been added with a Note indicating 
this Condition is only applicable to penetration flow paths with two 
[or more] containment isolation valves. Condition C is entered if two 
or more penetration flow paths with one containment isolation valve 
inoperable [for reasons other than Condition[s] E [and F]]. The Bases 
describes the Required Action C.1 Completion Time to isolate all but 
one of the affected containment isolation valves within 4 hours.
     The bases discussion for Required Action D.1 has been 
updated to account for new Conditions B and C and have been added where 
applicable.
     Condition B and Required Action B.1 has been re-numbered 
to Condition D and Required Action D.1.

[[Page 1260]]

     Condition C and Required Action C.1 and C.2 have been re-
numbered to Condition E and Required Action E.1 and E.2.
     Reference to BAW-2461-A has been added as Reference 6. 
Previous references 6, 7, and 8 have been re-numbered to references 7, 
8, and 9. Applicable changes have been made throughout the Bases.
     Condition D and Required Action D.1, D.2 and D.3 have been 
re-numbered to Condition F and Required Action F.1, F.2 and F.3.
     Condition E and Required Action E.1 and E.2 have been re-
numbered to Condition G and Required Action G.1 and G.2.

3.0 Technical Evaluation

    As stated previously, BAW-2461-A describes a method to revise the 
Completion Time for specific Conditions per Technical Specification 
3.6.3, Containment Isolation Valves. The NRC approved BAW-2461 on 
August 29, 2007, for referencing in license applications to the extent 
specified and under the limitations and conditions stated in the 
topical report and Section 4.1 of the staff's safety evaluation 
(Reference 6). TSTF-498 is proposing changes to the B&W STS, NUREG 
1430, which are in accordance with Topical Report BAW-2461-A and 
subject to the Limitations, Conditions and Regulatory Commitments 
specified in the staff Safety Evaluation. Any differences between TR 
BAW-2461-A Technical Specification examples and TSTF-498 proposed 
Technical Specifications have been evaluated and determined to be 
acceptable. BAW-2461-A, Table 2-1, Condition A note states ``Only 
applicable to penetration flow paths with two [or more] containment 
isolation valves with the exception of containment isolation valves in 
the main steam lines [and list of specific penetrations (if any) 
identified by the plant-specific risk-informed process to have high 
risk significance for ISLOCA].'' To be consistent with the ITS format 
and content rules, the Condition A Note was written as ``Only 
applicable to penetration flow paths with two [or more] containment 
isolation valves except containment isolation valves in the main steam 
lines and [ ].'' The Condition is modified by a Reviewer's Note which 
states, ``The Condition A Note should list the specific penetrations 
(if any) identified by the plant-specific risk analysis as having high 
risk significance for an interfacing systems loss of coolant accident 
(ISLOCA).'' This change is editorial and does not affect the 
application of the TS. The change in wording meets the requirements 
specified in BAW-2461-A and is therefore acceptable.
    The July 5, 2006 Request for Additional Information (RAI) response 
to NRC Question 1 stated that the following action would be added as 
Required Action A.1 with a 4 hour Completion Time, ``Verify that the 
redundant CIV on the same penetration is operable [applicable only if 
the redundant CIV has an operator and/or body type that is not diverse 
from the inoperable CIV depending on which parts are inoperable].'' In 
TSTF-498, Required Action A.1 has a 4 hour Completion Time and states, 
``Determine the OPERABLE containment isolation valve in the affected 
penetration is not inoperable due to common cause failure.'' The 
wording was chosen to be consistent with LCO 3.8.1, Required Action 
B.3.1, regarding inoperable diesel generators. The discussion of what 
is required to be evaluated, ``applicable only if the redundant CIV has 
an operator and/or body type that is not diverse from the inoperable 
CIV depending on which parts are inoperable,'' is placed in the 
Required Action A.1 Bases. Placing the detailed description of what is 
meant by common cause failure in the Bases is consistent with the ITS 
format and content rules. This change has been evaluated as a Revision 
to BAW-2461-A. TSTF-498 wording is equivalent to the proposed wording 
submitted as RAI response 1 and is consistent with NRC's 
Safety Evaluation for BAW-2461-A and is therefore acceptable.
    B&W STS Required Action A.1 and A.2 are being revised to re-number 
these actions to A.2 and A.3. This is necessary to incorporate the new 
Required Action A.1 as described above. Additionally, the completion 
time for the new Required Action A.2 which states ``isolate the 
affected penetration flow path by use of at least one closed and de-
activated automatic valve, closed manual valve, blind flange, or check 
valve with flow through the valve secured'' is being revised from 4 
hours to 7 days. This change is consistent with NRC's Safety Evaluation 
for BAW-2461-A and is therefore acceptable.
    B&W STS is adding a new Condition B for one or more penetration 
flow paths with one containment isolation valve inoperable [for reasons 
other than purge valve leakage not within limit] with a Note specifying 
``Only applicable to penetration flow paths with two [or more] 
containment isolation valves in the main steam lines and [ ].'' There 
is also a Reviewer's Note that states ``The Condition B Note should 
list the specific penetrations (if any) identified by the plant-
specific risk analysis as having high risk significance for an 
interfacing systems loss of coolant accident (ISLOCA).'' This wording 
is consistent with the change made to Condition A and is consistent 
with the format and content rules in ITS. Additionally, the Required 
Actions and associated Completion Times are consistent with Condition A 
and the change evaluated by the staff in the NRC's Safety Evaluation 
for BAW-2461-A. New Condition B for Main Steam Line Isolation Valves 
was added to conform with the NRC's Safety Evaluation for BAW-2461-A 
since main steam line isolation valves were explicitly excluded from 
the Topical Report CT extension and is therefore acceptable.
    B&W STS Condition B and Required Action B.1 are being revised to be 
Condition D and Required Action D.1. With the addition of new 
Conditions B and C the remaining Conditions and Required Actions need 
to be re-numbered. This change is editorial and results in no technical 
change and is therefore acceptable.
    B&W STS is adding a new Condition C which is applicable when two or 
more penetrations have one inoperable containment isolation valve. This 
Condition requires isolating all but one of the affected penetrations 
within 4 hours (the existing Completion Time for Condition A). Once 
this Completion Time is satisfied and since Condition A is still 
applicable then this essentially limits the 7 day Completion Time in 
Condition A to a single penetration. This change conforms to Condition 
and Limitation 6 in the NRC's Safety Evaluation for BAW-2461-A and is 
therefore acceptable.
    B&W STS Condition C and Required Actions C.1 and C.2 are being 
revised to be Condition E and Required Action E.1 and E.2. With the 
addition of new Conditions B and C the remaining Conditions and 
Required Actions need to be re-numbered. This change is editorial and 
results in no technical change and is therefore acceptable.
    B&W STS Condition D and Required Action D.1, D.2 and D.3 are being 
revised to be Condition F and Required Action F.1, F.2 and F.3. With 
the addition of new Conditions B and C the remaining Conditions and 
Required Actions need to be re-numbered. This change is editorial and 
results in no technical change and is therefore acceptable.
    B&W STS Condition E and Required Action E.1 and E.2 are being 
revised to be Condition G and Required Action G.1 and G.2. With the 
addition of new Conditions B and C the remaining

[[Page 1261]]

Conditions and Required Actions need to be re-numbered. This change is 
editorial and results in no technical change and is therefore 
acceptable.
    The following B&W STS Bases changes are being made and shall be 
submitted as required by 10 CFR 50.36(a). In all cases, the commission 
expects improved Bases to accompany requests for improved Technical 
specifications. The Staff's approval of the amendment was based on the 
information provided by the licensee, which includes the TS Bases. The 
changes to the Bases discussed below revise the current information in 
the STS Bases to support the changes made to the Technical 
Specifications. The Bases changes continue to meet the criteria 
specified in the Final Policy Statement on ``Technical Specifications 
Improvements for Nuclear Power Reactors'' (58 FR 39132, 39139, July 22, 
1993) by providing information necessary to support the Technical 
Specifications. After incorporation of the amendment, the licensee may 
follow TS 5.5.14, Bases Control Program, should it desire to make 
additional changes to the Bases.
     B&W STS Bases for B 3.6.3 Actions A.1, A.2 and A.3 are 
being revised to describe the Note that is being added indicating the 
Condition is only applicable to those penetration flow paths with two 
[or more] containment isolation valves and that the isolation valves in 
the main steam line are not applicable along with any specific 
penetrations identified by the plant-specific risk analysis. Since the 
changes are supported by risk-informed analyses, the Final Policy 
Statement on Technical Specifications Improvements for Nuclear Power 
Reactors, is satisfied. The Policy states, ``The Commission expects 
that licensees, in preparing their Technical Specification related 
submittals, will utilize any plant-specific probabilistic safety 
assessment (PSA) or risk su