[Federal Register Volume 68, Number 41 (Monday, March 3, 2003)]
[Notices]
[Pages 10052-10057]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 03-4890]
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NUCLEAR REGULATORY COMMISSION
Notice of Opportunity to Comment on Model Safety Evaluation on
Technical Specification Improvement To Eliminate Post Accident Sampling
Requirements for Babcock and Wilcox Reactors Using the Consolidated
Line Item Improvement Process
AGENCY: Nuclear Regulatory Commission.
ACTION: Request for comment.
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SUMMARY: Notice is hereby given that the staff of the Nuclear
Regulatory Commission (NRC) has prepared a model safety evaluation (SE)
relating to the elimination of requirements on post accident sampling
imposed on licensees through orders, license conditions, or technical
specifications. The NRC staff has also prepared a model no significant
hazards consideration (NSHC) determination relating to this matter. The
purpose of these models is to permit the NRC to efficiently process
amendments that propose to remove requirements for the Post Accident
Sampling System (PASS) for Babcock and Wilcox (B&W) Reactors. Licensees
[[Page 10053]]
of nuclear power reactors to which the models apply could request
amendments conforming to the models. In such a request, a licensee
should confirm the applicability of the SE and NSHC determination to
its reactor and provide the requested plant-specific verifications and
commitments. The NRC staff is requesting comments on the model SE and
model NSHC determination before announcing their availability for
referencing in license amendment applications.
DATES: The comment period expires April 2, 2003. Comments received
after this date will be considered if it is practical to do so, but the
Commission is able to ensure consideration only for comments received
on or before this date.
ADDRESSES: Comments may be submitted either electronically or via U.S.
mail.
Submit written comments to: Chief, Rules and Directives Branch,
Division of Administrative Services, Office of Administration, Mail
Stop: T-6 D59, U.S. Nuclear Regulatory Commission, Washington, DC
20555-0001.
Hand deliver comments to: 11545 Rockville Pike, Rockville,
Maryland, between 7:45 a.m. and 4:15 p.m. on Federal workdays.
Copies of comments received may be examined at the NRC's Public
Document Room, One White Flint North, 11555 Rockville Pike (first
floor), Rockville, Maryland.
Comments may be submitted by electronic mail to [email protected].
FOR FURTHER INFORMATION CONTACT: Robert Dennig, Mail Stop: O-12H2,
Technical Specifications Section, Operating Reactor Improvement
Program, Division of Regulatory Improvement Programs, Office of Nuclear
Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC
20555-0001, telephone 301-415-1156.
SUPPLEMENTARY INFORMATION:
Background
Regulatory Issue Summary 2000-06, ``Consolidated Line Item
Improvement Process for Adopting Standard Technical Specification
Changes for Power Reactors,'' was issued on March 20, 2000. The
Consolidated Line Item Improvement Process (CLIIP) is intended to
improve the efficiency and transparency of NRC licensing processes.
This is accomplished by processing proposed changes to the Standard
Technical Specifications (STS) in a manner that supports subsequent
license amendment applications. The CLIIP includes an opportunity for
the public to comment on proposed changes to the STS following a
preliminary assessment by the NRC staff and finding that the change
will likely be offered for adoption by licensees. This notice is
soliciting comment on a proposed change to the STS that removes
requirements for the PASS for B&W plants. The CLIIP directs the NRC
staff to evaluate any comments received for a proposed change to the
STS and to either reconsider the change or to proceed with announcing
the availability of the change for proposed adoption by licensees.
Those licensees opting to apply for the subject change to technical
specifications are responsible for reviewing the staff's evaluation,
referencing the applicable technical justifications, and providing any
necessary plant-specific information. Each amendment application made
in response to the notice of availability would be processed and
noticed in accordance with applicable rules and NRC procedures.
This notice involves the elimination of requirements for PASS and
related administrative controls in technical specifications for B&W
plants. This proposed change was proposed for incorporation into the
standard technical specifications by the B&W Owners Group (BWOG)
participants in the Technical Specification Task Force (TSTF) and is
designated TSTF-442. TSTF-442 is supported by the NRC staff's safety
evaluation dated November 14, 2002, for the BWOG topical report BAW-
2387, ``Justification for the Elimination of the Post Accident Sampling
System (PASS) from the Licensing Basis of Babcock and Wilcox-Designed
Plants,'' which was submitted to the NRC on June 25, 2001. The BWOG
request followed the staff's approval of similar requests for
elimination of PASS requirements from the Combustion Engineering Owners
Group (CEOG), the Westinghouse Owners Group (WOG), and the Boiling
Water Reactor Owners Group (BWROG).
Applicability
This proposed change to remove requirements for PASS from technical
specifications (and other elements of the licensing bases) is
applicable to B&W plants.
To efficiently process the incoming license amendment applications,
the staff requests each licensee applying for the changes addressed by
TSTF-442 using the CLIIP to address the following plant-specific
verifications and regulatory commitments. The CLIIP does not prevent
licensees from requesting an alternative approach or proposing the
changes without the requested verifications and regulatory commitments.
Variations from the approach recommended in this notice may, however,
require additional review by the NRC staff and may increase the time
and resources needed for the review. In making the requested regulatory
commitments, each licensee should address: (1) That the subject
capability exists (or will be developed) and will be maintained; (2)
where the capability or procedure will be described (e.g., severe
accident management guidelines, emergency operating procedures,
emergency plan implementing procedures); and (3) a schedule for
implementation. The amendment request need not provide details about
designs or procedures.
Each licensee shall fulfill the actions, verifications or
commitments that are identified in section 4.0 of the following
proposed safety evaluation.
Public Notice
This notice requests comments from interested members of the public
within 30 days of the date of publication in the Federal Register.
Following the staff's evaluation of comments received as a result of
this notice, the staff may reconsider the proposed change or may
proceed with announcing the availability of the change in a subsequent
notice (perhaps with some changes to the safety evaluation or proposed
no significant hazards consideration determination as a result of
public comments). If the staff announces the availability of the
change, licensees wishing to adopt the change will submit an
application in accordance with applicable rules and other regulatory
requirements. The staff will in turn issue for each application a
notice of consideration of issuance of amendment to facility operating
license(s), a proposed no significant hazards consideration
determination, and an opportunity for a hearing. A notice of issuance
of an amendment to operating license(s) will also be issued to announce
the elimination of the PASS requirements for each plant that applies
for and receives the requested change.
Proposed Safety Evaluation; Consolidated Line Item Improvement;
Technical Specification Task Force (TSTF) Change TSTF-442; Elimination
of the Post Accident Sampling System (PASS) From the Licensing Basis of
Babcock and Wilcox Designed Plants
1.0 Introduction
In its letter dated June 25, 2001, the BWOG submitted for the NRC
staff's review topical report BAW-2387,
[[Page 10054]]
``Justification for the Elimination of the Post Accident Sampling
System (PASS) from the Licensing Basis of Babcock and Wilcox-Designed
Plants.'' The NRC staff's safety evaluation for the BWOG topical report
is dated November 14, 2002 (ADAMS Accession Number ML022560119). The
BWOG proposed elimination of the PASS requirements from the standard
technical specifications by submitting TSTF-442.
In the aftermath of the accident at Three Mile Island (TMI), Unit
2, the Nuclear Regulatory Commission (NRC) imposed requirements on
licensees for commercial nuclear power plants to install and maintain
the capability to obtain and analyze post-accident samples of the
reactor coolant and containment atmosphere. The desired capabilities of
the Post Accident Sampling System (PASS) were described in NUREG-0737,
``Clarification of TMI Action Plan Requirements.'' The NRC issued
orders to licensees with plants operating at the time of the TMI
accident to confirm the installation of PASS capabilities (generally as
they had been described in NUREG-0737). A requirement for PASS and
related administrative controls was added to the technical
specifications (TS) of the operating plants and was included in the
initial TS for plants licensed during the 1980s and 90s. Additional
expectations regarding PASS capabilities were included in Regulatory
Guide 1.97, ``Instrumentation for Light-Water-Cooled Nuclear Power
Plants To Assess Plant and Environs Conditions During and Following an
Accident.''
Significant improvements have been achieved since the TMI accident
in the areas of understanding risks associated with nuclear plant
operations and developing better strategies for managing the response
to potentially severe accidents at nuclear plants. Recent insights
about plant risks and alternate severe accident assessment tools have
led the NRC staff to conclude that some TMI Action Plan items can be
revised without reducing the ability of licensees to respond to severe
accidents. The NRC's efforts to oversee the risks associated with
nuclear technology more effectively and to eliminate undue regulatory
costs to licensees and the public have prompted the NRC to consider
eliminating the requirements for PASS in TS and other parts of the
licensing bases of operating reactors.
The staff has completed its review of the topical report submitted
by the Babcock and Wilcox Owners Group (BWOG) that proposed the
elimination of PASS. The justifications for the proposed elimination of
PASS requirements center on evaluations of the various radiological and
chemical sampling and their potential usefulness in responding to a
severe reactor accident or making decisions regarding actions to
protect the public from possible releases of radioactive materials. As
explained in more detail in the staff's safety evaluations for the
topical report, the staff has reviewed the available sources of
information for use by decision-makers in developing protective action
recommendations and assessing core damage. Based on this review, the
staff found that the information provided by PASS is either unnecessary
or is effectively provided by other indications of process parameters
or measurement of radiation levels. The staff agrees, therefore, with
the owners group that licensees can remove the TS requirements for
PASS, revise (as necessary) other elements of the licensing bases, and
pursue possible design changes to alter or remove existing PASS
equipment.
2.0 Regulatory Evaluation
The ways in which the requirements and recommendations for PASS
were incorporated into the licensing bases of commercial nuclear power
plants varied as a function of when plants were licensed. Plants that
were operating at the time of the TMI accident are likely to have been
the subject of confirmatory orders that imposed the PASS functions
described in NUREG-0737 as obligations. The issuance of plant specific
amendments to adopt this change, which would remove PASS and related
administrative controls from TS, would also supersede the PASS specific
requirements imposed by post-TMI confirmatory orders.
The NRC staff prepared this model safety evaluation (SE) relating
to the elimination of requirements on post accident sampling for B&W
plants and solicited public comments in [insert FR number] in
accordance with the CLIIP. The use of the CLIIP in this matter is
intended to help the NRC to efficiently process amendments that propose
to remove the PASS requirements from TS. Licensees of nuclear power
reactors to which this model apply were informed that they could
request amendments conforming to the model, and, in such requests,
should confirm the applicability of the SE to their reactors and
provide the requested plant-specific verifications and commitments.
3.0 Technical Evaluation
The technical evaluations for the elimination of PASS sampling
requirements are provided in the safety evaluation dated November 14,
2002, for BWOG topical report BAW-2387. As described in its safety
evaluation for the topical report, the staff finds that the post-
accident sampling requirements for the following may be eliminated for
B&W plants:
1. Reactor coolant dissolved gases.
2. Reactor coolant hydrogen.
3. Reactor coolant oxygen.
4. Reactor coolant chlorides.
5. Reactor coolant pH.
6. Reactor coolant boron.
7. Reactor coolant conductivity.
8. Radionuclides in the reactor coolant.
9. Containment atmosphere hydrogen.
10. Containment atmosphere oxygen.
11. Radionuclides in the containment atmosphere.
12. Radionuclides in the containment sump.
13. Containment sump pH.
14. Chlorides in the containment sump.
15. Boron in the containment sump.
PASS sampling of the above 15 parameters is specified in NUREG-0737
and RG 1.97. The sampling of the parameters are either not required to
manage an accident and recover plant conditions, or not necessary due
to redundancy in sampling capabilities. Based upon the detailed
justifications provided in topical report BAW-2387 and its associated
safety evaluation of November 14, 2002, the staff concludes that the
proposals to eliminate PASS sampling of the above parameters is
acceptable.
The staff concludes that sampling of radionuclides is not required
to support emergency response decision making during the initial phases
of an accident because the information provided by PASS is either
unnecessary or is effectively provided by other indications of process
parameters or measurement of radiation levels. Therefore, it is not
necessary to have dedicated equipment to obtain this sample in a prompt
manner.
The staff does, however, believe that there could be significant
benefits to having information about the radioisotopes existing post-
accident in order to address public concerns and plan for long-term
recovery operations. As stated in the safety evaluation for the topical
report, the staff has found that licensees could satisfy this function
by developing contingency plans to describe existing sampling
capabilities and what actions (e.g., assembling temporary shielding)
may be necessary to obtain and analyze highly radioactive samples from
the reactor coolant system (RCS), containment sump, and containment
atmosphere. The use of the contingency plans for obtaining samples
would depend on the plant conditions
[[Page 10055]]
and the need for information by the decision-makers responsible for
responding to the accident (see section 4.0 below).
In addition, the staff considers radioisotope sampling information
to be useful in classifying certain types of events (such as a
reactivity excursion or mechanical damage) that could cause fuel damage
without having an indication of a loss of reactor coolant inventory.
However, the staff agrees with the topical report's contentions that
other indicators of failed fuel, such as radiation monitors, can be
correlated to the degree of failed fuel.
In lieu of the information that would have been obtained from PASS,
the staff believes that licensees should maintain or develop the
capability to monitor radioactive iodines that have been released to
offsite environs. This information would be useful for decision makers
trying to assess a release of and limit the public's exposure to
radioactive materials.
The staff believes that the changes related to the elimination of
PASS that are described in the topical report, related safety
evaluation and this proposed change to TS are unlikely to result in a
decrease in the effectiveness of a licensee's emergency plan. Each
licensee, however, must evaluate possible changes to its emergency plan
in accordance with 10 CFR 50.54(q) to determine if the change decreases
the effectiveness of its site-specific plan. Evaluations and reporting
of changes to emergency plans should be performed in accordance with
applicable regulations and procedures.
The staff notes that containment hydrogen concentration monitors
are required by 10 CFR 50.44 and are relied upon to meet the data
reporting requirements of 10 CFR part 50, Appendix E, section
VI.2.a.(ii)(3). The staff concludes that these hydrogen monitors
provide an adequate capability for monitoring containment hydrogen
concentration during the early phases of an accident. The staff sees
value in maintaining the capability to obtain grab samples for
complementing the information from the hydrogen monitors in the long
term (i.e., by confirming the indications from the monitors and
providing hydrogen measurements for concentrations outside the range of
the monitors). The licensee's contingency plan for obtaining highly
radioactive samples will include sampling of the containment atmosphere
and may, if deemed necessary and practical by the appropriate decision-
makers, be used to supplement the hydrogen monitors.
(Note 1--Each licensee should specify a desired implementation
period for its specific amendment request. The implementation period
would be that period necessary to develop and implement the items in
section 4.0 below and, as necessary, to make other changes to
documentation or equipment to support the elimination of PASS
requirements. As an alternative, the licensee may choose to have a
shorter implementation period and include the scheduling of items in
section 4.0 as part of the regulatory commitments associated with
this amendment request. Amendment requests that include commitments
for implementation of the items in section 4 within 6 months of the
implementation of the revised TS will remain within the CLIIP.)
(Note 2 --There may be some collateral changes to the TS as a
result of the removal of the administrative controls section for
PASS. For example, the elimination of the TS and other regulatory
requirements for PASS would result in additional changes to TS such
as (e.g., the renumbering of sections or pages or the removal of
references). The changes are included in the licensee's application
to revise the TS in order to take advantage of the CLIIP. The staff
has reviewed the changes and agrees that the revisions are necessary
due to the removal of the TS section on PASS. The changes do not
revise technical requirements beyond that reviewed by the NRC staff
in connection with the supporting topical reports or the preparation
of the TS improvement incorporated into the CLIIP.)
4.0 Summary and Licensee Required Actions
The staff concludes that BAW-2387 provides a sufficient technical
basis to eliminate sampling the above 15 PASS parameters specified in
NUREG-0737 and RG 1.97. The staff has identified the following licensee
required actions, verifications or commitments that must be fulfilled
by a licensee that eliminates the PASS for sampling the above 15
parameters in accordance with BAW-2387 and this safety evaluation. The
licensee shall verify that it has, and make a regulatory commitment to
maintain, or a regulatory commitment to develop and maintain:
1. A capability for classifying fuel damage events at the Alert
level threshold (typically this is 300 microcuries per ml dose
equivalent iodine). This capability may utilize the normal sampling
system or correlations of sampling or letdown line dose rates to
coolant concentrations.
2. Contingency plans for obtaining and analyzing highly radioactive
samples of reactor coolant, containment sump, and containment
atmosphere.
3. Offsite capability to monitor radioactive iodines.
The NRC staff finds that reasonable controls for the implementation
and for subsequent evaluation of proposed changes pertaining to the
above regulatory commitments are provided by the licensee's
administrative processes, including its commitment management program.
Should the licensee choose to incorporate a regulatory commitment into
the emergency plan, final safety analysis report, or other document
with established regulatory controls, the associated regulations would
define the appropriate change-control and reporting requirements. The
staff has determined that the commitments do not warrant the creation
of regulatory requirements, which would require prior NRC approval of
subsequent changes. The NRC staff has agreed that NEI 99-04, Revision
0, ``Guidelines for Managing NRC Commitment Changes,'' provides
reasonable guidance for the control of regulatory commitments made to
the NRC staff. (See Regulatory Issue Summary 2000-17, Managing
Regulatory Commitments Made by Power Reactor Licensees to the NRC
Staff, dated September 21, 2000 (ADAMS Accession Number ML003741774).)
The commitments should be controlled in accordance with the industry
guidance or comparable criteria employed by a specific licensee. The
staff may choose to verify the implementation and maintenance of these
commitments in a future inspection or audit.
5.0 State Consultation
In accordance with the Commission's regulations, the State official
was notified of the proposed issuance of the amendments. The State
official had ((1) no comments or (2) the following comments--with
subsequent disposition by the staff).
6.0 Environmental Consideration
The amendments change 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 and change surveillance
requirements. The NRC staff has determined that the amendments involve
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 Commission has previously issued a proposed
finding that the amendments involve no significant hazards
consideration, and there has been no public comment on such finding.
Accordingly, the amendments meet the eligibility criteria for
categorical exclusion set forth in 10 CFR
[[Page 10056]]
51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact
statement or environmental assessment need be prepared in connection
with the issuance of the amendments.
7.0 Conclusion
The Commission has concluded, based on 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 Commission'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.
Proposed No Significant Hazards Consideration Determination
Description of Amendment Request: The proposed amendments delete
requirements from the Technical Specifications (and, as applicable,
other elements of the licensing bases) to maintain a Post Accident
Sampling System (PASS). Licensees were generally required to implement
PASS upgrades as described in NUREG-0737, ``Clarification of TMI [Three
Mile Island] Action Plan Requirements,'' and Regulatory Guide 1.97,
``Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess
Plant and Environs Conditions During and Following an Accident.''
Implementation of these upgrades was an outcome of the lessons learned
from the accident that occurred at TMI, Unit 2. Requirements related to
PASS were imposed by Order for many facilities and were added to or
included in the technical specifications (TS) for nuclear power
reactors currently licensed to operate. Lessons learned and
improvements implemented over the last 20 years have shown that the
information obtained from PASS can be readily obtained through other
means or is of little use in the assessment and mitigation of accident
conditions.
Basis for proposed no significant hazards consideration
determination: As required by 10 CFR 50.91(a), an analysis of the issue
of no significant hazards consideration is presented below:
Criterion 1--The Proposed Change Does Not Involve a Significant
Increase in the Probability or Consequences of an Accident Previously
Evaluated
The PASS was originally designed to perform many sampling and
analysis functions. These functions were designed and intended to be
used in post accident situations and were put into place as a result of
the TMI-2 accident. The specific intent of the PASS was to provide a
system that has the capability to obtain and analyze samples of plant
fluids containing potentially high levels of radioactivity, without
exceeding plant personnel radiation exposure limits. Analytical results
of these samples would be used largely for verification purposes in
aiding the plant staff in assessing the extent of core damage and
subsequent offsite radiological dose projections. The system was not
intended to and does not serve a function for preventing accidents and
its elimination would not affect the probability of accidents
previously evaluated.
In the 20 years since the TMI-2 accident and the consequential
promulgation of post accident sampling requirements, operating
experience has demonstrated that a PASS provides little actual benefit
to post accident mitigation. Past experience has indicated that there
exists in-plant instrumentation and methodologies available in lieu of
a PASS for collecting and assimilating information needed to assess
core damage following an accident. Furthermore, the implementation of
Severe Accident Management Guidance (SAMG) emphasizes accident
management strategies based on in-plant instruments. These strategies
provide guidance to the plant staff for mitigation and recovery from a
severe accident. Based on current severe accident management strategies
and guidelines, it is determined that the PASS provides little benefit
to the plant staff in coping with an accident.
The regulatory requirements for the PASS can be eliminated without
degrading the plant emergency response. The emergency response, in this
sense, refers to the methodologies used in ascertaining the condition
of the reactor core, mitigating the consequences of an accident,
assessing and projecting offsite releases of radioactivity, and
establishing protective action recommendations to be communicated to
offsite authorities. The elimination of the PASS will not prevent an
accident management strategy that meets the initial intent of the post-
TMI-2 accident guidance through the use of the SAMGs, the emergency
plan (EP), the emergency operating procedures (EOP), and site survey
monitoring that support modification of emergency plan protective
action recommendations (PARs).
Therefore, the elimination of PASS requirements from Technical
Specifications (TS) (and other elements of the licensing bases) does
not involve a significant increase in the consequences of any accident
previously evaluated.
Criterion 2--The Proposed Change Does Not Create the Possibility of a
New or Different Kind of Accident From Any Previously Evaluated
The elimination of PASS related requirements will not result in any
failure mode not previously analyzed. The PASS was intended to allow
for verification of the extent of reactor core damage and also to
provide an input to offsite dose projection calculations. The PASS is
not considered an accident precursor, nor does its existence or
elimination have any adverse impact on the pre-accident state of the
reactor core or post accident confinement of radioisotopes within the
containment building.
Therefore, this change does not create the possibility of a new or
different kind of accident from any previously evaluated.
Criterion 3--The Proposed Change Does Not Involve a Significant
Reduction in the Margin of Safety
The elimination of the PASS, in light of existing plant equipment,
instrumentation, procedures, and programs that provide effective
mitigation of and recovery from reactor accidents, results in a neutral
impact to the margin of safety. Methodologies that are not reliant on
PASS are designed to provide rapid assessment of current reactor core
conditions and the direction of degradation while effectively
responding to the event in order to mitigate the consequences of the
accident. The use of a PASS is redundant and does not provide quick
recognition of core events or rapid response to events in progress. The
intent of the requirements established as a result of the TMI-2
accident can be adequately met without reliance on a PASS.
Therefore, this change does not involve a significant reduction in
the margin of safety.
Based upon the reasoning presented above and the previous
discussion of the amendment request, the requested change does not
involve a significant hazards consideration.
Dated in Rockville, Maryland, this 21st day of February, 2003.
[[Page 10057]]
For the Nuclear Regulatory Commission.
Robert L. Dennig,
Section Chief, Technical Specifications Section, Operating Reactor
Improvements Program, Division of Regulatory Improvement Programs,
Office of Nuclear Reactor Regulation.
[FR Doc. 03-4890 Filed 2-28-03; 8:45 am]
BILLING CODE 7590-01-P