TSTF-24-02, Technical Specifications Task Force - Transmittal of TSTF-597, Revision 0, Eliminate LCO 3.0.3 Mode 2 Requirement

From kanterella
(Redirected from TSTF-24-02)
Jump to navigation Jump to search

Technical Specifications Task Force - Transmittal of TSTF-597, Revision 0, Eliminate LCO 3.0.3 Mode 2 Requirement
ML24075A080
Person / Time
Site: Technical Specifications Task Force, 99902042
Issue date: 03/15/2024
From: Lashley P, Lueshen K, Richards A, Vaughan J
Technical Specifications Task Force
To:
Document Control Desk
References
TSTF-24-02 TSTF-597, Rev 0
Download: ML24075A080 (23)
v • d • e


Text

11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 804-339-7034 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF March 15, 2024 TSTF-24-02 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Transmittal of TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement" Enclosed for NRC review is TSTF-597, Revision 0, "Eliminate LCO 3.0.3 Mode 2 Requirement."

The following information is provided to assist the NRC staff in prioritizing their review of TSTF-597:

  • Applicability: TSTF-597 is applicable to all boiling water reactor (BWR) plant types.
  • Classification: TSTF-597 revises the BWR LCO 3.0.3 to eliminate the requirement to enter Mode 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.
  • Specialized Resource Availability: TSTF-597 is a normal priority change. The TSTF requests that TSTF-597 be reviewed within 18 months and be made available for adoption under the Consolidated Line Item Improvement Process (CLIIP).

The Technical Specifications Task Force should be billed for the review of the traveler.

TSTF 24-02 March 15, 2024 Page 2 Should you have any questions, please do not hesitate to contact us.

Andrew M. Richards, Jr. (PWROG/W)

Phil H. Lashley (BWROG)

Kevin Lueshen (PWROG/CE)

Jordan L. Vaughan (PWROG/B&W)

Wesley A. Sparkman (PWROG/AP1000)

Enclosure cc:

Michelle Honcharik, Technical Specifications Branch Shivani Mehta, Technical Specifications Branch Victor Cusumano, Technical Specifications Branch

TSTF-597, Rev. 0 BWROG-149, Rev. 0 NUREGs Affected:

Eliminate LCO 3.0.3 Mode 2 Requirement Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement:

Improvement NRC Fee Status:

Not Exempt Benefit:

Provides Longer Completion Time Changes Marked on ISTS Rev 5.0 2194 PWROG RISD & PA (if applicable): N/A N/A See attached.

Revision History Affected Technical Specifications OG Revision 0 Revision Status: Active Original Issue Revision

Description:

Revision Proposed by:

Licensing Committee Owners Group Review Information Date Originated by OG:

01-Feb-23 Owners Group Comments (No Comments)

Date: 28-Feb-23 Owners Group Resolution:

Approved TSTF Review Information TSTF Received Date:

29-Feb-24 Date Distributed for Review 29-Feb-24 TSTF Comments:

(No Comments)

Date: 15-Mar-24 TSTF Resolution:

Approved NRC Review Information NRC Received Date:

15-Mar-24 LCO 3.0.3 LCO Applicability 15-Mar-24 Copyright(C) 2024, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-597, Rev. 0 BWROG-149, Rev. 0 LCO 3.0.3 Bases LCO Applicability 15-Mar-24 Copyright(C) 2024, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-597, Rev. 0 Page 1

1.

SUMMARY

DESCRIPTION The proposed change revises Boiling Water Reactor (BWR) Limiting Condition for Operation (LCO) 3.0.3 to eliminate the requirement to enter Mode 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. The proposed change affects the Standard Technical Specifications (STS) in NUREG-1433 and NUREG-14341.

2. DETAILED DESCRIPTION 2.1. System Design and Operation LCO 3.0.3 requires a plant shutdown under three conditions:
1.

An LCO is not met, and the associated Actions are not met;

2.

An LCO is not met, and an associated Action is not provided; or

3.

An LCO is not met, and LCO 3.0.3 entry is directed by the associated Actions.

LCO 3.0.3 requires initiation of actions to shut down the plant within one hour if any of these conditions are met.

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, paragraph 50.36(c)(2), "Limiting Conditions for Operation," states, "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." LCO 3.0.3 satisfies this regulation by providing a requirement to shut down the reactor if an LCO is not met and the TS does not provide any other remedial action.

1 NUREG-1433 provides the STS for BWR/4 plant designs, but is also representative of the BWR/2, BWR/3, and, in this case, of the BWR/5 plant design.

NUREG-1434 provides the STS for BWR/6 plant designs, but is also representative in some cases of the BWR/5 plant design.

TSTF-597, Rev. 0 Page 2 2.1.1. BWR Modes and the Reactor Mode Switch The BWR Modes are defined in STS Table 1.1-1:

MODE TITLE REACTOR MODE SWITCH POSITION AVERAGE REACTOR COOLANT TEMPERATURE

(°F) 1 Power Operation Run NA 2

Startup Refuel(a) or Startup/Hot Standby NA 3

Hot Shutdown(a)

Shutdown

> [200]

4 Cold Shutdown(a)

Shutdown

[200]

5 Refueling(b)

Shutdown or Refuel NA (a) All reactor vessel head closure bolts fully tensioned.

(b) One or more reactor vessel head closure bolts less than fully tensioned.

Unlike the Pressurized Water Reactor (PWR) STS2 Modes, the BWR Modes are almost entirely dictated by the position of the Reactor Mode Switch, and not on the combination of reactivity condition, rated thermal power, and average reactor coolant temperature. Only BWR Mode 3 and Mode 4 are distinguished by the average reactor coolant temperature. The BWR STS only provides operability requirements and Required Actions associated with the "Shutdown" position (e.g., "Place the reactor mode switch in the shutdown position."), except during refueling and testing during shutdown.

The Reactor Mode Switch sets various control functions for the plant operating condition. The Reactor Mode Switch is manually placed in one of the four positions which places into effect the corresponding trip functions.

2 NUREG-1430 provides the STS for Babcock & Wilcox plant designs.

NUREG-1431 provides the STS for Westinghouse plant designs.

NUREG-1432 provides the STS for Combustion Engineering plant designs.

NUREG-2194 provides the STS for Westinghouse AP1000 plant designs.

TSTF-597, Rev. 0 Page 3

  • Placing the Reactor Mode Switch in "Startup/Hot Standby" allows the operator to withdraw control rods for a plant startup and initiates low power setpoints and protection features.

Placing the Reactor Mode Switch in "Startup/Hot Standby" when greater than 20% Rated Thermal Power (RTP) (or a plant-specific value) will cause a reactor scram.

  • Placing the Reactor Mode Switch in "Refuel" allows single control rod withdrawal to support refueling activities, and disables or enables various functions.

2.2. Current Technical Specifications Requirements NUREG-1433 LCO 3.0.3 states:

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 2 within [7] hours,

b.

MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and

c.

MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

REVIEWER'S NOTE-----------------------------------

The brackets around the time provided to reach MODE 2 allow a plant to extend the time from 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to a plant specific time. Before the time can be changed, plant specific data must be provided to support the extended time.

The Reviewer's Note and the brackets around the 7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> Completion Time to be in Mode 2 provide an option for a licensee to request a longer period to enter Mode 2 based on plant-specific constraints.3 3 For example, "Brunswick Steam Electric Plant, Units 1 and 2 - Issuance of Amendment Nos. 288 and 316 to Adopt TSTF-208, Revision 0, 'Extension of Time to Reach Mode 2 in LCO 3.0.3'," dated January 9, 2019, NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML18291B322.

TSTF-597, Rev. 0 Page 4 In NUREG-1434, LCO 3.0.3 is the same except that the time to be in Mode 2 is not bracketed and there is no Reviewer's Note.

2.3. Reason for the Proposed Change The BWR STS LCO 3.0.3 requirement to enter Mode 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> is inconsistent with the remainder of the STS and inconsistent with typical plant operation.

All other BWR STS Actions require being in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and if applicable, being in Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. There are no BWR STS Actions that require being in Mode 2 except a limited number of specifications that are only applicable in Mode 1. The BWR LCO 3.0.3 requirement to be in Mode 2 in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> is overly restrictive compared to Actions in the STS that represent conditions of equivalent safety significance to entry into LCO 3.0.3.

The requirement to be in Mode 2 in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> is also inconsistent with plant practice. During a shutdown, the typical BWR operating practice is to lower power and while in Mode 1 to place the Mode Switch in "Shutdown," which scrams the reactor. When the Mode Switch is placed in "Shutdown," the unit enters Mode 3 from Mode 1, without entering Mode 2. In this situation, licensees have interpreted LCO 3.0.3 as requiring being in Mode 3 in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> when 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is permitted for any other shutdown in the STS. This places unnecessary time constraints on plant operators.

2.4. Description of the Proposed Change The proposed change revises LCO 3.0.3 to eliminate the requirement to be in Mode 2.

With the removal of the Mode 2 requirement, the Reviewer's Note is no longer needed in NUREG-1433.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 2 within [7] hours, ab.

MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and bc.

MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

TSTF-597, Rev. 0 Page 5

REVIEWER'S NOTE-----------------------------------

The brackets around the time provided to reach MODE 2 allow a plant to extend the time from 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to a plant specific time. Before the time can be changed, plant specific data must be provided to support the extended time.

The TS Bases are revised to reflect these changes.

A model application is attached. The model may be used by licensees desiring to adopt the traveler following NRC approval.

3. TECHNICAL EVALUATION The proposed change to eliminate the LCO 3.0.3 requirement to enter Mode 2 is justified because:
  • The LCO 3.0.3 requirement to enter Mode 2 is unique in the BWR STS and is not consistent with the safety significance of the condition.
  • Requiring entry into Mode 2 does not improve plant safety.
  • The BWR LCO 3.0.3 requirement to enter Mode 2 is inconsistent with typical plant operation.

3.1.1. BWR LCO 3.0.3 Shutdown Completion Times are Unique in the STS The typical Completion Times provided to shut down the plant in the current BWR STS are shown in Section 1.3, "Completion Times," Example 1.3-1:

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours These Completion Times have been the typical shutdown times since the original BWR STS were issued in 1976.

All other BWR STS require being in Mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and if applicable, being in Mode 4 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, including safety significant conditions in which an LCO or associated Actions are not met, such as:

TSTF-597, Rev. 0 Page 6

  • No recirculation loops in operation,
  • Violation of the RCS pressure and temperature limits,

The only BWR STS Actions that require being in Mode 2 are for inoperable Reactor Protection System instrumentation functions that are only applicable in Mode 1, ATWS-RPT Instrumentation and Main Steam Line Pressure - Low Instrumentation which are only applicable in Mode 1, and LCO 3.0.3 that is applicable in Modes 1, 2, 3. The BWR LCO 3.0.3 requirement to be in Mode 2 in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> is inconsistent compared to other Actions in the STS that represent significant degradations in plant safety.

3.1.2. Requiring Entry into Mode 2 Does Not Improve Plant Safety LCO 3.0.3 Bases state that the purpose of LCO 3.0.3 is to delineate the time limits for placing the unit in a safe Mode or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its Actions. However, a requirement to enter Mode 2, in which the reactor is still critical but at low power, does not place the unit in a safe Mode in which the LCO and its Actions are not applicable. In fact, the plant is less stable at low power than at full power.

It is notable that LCO 3.0.3 in the PWR STS does not require entering Mode 2 (reactor critical at low power, similar to BWR STS Mode 2). The PWR STS LCO 3.0.3 requires being in Mode 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. PWR plants can enter Mode 3 from Mode 1 during a controlled shutdown faster than equivalent BWR plants for several reasons. For example, PWR control rods are arranged in groups and the groups can be quickly driven into the reactor following a hardware-enforced sequence, while BWR control rods must be manually inserted individually in accordance with a procedure following an approved rod pattern. In addition, field manipulation of components, such as feedwater heaters, may take longer at BWRs due to the need for radiation protection controls on potentially contaminated areas.

3.1.3. The BWR LCO 3.0.3 Requirement to Enter Mode 2 is Inconsistent with Typical Plant Operation During a shutdown, the usual BWR operating practice is to lower power and then place the Mode Switch in "Shutdown," initiating a reactor scram. When the Mode Switch is placed in "Shutdown," the unit enters Mode 3 from Mode 1, without entering Mode 2. In this situation, licensees have interpreted LCO 3.0.3 as requiring being in Mode 3 in 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> instead of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> as stated in LCO 3.0.3. This places unnecessary time constraints on plant operators. There are no other BWR STS Actions that require being in Mode 3 in less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

In some cases, licensees may manually insert the control rods to the fully inserted position, knowns as "soft shutdown." At low power, the Reactor Mode Switch is placed in "Startup,"

entering Mode 2. After the control rods are fully inserted, the Reactor Mode Switch is

TSTF-597, Rev. 0 Page 7 temporarily bypassed and placed in "Shutdown," to avoid a hydraulic "slamming" effect on the already inserted rods. This results in entry into Mode 3. Even in these nontypical shutdowns, the requirement to enter Mode 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> is consistent with the other shutdown requirements in the STS and does not justify imposing a 7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> requirement to enter Mode 2.

In summary, elimination of the BWR LCO 3.0.3 requirement to enter Mode 2 is justified because it is unique in the BWR STS and not warranted by the safety significance of the condition, the requirement to enter Mode 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> does not improve plant safety, and the requirement to enter Mode 2 is inconsistent with typical plant operation.

4. REGULATORY EVALUATION The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The Commission may include such additional technical specifications as the Commission finds appropriate.

Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate.

Section IV, "The Commission Policy," of the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58FR39132), dated July 22, 1993, states in part that improved STS have been developed and will be maintained for each NSSS owners group. The Commission Policy encourages licensees to use the improved STS as the basis for plant-specific Technical Specifications." The industry's proposal of travelers and the NRC's approval of travelers is the method used to maintain the improved STS as described in the Commission's Policy. Following NRC approval, licensees adopt travelers into their plant-specific technical specifications following the requirements of 10 CFR 50.90. Therefore, the traveler process facilitates the Commission's policy while satisfying the requirements of the applicable regulations.

The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls. The proposed traveler revises the Bases to be consistent with the Technical Specifications, and therefore, is in compliance with 10 CFR 50.36(a)(1).

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner,

TSTF-597, Rev. 0 Page 8 (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

5. REFERENCES None.

TSTF-597, Rev. 0 Model Application

TSTF-597, Rev. 0 Page 1

[DATE]

10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOCKET NO. PLANT NAME

[50]-[xxx]

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-597, "Eliminate LCO 3.0.3 Mode 2 Requirement" Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].

[LICENSEE] requests adoption of TSTF-597, "Eliminate LCO 3.0.3 Mode 2 Requirement,"

which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-597 revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. Attachment 2 provides revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.

[LICENSEE] requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within [90] days.

There are no regulatory commitments in this letter.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated [STATE] Official.

[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.

Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]

TSTF-597, Rev. 0 Page 2 If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Enclosure:

Description and Assessment Attachments: 1.

Proposed Technical Specification Changes (Mark-Up)

2.

Revised Technical Specification Pages

3.

Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only

[The attachments are to be provided by the licensee and are not included in the model application.]

cc:

NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact

TSTF-597, Rev. 0 Page 3 ENCLOSURE DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

[LICENSEE] requests adoption of TSTF-597, "Eliminate LCO 3.0.3 Mode 2 Requirement,"

which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-597 revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation

[LICENSEE] has reviewed the safety evaluation for TSTF-597 provided to the Technical Specifications Task Force in a letter dated [DATE]. This review included the NRC staffs evaluation, as well as the information provided in TSTF-597. [LICENSEE] has concluded that the justifications presented in TSTF-597 and the safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS.

2.2 Variations

[LICENSEE is not proposing any variations from the TS changes described in TSTF-597 or the applicable parts of the NRC staffs safety evaluation.] [LICENSEE is proposing the following variations from the TS changes described in TSTF-597 or the applicable parts of the NRC staffs safety evaluation:]

[The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-597 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-597 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-597 to the [PLANT] TS.]

The [PLANT] TS permits a longer Completion Time to enter Mode 2 than the 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> in the STS. This change was approved by the NRC in [TSTF-208 adoption amendment reference].

The different Completion Time does not affect the applicability of the proposed change to the

[PLANT] TS.

[The [PLANT] TS contain requirements that differ from the STS on which TSTF-597 was based but are encompassed in the TSTF-597 justification. [Describe differences and why TSTF-597 is still applicable.]

TSTF-597, Rev. 0 Page 4

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

[LICENSEE] requests adoption of TSTF-597, "Eliminate LCO 3.0.3 Mode 2 Requirement,"

which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-597 revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

The time required to shut down the plant after entering LCO 3.0.3 is not an initiator of any accident previously evaluated. Under the proposed change, the TS continue to require the plant to shut down and enter Mode 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. The consequences of any accident previously evaluated during the revised LCO 3.0.3 shutdown requirements are no different than the consequences of the same accident during the existing times.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

The proposed change does 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 current plant operating practice for all other TS required shutdowns.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No

TSTF-597, Rev. 0 Page 5 The proposed change revises LCO 3.0.3 to eliminate the requirement to enter Mode 2.

The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, [LICENSEE] concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

TSTF-597, Rev. 0 Technical Specifications Changes

LCO Applicability 3.0 General Electric BWR/4 STS 3.0-1 Rev. 5.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 2 within [7] hours, ab.

MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and bc.

MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

REVIEWER'S NOTE-----------------------------------

The brackets around the time provided to reach MODE 2 allow a plant to extend the time from 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to a plant specific time. Before the time can be changed, plant specific data must be provided to support the extended time.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; TSTF-597, Rev. 0

LCO Applicability B 3.0 General Electric BWR/4 STS B 3.0-4 Rev. 5.0 BASES LCO 3.0.3 (continued) less time than allowed, however, the total allowable time to enter MODE 4, or other applicable MODE, is not reduced. For example, if MODE 32 is entered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for entering MODE 43 is the next 11 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />, because the total time for entering MODE 43 is not reduced from the allowable limit of 13 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.8, "Spent Fuel Storage Pool Water Level." LCO 3.7.8 has an Applicability of "During movement of irradiated fuel assemblies in the spent fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.8 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.8 of "Suspend movement of irradiated fuel assemblies in the spent fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered following entry into the MODE or other specified condition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time. Compliance with ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an TSTF-597, Rev. 0

LCO Applicability 3.0 General Electric BWR/6 STS 3.0-1 Rev. 5.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, LCO 3.0.8, and LCO 3.0.9.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a.

MODE 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, ab.

MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, and bc.

MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, and 3.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications); or

c.

When an allowance is stated in the individual value, parameter, or other Specification.

TSTF-597, Rev. 0

LCO Applicability B 3.0 General Electric BWR/6 STS B 3.0-4 Rev. 5.0 BASES LCO 3.0.3 (continued)

MODE 32 is entered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for entering MODE 43 is the next 3511 hours0.0406 days <br />0.975 hours <br />0.00581 weeks <br />0.00134 months <br />, because the total time for entering MODE 43 is not reduced from the allowable limit of 3713 hours0.043 days <br />1.031 hours <br />0.00614 weeks <br />0.00141 months <br />.

Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, and 3, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 4 and 5 because the unit is already in the most restrictive Condition required by LCO 3.0.3. The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, or 3) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken.

Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.7, "Fuel Pool Water Level." LCO 3.7.7 has an Applicability of "During movement of irradiated fuel assemblies in the associated fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.7 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.7 of "Suspend movement of irradiated fuel assemblies in the associated fuel storage pool(s)" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.0.4.c.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered following entry into the MODE or other specified condition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time. Compliance with ACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard TSTF-597, Rev. 0

Retrieved from "https://kanterella.com/w/index.php?title=TSTF-24-02,_Technical_Specifications_Task_Force_-_Transmittal_of_TSTF-597,_Revision_0,_Eliminate_LCO_3.0.3_Mode_2_Requirement&oldid=5526179"