RC-04-0074, License Amendment Request - LAR 03-4159 Elimination of Hydrogen Recombiners and Change to Hydrogen Analyzers Using the Consolidated Line Item Improvement Process

License Amendment Request - LAR 03-4159 Elimination of Hydrogen Recombiners and Change to Hydrogen Analyzers Using the Consolidated Line Item Improvement Process

ML041470124
Person / Time
Site:	Summer
Issue date:	05/21/2004
From:	Byrne S South Carolina Electric & Gas Co
To:	Cotton K Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 03-4159, RC-04-0074
Download: ML041470124 (17)

Text

Stephen A. Byrne Senior Vice President, Nuclear Operations 803.345.4622 May 21, 2004 RC-04-0074 A SCANA COMPANY Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTN: Ms. K. R. Cotton

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 LICENSE AMENDMENT REQUEST - LAR 03-4159 ELIMINATION OF HYDROGEN RECOMBINERS AND CHANGE TO HYDROGEN ANALYZERS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP)

Pursuant to 10 CFR 50.90, South Carolina Electric & Gas Company (SCE&G), acting for itself and as agent for South Carolina Public Service Authority, hereby requests an amendment to the Virgil C. Summer Nuclear Station (VCSNS) Technical Specifications (TS).

The proposed amendment will delete the Technical Specification requirements related to the hydrogen recombiners and hydrogen analyzers. The proposed Technical Specification changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this Technical Specification improvement was announced in the Federal Register on September 25, 2003, (68 FR 55416) as part of the consolidated line item improvement process (CLIIP).

SCE&G's evaluation of the proposed changes is provided in the Attachment I to this letter. The attachment provides a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications and commitments. The proposed Technical Specification changes are presented in Attachments II and Ill. New regulatory commitments associated with this request are provided in Attachment IV. Implementation of TSTF-447 also involves changes to the Technical Specification Bases. The Technical Specification Bases changes will be submitted with a future update in accordance with Technical Specification 6.8.4i, "Technical Specifications (TS) Bases Control Program."

The proposed amendment has been reviewed by the VCSNS review committees. SCE&G has notified the State of South Carolina in accordance with 1 OCFR50.91 (b).

SCE&G requests approval of the proposed amendments by March 30, 2005, so that sufficient time is provided to include consideration of the proposed amendments in the work planning SCE&G I Virgil C Summer Nuleor Station

• P.O. Box 88. Jenkinsville, South Carolina 29065.T (803) 345.5209 *www.scono.rom

.3

Document Control Desk LAR 03-4159 RC-04-0074 Page 2 of 2 process for the next VCSNS refueling outage, which is scheduled for the Spring of 2005. Once approved, the amendments shall be implemented within 60 days.

If you have any questions or require additional information, please contact Mr. Ronald B. Clary at (803)-345-4757.

I certify under penalty of perjury that the information contained herein is true and correct.

Executed on Stephen A. Byrne AJC/SAB/dr

Enclosures:

Attachment(s): 4

1. Evaluation of the proposed change

2. Proposed Technical Specification Change - Mark-up

3. Proposed Technical Specification Change - Retyped

4. List of Regulatory Commitments c:

N. 0. Lorick N. S. Carns T. G. Eppink (w/o Attachments)

R. J. White Regional Administrator K. R. Cotton NRC Resident Inspector P. Ledbetter K. M. Sutton T. P. O'Kelley RTS (LAR 03-4159)

File (813.20)

DMS (RC-04-0074)

Document Control Desk Attachment I LAR 03-4159 RC-04-0074 Page 1 of 4 Description and Assessment

1.0 INTRODUCTION

The proposed License amendment deletes the V. C. Summer Nuclear Station (VCSNS)

Technical Specifications (TS) 3.6.5.2 and Surveillance Requirement (SR) 4.6.5.2 for the containment hydrogen recombiners, TS 3.3.3.6.b.2 for the containment hydrogen monitor limiting conditions for operability, Table 3.3-10, item 4, for the reactor building hydrogen concentration instrument channel requirements, and Index item 3/4 6.5, Combustible Gas Control. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors, which became effective on October 16, 2003.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors. The availability of this TS improvement was announced in the Federal Register on September 25, 2003 as part of the consolidated line item improvement process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

1. Index 3/4 6.5 Combustible Gas Control Deleted

2. TS 3.3.3.6.b.2 Accident Monitoring Instrumentation Deleted

3. Table 3.3-10, Item 4 Accident Monitoring Instrumentation Deleted

4. TS 3.6.5.2 Electric Hydrogen Recombiners Deleted

5. SR 4.6.5.2 Electric Hydrogen Recombiners Deleted The proposed Technical Specification changes are provided in Attachments II and l1l. The proposed changes to the TS are shown with a strike-through or by page deletions.

As a result of the above changes to the TS requirements, changes to the TS Bases to delete the related discussions concerning combustible gas control will also be required. The TS Bases changes will be submitted with a future update in accordance with TS 6.8.4i, 'Technical Specification (TS) Bases Control Program."

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

Document Control Desk Attachment I LAR 03-4159 RC-04-0074 Page 2 of 4 4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 TECHNICAL ANALYSIS

SCE&G has reviewed the safety evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staff's SE, as well as the supporting information provided to support TSTF-447. SCE&G has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to the VCSNS and justify this amendment for the incorporation of the changes to the VCSNS TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model Safety Evaluation published in the Federal Register on September 25, 2003 (68 FR 55416) for this TS improvement, SCE&G is making the following verifications and regulatory commitments:

SCE&G has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at VCSNS and is making a regulatory commitment to maintain that capability.

The hydrogen analyzers installed at VCSNS are capable of monitoring the hydrogen concentration within the containment within the indicating range of 0 to 10% hydrogen. This range was previously approved by the NRC as acceptable and remains sufficient to support this license amendment request. For severe accident conditions that could potentially produce hydrogen concentrations in containment beyond this range, computational aids are included in the VCSNS Severe Accident Mitigation Guidelines to estimate the hydrogen concentration based on bounding fractions of fuel cladding/water reaction when the core has been uncovered and reflooded.

In addition, the VCSNS Post Accident Sampling Contingency Plan, established as part of the elimination of the Post Accident Sampling System, includes

Document Control Desk Attachment I LAR 03-4159 RC-04-0074 Page 3 of 4 provisions for obtaining grab samples of the containment atmosphere, which can be used to supplement the hydrogen monitors.

The requirements for maintaining a hydrogen monitoring system capable of diagnosing beyond design basis accidents as described above will be included in the VCSNS updated Final Safety Analysis Report (FSAR). This regulatory commitment will be implemented with the proposed amendment implementation (Refer to Attachment 4, List of Regulatory Commitments). When implementing the proposed amendments, SCE&G does not intend to relocate the current VCSNS Technical Specification requirements for the hydrogen recombiners into another Licensee controlled document. Changes to the VCSNS FSAR sections describing the use of hydrogen recombiners for combustible gas control will be made under 10 CFR 50.59.

VCSNS does not have an inerted containment. The VCSNS containment is an atmospheric designed containment.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION SCE&G has reviewed the proposed no significant hazards consideration determination published on September 25, 2003, (68 FR 55416) as part of the CLIIP. SCE&G has concluded that the proposed determination presented in the notice is applicable to VCSNS, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

8.0 ENVIRONMENTAL CONSIDERATION

SCE&G has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. SCE&G has concluded that the Staff's findings presented in that evaluation are applicable to VCSNS and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This license amendment request is being made in accordance with the CLIPP. SCE&G is not proposing variations or deviations from the TS changes described in TSTF-447 or the NRC staff's model SE published on September 25, 2003 (68 FR 55416) other than those differences in the proposed TS changes that result because the VCSNS TS do not match the format of the Improved Standard Technical Specifications for Westinghouse Plants. The VCSNS proposed TS changes only deletes the hydrogen analyzer and hydrogen recombiner requirements from the TS which is consistent with the NRC approved changes in TSTF-447, Revision 1.

Document Control Desk Attachment I LAR 03-4159 RC-04-0074 Page 4 of 4

10.0 REFERENCES

1.

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement to Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published, September 25, 2003 (68 FR 55416).

2.

10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors."

3.

Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors," Revision 1, August 2003.

Document Control Desk Attachment II LAR 03-4159 RC-04-0074 Page 1 of 5 ATTACHMENT II PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Attachment to License Amendment No. XXX To Facility Operating License No. NPF-12 Docket No. 50-395 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages VII 3/4 3-56 3/4 3-57 3/4 6-22 Insert Pages VII 3/4 3-56 3/4 3-57 3/4 6-22 SCE&G - EXPLANATION OF CHANGES Page Affected Bar Description of Change Reason for Change Section VII Index 1

Revising Index to delete 3/4 Incorporate guidance TSTF-6.5 447.

3/4 3-56 3.3.3.6 1

Revising Action to delete b.2 Incorporate guidance TSTF-447.

3/4 3-57 Table 3.3-1 Revising Table to delete Item Incorporate guidance TSTF-10, Item 4 4

447.

3/4 6-22 3.6.5.2 1

Delete entire page Incorporate guidance TSTF-4.6.5.2 447.

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS _

SECTION PAGE 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT Containment Integrity 9

9 9

9 9

9 9

3/4 6.2 Containment Leakage Containment Air Locks Internal Pressure Air Temperature Containment Structural Integrity............

Containment Ventilation System.............

DEPRESSURIZATION AND COOLING SYSTEMS Reactor Building Spray System Spray Additive.System Reactor Building Cooling System PARTICULATE IODINE CLEANUP SYSTEM CONTAINMENT ISOLATION VALVES......

3/4 6-1 3/4 6-2 3/4 6-4 3/4 6-6 3/4 6-7

• 3/4 6-8 3/4 6-11 i

3/4 3/4 3/4 3/4 3/4 6-12 6-13 6-14 6-15 6-17 3/4.6.3 3/4 6.4 GAS-CONTROL

1.

-ledectric-Hydrogen Recombiners I

SUMMER - UNIT 1 VII Amendment No.

118

INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.6 The. acci..at monitoring instrumentation channels shown in Table 3.3-10 shall be OPERABLE.

APPLICABILITY MODES 1, 2, and 3.

ACTION:

a.

Withn the number of OPERABLE accident monitoring channels less than the Required Number of Channels shown on Table 3.3-10, either restore the inoperable channel(s) to OPERABLE-status within 30 days or submit a Special Report within the following 14 days from the time the action is required. The report shall outline the preplanned alter--.7e method of monitoring, the cause of the inoperability, and the plar-and schedule for restoring the instrumentation channels to operable status.

b.1 With the number of OPERABLE Reactor Building radiation monitoring channels less than the Minimum Channels Operable requirement of Table 3.3-10, either restore the inoperable channel(s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or:

i)

Initiate the preplanned alternate method of monitoring the appropriate parameter(s), and ii)

Submit a Special Report to the Commission pursuant to

zecification 6.9.2 within 14 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.

b. -Wi-th-thenumber of Hydrogen monitoring channels less tm Channels Ope-r-eq t f Table 3reat least one monitor to operable status s or be in at least HOT STANDBY Wi*he-n UTDOWK ithin the next l l!

b.1 With the number of OPERABLE accident monitoring channels less than the Minimum Channels Operable requirement of Table 3.3-10, either restore the inoperable channels to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.6 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performing a monthly CHANNEL CHECK and a CHANNEL CALIBRATION every refueling outage. The Reactor Building Radiation Level Instrumentation CHANNEL I

CALIBRATION may consist of an electronic calibration of the channel, not Including the detector, for the range decades above 1OR/hr and a single point calibration of the detector below 1OR/hr with an installed or portable gamma source.

SUMMER - UNIT I 3/4 3-56 Amendment No. 118

TABLE 3.3-10 cn x

A;0 C

aI

-4 ACCIDENT MONITORING INSTRUMENTATION I I INSTRUMENT REQUIRED NO. OF CHANNELS MINIMUM CHANNELS OPERABLE

1. Reactor Building Pressure - Narrow Range Instrument Loop/Indicator:

Channel D IPT-951/IPI-951 Channel B IPT-952/IPI-952

2. Reactor Building Pressure - Wide Range Instrument Loop/Indicator:

Channel D IPT-954A/IPI-954A Channel E IPT-954B/IPI-954B 2

1 2

1 Ln

-41

3. Reactor Building Radiation Level Instrument Loop/Indicator:

Channel A RMG-18 Channel B RMG-7

- High Range 2

1 a

-1,Je I t a

CD 0.

a'-"

5. Reactor Building/RHR Sump Level Instrument Loop/Indicator:

Channel A ILT-1969/ILI-1969 Channel B ILT-1970/ILI-1970

6. Reactor Coolant Outlet Temperature - THot-Wide Range Instrument Loop/Indicator:

Channel A ITE-413/ITI-413 Channel A ITE-423/ITI-423 Channel E ITE-433/ITR-413

7. Reactor Coolant Inlet Temperature - TCold - Wide Range Instrument/Loop Indicator:

Channel E ITE-410/ITI-410 Channel E ITE-420/ITI-420 Channel E ITE-430/ITR-410 2

I 1

2 2

1 1

7)E-LE one Ai E 3.6.5.2 independent post accident hydrogen recombiner-systems all be OPERABLE.

APPLICABILITY:

MODES I and 2.

ACTION:

With one hydrogen rec inbiner system inoperable, restore t inoperable system to OPERABLE status withn 30 days or be in at least HOT ANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.6.5.2 Each hydrogen recombiner ystem shal e demonstrated OPERABLE:

a.

At least once per 6 months ver fying, during a recombiner system functional test, that the mi imy heater sheath temperature increases to greater than or equal to O0°F within 90 minutes.

Upon reaching 7000F, increase the power sett g to maximum power for 2 minutes and verify that the power meter ea greater than or equal to 60 Kw.

b.

At least once per 18 monf's by:

1.

Performing a CHAP$EL CALIBRATION f all recombiner instrumenta-tion and contro/ circuits,

2.

Verifying thr ugh a visual examinatio that there is no evidence of abnormal/conditions within the reco iner enclosure (i.e.,

lTose wir fig or structural connections, eposits of foreign material/, etc.), and

3.

Verif ng the integrity of all heater elect acal circuits by psf rming a resistance to ground test follow pg the above re% ired functional test.

The resistance to gi und for any e'ater phase shall be greater than or equal to 1 000 ohms.

j MMER -

UNIT 1 3/4 6-22

Document Control Desk Attachment III LAR 03-4159 RC-04-0074 Page 1 of 5 ATTACHMENT III PROPOSED TECHNICAL SPECIFICATION CHANGES (RETYPED)

V INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT Containment Integrity................................

3/4 6-1 Containment Leakage.................................

3/4 6-2 Containment Air Locks................................

3/4 6-4 Internal Pressure................................

3/4 6-6 Air Temperature.................................

3/4 6-7 Containment Structural Integrity.................................

3/4 6-8 Containment Ventilation System................................

3/4 6-11 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS Reactor Building Spray System.3/4 6-12 Spray Additive System.3/4 6-13 Reactor Building Cooling System.3/4 6-14 3/4.6.3 PARTICULATE IODINE CLEANUP SYSTEM.3/4 6-15 3/4.6.4 CONTAINMENT ISOLATION VALVES.3/4 6-17 3/4.6.5 Deleted SUMMER - UNIT 1 Vll Amendment No. 148,

INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.6 The accident monitoring instrumentation channels shown in Table 3.3-10 shall be OPERABLE.

APPLICABILITY MODES 1, 2, and 3.

ACTION:

a.

With the number of OPERABLE accident monitoring channels less than the Required Number of Channels shown on Table 3.3-10, either restore the inoperable channel(s) to OPERABLE status within 30 days or submit a Special Report within the following 14 days from the time the action is required. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels to operable status.

b.1 With the number of OPERABLE Reactor Building radiation monitoring channels less than the Minimum Channels Operable requirement of Table 3.3-10, either restore the inoperable channel(s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or:

i)

Initiate the preplanned alternate method of monitoring the appropriate parameter(s), and ii)

Submit a Special Report to the Commission pursuant to Specification 6.9.2 within 14 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.

b.2 Deleted b.3 With the number of OPERABLE accident monitoring channels less than the Minimum Channels Operable requirement of Table 3.3-10, either restore the inoperable channels to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

c.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.6 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performing a monthly CHANNEL CHECK and a CHANNEL CALIBRATION every refueling outage. The Reactor Building Radiation Level Instrumentation CHANNEL CALIBRATION may consist of an electronic calibration of the channel, not including the detector, for the range decades above 1 OR/hr and a single point calibration of the detector below 1 OR/hr with an installed or portable gamma source.

SUMMER - UNIT 1 3/4 3-56 Amendment No. 448

TABLE 3.3-10 ACCIDENT MONITORING INSTRUMENTATION Cl REQUIRED MINIMUM NO. OF CHANNELS INSTRUMENT CHANNELS OPERABLE mT

1. Reactor Building Pressure - Narrow Range 2

1 C

Instrument Loop/Indicator:

z Channel D IPT-951/IPI-951 Channel B IPT-952/IPI-952

2.

Reactor Building Pressure - Wide Range 2

1 Instrument Loop/Indicator:

Channel D IPT-954A/IPI-954A Channel E IPT-954B/IPI-954B

3.

Reactor Building Radiation Level - High Range 2

1 Instrument Loop/indicator:

Channel A RMG-18 C,,

Channel B RMG-7

4.

Deleted Ca

5.

Reactor Building/RHR Sump Level 2

1 Instrument Loop/indicator:

Channel A ILT-1969/1LI-1969 Channel B ILT-1970/1LI-1970

6.

Reactor Coolant Outlet Temperature - THM-Wide Range 2

1 Instrument Loop/Indicator:

Channel A ITE-413/ITI-413 3

Channel A ITE-423/ITI-423 CD QL Channel E ITE-433/ITR-413 CD

7.

Reactor Coolant Inlet Temperature - Tcold-Wide Range 2

1 Instrument Loop/indicator:

ze Channel E ITE-410/ITI-410 Channel E ITE-420/ITI-420 Channel E ITE-430/ITR-410

THIS PAGE INTENTIONALLY LEFT BLANK SUMMER - UNIT 1 3/4 6-22 Amendment No.

Document Control Desk Attachment IV LAR 03-4159 RC-04-0074 Page 1 of 1 ATTACHMENT IV LIST OF REGULATORY COMMITMENTS SCE&G will comply with the requirements addressed in the Federal Register Notice of Availability of Model Application Concerning Technical Specification Improvement to Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416).

Requirements for maintaining a hydrogen monitoring system capable of diagnosing beyond design basis accidents will be included in the VCSNS Final Safety Analysis Report. This action will be completed consistent with the approved implementation date for this submittal.