ML070390053

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License Amendment Request for Removal of Out of Date Requirements Associated with the Completion of the Control Room Intake / Booster Fan Modifications
ML070390053
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 01/31/2007
From: Brandi Hamilton
Duke Energy Corp
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 06-08
Download: ML070390053 (22)
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Text

BRUCE H HAMILTON Duke Vice President PoEnergy Oconee Nuclear Station Duke Energy Corporation ON01 VP / 7800 Rochester Highway Seneca, SC 29672 864 885 3487 864 885 4208 fax bhhamilton@duke-energy.corn January 31, 2007 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

Subject:

Oconee Nuclear Site, Units 1, 2 and 3 Docket Numbers 50-269, 50-270, and 50-287 License Amendment Request for Removal of Out of Date Requirements Associated With the Completion of the Control Room Intake / Booster Fan Modifications License Amendment Request No. 2006-08 In accordance with Title 10, Code of Federal Regulations, Part 50, Section 90 (10 CFR 50.90),

Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke) proposes to amend Appendix A, Technical Specifications, for Facility Operating Licenses (FOLs) DPR-38, DPR-47 and DPR-55 for Oconee Nuclear Station (ONS), Units 1, 2, and 3. The proposed License Amendment Request (LAR) proposes an administrative change that removes additional notes Technical Specification (TS) requirements that are no longer applicable to Oconee Nuclear niA Station due to the completion of Control Room Intake / Booster Fan Modifications.

Implementation of these changes will not result in an undue risk to the health and safety of the public. The Oconee Updated Final Safety Analysis Report has been reviewed and no further changes are required.

In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, these proposed changes have been reviewed and approved by the Plant Operations Review Committee and Nuclear Safety Review Board. Additionally, in accordance with 10 CFR 50.91, a copy of this proposed amendment is being sent to the South Carolina Department of Health and Environmental Control for review, and as deemed necessary and appropriate, subsequent consultation with the NRC staff.

rn www. duke-energy. com Do

Nuclear Regulatory Commission License Amendment Request No. 2006-08 January 31, 2007 Page 2 Inquiries on this proposed amendment requested should be directed to Reene' Gambrell of the Oconee Regulatory Compliance Group at (864) 885-3364.

Sincerely, B. H. Hamilton, Vice President Oconee Nuclear Site

Enclosures:

1. Notarized Affidavit
2. Evaluation of Proposed Change Attachments:
1. Technical Specifications - Mark Ups
2. Technical Specifications - Reprinted Pages

Nuclear Regulatory Commission License Amendment Request No. 2006-08 January 31, 2007 Page 3 cc Mr. L.N. Olshan, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, D.C. 20555 Mr. W. D. Travers, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. D. W. Rich Senior Resident Inspector Oconee Nuclear Station Mr. Henry Porter, Director Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health & Environmental Control 2600 Bull Street Columbia, S.C. 29201

Nuclear Regulatory Commission License Amendment Request No. 2006-08 January 31, 2007 Page 4 bcc: w/attachments L.F. Vaughn R.L. Gill - NRI & IA C. J. Thomas - MNS R. D. Hart - CNS B. G. Davenport R.V. Gambrell S. D. Capps R. H. Burley K. R. Alter BWOG Tech Spec Committee ELL NSRB File- T. S. Working ONS Document Management

ENCLOSURE 1 NOTARIZED AFFIDAVIT

- Notarized Affidavit License Amendment Request No. 2006-08 January 31, 2007 Page 1 AFFIDAVIT B. H. Hamilton, being duly sworn, states that he is Vice President, Oconee Nuclear Site, Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC, that he is authorized on the part of said Company to sign and file with the U.S. Nuclear Regulatory Commission this revision to the Renewed Facility Operating License Nos. DPR-38, DPR-47, and DPR-55; and that all the statements and matters set forth herein are true and correct to the best of his knowledge.

B. H. Hamilton, Vice President Oconee Nuclear Site Subscribed and sworn to before me this day oi 07 T~otary Pub-lic My Commission Expires:

2o/4 //i?/

ENCLOSURE 2 EVALUATION OF PROPOSED CHANGE

- Evaluation of Proposed Change License Amendment Request No. 2006-08 January 31, 2007 Page 1

Subject:

License Amendment Request for Removal of Out of Date Requirements Associated With the Completion of the Control Room Intake / Booster Fan Modifications

1. DESCRIPTION
2. PROPOSED CHANGE
3. BACKGROUND
4. TECHNICAL ANALYSIS
5. REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration
6. ENVIRONMENTAL CONSIDERATION

- Evaluation of Proposed Change License Amendment Request No. 2006-08 January 31, 2007 Page 2

1.0 DESCRIPTION

Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke) proposes to amend the Oconee Nuclear Station Renewed Facility Operating License (FOL) and Technical Specifications (TS) in accordance with 10 CFR 50.90. This License Amendment Request proposes to modify Technical Specification 3.7.9 to remove the notes allowing and extended Completion Time when entering the conditions because of Control Room Intake / Booster Fan Modification.

2.0 PROPOSED CHANGE

The Oconee Technical Specifications currently contain notes which allow additional time to complete Required Actions B. I and C. I of TS 3.7.9 when entering the condition to implement the Control Room Intake/ Booster Fan Modification. Duke proposes removing these notes as the modifications have been completed. The changes involved are described below:

The Note to RA B. 1 of TS 3.7.9 currently indicates that an additional 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> is allowed when entering this condition for implementation of Control Room Intake /

Booster Fan Modification. Duke proposes that this note be removed.

The Note to RA C.1 of TS 3.7.9 currently indicates that an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed when entering this condition for implementation of Control Room Intake /

Booster Fan Modification. Duke proposes that this note be removed.

3.0 BACKGROUND

The NRC issued Amendment Nos. 338, 339, and 339 on June 1, 2004 to Renewed Facility Operating Licenses DPR-38, DPR-47 and DPR-55 respectively for the Oconee Nuclear Station, Units 1, 2 and 3. These amendments issued changes to the Technical Specification associated with the use of an alternate source term.

The amendments revised Technical Specification (TS) 3.7.9, "Control Room Ventilation System (CRVS) Booster Fans." Notes were added to the Completion Times for the proposed Control Room Ventilation System (CRVS) TS conditions for one and two inoperable CRVS Booster Fans respectively. These notes allowed additional completion time when entering the TS Condition to implement the Control Room Intake / Booster Fan Modification.

The Control Room Intake / Booster Fan Modifications have been completed. As

- Evaluation of Proposed Change License Amendment Request No. 2006-08 January 31, 2007 Page 3 such, the TS change allowed by Amendment Nos. 338, 339, and 339 is no longer applicable. Consequently, the Completion Time notes are outdated and should be removed.

4.0 TECHNICAL ANALYSIS

With the completion of the Control Room Intake / Booster Fan Modification, the notes that allow extension of the Completions Times (CTs) for Required Actions (RAs) B. 1 and C. 1 are out of date. Therefore, Duke proposes to remove the out of date notes.

The note to RA B. 1 indicates that an additional 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> is allowed when entering this condition for implementation of Control Room Intake / Booster Fan Modification.

The note to RA C. 1 indicates that an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is allowed when entering this condition for implementation of Control Room Intake / Booster Fan modification.

With the completion of the Control Room Intake / Booster Fan Modification, these notes are no longer applicable and can be removed.

Since the TS changes described above involve only the removal of TS notes that are no longer applicable, the proposed changes are administrative.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration In accordance with 10 CFR 50.91, Duke has made the determination that this amendment request involves a No Significant Hazards Consideration by applying the standards established by the NRC regulations in 10 CFR 50.92.

This ensures that operation of the facility in accordance with the proposed amendment would not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated:

The proposed change to Technical Specification 3.7.9 removes out of date requirements associated with temporary extensions of Required

- Evaluation of Proposed Change License Amendment Request No. 2006-08 January 31, 2007 Page 4 Action Completion Times that are not applicable because of the completion of the Control Room Intake / Booster Fan Modification. As such, the proposed change is administrative. No actual plant equipment, operating practices, or accident analyses are affected by this change.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident from any kind of accident previously evaluated:

The proposed change to Technical Specification 3.7.9 removes out of date requirements associated with a temporary extension of Required Actions Completion Times that are no longer applicable because of the completion of the Control Room Intake / Booster Fan Modification. As such, the proposed changes are administrative. No actual plant equipment, operating practices, or accident analyses are affected by this change. No new accident causal mechanisms are created as a result of this change. The proposed change does not impact any plant systems that are accident initiators; neither does it adversely impact any accident mitigating systems. Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) Involve a significant reduction in a margin of safety:

The proposed change does not adversely affect any plant safety limits, set points, or design parameters. The change also does not adversely affect the fuel, fuel cladding, Reactor Coolant System, or containment integrity. The proposed change eliminates out of date requirements and is administrative in nature. Therefore, the proposed change does not involve a reduction in a margin of safety.

Duke has concluded, based on the above, that there are no significant hazards considerations involved in this amendment request.

- Evaluation of Proposed Change License Amendment Request No. 2006-08 January 31, 2007 Page 5

6.0 ENVIRONMENTAL CONSIDERATION

In accordance with 10 CFR 51.22(b), an evaluation of the License Amendment Request (LAR) has been performed to determine whether or not it meets the criteria for categorical exclusion set forth in 10 CFR 51.22(c)9 of the regulations. The LAR does not involve:

1) A significant hazards consideration.

As demonstrated in Section 5.1, this proposed amendment involves no significant hazards consideration.

2) A significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

This LAR is administrative and will not significantly change the types or amounts of any effluents that may be released offsite.

3) A significant increase in the individual or cumulative occupational radiation exposure.

This LAR is administrative and will not increase the individual or cumulative occupational radiation exposure.

In summary, this LAR meets the criteria set forth in 10 CFR 51.22 (c)9 of the regulations for categorical exclusion from an environmental impact statement.

- Technical Specification Mark-Ups License Amendment Request No. 2006-08 January 31, 2007 Page 1 ATTACHMENT 1 TECHNICAL SPECIFICATION - MARK UPS

CRVS Booster Fans 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Control Room Ventilation System (CRVS) Booster Fans LCO 3.7.9 Two CRVS Booster Fan trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4, During movement of recently irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Control Room pressure A.1 Restore Control Room 30 days

< 0.0 psig during pressure to > 0.0 psig operation of two CRVS during operation of two Booster Fan trains. CRVS Booster Fan trains.

B. One CRVS Booster Fan B. 1 Restore CRVS B ter K I('Tr-:

train inoperable for Fan train to 0RABLE A- AG+;---1 Oa k-.-  ;-

reasons other than status. allowIA~ed- wAfh.en entering Condition A. thiG conRdition for /

imnlQme~nf~finn Af cnntrml

""Mfi at r, "Cv4 cr 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

/

~(continuedj OCONEE UNITS 1, 2, & 3 3.7.9-1 Amendment

CRVS Booster Fans 3.7.9 CONDITION REQUIRED ACTION COMP LITIME C. Two CRVS Booster Fan C.1 Restore one CR NOTE.-*

trains inoperable for Booster Fan tr *n to An additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is reasons other than OPERABLE atus. allowed when entering Condition A. this con-ditionR for.

implementation of Control RoGm n*take/booster fan odificatiour 24 our D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met in MODE AND 1,2, 3, or4.

D.2 Be in MODE 5 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> E. Required Action and E.1 Suspend movement of Immediately associated Completion recently irradiated fuel Time not met during assemblies.

movement of recently irradiated fuel assemblies.

OCONEE UNITS 1, 2, & 3 3.7.9-2 Amendm

CRVS Booster Fans B 3.7.9 BASES ACTIONS A.1 (continued) be OPERABLE in this Condition. If one or both CRVS Booster Fans are simultaneously inoperable, the Completion Time for these separate.

Conditions is more limiting than the 30 day Completion Time for Action A. 1. If OPERABLE the CRVS Booster Fan train(s) can provide some dose reduction. The 30 day Completion Time is based on the low probability of an accident occurring during the time period and the potential for OPERABLE CRVS Booster Fan trains to provide some dose reduction.

B._1 With one CRVS Booster Fan train inoperable for reasons other than Condition A, action must be taken to restore the train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, the remaining OPERABLE CRVS Booster Fan train provid ction for personnel in (the rerfainingtain t p~rovide somedose redcin E

thes Contion for p of Control Room Itike/Booste r Fan With the two CRVS Booster Fan trains inoperable for reasons other than A note is being added to4 alo-W forC an additional 18 houF hr etFR Condition A, one train must be restored to OP-ERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In this~dtin ,capab'l Con-t iimize oo-mI ntake/B the rýdition ooster Fa ton dose ie mne rng ntati on Of d athis rol R

r. CRondiio fo imr ple c Ce / *
  • V ahae d in C on Ijlrco m d uring a nd after a n uaal [ble. h 4hu Completion Time is based on the low Fa

/Iro bab ility of an accident occurring during this time period. '

(,iGb AWifhtheinopeal ig CRVS d eBooster tG ale-P

  • o Fanf atrainsad-dit*.AA;-l 4R- hG1F canoterblefo...... . en reaosotored .. toa D.1 If the inoperable CRVS oser Fan trains cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve)thi&

OCONEE UNITS 1, 2, & 3 B 3.7.9-3 Amendi

- Technical Specification Reprinted Pages License Amendment Request No. 2006-08 January 31, 2007 Page 1 ATTACHMENT 2 TECHNICAL SPECIFICATION - REPRINTED PAGES Remove Page Insert Page Technical Specifications 3.7.9-1 3.7.9-1 3.7.9-2 3.7.9-2 3.7.9-3 Technical Specifications Bases 3.7.9-3 3.7.9-3 3.7.9-4 3.7.9-4 3.7.9-5 3.7.9-5

CRVS Booster Fans 3.7.9 3.7 PLANT SYSTEMS 3.7.9 Control Room Ventilation System (CRVS) Booster Fans LCO 3.7.9 Two CRVS Booster Fan trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4, During movement of recently irradiated fuel assemblies.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Control Room pressure A.1 Restore Control Room 30 days

_<0.0 psig during pressure to > 0.0 psig operation of two CRVS during operation of two Booster Fan trains. CRVS Booster Fan trains.

B. One CRVS Booster Fan B.1 Restore CRVS Booster 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> train inoperable for Fan train to OPERABLE reasons other than status.

Condition A.

C. Two CRVS Booster Fan C.1 Restore one CRVS 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> trains inoperable for Booster Fan train to reasons other than OPERABLE status.

Condition A.

(continued)

OCONEE UNITS 1, 2, & 3 3.7.9-1 Amendment Nos.

CRVS Booster Fans 3.7.9 CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time not met in MODE AND 1, 2, 3, or4.

D.2 Be in MODE 5 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> E. Required Action and E.1 Suspend movement of Immediately associated Completion recently irradiated fuel Time not met during assemblies.

movement of recently irradiated fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Operate each CRVS Booster Fan train for 92 days

_ 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

SR 3.7.9.2 Perform required CRVS Booster Fan train In accordance with the filter testing in accordance with the Ventilation VFTP Filter Testing Program (VFTP).

SR 3.7.9.3 Verify two CRVS Booster Fan trains can 18 months maintain the Control Room at a positive pressure.

OCONEE UNITS 1, 2, & 3 3.7.9-2 Amendment Nos.

CRVS Booster Fans B 3.7.9 BASES ACTIONS A.1 (continued) be OPERABLE in this Condition. If one or both CRVS Booster Fans are simultaneously inoperable, the Completion Time for these separate Conditions is more limiting than the 30 day Completion Time for Action A. 1. If OPERABLE the CRVS Booster Fan train(s) can provide some dose reduction. The 30 day Completion Time is based on the low probability of an accident occurring during the time period and the potential for OPERABLE CRVS Booster Fan trains to provide some dose reduction.

B.1 With one CRVS Booster Fan train inoperable for reasons other than Condition A, action must be taken to restore the train to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. In this Condition, the remaining OPERABLE CRVS Booster Fan train provides some dose reduction for personnel in the Control Room. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on the low probability of an accident occurring during this time period, and ability of the remaining train to provide some dose reduction.

C._1 With the two CRVS Booster Fan trains inoperable for reasons other than Condition A, one train must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In this Condition, the capability to minimize the radiation dose to personnel located in the Control Room during and after an accident is unavailable. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is based on the low probability of an accident occurring during this time period.

D.1 If the inoperable CRVS Booster Fan trains cannot be restored to OPERABLE status within' the required Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

OCONEE UNITS 1, 2, & 3 B 3.7.9-3 Amendment Nos.

CRVS Booster Fans B 3.7.9 BASES ACTIONS E.1 (continued)

During movement of recently irradiated fuel assemblies, when one or more CRVS trains are inoperable, action must be taken immediately to suspend activities that could release radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

SURVEILLANCE SR 3.7.9.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train once every 92 days adequately checks this system. The trains need only be operated for

_>one hour and all dampers verified to be OPERABLE to demonstrate the function of the system. This test includes an external visual inspection of the CRVS Booster Fan trains. The 92 day Frequency is based on the known reliability of the equipment.

SR 3.7.9.2 This SR verifies that the required CRVS Booster Fan train testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CRVS Booster Fan train filter test frequencies are in accordance with Regulatory 'Guide 1.52 (Ref. 4). The VFTP includes testing HEPA filter performance and carbon adsorber efficiency. Specific test frequencies and additional information are discussed in detail in the VFTP.

SR 3.7.9.3 This SR verifies the integrity of the Control Room enclosure. The Control Room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify that the CRVS Booster Fan trains are functioning properly. During the emergency mode of operation, the CRVS Booster Fan trains are designed to pressurize the Control Room to minimize unfiltered inleakage. The CRVS Booster Fan trains are designed to maintain this positive pressure with both trains in operation.

The Frequency of 18 months is consistent with industry practice.

OCONEE UNITS 1, 2, & 3 B 3.7.9-4 Amendment Nos. , , & I

CRVS Booster Fans B 3.7.9 BASES REFERENCES 1. UFSAR, Section 9.4.

2. UFSAR, Chapter 15.
3. 10 CFR 50.36.
4. Regulatory Guide 1.52, Rev. 2, March 1978.

OCONEE UNITS 1, 2, & 3 B 3.7.9-5 Amendment.Nos. , , & I

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