ML042360253

Amendment, Elimination of Requirements for Hydrogen Recombiners and Hydrogen Monitors

ML042360253
Person / Time
Site:	Sequoyah
Issue date:	09/20/2004
From:	Robert Pascarelli NRC/NRR/DLPM/LPD2
To:	Singer K Tennessee Valley Authority
Pascarelli,R J,NRC/NRR/DIPM,415-1245
Shared Package
ML042360434	List: ML042360253
References
TAC MC2444, TAC MC2445
Download: ML042360253 (14)

Text

September 20, 2004 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 ISSUANCE OF AMENDMENTS REGARDING ELIMINATION OF REQUIREMENTS FOR HYDROGEN RECOMBINERS AND HYDROGEN MONITORS (TAC NOS. MC2444 AND MC2445) (TS 03-14)

Dear Mr. Singer:

The Commission has issued the enclosed Amendment No. 296 to Facility Operating License No. DPR-77 and Amendment No. 286 to Facility Operating License No. DPR-79 for the Sequoyah Nuclear Plant, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated March 5, 2004.

The amendments eliminate the TSs for hydrogen recombiners and hydrogen monitors. A notice of availability for this TS improvement using the Consolidated Line Item Improvement Process was published in the Federal Register on September 25, 2003 (68 FR 55416).

A copy of the Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Robert J. Pascarelli, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosures:

1. Amendment No. 296 to License No. DPR-77

2. Amendment No. 286 to License No. DPR-79

3. Safety Evaluation cc w/enclosures: See next page

September 20, 2004 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 ISSUANCE OF AMENDMENTS REGARDING ELIMINATION OF REQUIREMENTS FOR HYDROGEN RECOMBINERS AND HYDROGEN MONITORS (TAC NOS. MC2444 AND MC2445) (TS 03-14)

Dear Mr. Singer:

The Commission has issued the enclosed Amendment No. 296 to Facility Operating License No. DPR-77 and Amendment No. 286 to Facility Operating License No. DPR-79 for the Sequoyah Nuclear Plant, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated March 5, 2004.

The amendments eliminate the TSs for hydrogen recombiners and hydrogen monitors. A notice of availability for this TS improvement using the Consolidated Line Item Improvement Process was published in the Federal Register on September 25, 2003 (68 FR 55416).

A copy of the Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Robert J. Pascarelli, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosures:

1. Amendment No. 296 to License No. DPR-77

2. Amendment No. 286 to License No. DPR-79

3. Safety Evaluation cc w/enclosures: See next page DISTRIBUTION: See next page Package:ML042360434

Enclosure:

ADAMS ACCESSION NO. ML042360253 NRR-058 OFFICE CLIIP LPM PDII-2/PM PDII-2/LA OGC PDII-2/SC(A)

NAME WReckley RPascarelli BClayton McGurren MMarshall NLO DATE 8/16/04 8/23/04 8/23/04 9/1/04 9/20/04 OFFICIAL RECORD COPY

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 ISSUANCE OF AMENDMENTS REGARDING ELIMINATION OF REQUIREMENTS FOR HYDROGEN RECOMBINERS AND HYDROGEN MONITORS (TAC NOS. MC2444 AND MC2445) (TS 03-14)

Date: September 20, 2004 Distribution:

PUBLIC PDII-2 Reading RidsNrrDlpmLpdii (EHackett)

RidsNrrDlpmLpdii2 (MMarshall)

RidsNrrPMRPascarelli BClayton (Hard Copy)

RidsOgcRp RidsAcrsAcnwMailCenter GHill (42 paper copies)

TBoyce (DRIP/IROB)

WReckley RidsRgn2MailCenter (SCahill)

RidsNrrDlpmDpr

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-327 SEQUOYAH NUCLEAR PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 296 License No. DPR-77

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated March 5, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. DPR-77 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 296, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance, to be implemented no later than 45 days after issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Michael L. Marshall, Acting Chief Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: September 20, 2004

ATTACHMENT TO LICENSE AMENDMENT NO. 296 FACILITY OPERATING LICENSE NO. DPR-77 DOCKET NO. 50-327 Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT VIII VIII 3/4 6-24 3/4 6-24 3/4 6-25 3/4 6-25

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-328 SEQUOYAH NUCLEAR PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 286 License No. DPR-79

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated March 5, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. DPR-79 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 286, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Michael L. Marshall, Acting Chief Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: September 20, 2004

ATTACHMENT TO LICENSE AMENDMENT NO. 286 FACILITY OPERATING LICENSE NO. DPR-79 DOCKET NO. 50-328 Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT VIII VIII 3/4 6-24 3/4 6-24 3/4 6-25 3/4 6-25

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 296 TO FACILITY OPERATING LICENSE NO. DPR-77 AND AMENDMENT NO. 286 TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION

By application dated March 5, 2004, the Tennessee Valley Authority (the licensee) proposed amendments to the Technical Specifications (TSs) for Sequoyah Nuclear Plant (SQN), Units 1 and 2 (ADAMS Accession No. ML040760878). The proposed amendments eliminate the requirements in the TSs associated with hydrogen recombiners and hydrogen monitors. A notice of availability for this TS improvement using the Consolidated Line Item Improvement Process (CLIIP) was published in the Federal Register on September 25, 2003 (68 FR 55416).

The Nuclear Regulatory Commission (NRC) has revised Title 10, Code of Federal Regulations (10 CFR) Section 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors." The amended standards eliminated the requirements for hydrogen recombiners and relaxed the requirements for hydrogen and oxygen monitoring. In letters dated December 17, 2002, and May 12, 2003, the Nuclear Energy Institute (NEI) Technical Specification Task Force (TSTF) proposed to remove requirements for hydrogen recombiners and hydrogen and oxygen monitors from the standard technical specifications (STSs)

(NUREGs 1430 - 1434) on behalf of the industry to incorporate the amended standards. This proposed change was designated TSTF-447.

The NRC staff prepared a model safety evaluation (SE) for the elimination of requirements regarding containment hydrogen recombiners and the removal of requirements from TSs for containment hydrogen and oxygen monitors and solicited public comment (67 FR 50374, published August 2, 2002) in accordance with the CLIIP. The use of the CLIIP was intended to help the NRC to efficiently process amendments that propose to remove the hydrogen recombiner and hydrogen and oxygen monitor requirements from TSs. Licensees of nuclear power reactors to which this model applied were informed (68 FR 55416, published September 25, 2003) 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.

2.0 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 CLIIP is intended to improve the efficiency of NRC licensing processes.

This is accomplished by processing proposed changes to the STSs in a manner that supports subsequent license amendment applications. The CLIIP includes an opportunity for the public to comment on proposed changes to the STSs following a preliminary assessment by the NRC staff and finding that the change will likely be offered for adoption by licensees. The NRC staff evaluates any comments received for a proposed change to the STSs and either reconsiders the change or proceeds with announcing the availability of the change for proposed adoption by licensees. Those licensees opting to apply for the subject change to TSs are responsible for reviewing the staffs 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.

The Commissions regulatory requirements related to the content of TSs are set forth in 10 CFR 50.36. This regulation requires that the TSs include items in five specific categories.

These categories include (1) safety limits, limiting safety system settings and limiting control settings, (2) limiting conditions for operation (LCO), (3) surveillance requirements, (4) design features, and (5) administrative controls. However, the regulation does not specify the particular TSs to be included in a plants license.

Additionally, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether an LCO is required to be included in the TS. These criteria are as follows:

1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

2. A process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that assumes either the failure of or presents a challenge to the integrity of a fission product barrier.

3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

4. A structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

Existing LCOs and related surveillances included as TS requirements which satisfy any of the criteria stated above must be retained in the TSs. Those TS requirements which do not satisfy these criteria may be relocated to other licensee-controlled documents.

As part of the rulemaking that revised 10 CFR 50.44, the Commission retained requirements for ensuring a mixed atmosphere, inerting Mark I and II containments, and providing hydrogen control systems capable of accommodating an amount of hydrogen generated from a metal-water reaction involving 75 percent of the fuel cladding surrounding the active fuel region in Mark III and ice condenser containments. The Commission eliminated the design-basis loss-of-coolant accident (LOCA) hydrogen release from 10 CFR 50.44 and consolidated the requirements for hydrogen and oxygen monitoring to 10 CFR 50.44 while relaxing safety classifications and licensee commitments to certain design and qualification criteria. The Commission also relocated without change, the hydrogen control requirements in 10 CFR 50.34(f) to 10 CFR 50.44 and the high point vent requirements from 10 CFR 50.44 to 10 CFR 50.46a.

3.0 EVALUATION The ways in which the requirements and recommendations for combustible gas control 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 Three Mile Island (TMI), Unit 2, accident are likely to have been the subject of confirmatory orders that imposed the combustible gas control functions described in NUREG-0737, "Clarification of TMI Action Plan Requirements," as obligations. The issuance of plant-specific amendments to adopt these changes, which would remove hydrogen recombiner and hydrogen monitoring controls from TSs, supersede the combustible gas control specific requirements imposed by post-TMI confirmatory orders.

3.1 Hydrogen Recombiners The revised 10 CFR 50.44 no longer defines a design-basis LOCA hydrogen release, and eliminates the requirements for hydrogen control systems to mitigate such a release. The installation of hydrogen recombiners and/or vent and purge systems required by 10 CFR 50.44(b)(3) was intended to address the limited quantity and rate of hydrogen generation that was postulated from a design-basis LOCA. The Commission has found that this hydrogen release is not risk-significant because the design-basis LOCA hydrogen release does not contribute to the conditional probability of a large release up to approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the onset of core damage. In addition, these systems were ineffective at mitigating hydrogen releases from risk-significant beyond design-basis accidents. Therefore, the Commission eliminated the hydrogen release associated with a design-basis LOCA from 10 CFR 50.44 and the associated requirements that necessitated the need for the hydrogen recombiners and the backup hydrogen vent and purge systems. As a result, the staff finds that requirements related to hydrogen recombiners no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in TSs and the existing TS requirements may, therefore, be eliminated for all plants.

3.2 Hydrogen Monitoring Equipment Section 50.44(b)(1), the STSs, and plant-specific TSs currently contain requirements for monitoring hydrogen. Licensees have also made commitments to design and qualification criteria for hydrogen monitors in Item II.F.1, Attachment 6 of NUREG-0737 and Regulatory Guide (RG) 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident." The hydrogen monitors are

required to assess the degree of core damage during a beyond design-basis accident and confirm that random or deliberate ignition has taken place. If an explosive mixture that could threaten containment integrity exists during a beyond design-basis accident, then other severe accident management strategies, such as purging and/or venting, would need to be considered.

The hydrogen monitors are needed to implement these severe accident management strategies.

With the elimination of the design-basis LOCA hydrogen release, hydrogen monitors are no longer required to mitigate design-basis accidents and, therefore, the hydrogen monitors do not meet the definition of a safety-related component as defined in 10 CFR 50.2. RG 1.97 recommends classifying the hydrogen monitors as Category 1. Category 1 in RG 1.97 is intended for key variables that most directly indicate the accomplishment of a safety function for design-basis accident events and, therefore, are items usually addressed within TSs. As part of the rulemaking to revise 10 CFR 50.44, the Commission found that the hydrogen monitors no longer meet the definition of Category 1 in RG 1.97. The Commission concluded that Category 3, as defined in RG 1.97, is an appropriate categorization for the hydrogen monitors because the monitors are required to diagnose the course of beyond design-basis accidents.

Hydrogen monitoring is not the primary means of indicating a significant abnormal degradation of the reactor coolant pressure boundary. Section 4 of Attachment 2 to SECY-00-0198, "Status Report on Study of Risk-Informed Changes to the Technical Requirements of 10 CFR Part 50 (Option 3) and Recommendations on Risk-Informed Changes to 10 CFR 50.44 (Combustible Gas Control)," found that the hydrogen monitors were not risk-significant. Therefore, the staff finds that hydrogen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in TSs and, therefore, may be relocated to other licensee-controlled documents.

However, because the monitors are required to diagnose the course of beyond design-basis accidents, each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing beyond design-basis accidents.

The elimination of post-accident sampling system requirements from some plant-specific TSs (and associated CLIIP notices) indicated that during the early phases of an accident, safety-grade hydrogen monitors provide an adequate capability for monitoring containment hydrogen concentration. The staff has subsequently concluded that Category 3 hydrogen monitors also provide an adequate capability for monitoring containment hydrogen concentration during the early phases of an accident.

4.0 VERIFICATIONS AND COMMITMENTS As requested by the staff in the notice of availability for this TS improvement, the licensee has addressed the following plant-specific verifications and commitments.

4.1 Each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing beyond design-basis accidents.

The licensee has verified that it has a hydrogen monitoring system capable of diagnosing beyond design-basis accidents. The licensee has committed to maintain the hydrogen monitors within its Technical Requirements Manual. The licensee will

implement this commitment in conjunction with the implementation of this license amendment.

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 licensees 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.) 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 Tennessee State official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. 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 (69 FR 19576; April 13, 2004). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 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.

5.0 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 these amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: W. Reckley Dated: September 20, 2004

Mr. Karl W. Singer SEQUOYAH NUCLEAR PLANT Tennessee Valley Authority cc:

Mr. Ashok S. Bhatnagar, Senior Vice President Mr. Pedro Salas, Manager Nuclear Operations Licensing and Industry Affairs Tennessee Valley Authority Sequoyah Nuclear Plant 6A Lookout Place Tennessee Valley Authority 1101 Market Street P.O. Box 2000 Chattanooga, TN 37402-2801 Soddy Daisy, TN 37384-2000 Mr. James E. Maddox, Vice President Mr. David A. Kulisek, Plant Manager Engineering & Technical Services Sequoyah Nuclear Plant Tennessee Valley Authority Tennessee Valley Authority 6A Lookout Place P.O. Box 2000 1101 Market Street Soddy Daisy, TN 37384-2000 Chattanooga, TN 37402-2801 Senior Resident Inspector Mr. Randy Douet Sequoyah Nuclear Plant Site Vice President U.S. Nuclear Regulatory Commission Sequoyah Nuclear Plant 2600 Igou Ferry Road Tennessee Valley Authority Soddy Daisy, TN 37379 P.O. Box 2000 Soddy Daisy, TN 37384-2000 Mr. Lawrence E. Nanney, Director Division of Radiological Health General Counsel Dept. of Environment & Conservation Tennessee Valley Authority Third Floor, L and C Annex ET 11A 401 Church Street 400 West Summit Hill Drive Nashville, TN 37243-1532 Knoxville, TN 37902 County Mayor Mr. John C. Fornicola, Manager Hamilton County Courthouse Nuclear Assurance and Licensing Chattanooga, TN 37402-2801 6A Lookout Place 1101 Market Street Ms. Ann P. Harris Chattanooga, TN 37402-2801 341 Swing Loop Road Rockwood, Tennessee 37854 Mr. Mark J. Burzynski, Manager Nuclear Licensing Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801