ML042260359

Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process

ML042260359
Person / Time
Site:	Ginna
Issue date:	08/06/2004
From:	Korsnick M Constellation Energy Group
To:	Clark R Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML042260359 (21)

Text

Maria Korsnick 1503 Lake Road Vice President Ontario, New York 14519-9364 585.771.3494 585.771.3943 Fax maria.korsnick~constellation.com Constellation Energy R.E. Ginna Nuclear Power Plant August 6, 2004 Mr. Robert L Clark Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C. 20555-0001 Subject Application for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated LUne Item Improvement Process R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Clark:

Pursuant to 10 CFR 50.90, R.E. Ginna Nuclear Power Plant, LLC hereby requests an amendment to the Technical Specifications (TS) for Ginna Station.

The proposed amendment will delete the TS requirements related to hydrogen recombiners and hydrogen monitors. The proposed TS changes support Implementation of the revisions to 10 CFR 50.44, Standards for Combustible Gas Control System In IUght-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 TS improvement was announced In the Federal Register on September 25, 2003 as part of the consolidated line Item improvement process (CLIIP).

Attachment I provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Attachment 3 provides revised, clean TS pages. Implementation of TSTF-447 also involves various changes to the TS Bases.

The TS Bases changes will be submitted with a future update In accordance with TS 5.5.13, Technical Specifications (TS) Bases Control Program."

100

R.E. Ginna Nuclear Power Plant, LLC requests approval of the proposed License Amendment by November 6, 2004, with the amendment being implemented within 60 days of issuance. If you have questions regarding the content of this correspondence please contact Mr. George Wrobel at (585) 771-3535 or Mr. Mike Ruby at (585) 771-3572.

Very truly yours Mary G. Korsnick STATE OF NEW YORK

TO WIT:

COUNTY OF WAYNE I, Mary G. Korsnick, being duly sworn, state that I am Vice President - R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this response on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and for the State of New York and County of

,this to day of _.

2004.

WITNESS my Hand and Notarial Seal:

My Commission Expires:

(S -gl-o4 Date

/1ah nA;Adice Notary Public SMARONLMER

1. Npl8~

cid New York i01M160177i5 CWueobw

21O2, Attachments:

1.

Description and Assessment

2.

Proposed Technical Specification Changes

3.

Revised Technical Specification Pages

4.

List of Regulatory Commitments

Cc:

Mr. Robert L. Clark (Mail Stop 0-8-C2)

Project Directorate I Division of Licensing Project Management Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector Mr. Peter R. Smith New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Mr. Paul Eddy NYS Department of Public Service 3 Empire State Plaza, 10 th Floor Albany, NY 12223 James M. Petro Jr., Esquire Counsel Constellation Energy 750 East Pratt Street, 5th Floor Baltimore, MD 21202 Daniel F. Stenger Ballard Spahr Andrews & Ingersoll, LLP 601 1 3 th Street, N.W., Suite 1000 South Washington, DC 20005

Attachment I Description and Assessment

Attachment I Description and Assessment 1.0 Introduction The proposed License amendment deletes Technical Specification (TS) 3.6.7, "Hydrogen Recombiners," and references to the hydrogen monitors in TS 3.3.3, "Post Accident Monitoring (PAM) Instrumentation." 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," 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 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:

TS 3.3.3, Condition E Inoperable Hydrogen Monitors Deleted Table 3.3.1-1 Item 11, Hydrogen Monitors Deleted TS 3.6.7 Hydrogen Recombiners Deleted As described in NRC-approved Revision 1 of TSTF-447, the changes to TS requirements results in changes to various TS Bases sections. The TS Bases changes will be submitted with a future update in accordance with TS 5.5.13, "Technical Specifications (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.

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 R.E. Ginna Nuclear Power Plant, LLC 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. R.E. Ginna Nuclear Power Plant, LLC has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Ginna Station and justify this amendment for the incorporation of the changes to the Ginna 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 (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 SE published in the Federal Register on September 25, 2003 (68 FR 55416) for this TS improvement, R.E. Ginna Nuclear Power Plant, LLC is making the following verifications and regulatory commitments:

1. R.E. Ginna Nuclear Power Plant, LLC has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at Ginna Station and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Ginna Technical Requirements Manual (TRM). This regulatory commitment will be implemented with implementation of this TS amendment.

2. Ginna Station does not have an inerted containment.

7.0 No Significant Hazards Consideration R.E. Ginna Nuclear Power Plant, LLC has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) as part of the CLIIP. R.E. Ginna Nuclear Power Plant, LLC has concluded that the proposed determination presented in the notice is applicable to Ginna Station and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 Environmental Evaluation R.E. Ginna Nuclear Power Plant, LLC has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. R.E. Ginna Nuclear Power Plant, LLC has concluded that the staffs findings presented in that evaluation are applicable to Ginna and the evaluation is hereby incorporated by reference for this application.

9.0 Precedent This application is being made in accordance with the CLIIP. R.E. Ginna Nuclear Power Plant, LLC 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).

10.0 References 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).

Proposed Technical Specification Changes

3.3 PAM Instrumentation 3.3.3 INSTRUMENTATION Post Accident Monitoring (PAM) Instrumentation 3

The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE.

3.3.3 LCO 3.3.3 APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

-NOTE-

1.

LCO 3.0.4 is not applicable.

2.

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A.

A.1 Restore required channel to 30 days OPERABLE status.

- NOTE -

Not applicable to Functions 3 and 4.

One or more Functions with one required channel inoperable.

B.

Required Action and B.1 Initiate action to prepare Immediately associated Completion and submit a special report.

Time of Condition A not met.

C.

C.1 Restore required channel to 7 days

_-_-_-__-___-_.OPERABLE status.

- NOTE -

Only applicable to Functions 3 and 4.

One or more Functions with required channel inoperable.

R.E. Ginna Nuclear Power Plant 3.3.3-1 AmendmentW

PAM Instrumentation 3.3.3 CONDITION REQUIRED ACTION COMPLETION TIME D.

D.1 Restore one channel to 7 days OPERABLE status.

NOTE -

One or more Functions with two required channels inoperable.

E.

Two hydcgen mneitorm

-E.1 Restero I_

hAd ewi on 2

hydreog channoel inoporablo.

monitor channel to O PERAABLE status.

-F--

Required Action and Enter the Condition Immediately associated Completion g

referenced in Table 3.3.3-1 Time of Condition C r

for the channel.

E. not met.

As required by Required 6G:1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> P

Actiorul and referenced F

inTable 3.3.3-1.

AND

-&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 /> e+

As required by Required

+.1 Initiate action to prepare Immediately G

Actiori.1 and referenced G and submit a special report.

m in 'Tab e 3.3.3-1.

SURVEILLANCE REQUIREMENTS

- NOTE-SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

SR 3.3.3.2 Perform CHANNEL CALIBRATION.

24 months R.E. Ginna Nuclear Power Plant 3.3.3-2 Amendment.W

PAM Instrumentation 3.3.3 Table 3.3.3-1 Post Accident Monitoring Instrumentation REQUIRED FUNCTION CHANNELS CONDITION

1. Pressurizer Pressure 2

'e-)r

2.

Pressurizer Level 2

e

3.

Reactor Coolant System (RCS) Hot Leg Temperature 1 per loop

,. 2

4.

RCS Cold Leg Temperature 1 per loop 8 P

5.

RCS Pressure (Wide Range) 2 P

6.

RCS Subcooling Monitor 2

7.

Reactor Vessel Water Level 2

8.

Containment Sump B Water Level 2

,SK f:

9.

Containment Pressure (Wide Range) 2 a

10.

Containment Area Radiation (High Range) 2 G

11 Hydrogan Monitors 2

C 4:

Condensate Storage Tank Level 2

ea 12-Refueling Water Storage Tank Level 2

_3 44-Residual Heat Removal Flow 2

1 Core Exit Temperature-Quadrant 1 2(a)

_3f I5X-*.- Core Exit Temperature-Quadrant 2 2(8)

F 16 4?7 Core Exit Temperature-Quadrant 3 2(a)

- F

/ 7-4 Core Exit Temperature-Quadrant 4 2(a)

J

- F

/,1 40 Auxiliary Feedwater (AFW) Flow to Steam Generator (SG) A 2

-e F I 1-ft AFW Flow to SG B 2

20.2.¶ SG A Water Level (Narrow Range) 2 2/

t.- SG B Water Level (Narrow Range) 2 F

R.E. Ginna Nuclear Power Plant 3.3.3-3 Amendment 0-01'

.,WV

PAM Instrumentation 3.3.3 Table 3.3.3-1 Post Accident Monitoring Instrumentation REQUIRED FUNCTION CHANNELS CONDITION

.287 SG A Water Level(ide Range) 2 F

23 24-SG B Water Level (Wide Range) 2 F

.?.2' SGAPressure 2

f S 26-SG B Pressure 2

(a)

A channel consists of two core exit thermocouples (CETs).

R.E. Ginna Nuclear Power Plant 3.3.3-4 Amendment.9T

3.6.

LCO 3.6.7 APPLICAI ACTIONS CONTAINMENT SYSTEMS Hydrogen Recombiners Two hydrogen recombiners shall be OPERABLE.

3ILITY:\\

MODES 1 and 2.

Hydrogen Recombine

3. 7

/

CONDITION REQUIRED ACTION COMPLETION TIME A.

One hydrogen

\\

A.1/

recombiner inoperable.

-NOTE LCO 3.0.4 is et applicable.

Restore drogen 30 days

\\ recombhrt OPERABLE

\\statu~

B.

Two hydrogen B.1 ifby administrative 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> recombiners inoperable.

e ns that the hydrogen cont I function is AND

/mainta ed.

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter B.2 Restore one hydr en 7 days recombiner to OPE BLE status.

C.

Required Actio nd C.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated C pletion Time not mes

/

\\

E Ginna Nuclear Power Plant Amend ent 3.6.7-1

Hydrogen Recombine 3..7

\\RVEILLANCE REQUIREMENTS SURVEILLANCE Perform a system functional check for each hydrogen recombiner.

I24 Perform CHANNEL CALIBRATION for each hydrogen recombiner actuation and control channel.

I24

.E. Ginna Nuclear Power Plant 3.6.7-2 Revised Technical Specification Pages

3.3 PAM Instrumentation 3.3.3 INSTRUMENTATION Post Accident Monitoring (PAM) Instrumentation The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE.

3.3.3 LCO 3.3.":

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

-NOTE-

1.

LCO 3.0.4 is not applicable.

2.

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A.

A.1 Restore required channel to 30 days OPERABLE status.

- NOTE -

Not applicable to Functions 3 and 4.

One or more Functions with one required channel inoperable.

B.

Required Action and B.1 Initiate action to prepare Immediately associated Completion and submit a special report.

Time of Condition A not met.

C.

0.1 Restore required channel to 7 days OPERABLE status.

-NOTE-Only applicable to Functions 3 and 4.

One or more Functions with required channel inoperable.

R.E. Ginna Nuclear Power Plant333-Amn et 3.3.3-1 Amendment

PAM Instrumentation 3.3.3 CONDITION REQUIRED ACTION COMPLETION TIME D.

One or more Functions D.1 Restore one channel to 7 days with two required OPERABLE status.

channels inoperable.

E.

Required Action and E.1 Enter the Condition Immediately associated Completion referenced in Table 3.3.3-1 Time of Condition C or D for the channel.

not met.

F.

As required by Required F.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action E.1 and referenced in Table 3.3.3-1.

AND F.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 /> G.

As required by Required G.1 Initiate action to prepare Immediately Action E.1 and referenced and submit a special report.

in Table 3.3.3-1.

SURVEILLANCE REQUIREMENTS

-NOTE-SR 3.3.3.1 and SR 3.3.3.2 apply to each PAM instrumentation Function in Table 3.3.3-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

SR 3.3.3.2 Perform CHANNEL CALIBRATION.

24 months R.E. Ginna Nuclear Power Plant 3.3.3-2 Amendment

PAM Instrumentation 3.3.3 Table 3.3.3-1 Post Accident Monitoring Instrumentation FUNCTION REQUIRED CONDITION CHANNELS

1.

Pressurizer Pressure 2

F

2.

Pressurizer Level 2

F l

3 Reactor Coolant System (RCS) Hot Leg Temperature 1 per loop F

4. RCS Cold Leg Temperature 1 per loop F

5. RCS Pressure (Wide Range) 2 F

6.

RCS Subcooling Monitor 2

F

7.

Reactor Vessel Water Level 2

G

8. Containment Sump B Water Level 2

F

9.

Containment Pressure (Wide Range) 2 F

10.

Containment Area Radiation (High Range) 2 G

11.

Condensate Storage Tank Level 2

F

12.

Refueling Water Storage Tank Level 2

F

13.

Residual Heat Removal Flow 2

F

14.

Core Exit Temperature-Quadrant 1 2(a)

F

15.

Core Exit Temperature-Quadrant 2 2(a)

F

16.

Core Exit Temperature-Quadrant 3 2(a)

F

17.

Core Exit Temperature-Quadrant 4 2(a)

F

18.

Auxiliary Feedwater (AFW) Flow to Steam Generator (SG) A 2

F

19.

AFWFlowtoSGB 2

F

20.

SG A Water Level (Narrow Range) 2 F

21.

SG B Water Level (Narrow Range) 2 F

22.

SG A Water Level (Wide Range) 2 F

R.E. Ginna Nuclear Power Plant 3.3.3-3 Amendment

PAM Instrumentation 3.3.3 I

I Table 3.3.3-1 Post Accident Monitoring Instrumentation FUNCTION REQUIRED CONDITION CHANNELS

23.

SG B Water Level (Wide Range) 2 F

24.

SG A Pressure 2

F

25.

SG B Pressure 2

F (a)

A channel consists of two core exit thermocouples (CETs).

R.E. Ginna Nuclear Power Plant 3.3.3-4 Amendment List of Regulatory Commitments

List of Regulatory Commitments The following table identifies those actions committed to by R.E. Ginna Nuclear Power Plant, LLC in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENT DUE DATE The hydrogen monitors will be included in the This regulatory commitment will be Ginna Technical Requirements Manual (TRM).

implemented with implementation of this TS amendment.