[Federal Register Volume 74, Number 127 (Monday, July 6, 2009)]
[Notices]
[Pages 31996-32006]
From the Federal Register Online via the Government Publishing 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: http://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
the SSC, including both standby and demand contributions. The SSC
failure rate (per unit time) is assumed to be unaffected by the change
in test frequency, and will be confirmed by the required monitoring and
feedback implemented after the change in surveillance frequency is
implemented. The process requires consideration of qualitative sources
of information with regards to potential impacts of test frequency on
SSC performance, including industry and plant-specific operating
experience, vendor recommendations, industry standards, and code-
specified test intervals. Thus the process is not reliant upon risk
analyses as the sole basis for the proposed changes.
The potential beneficial risk impacts of reduced surveillance
frequency, including reduced downtime, lesser potential for restoration
errors, reduction of potential for test caused transients, and reduced
test-caused wear of equipment, are identified qualitatively, but are
conservatively not required to be quantitatively assessed. Thus,
through the application of NEI 04-10, Rev. 1, [Licensee] has employed
reasonable assumptions with regard to extensions of surveillance test
intervals, and is consistent with regulatory position 2.3.4 of RG
1.177.
3.4.5 Sensitivity and Uncertainty Analyses
NEI 04-10, Rev. 1, requires sensitivity studies to assess the
impact of uncertainties from key assumptions of the PRA, uncertainty in
the failure probabilities of the affected SSCs, impact to the frequency
of initiating events, and of any identified deviations from capability
Category II of ASME PRA Standard (ASME RA-Sb-2005) (Reference 4). Where
the sensitivity analyses identify a potential impact on the proposed
change, revised surveillance frequencies are considered, along with any
qualitative considerations that may bear on the results of such
sensitivity studies. Required monitoring and feedback of SSC
performance once the revised surveillance frequencies are implemented
will also be performed. Thus, through the application of NEI 04-10,
Rev. 1, [Licensee] has appropriately considered the possible impact of
PRA model uncertainty and sensitivity to key assumptions and model
limitations, consistently with regulatory position 2.3.5 of RG 1.177.
3.4.6 Acceptance Guidelines
[Licensee] will quantitatively evaluate the change in total risk
(including
[[Page 32005]]
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. Each individual change to
surveillance frequency must show a risk impact below 1E-6 per year for
change to CDF, and below 1E-7 per year for change to LERF. These are
consistent with the limits of RG 1.174 for very small changes in risk.
Where the RG 1.174 limits are not met, the process either considers
revised surveillance frequencies which are consistent with RG 1.174, or
the process terminates without permitting the proposed changes. Where
quantitative results are unavailable to permit comparison to acceptance
guidelines, appropriate qualitative analyses are required to
demonstrate that the associated risk impact of a proposed change to
surveillance frequency is negligible or zero. Otherwise, bounding
quantitative analyses are required which demonstrate the risk impact is
at least one order of magnitude lower than the RG 1.174 acceptance
guidelines for very small changes in risk. In addition to assessing
each individual SSC surveillance frequency change, the cumulative
impact of all changes must result in a risk impact below 1E-5 per year
for change to CDF, and below 1E-6 per year for change to LERF, and the
total CDF and total LERF must be reasonably shown to be less than 1E-4
per year and 1E-5 per year, respectively. These are consistent with the
limits of RG 1.174 for acceptable changes in risk, as referenced by RG
1.177 for changes to surveillance frequencies. The staff interprets
this assessment of cumulative risk as a requirement to calculate the
change in risk from a baseline model utilizing failure probabilities
based on the surveillance frequencies prior to implementation of the
SFCP, compared to a revised model with failure probabilities based on
changed surveillance frequencies. The staff further notes that
[Licensee] includes a provision to exclude the contribution to
cumulative risk from individual changes to surveillance frequencies
associated with small risk increases (less than 5E-8 CDF and 5E-9 LERF)
once the baseline PRA models are updated to include the effects of the
revised surveillance frequencies.
The quantitative acceptance guidance of RG 1.174 is supplemented by
qualitative information to evaluate the proposed changes to
surveillance frequencies, including industry and plant-specific
operating experience, vendor recommendations, industry standards, the
results of sensitivity studies, and SSC performance data and test
history.
The final acceptability of the proposed change is based on all of
these considerations and not solely on the PRA results compared to
numerical acceptance guidelines. Post implementation performance
monitoring and feedback are also required to assure continued
reliability of the components. The licensee's application of NEI 04-10,
Rev. 1, provides reasonable acceptance guidelines and methods for
evaluating the risk increase of proposed changes to surveillance
frequencies, consistent with Regulatory Position 2.4 of RG 1.177.
Therefore, the proposed [Licensee] methodology satisfies the fourth key
safety principle of RG 1.177 by assuring any increase in risk is small
consistent with the intent of the Commission's Safety Goal Policy
Statement.
3.4.7 The Impact of the Proposed Change Should Be Monitored Using
Performance Measurement Strategies
[LICENSEE] adoption of TSTF-425, Rev. 3, requires application of
NEI 04-10, Rev. 1, in the SFCP. NEI 04-10, Rev. 1, requires performance
monitoring of SSCs whose surveillance frequency has been revised as
part of a feedback process to assure that the change in test frequency
has not resulted in degradation of equipment performance and
operational safety. The monitoring and feedback includes consideration
of maintenance rule monitoring of equipment performance. In the event
of degradation of SSC performance, the surveillance frequency will be
reassessed in accordance with the methodology, in addition to any
corrective actions which may apply as part of the maintenance rule
requirements. The performance monitoring and feedback specified in NEI
04-10, Rev. 1, is sufficient to reasonably assure acceptable SSC
performance and is consistent with regulatory position 3.2 of RG 1.177.
Thus, the fifth key safety principle of RG 1.177 is satisfied.
3.4.8 Addition of Surveillance Frequency Control Program to TS Section
5
[Licensee] has included the SFCP and specific requirements into TS
Section [5.5.15 or 5.5.18], administrative controls, as follows:
This program provides controls for surveillance frequencies. The
program ensures that surveillance requirements specified in the
technical specifications are performed at intervals (frequencies)
sufficient to assure that the associated limiting conditions for
operation are met.
a. The Surveillance Frequency Control Program contains a list of
frequencies of those surveillance requirements for which the frequency
is controlled by the program.
b. Changes to the frequencies listed in the Surveillance Frequency
Control Program shall be made in accordance with NEI 04-10, ``Risk-
Informed Method for Control of Surveillance Frequencies,'' Revision 1.
c. The provisions of surveillance requirements 3.0.2 and 3.0.3 are
applicable to the frequencies established in the Surveillance Frequency
Control Program.
Summary and Conclusions
The staff has reviewed the [Licensee] proposed relocation of some
surveillance frequencies to a licensee controlled document, and
controlling changes to surveillance frequencies in accordance with a
new program, the SFCP, identified in the administrative controls of TS.
The SFCP and TS Section [5.5.15, 5.5.18] references NEI 04-10, Rev. 1,
which provides a risk-informed methodology using plant-specific risk
insights and performance data to revise surveillance frequencies within
the SFCP. This methodology supports relocating surveillance frequencies
from TS to a licensee-controlled document, provided those frequencies
are changed in accordance with NEI 04-10, Rev. 1, which is specified in
the administrative controls of the TS.
The proposed [Licensee] adoption of TSTF-425, Rev. 3, and risk-
informed methodology of NEI 04-10, Rev. 1, as referenced in the
administrative controls of TS, satisfies the key principles of risk-
informed decision making applied to changes to TS as delineated in RG
1.177 and RG 1.174, in that:
The proposed change meets current regulations;
The proposed change is consistent with defense-in-depth
philosophy;
The proposed change maintains sufficient safety margins;
Increases in risk resulting from the proposed change are
small and consistent with the Commission's Safety Goal Policy
Statement; and
[[Page 32006]]
The impact of the proposed change is monitored with
performance measurement strategies.
10 CFR 50.36(c)(3) states ``Technical specifications will include
items in the following categories: Surveillance Requirements.
Surveillance Requirements are requirements relating to test,
calibration, or inspection to assure that the necessary quality of
systems and components is maintained, that facility operation will be
within safety limits, and that the limiting conditions for operation
will be met.'' The NRC staff finds that with the proposed relocation of
surveillance frequencies to an owner-controlled document and
administratively controlled in accordance with the TS SFCP, [Licensee]
continues to meet the regulatory requirement of 10 CFR 50.36, and
specifically, 10 CFR 50.36(c)(3), surveillance requirements.
The NRC has concluded, on the basis of the considerations discussed
above, that (1) there is reasonable assurance that the health and
safety of the public will not be endangered by operation in the
proposed manner, (2) such activities will be conducted in compliance
with the NRC's regulations, and (3) the issuance of the amendments will
not be inimical to the common defense and security or to the health and
safety of the public.
4.0 State Consultation
In accordance with the NRC's regulations, the [ ] State official
was notified of the proposed issuance of the amendment. The State
official had [(1) no comments or (2) the following comments--with
subsequent disposition by the staff].
5.0 Environmental Consideration
The amendment[s] change[s] a requirement with respect to the
installation or use of a facility component located within the
restricted area as defined in 10 CFR Part 20 or surveillance
requirements. The NRC staff has determined that the amendment involves
no significant increase in the amounts, and no significant change in
the types, of any effluents that may be released offsite, and that
there is no significant increase in individual or cumulative
occupational radiation exposure. The NRC has previously issued a
proposed finding that the amendment involves no significant hazards
consideration and there has been no public comment on such finding
published [DATE] ([ ] FR [ ]). Accordingly, the amendment meets the
eligibility criteria for categorical exclusion set forth in 10 CFR
51.22(c)(9) and c(10). Pursuant to 10 CFR 51.22(b), no environmental
impact statement or environmental assessment need be prepared in
connection with the issuance of the amendment.
6.0 References
1. TSTF-425, Revision 3, ``Relocate Surveillance Frequencies to
Licensee Control--RITSTF Initiative 5b,'' March 18, 2009 (ADAMS
Accession Number: ML090850642).
2. NEI 04-10, Revision 1, ``Risk-Informed Technical Specifications
Initiative 5B, Risk-Informed Method for Control of Surveillance
Frequencies,'' April 2007 (ADAMS Accession Number: ML071360456).
3. Regulatory Guide 1.177, ``An Approach for Plant-Specific, Risk-
Informed Decision-making: Technical Specifications,'' August 1998
(ADAMS Accession Number: ML003740176).
4. Regulatory Guide 1.200, Rev. 1 ``An Approach for Determining the
Technical Adequacy of Probabilistic Risk Assessment Results for
Risk-Informed Activities,'' Revision 1, January 2007 (ADAMS
Accession Number: ML070240001).
5. Regulatory Guide 1.174, ``An Approach for Using Probabilistic
Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes
to the Licensing Basis,'' NRC, August 1998 (ADAMS Accession Number:
ML003740133).
6. ASME PRA Standard ASME RA-Sb-2005, Addenda to ASME RA-S-2002,
``Standard for Probabilistic Risk Assessment for Nuclear Power Plant
Application.''
7. NEI 00-02, Rev. 1 ``Probabilistic Risk Assessment (PRA) Peer
Review Process Guidance, Rev. 1, May 2006 (ADAMS Accession Number:
ML061510621).
8. NEI 05-04, ``Process for Performing Follow-On PRA Peer Reviews
Using the ASME PRA Standard'', Rev. 0, August 2006.
[FR Doc. E9-15780 Filed 7-2-09; 8:45 am]
BILLING CODE 7590-01-P