JAFP-19-0033, License Amendment Request - Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Revision 0

License Amendment Request - Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Revision 0

ML19066A251
Person / Time
Site:	FitzPatrick
Issue date:	03/07/2019
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-19-0033
Download: ML19066A251 (10)

Text

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp com 10 CFR 50.90 JAFP-19-0033 March 7, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

License Amendment Request- Revise Technical Specifications to Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month," Revision 0 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) is submitting a request for an amendment to the Technical Specifications (TS), Appendix A, of Renewed Facility Operating License No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF).

The proposed amendment would modify the JAF TS requirements to operate ventilation systems with charcoal filters for 1O hours each month in accordance with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month." provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the Proposed TS Marked-Up Pages. Attachment 3 provides the Proposed Technical Specifications Bases Marked-Up Pages for information only.

The proposed changes have been reviewed by the JAF Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

Exelon requests approval of the proposed amendment by August 31, 2019. Once approved, the amendment shall be implemented within 60 days.

There are no regulatory commitments contained in this request.

Exelon has concluded that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92.

U.S. Nuclear Regulatory Commission License Amendment Request Adopt TSTF-522, Revision 0 Docket No. 50-333 March 7, 2019 Page2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is transmitting a copy of this application and its attachments to the designated State Officials.

Should you have any questions concerning this submittal, please contact Christian Williams at (610) 765-5229.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 71t1 day of March 2019.

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James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments:

1) Evaluation of Proposed Changes

2) Proposed Technical Specification Marked-Up Pages

3) Proposed Technical Specification Bases Marked-Up Pages cc: USNRC Region I, Regional Administrator w/attachments USNRC Senior Resident Inspector, JAF w/attachments USNRC Project Manager, JAF w/attachments A. L. Peterson, NYSERDA w/attachments

ATTACHMENT 1 License Amendment Request James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 EVALUATION OF PROPOSED CHANGES CONTENTS

SUBJECT:

Revise Technical Specifications to Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month,"

Revision 0

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Determination 4.0 ENVIRONMENTAL EVALUATION

License Amendment Request Attachment 1 Adoption of TSTF-522, Revision 0 Page 1 of 3 Docket No. 50-333 Evaluation of Proposed Changes

1.0 DESCRIPTION

The proposed change revises the Surveillance Requirements which currently require operating ventilation systems with the heaters operating for a continuous 10-hour period every 31 days.

The Surveillance Requirements are revised to require operation of the systems for 15 continuous minutes every 31 days.

The proposed amendment is consistent with TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month."

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Exelon has reviewed the model safety evaluation dated September 20, 2012, as part of the Federal Register Notice of Availability. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-522. Exelon has concluded that the justifications presented in the TSTF-522 proposal and the model safety evaluation prepared by the NRC staff are applicable to James A. FitzPatrick (JAF) and justify this amendment for the incorporation of the changes to the JAF Technical Specifications (TS).

2.2 Optional Changes and Variations JAF has implemented the Surveillance Frequency Control Program (SFCP) and therefore the 31-day requirement will be incorporated into the SFCP and the Frequency in the TS will state, "In accordance with the Surveillance Frequency Control Program" for SR 3.6.4.3.1. Additionally, JAF TS 3.7.3, "Control Room Emergency Ventilation Air Supply (CREVAS) relates to the TSTF-522 Section 3.7.4, "Main Control Room Environmental Control (MCREC) System."

However, the JAF CREVAS system does not have installed heaters and the current duration required by SR 3.7.3.1 is already consistent with this TSTF. There are no changes recommended to TS 3.7.3.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination James A. FitzPatrick (JAF) requests adoption of an approved change to the standard technical specifications (STS) to revise Technical Specification (TS) 3.6.4.3, "Standby Gas Treatment (SGT) System," to revise the Surveillance Requirement to operate the SGT System with the electric heaters operating for a continuous 10-hour period every 31 days. The Surveillance Requirement is revised to require operation of the system for 15 continuous minutes every 31 days.

As required by 10 CFR 50.91(a), an analysis of the issue of no significant hazards consideration is presented below:

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

License Amendment Request Attachment 1 Adoption of TSTF-522, Revision 0 Page 2 of 3 Docket No. 50-333 Evaluation of Proposed Changes Response: No.

The proposed change replaces an existing Surveillance Requirement to operate the SGT System equipped with electric heaters for a continuous 10-hour period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating.

The system is not an accident initiator and therefore, these changes do not involve a significant increase in the probability of an accident. The proposed system and filter testing change is consistent with current regulatory guidance for the system and will continue to assure that the system performs the design function which may include mitigating accidents. Thus, the change does not involve a significant increase in the consequences of an accident.

Therefore, it is concluded that this 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 accident previously evaluated?

Response: No.

The proposed change replaces an existing Surveillance Requirement to operate the SGT System for a continuous 10-hour period every 31 days with a requirement to operate the system for 15 continuous minutes with heaters operating.

The change proposed for the ventilation system does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met, and the system components are capable of performing their intended safety functions. The change does not create new failure modes or mechanisms and no new accident precursors are generated.

Therefore, it is concluded that this change does 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 a margin of safety?

Response: No.

The proposed change replaces an existing Surveillance Requirement to operate the SGT System equipped with electric heaters for a continuous 10-hour period every 31 days with a requirement to operate the systems for 15 continuous minutes with heaters operating, if needed.

The design basis for the ventilation systems' heaters is to heat the incoming air which reduces the relative humidity. The heater testing change proposed will continue to demonstrate that the heaters are capable of heating the air and will perform their design function. The proposed change is consistent with regulatory guidance.

License Amendment Request Attachment 1 Adoption of TSTF-522, Revision 0 Page 3 of 3 Docket No. 50-333 Evaluation of Proposed Changes Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety. Based on the above, Exelon 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.

4.0 ENVIRONMENTAL EVALUATION The proposed change 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 change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change 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 change.

License Amendment Request Attachment 1 Adoption of TSTF-522, Revision 0 Page 1 of 1 Docket No. 50-333 Evaluation of Proposed Changes ATTACHMENT 2 License Amendment Request James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Revise Technical Specifications to Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month," Revision 0 Proposed Technical Specification Marked-Up Pages TS Pages 3.6.4.3-3

SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for > 10 15 In accordance continuous hours minutes with heaters operating. with the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required SGT filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual In accordance or simulated initiation signal. with the Surveillance Frequency Control Program SR 3.6.4.3.4 Manually cycle each SGT subsystem filter cooling In accordance cross-tie valve. with the Surveillance Frequency Control Program JAFNPP 3.6.4.3-3 Amendment

License Amendment Request Attachment 1 Adoption of TSTF-522, Revision 0 Page 1 of 1 Docket No. 50-333 Evaluation of Proposed Changes ATTACHMENT 3 License Amendment Request James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Revise Technical Specifications to Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month," Revision 0 Proposed Technical Specification Bases Marked-Up Pages (for information only)

Bases Pages B 3.6.4.3-5

SGT System B 3.6.4.3 BASES ACTIONS E.1 (continued)

When two SGT subsystems are inoperable, if applicable, movement of recently irradiated fuel assemblies in secondary containment must immediately be suspended. Suspension of this activity shall not preclude completion of movement of a component to a safe position.

LCO 3.0.3 is not applicable in MODE 4 or 5. However, since recently irradiated fuel assembly movement can occur in MODE 1, 2, or 3, Required Action E.1 has been modified by a Note stating that LCO 3.0.3 is not applicable. If moving recently irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving recently irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of recently irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.6.4.3.1 REQUIREMENTS Operating each SGT subsystem fan for > 10 15 continuous hours minutes ensures that both subsystems are OPERABLE and that all associated controls are functioning properly. It also ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action. Operation with the heaters on for > 10 continuous hours periodically eliminates moisture on the adsorbers and HEPA filters. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.6.4.3.2 This SR verifies that the required SGT filter testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations). Specific test frequencies and additional information are discussed in detail in the VFTP.

(continued)

JAFNPP B 3.6.4.3-5 Revision