Notice of Availability of 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 3, 31996-32006 [E9-15780]

Agencies

• NUCLEAR REGULATORY COMMISSION

[Federal Register Volume 74, Number 127 (Monday, July 6, 2009)]
[Notices]
[Pages 31996-32006]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-15780]


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NUCLEAR REGULATORY COMMISSION

[NRC-2008-0637]


Notice of Availability of 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 3

AGENCY: Nuclear Regulatory Commission.

ACTION: Notice of Availability.

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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, Revision 3, 
``Relocate Surveillance Frequencies to Licensee Control--RITSTF 
Initiative 5b,'' (Agencywide Documents Access Management System (ADAMS) 
Accession No. ML090850642). The purpose of these models is to permit 
the NRC to efficiently process amendments that propose to relocate 
technical specifications (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. Previously, on December 5, 2008, drafts of the model SE, 
model NSHC determination, and model LAR were published in the Federal 
Register for public comment (73 FR 74202-74210). Based on its 
evaluation of the public comments received in response to that notice, 
the NRC staff made appropriate changes to the models, and is including 
the final versions of the models in this notice. This notice also 
contains a description of each public comment and its disposition by 
the NRC staff. Based on its evaluation of the public comments, the NRC 
staff has decided to announce the availability of the model SE and 
model NSHC determination to licensees for referencing in LARs to adopt 
TSTF-425, Rev 3. Licensees of nuclear power reactors proposing to adopt 
these changes should follow the guidance in the model LAR and confirm 
the applicability of the model SE and model NSHC determination to their 
reactors.

DATES: The NRC staff hereby announces that the attached model SE and 
model NSHC determination (which differ only slightly from the versions 
previously published) may be used in support of plant specific 
applications to adopt the relocation of TS Surveillance Requirements. 
The staff has also posted the model LAR (which also differs only 
slightly from the versions previously published) to assist licensees in 
applying for the proposed TS change. The NRC staff can most efficiently 
consider applications based upon the model application if the 
application is submitted within a year of this Federal Register Notice.

FOR FURTHER INFORMATION CONTACT: Michelle Honcharik, Mail Stop: O-12E1, 
Special Projects Branch, Division of Policy and Rulemaking, Office of 
Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, 
Washington, DC 20555-0001, telephone 301-415-1774.

SUPPLEMENTARY INFORMATION:

Background

    This notice makes available for adoption by licensees a change to 
the STS that modifies surveillance frequencies. Licensees opting to 
apply for this change are responsible for reviewing the staff's 
evaluation, providing the applicable technical justifications, and 
providing any necessary plant-specific information. The NRC will 
process each amendment application responding to the notice of 
availability according to applicable NRC rules and procedures.
    TSTF-425, Rev. 3 involves the relocation of most time-based 
surveillance frequencies to a licensee-controlled program, called the 
Surveillance Frequency Control Program (SFCP), and adds the SFCP to the 
administrative controls section of TS. The SFCP does not include 
surveillance frequencies that are event driven, controlled by an 
existing program, or are condition-based.
    Revision 3 of TSTF-425 addresses all four reactor vendor types. The 
owners groups participants proposed this change for incorporation into 
the STS. TSTF-425, Rev. 3 (ADAMS Accession No. ML090850642), can be 
viewed on the NRC's Web page at: https://www.nrc.gov/reading-rm/adams.html.

Applicability

    TSTF-425, Rev. 3, is applicable to all STS for 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, Rev. 1, by letter dated September 19, 2007 (ADAMS Accession 
No. ML072570267). Each licensee applying for the changes proposed in 
TSTF-425 will need to include documentation regarding the probabilistic 
risk assessment [PRA] technical adequacy consistent with the guidance 
in Section 4.2 of Regulatory Guide (RG) 1.200, ``An Approach for 
Determining the Technical Adequacy of Probabilistic Risk Assessment 
[PRA] 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. Sections 1.2 and 1.3 of RG 
1.200 provides guidance on the supporting information needed for new 
methods. Applicants must give supporting evidence for methods to be 
applied for assessing the risk contribution for those sources of risk 
not addressed by NRC endorsed 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. 3. 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 3.

Evaluation of Public Comments on the Model Safety Evaluation

    The NRC staff evaluated the public comments received on the model 
SE, model NSHC determination, and model LAR published in the Federal 
Register on December 5, 2008 (73 FR 74202-

[[Page 31997]]

74210). Fifteen comments were received from the pressurized and boiling 
water reactor owners groups, TSTF (ADAMS Accession No. ML090080162). 
The comments and NRC staff's disposition of each comment follows. It 
should be noted that the following comments were made to the Federal 
Register Notice for Comment which referenced TSTF-425, Revision 2 
(ADAMS Accession No. ML080280275). TSTF-425, Revision 3 was submitted 
by the TSTF by letter dated March 18, 2009 (ADAMS Accession NO. 
ML090850642) to address NRC disposition of TSTF comment number 10.
    1. (TSTF) Reference; model application (73 FR 74204). Comment: 
``The model application contains statements that are not consistent 
with a letter from a licensee to the NRC, and in many cases the model 
application is worded similar to the NRC-issued Safety Evaluation. For 
example, Section 2.1, paragraph 2, of the model application states, 
`The licensee has submitted documentation which identifies the quality 
characteristics of those models, as described in RG 1.200 (ADAMS 
Accession No. ML070240001).' We recommend that the model application be 
reviewed from the standpoint of a letter from a specific licensee to 
the NRC and modify the wording to be consistent with that task. For 
example, if Comment 2 is incorporated, the sentence above could be 
rewritten as discussed in Comment 6, below.''
    Disposition: The NRC staff accepted the comment regarding 
consistency of a letter from a licensee to the NRC and incorporated the 
recommended change into the model application, where appropriate. 
Disposition of Comment Nos. 2 and 6 are discussed below.
    2. (TSTF) Reference; model application (73 FR 74205). Comment: ``We 
recommend that the licensee's documentation of PRA adequacy be a new 
Attachment 2 and the existing attachments be renumbered. This will 
allow standardization of the model amendment and allow reference to the 
attachment number in the Safety Evaluation.''
    Disposition: The NRC staff accepted the comment and incorporated 
the recommended change into the model application as new ``Attachment 
2, Documentation of PRA Technical Adequacy.''
    3. (TSTF) Reference; model application (73 FR 74205). Comment: 
``Attachment 3 of the model application includes the revised (clean) 
Technical Specification (TS) pages. Whether licensees are requested to 
include clean typed TS pages with license amendments varies among the 
NRC Project Managers. Given the number of pages affected by this 
amendment and the straightforward nature of the changes, this 
attachment should be marked as optional, allowing the licensee and the 
NRC Project Manager to decide whether clean TS pages should be 
submitted.''
    Disposition: Essentially, the commenter objects to providing final 
requested change. When an applicant desires to amend its TS, the 
combination of Sec.  50.36 and 50.90 require submission of the new, 
clean, unmarked TS and bases. An applicant could not reasonably decline 
to submit proposed TS and bases under the claim that the proposed pages 
were not ``applicable'' to its request. Thus, an application is likely 
incomplete if it fails to contain final clean TS and bases.
    Regarding marked-up pages, applicants generally submit marked-up TS 
pages and bases. There is, however, no direct requirement for 
submission of the mark-ups. Should the Staff need the mark-ups for 
their amendment review, Sec.  50.90's requirement that an LAR ``fully 
describe[s] the changes desired'' could be used to request a mark-up 
version. No changes were made as a result of this comment.
    4. (TSTF) Reference; model application (73 FR 74205) ``Attachment 5 
of the model application includes the affected Bases pages. In the 
transmittal letter for TSTF-425, Revision 1, dated April 20, 2007, the 
TSTF stated, ``In the CLIIP model application for TSTF-425, we request 
that NRC reflect that appropriate plant-specific changes will be made 
to the Technical Specifications Bases by the licensees under the 
Technical Specification Bases Control Program and that, therefore, 
revised Bases pages need not be included. This will significantly 
reduce the size of the plant-specific license amendment requests 
submitted to adopt TSTF-425.''
    ``As further discussed in the TSTF's response to NRC's RAI 
8 (Letter from TSTF to NRC dated January 17, 2008, `Response 
to NRC Request for Additional Information Regarding TSTF-425,' Revision 
1, `Relocate Surveillance Frequencies to Licensee Control--RITSTF 
Initiative 5b,' dated October 2, 2007), licensees have the option of 
retaining the existing description of the Frequency in their Bases (as 
adoption of TSTF-425 does not alter any existing Frequencies) or of 
adopting the recommended Bases in TSTF-425. In either case, neither the 
existing Bases nor the revised Bases in TSTF-425 include any 
information material to the NRC's review. Therefore, we recommend that 
the model application be revised to not reference the inclusion of 
Bases changes. See also the related comment on the Safety Evaluation 
below.''
    Disposition: For more than 50 years, since the regulation governing 
license amendment requests, 10 CFR 50.90, has required that an 
applicant fully describes the changes desired, and also required the 
applicant to follow, as far as applicable, the form prescribed for the 
original operating license application. The NRC's regulation at 10 CFR 
50.36 continues this philosophy of requiring applications to include 
technical specifications and bases. Thus, to meet the requirements of 
10 CFR 50.90, the applicant will need to submit the applicable TSs and 
bases. An applicant who does otherwise is at risk of failing to meet 
the requirements in 10 CFR 50.90 of ``fully describing the changes 
desired, and following as far as applicable, the form prescribed for 
original applications''. No changes were made to the Federal Register 
Notice (73 FR 74202-74210) as a result of this comment.
    5. (TSTF) Reference; model application (73 FR 74204). ``Section 
2.1, `Applicability of the Published Safety Evaluation,' first 
paragraph, states, `[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).' It is not clear what information is included in `the 
supporting information provided to support TSTF-425, Rev. 2.' In order 
for licensees to provide complete and accurate information, a more 
specific description is needed.''
    Disposition: The NRC staff accepted the comment and revised Section 
2.1 to read as follows: ``[LICENSEE] has reviewed the safety evaluation 
dated [DATE]. This review included a review of the NRC evaluation, 
TSTF-425, Rev. 2, and the requirements specified in NEI 04-10, Rev. 1 
(ADAMS Accession No. ML071360456).'' The statement regarding ``The 
supporting information provided to support TSTF-425, Revision 2'' was 
replaced by ``TSTF-425, Revision 2'' since the TSTF includes 
information which explains and supports the STS changes and must be 
considered by the licensee as part of the license amendment request to 
determine if the TSTF is applicable to the licensee's facility.
    6. (TSTF) ``Section 2.1, `Applicability of the Published Safety 
Evaluation,' contains two numbered paragraphs joined by an `and' 
referring to documentation of PRA adequacy. These

[[Page 31998]]

paragraphs do not provide sufficient guidance to a licensee on what 
should be submitted. Using the change in Comment 2, we recommend that 
these paragraphs be replaced with the following, `Attachment 2 includes 
documentation with regard to PRA technical adequacy consistent with the 
requirements of Regulatory Guide 1.200, Revision 1, Section 4.2, and 
describes any PRA models without NRC-endorsed standards, including 
documentation of the quality characteristics of those models in 
accordance with Regulatory Guide 1.200.' Additional guidance, if 
available, such as preferred organization of the information, can be 
added to the model application in Attachment 2.''
    Disposition: The NRC staff accepted the comment and revised Section 
2.1, ``Applicability of the Published Safety Evaluation''. The numbered 
paragraphs (1 and 2) of Section 2.1 are replaced to state the 
following: ``Attachment 2 includes [LICENSEE] documentation with regard 
to PRA technical adequacy consistent with the requirements of 
Regulatory Guide 1.200, Revision 1 (ADAMS Accession No. ML070240001), 
Section 4.2, and describes any PRA models without NRC-endorsed 
standards, including documentation of the quality characteristics of 
those models in accordance with Regulatory Guide 1.200.''
    7. (TSTF) ``We recommend Section 2.2, ``Optional changes and 
variations,'' be replaced with, `The proposed amendment is consistent 
with the TS changes described in TSTF-425, Rev. 2, but proposes to 
modify the plant-specific Surveillances, which may include more or less 
Surveillances than those modified in TSTF-425, Rev. 2, and those plant-
specific Surveillances may have differing Surveillance numbers. The 
plant-specific changes are consistent with the NRC staff's model safety 
evaluation dated [DATE], especially the scope exclusions in Section 1.0 
of that model safety evaluation, as revised.'''
    Disposition: Deviations or variations from that described in TSTF 
are recognized and addressed in Notice of Opportunity to Comment on 
Model SE on TS Improvement to Relocate Surveillance Frequencies to 
Licensee Control--RITSTF Initiative 5b, TSTF-425, Revision 2 as 
published in the Federal Register for public comment (73 FR 74203) 
which states: ``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.'' No changes were made as a result of this comment.
    8. (TSTF) The proposed regulatory commitment in Attachment 4 to 
implement NEI 04-10, Rev. 1, should be deleted. The TS Administrative 
Controls, `Surveillance Frequency Control Program,' required to be 
adopted as part of the amendment, states, `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.'
    NRC Office Instruction LIC-105, `Managing Regulatory Commitments 
Made by Licensees to the NRC,' states, `Regulatory commitments are 
appropriate for matters in which the staff has significant interest but 
which do not warrant either legally binding requirements or inclusion 
in Updated Final Safety Analysis Reports (UFSARs) or programs subject 
to a formal regulatory change control mechanism.' As TSTF-425, Rev. 2, 
proposes to have a Technical Specification requirement to implement NEI 
04-10, Rev. 1, which is a legally binding requirement, a regulatory 
commitment to implement NEI 04-10, Rev. 1, is unnecessary.''
    Disposition: The NRC staff accepted the comment and revised the 
Model Application by deleting the reference to and the ``Attachment 4 
Regulatory Commitments.''
    9. The ``Proposed No Significant Hazards Consideration 
Determination'' Criterion 3 discussion, should be revised as shown, 
``To evaluate a change in the relocated surveillance frequency, 
[LICENSEE] will perform a probabilistic risk evaluation using the 
guidance contained in NRC approved NEI 04-10, Rev. 1.''
    Disposition: The NRC staff accepted the comment and provided 
additional clarification with reference to the SFCP. As a clarification 
of the ``Proposed No Significant Hazards Consideration'' Criterion 3 
(73 FR 74205) discussion the statement was revised as follows: ``To 
evaluate a change in the relocated surveillance frequency, [LICENSEE] 
will perform a probabilistic risk evaluation using the guidance 
contained in NRC approved NEI 04-10, Rev. 1 in accordance with the TS 
SFCP.''
    10. (TSTF) ``Section 1.0, `Introduction,' states that all 
Surveillance Frequencies can be relocated except those meeting four 
conditions. The first three conditions are a restatement of the 
conditions described in TSTF-425, Rev. 2, Section 2.0, `Proposed 
Change.' The fourth condition, `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'), does 
not appear in TSTF-425, Rev. 2, and is not consistent with the markups 
in TSTF-425, Rev. 2.''
    The TSTF's response to NRC's RAI 2 (Letter from TSTF to 
NRC dated January 17, 2008, `Response to NRC Request for Additional 
Information Regarding TSTF-425, Revision 1,' `Relocate Surveillance 
Frequencies to Licensee Control--RITSTF Initiative 5b, dated October 2, 
2007'), addressed this issue. It states, `The TSTF agrees that the 
specific conditions of battery degradation, age, and capacity are not 
within the scope of NEI 04-10. Surveillance 3.8.6.6 in NUREG-1430, -
1431, -1432, -1433, and -1434 is revised to retain the conditions of 
battery degradation, age, and capacity, while relocating the 
Frequencies consistent with the NRC-approved Limerick lead plant 
submittal. The Limerick Surveillances, 4.8.2.1.e and 4.8.2.1.f, contain 
the same requirements as ISTS Surveillance 3.8.6.6. The 60 month 
Frequency is relocated to the SFCP. The 12 month and 24 month 
Frequencies associated with degraded batteries, or batteries exceeding 
85 percent of their expected life based on available capacity are 
relocated to the SFCP, but the criteria related to battery degradation, 
age, and capacity are retained.'
    Therefore, based on this response and the NRC's approval of the 
Limerick LAR, the Surveillance Frequencies related to specific 
conditions are not excluded from the scope of TSTF-425, Rev. 2.
    Disposition: The NRC Request for Additional Information (RAI) 
Regarding TSTF-425, Revision 1, dated October 2, 2007 (ADAMS Accession 
No. ML072120630) states as follows: ``In NUREG-1433 SR 3.8.6.6, and 
NUREG-1434 SR 3.8.6.6, TSTF-425 will relocate the 12-month and 24-month 
surveillance frequencies associated with degraded batteries, or 
batteries exceeding 85 percent of their expected life based on 
available capacity. This is inconsistent with the proposed changes to 
similar SRs in NUREG-1430, NUREG-1431, and NUREG-1432, which would only 
relocate the 60-month frequency associated with non-degraded

[[Page 31999]]

batteries. The staff considers the specific conditions of battery 
degradation, age, and capacity as not within the scope of NEI 04-10. 
Provide a revision to TSTF-425 which retains, in NUREG-1433 and NUREG-
1434, the SRs for degraded or old batteries.'' As the NRC staff 
indicated in the RAI and TSTF states in their response (ADAMS Accession 
No. ML090080162), ``TSTF agrees that the specific conditions of battery 
degradation, age, and capacity are not within the scope of NEI 04-10.'' 
TSTF-425, Revision 2, requires the use of NEI 04-10, Revision 1, in 
accordance with the TS Surveillance Frequency Control Program. 
Therefore, Surveillance Frequencies related to specific conditions 
remain an exception to relocation under the SFCP. No changes were made 
as a result of this comment.
    11. (TSTF) ``Section 1.0, `Introduction,' (Federal Register page 
74205, first column) states, `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.' As 
discussed in Comment 4, licensees are not required to revise the Bases 
to adopt TSTF-425 and any voluntary Bases changes should not be 
submitted with the amendment as they contain no information material to 
the NRC's review and can be made under the Technical Specifications 
Bases Control Program. In addition, Bases changes are not within the 
scope of the NRC's review under 10 CFR 50.90 because, as stated in 10 
CFR 50.36(a), Bases are not part of the Technical Specifications. 
Therefore, the Bases changes should not be discussed in the NRC's 
Safety Evaluation.''
    Disposition: As identified by 10 CFR 50.90, Application for 
amendment of license, construction permit, or early site permit, which 
states: ``Whenever a holder of a license, including a construction 
permit and operating license under this part, and an early site permit, 
combined license, and manufacturing license under part 52 of this 
chapter, desires to amend the license or permit, application for an 
amendment must be filed with the Commission, as specified in Sec. Sec.  
50.4 or 52.3 of this chapter, as applicable, fully describing the 
changes desired, and following as far as applicable, the form 
prescribed for original applications.'' Applicants requesting a license 
amendment, such as the adoption of TSTF-425, under 10 CFR 50.90 are, 
therefore, required to submit an application that includes the affected 
TS Bases ``* * * fully describing the changes desired, and following as 
far as applicable, the form prescribed for original applications.'' 
Therefore, while the Bases are not part of the TSs, affected TS Bases 
pages are required to be submitted with an application for a licensee 
amendment request. No changes were made as a result of this comment.
    12. (TSTF) Section 3.2, ``The Proposed Change Maintains Sufficient 
Safety Margins,'' should be revised as follows: `The engineering 
evaluations that will be conducted by the licensee under the 
Surveillance Frequency Control Program when Frequencies are revised 
will assess the impact of the proposed Frequency change with the 
principle that sufficient safety margins are maintained. The guidelines 
used for making that assessment will include ensuring the proposed 
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.' This section is referring to Surveillance Frequency 
changes that will be performed by the licensee under the SFCP after 
approval of the license amendment, not to any evaluations provided with 
the license amendment request.
    Disposition: The NRC staff accepted the comment and revised the 
first paragraph of Section 3.4 to state as follows: ``The engineering 
evaluations that will be conducted by the licensee under the 
Surveillance Frequency Control Program when Frequencies are revised 
will assess the impact of the proposed Frequency change with the 
principle that sufficient safety margins are maintained. The guidelines 
used for making that assessment will include ensuring the proposed 
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.''
    13. ``Section 3.4.1, `Quality of the PRA,' references NEI 00-02, 
`PRA Peer Review Process Guidance.' While NEI 00-02 should continue to 
be referenced, NEI 05-04, Rev. 2, `Process for Performing Internal 
Events PRA Peer Reviews,' should also be referenced.''
    Disposition: Staff accepted the comment as NRC has endorsed NEI 05-
04 Rev.2, ``Process for Performing Internal Events PRA Peer Reviews,'' 
and NEI 05-04 can be referenced as an acceptable method.
    14. (TSTF) ``Section 3.4.6, `Acceptance Guidelines,' first 
paragraph, should be revised to clarify that the acceptance guidelines 
are in NEI 04-10, Rev. 1, so that it is not implied that the Safety 
Evaluation contains additional requirements. For example, the first 
sentence could be revised to state, `In accordance with NEI 04-10, Rev. 
1, [LICENSEE] will quantitatively evaluate the change in total risk 
(including internal and external events contributions) in terms of core 
damage frequency (CDF) and large early release frequency (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.'''
    Disposition: Section 3.4.6, first paragraph, is rewritten to 
clarify that the Safety Evaluation does not add additional 
requirements. The revised text states as follows: ``[LICENSEE] will 
quantitatively evaluate the change in total risk (including internal 
and external events contributions) in terms of core damage frequency 
(CDF) and large early release frequency (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 using the guidance contained in NRC approved NEI 04-10, 
Rev. 1, in accordance with the TS SFCP.''
    15. (TSTF) ``Section 6.0, `References', Item 2, should be revised 
as follows, `NEI 04-10, Rev. 1,' for consistency with the rest of the 
document.''
    Disposition: The NRC staff accepted the comment and revised Section 
6.0, ``References,'' Item 2, to state: ``NEI 04-10, Revision 1'' to 
correct the omission of the revision number.
    For each application the NRC staff will publish a notice of 
consideration of issuance of amendment to facility operating licenses, 
a proposed no

[[Page 32000]]

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 23rd day of June 2009.

    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 of License, Construction Permit, or 
Early Site Permit,'' [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 documentation of PRA technical 
adequacy. Attachment 3 provides the existing TS pages marked up to 
show the proposed change. Attachment 4 provides revised (clean) TS 
pages. Attachment 5 provides the proposed TS Bases changes. 
Attachment 6 Proposed No Significant Hazards Consideration.
    [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. Documentation of PRA Technical Adequacy
3. Proposed Technical Specification Changes
4. Revised Technical Specification Pages
5. Proposed Technical Specification Bases Changes
6. Proposed No Significant Hazards Consideration
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 3, ``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 3, (Rev. 3) (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, TSTF-425, 
Revision 3, and the requirements specified in NEI 04-10, Rev. 1, (ADAMS 
Accession No. ML071360456).
    Attachment 2 includes [Licensee] documentation with regard to PRA 
technical adequacy consistent with the requirements of Regulatory Guide 
1.200, Revision 1 (ADAMS Accession No. ML070240001), Section 4.2, and 
describes any PRA models without NRC-endorsed standards, including 
documentation of the quality characteristics of those models in 
accordance with Regulatory Guide 1.200.
    [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 
STS changes described in TSTF-425, Rev. 3, and the NRC staff's model 
safety evaluation dated [Date].
    [The proposed amendment is consistent with the STS changes 
described in TSTF-425, Revision 3, but [Licensee] proposes variations 
or deviations from TSTF-425, as identified below and may include 
differing TS Surveillance numbers].

3.0 Regulatory Analysis

3.1 No Significant Hazards Consideration
    [Licensee] has reviewed the proposed no significant hazards 
consideration determination (NSHC) published in the Federal Register 
[Date]([ ] FR [ ]). [Licensee] has concluded that the proposed NSHC 
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).

Attachment 2--Documentation of PRA Technical Adequacy

Attachment 3--Proposed Technical Specification Changes (Mark-Up)

Attachment 4--Proposed Technical Specification Pages

Attachment 5--Proposed Changes to Technical Specification Bases Pages

Attachment 6--Proposed No Significant Hazards Consideration

    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

[[Page 32001]]

described in Technical Specification Task Force (TSTF) Traveler, TSTF-
425, Revision 3 (Rev. 3) (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. 3, 
``Relocate Surveillance Frequencies to Licensee Control--RITSTF 
Initiative 5b.'' The proposed change relocates surveillance frequencies 
to a licensee-controlled program, the 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: 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] will perform a probabilistic risk evaluation using the 
guidance contained in NRC approved NEI 04-10, Rev. 1 in accordance 
with the TS SFCP. 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, licensee concludes that 
the requested change does not involve a significant hazards 
consideration as set forth in 10 CFR 50.92(c), Issuance of Amendment.

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 3, 
``Relocate Surveillance Frequencies to Licensee Control--RITSTF 
Initiative 5b'' (Reference 1). When implemented, TSTF-425, Revision 3 
(Rev. 3) relocates most periodic frequencies of technical specification 
(TS) surveillances to a licensee controlled program, the 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 
>=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 deleted. [Licensee] adopts TSTF-425, Rev. 3, and no 
longer uses this defined term in the technical specifications and 
proposes removing 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 SFCP and describes the requirements for the 
program to control changes to the relocated surveillance frequencies. 
The TS Bases for each affected surveillance are revised to state that 
the frequency is set in accordance with the Surveillance Frequency 
Control Program. [Various editorial changes have been made to the Bases 
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 
licensee changes to the administrative controls of TS to incorporate 
the SFCP include 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

[[Page 32002]]

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.''
    ``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 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 (60 FR 42622, August 16, 1995) the 
NRC addressed the use of Probabilistic Risk Assessment. In this FR 
publication, the NRC 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.''
    ``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-
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.'' These categories will remain in TS. The new TS SFCP 
provides the necessary administrative controls to require that 
surveillances relocated to the SFCP are conducted at a frequency 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. 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, and required to be 
documented. Furthermore, 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

[[Page 32003]]

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 
complement the deterministic approach and support 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. 3, 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. 3, 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. 3, 
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. The second through 
the fifth principles, which relate to the technical aspects of the 
proposed change, are discussed below in Sections 3.1 through 3.4. The 
first principle requires the proposed change to meet the current 
regulations. The staff finds that the change meets that requirement.

3.1 The Proposed Change Is Consistent With the Defense-in-Depth 
Philosophy

    Consistency with the defense-in-depth philosophy, the second key 
safety principle of RG 1.177, 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 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. 3, 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 that will be conducted by the licensee 
under the Surveillance Frequency Control Program when Frequencies are 
revised will assess the impact of the proposed Frequency change with 
the principle that sufficient safety margins are maintained. The 
guidelines used for making that assessment will include ensuring the 
proposed 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 [Updated] 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. 
3, 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

[[Page 32004]]

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), NEI 
00-02, PRA Peer Review Process guidelines (Reference 7) and NEI 05-04, 
Process for Performing Follow-On PRA Peer Reviews Using the ASME PRA 
Standard (Reference 8). 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] will determine 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 will perform quantitative evaluations of the impact of 
selected testing strategy (i.e., staggered testing or sequential 
testing) consistently with the 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 
t