ML090340465

Issuance of Amendments Regarding Ventilation Filter Testing

ML090340465
Person / Time
Site:	Hatch
Issue date:	04/15/2009
From:	Martin R Plant Licensing Branch II
To:	Madison D Southern Nuclear Operating Co
Martin, R E, NRR/DORL/LPLII-1, 415-1493
References
TAC MD9236, TAC MD9237
Download: ML090340465 (20)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Apr; 1 15, 2009 Mr. Dennis R. Madison Vice President - Hatch Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North Baxley, GA 31513

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING VENTILATION FILTER TESTING (TAC NOS. MD9236 AND MD9237)

Dear Mr. Madison:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment N0261 to Renewed Facility Operating License DPR-57 and Amendment No.205to Renewed Facility Operating License NPF-5 for the Edwin I. Hatch Nuclear Plant, Units 1 and 2, respectively. The amendments consist of changes to the technical specifications (TSs) in response to your application dated July 15, 2008.

The amendments revise the TS 5.5.7 Ventilation Filter Testing Program to eliminate the requirement to test the power output of the standby gas treatment system's (SGTS) electric heater and to raise the testing requirement for the relative humidity of the charcoal adsorber air stream.

Also, a surveillance requirement is being revised to eliminate reference to the heater and to shorten the required SGTS run time.

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

Sincerely,

/?~~l~

V ~bei1 E. Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosures:

1. Amendment N0261 to DPR-57

2. Amendment N0205to NPF-5

3. Safety Evaluation cc w/encls: Distribution via ListServ

Edwin I. Hatch Nuclear Plant, Units 1 & 2 cc:

Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE., Suite 1252 Atlanta, GA 30334 Chairman Appling County Commissioners County Courthouse Baxley, GA 31513 Additional Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-321 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO.1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 261 Renewed License No. DPR-57

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

A. The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit 1 (the facility) Renewed Facility Operating License No. DPR-57 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated July 15, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 Commission's regulations set forth in 10 CFR Chapter I; 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 Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-57 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No.26t are hereby incorporated in the license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

r FOR THE NUCLEAR REGULATORY COMMISSION "11{~.

Melanie C. Wong, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facililty Operating License 1\10. DPR-57 and the Technical Specifications Date of Issuance: Apr; 1 15, 2009

ATTACHMENT TO LICENSE AMENDMENT N0261 RENEWED FACILITY OPERATING LICENSE NO. DPR-57 DOCKET NO. 50-321 Replace the following pages of the License and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License Page 4 Page 4 3.6-40 3.6-40 5.0-12 5.0-12

-4 for sample analysis or Instrument calibration, or associated with radloactlvs apparatus or components; (6) Southern Nuclear, pursuant 10 the Act and 10 CFA Parts 30 and 70, to possess, but not separate,such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and Is SUbject 10 theconditions*

,specified In the following Commission regulations In 10 CFA Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part sa, and Section 70.32 of Part 70; all appncable provisions of the Act and the rules, regulations. and orders of the CommissIon now or hereafter In eHect; and the additional conditions specified or Incorporated below:

(1) Maximum Power Level Southam Nuclear Is authorized 10 operate the facility at steady slate reactor core power levels notIn excess of 2B04megawatts thermal.

(2) , Technlcal Specifications The Technlcel Specifications (Appendix: A) and Ihe Environmental' Protection Plan (Appendix B), as revised through Amendment No.

are hereby Incorporated In.the renewed license. Southern Nuclear shall operate the facility In accordance with the TechnIcal Specifications and the Environmental Protection Plan.

The Survel1lance Requlrement (SR) contalned In theTechnical Specifications and fisted below. Is not required to be performed .

Immediately upon Implementation of AmendmenlNo. 195. The SR nsted below shan be successfully demon'slratedprlor to the time and conditIon specified:

SR 3.8.1.18 shall be successfully demonstrated at Itsnext regularly scheduled performance (3) fire Protection Southern Nuclear shall Implement and maintain In effect all provisions of the fire protection program, whIch Is referenced In the Updated FInal Safety Analysis Report for thefacility, as contained In the updated Fire Hazards Analysis and Are ProteetJon Program for Edwin I. Hatch Nuclear Plant.Units 1 and2. which was originallysubmitted by letter dated July 22. 1986. Southem Nuclear may make changes to the fire protecUon program without priorCommission approval only ff the changes Renewed Llcense No. DPR-57 Amendment N0I 261

SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two or more required SGT F.1 -----------NOTE---*--------*

subsystems inoperable LCO 3.0.3 is not during movement of applicable.

irradiated fuel assemblies in the secondary containment, during CORE Suspend movement of Immediately ALTERATIONS, or during irradiated fuel OPDRVs. assemblies in secondary containment.

AND F.2 Suspend CORE Immediately ALTERATIONS.

AND F.3 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each required SGT subsystem for 31 days

~ 15 continuous minutes.

SR 3.6.4.3.2 Perform required SGT filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.6.4.3.3 Verify each required SGT subsystem actuates on 24 months an actual or simulated initiation signal.

HATCH UNIT 1 3.6-40 Amendment N0261

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, Section C.6.b, and ASME N510-1989, Section 15 and Appendix B, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM 03803-1989 at a temperature of ~ 30°C and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration (%) RH (%)

SGT System 2.5 95 MCREC System 2.5 95

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with ASME N510-1989, Section 8.5.1, at the system flowrate specified below.

ESF Ventilation System l\P Cinches wg) Flowrate (cfm)

SGT System <6 3000 to 4000 MCREC System <6 2250 to 2750

e. (Not used)

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.8 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the main condenser o11gas treatment system, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

(continued)

HATCH UNIT 1 5.0-12 Amendment No. 261

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-366 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO.2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment NO.205 Renewed License No. NPF-5

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

A. The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit 2 (the facility) Renewed Facility Operating License No. NPF-5 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated July 15, 2008, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 Commission's regulations set forth in 10 CFR Chapter I; 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 Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-5 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment N0205 are hereby incorporated in the license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Melanie C. Wong, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facililty Operating License No. NPF-5 and the Technical Specifications Date of Issuance: Apr; 1 15, 2009

ATTACHMENT TO LICENSE AMENDMENT NO. 205 RENEWED FACILITY OPERATING LICENSE NO.*I\JPF-5 DOCKET NO. 50-366 Replace the following pages of the License and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License Page 4 Page 4 TSs TSs 3.6-41 3.6-41 5.0-12 5.0-12

-4 (6) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain, and is subject to, the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions" specified or incorporated below:

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at steady state reactor core power levels not in excess of 2,804 megawatts thermal, in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No.205 ,are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the renewed license or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the license supported by a favorable evaluation by the Commission.

(a) Fire Protection Southern Nuclear shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the the Updated Final Safety Analysis Report for the facility, as contained 2 The original licensee authorized to possess, use, and operate the facility was Georgia Power Company (GPC). Consequently, certain historical references to GPC remain in certain license conditions.

Renewed License No. NPF-5 Amendment N0205

SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two or more required SGT E.1 Enter LCO 3.0.3. Immediately subsystems inoperable in MODE 1, 2, or 3.

F. Two or more required SGT F.1 ----------- NOTE-----------

subsystems inoperable LCO 3.0.3 is not during movement of applicable.

irradiated fuel assemblies ---_._---_ .._-----_ ....... _.- ..._-

in the secondary containment, during CORE Suspend movement of Immediately ALTERA TIONS, or during irradiated fuel OPDRVs. assemblies in secondary containment.

AND F.2 Suspend CORE Immediately ALTERATIONS.

AND F.3 Initiate action to Immediately suspend OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each required SGT subsystem for 31 days

~ 15 continuous minutes.

SR 3.6.4.3.2 Perform required SGT filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP). the VFTP SR 3.6.4.3.3 Verify each required SGT subsystem actuates on 24 months an actual or simulated initiation signal.

HATCH UNIT 2 3.6-41 Amendment No. 205

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP) (continued)

c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, Section C.6.b, and ASME N510-1989, Section 15 and Appendix B, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM 03803-1989 at a temperature of :S 30°C and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration (%) RH (%)

SGT System 2.5 95 MCREC System 2.5 95

d. Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with ASME N510-1989, Section 8.5.1, at the system flowrate specified below.

ESF Ventilation System ~P (inches wg) Flowrate (cfm)

SGT System <6 3000 to 4000 MCREC System <6 2250 to 2750

e. (Not used)

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.8 Explosive Gas and Storage Tank Radioactivitv Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the main condenser offgas treatment system, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.

(continued)

HATCH UNIT 2 5.0-12 Amendment No. 205

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. ?fiHO RENEWED FACILITY OPERATING LICENSE NO. DPR-57 AND AMENDMENT NO.20STO RENEWED FACILITY OPERATING LICENSE NO. NPF-5 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-321 AND 50-366

1.0 INTRODUCTION

By application dated July 15, 2008, to the U.S. Nuclear Regulatory Commission (NRC, the Commission) (Agencywide Documents and Management System (ADAMS) Accession No. ML081970620), Southern Nuclear Operating Company, Inc. (SNC, the licensee), requested changes to the technical specifications (TSs) for the Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2 (HNP).

The proposed changes would revise the TS Section 5.5.7, "Ventilation Filter Testing Program,"

to remove the standby gas treatment system (SGTS) heaters from the TS. As a consequence, the relative humidity (RH) criteria for carbon filter efficiency testing provided in TS Section 5.5.7.c, will be changed from 70 percent to 95 percent, and a surveillance requirement (SR) for the SGTS which references the heater, will be revised.

2.0 REGULATORY EVALUATION

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.36, "Technical Specifications," the HNP TS includes requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Acceptable methods to meet the requirements of 10 CFR 10 CFR 50.36 for in-place testing of engineered safety feature (ESF) atmosphere cleanup systems and laboratory testing of activated carbon, are contained in the following:

Revision 2 of Regulatory Guide (RG) 1.52, "Design, Testing, And Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration And Adsorption Units of Light-Water-Cooled Nuclear Power Plants," and Revision 3 of RG 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident

-2 Engineered- Safety-Feature Atmosphere Cleanup Systems in Light-water-Cooled Nuclear Power Plants," which provides guidance on design, testing, and maintenance of ESF air filtration and adsorption systems.

Generic Letter (GL) 99-02, "Laboratory Testing of Nuclear Grade Activated Charcoal," June 3, 1999, which provides requirements for charcoal tested in accordance with American Society for Testing and Materials (ASTM) 03803-1989.

ASTM 03803-1989, "Standard Test Method for Nuclear Grade activated Carbon," provides QC methodology for charcoal testing at 30 and 95% relative humidity.

3.0 TECHNICAL EVALUATION

As described in the licensee's request, the proposed changes are needed to support removing the SGTS heaters from the TSs. Although the heaters will be removed from the TS and will no longer be credited in the design basis accident analyses, the licensee states that "the heater will remain in place and functional as a defense-in-depth feature." The licensee proposes three changes to the HNP TS:

3.1 TS 5.5.7, "Ventilation Filter Testing Program," paragraph c, is changed as follows:

c. Oemonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, Section C.6.b, and ASME N510-1989, Section 15 and Appendix B, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM 03803 1989 at a temperature of < 30 [degrees Centigrade] and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration (%) RH (%)

SGT System 2.5 70 changes to 95 MCREC System 2.5 95 TS 5.5.7.c is revised to change the relative humidity at which the charcoal adsorber must be tested from 70 percent to 95 percent. GL 99-02, dated June 3, 1999, reflects the acceptability to the NRC staff of conducting the charcoal adsorber test at an RH of 70 percent if heaters are used in the system or at 95 percent if no heaters are included in the system design or no credit is given for them, as follows:

Analyses of design-basis accidents assume a particular ESF charcoal filter adsorption efficiency when calculating offsite and control room operator doses.

Licensees then test charcoal filter samples to determine whether the filter adsorber efficiency is greater than that assumed in the design-basis accident analysis. The laboratory test acceptance criteria contain a safety factor to ensure that the efficiency assumed in the accident analysis is still valid at the end of the operating cycle. Because ASTM 03803-1989 is a more accurate and demanding test than older tests, addressees that upgrade their TS to this new protocol will be

-3 cycle. Because ASTM 03803-1989 is a more accurate and demanding test than older tests, addressees that upgrade their TS to this new protocol will be able to use a safety factor as low as 2 for determining the acceptance criteria for charcoal filter efficiency. This safety factor can be used for systems with or without humidity control because the lack of humidity control is already accounted for in the test conditions (systems without humidity control test at 95 percent RH and systems with humidity control can test at 70 percent RH).

An amendment to HNP TS 5.5.7 was issued on October 3,2000, (AOAMS Accession No. ML003757914), to include the requirement for testing charcoal filter samples in accordance with ASTM 03803-1989 and the application of a safety factor of 2 to the assumed charcoal filter efficiency. As the licensee notes in its submittal, it will continue to test, with respect to RH, in accordance with ASTM 03803-1989 and will continue to maintain the safety factor of 2 on the calculated methyl iodide penetration criterion. This will continue to support the assumption of 95 percent carbon filter efficiency in accident analyses. The safety factor of 2 and the 95 percent filter efficiency factors are unchanged and continue to be acceptable.

As the licensee notes, the option of conducting charcoal testing at 70 percent if heaters are included in the design and at 95 percent RH without heaters is reflected in the NRC Standard Technical Specifications, NUREG-1433, as follows:

When ASTM 03803-1989 is used with 30°C (86°F) and 95% RH (or 70% RH with humidity control) is used, the staff will accept the following: Safety factor ~ 2 for systems with or without humidity control.

As discussed above, the NRC reviewed the proposed change and finds that the licensee will test charcoal adsorbers in accordance with the RH provision of ASTM 03803-1989, of 95 percent to continue to show methyl iodide penetration of less than 2.5 percent (and its associated safety factor of 2.0). This is in accordance with the NRC staff guidance discussed above for RH and is, therefore, acceptable.

3.2 TS 5.5.7. paragraph e, as shown below. is deleted.

e. Demonstrate that the heaters for the ESF system dissipate the value specified below when tested in accordance with ASME N510-1989, Section 14.5.1 ESF Ventilation system Wattage (kW)

GT System 15 to 20 As discussed above, the NRC staff has found the licensee's proposal to remove credit for the SGTS heaters and to compensate by changing the RH for charcoal testing from 70 percent to 95 percent to be acceptable. Accordingly, as credit is no longer taken for the heaters in the design basis accident analysis, the TS 5.5.7.e, requirement to demonstrate their operability may be deleted from the TS.

-4 3.3 Operating Time for SGTS Currently SR 3.6.4.3.1, is:

"Operate each required SGT subsystem for ~ 10 continuous hours with heaters operating."

The licensee proposes to change this to:

"Operate each required SGT subsystem for ~ 15 continuous minutes."

The purpose of the 1O-hour SR was to verify that both the heaters and the system are capable of operating as assumed in the accident analysis. In this case, the licensee proposes to remove the heaters from the TSs and to reduce the surveillance time from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 minutes and therefore, will no longer take credit for the operation of heaters in the accident analysis, as stated in the following paragraph from the licensee's submittal:

SR 3.6.4.3.1 currently requires that the SGTS be operated continuously for a period of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the electric heaters operating. The run time is based on reducing the moisture in the system. Following implementation of this amendment, the heater will no longer be a credited component of the SGTS train. Consequently, laboratory testing of the carbon will be done at a higher RH level (95%) to ensure adequate iodine adsorption with a moist bed. Keeping the system dry with heater operation will therefore no longer be necessary. Nevertheless, the heater will be retained for defense-in-depth purposes. The revised run time of 15 minutes is sufficient to ensure that the associated controls are functioning properly and to check for abnormalities such as excessive vibrations, motor failures, blockages, etc.

The licensee continues to verify the operability of the charcoal adsorbers by testing them at 95 percent RH as compared to 70 percent RH (see Section 3.1 above). The NRC staff's position, as outlined in Regulatory Position C.6.1 of RG 1.52, Revision 3, June 2001, is that ESF atmospheric cleanup trains should be operated for 15 minutes each month to justify operability of the system and its components. Since the operability of the charcoal adsorbers will be verified by this 15 minute run time, this requested change is consistent with the NRC staff's position and is acceptable.

3.4 Summary The NRC staff reviewed the changes to the TS and understands that the changes are based on the removal of credit for the heaters in the design basis accident analyses. The purpose of the heaters is humidity control; without the heaters charcoal adsorber testing must be conducted at 95 percent relative humidity. The revised TS 5.5.7.c will require testing at 95 percent relative humidity; therefore, the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendment. The State official had no comments.

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5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff 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 (74 FR 6668), dated February 10, 2009. 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.

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

Principal Contributors: R. Martin H. Walker Date of Issuance: Apr i 1 15, 2009

ML090340465 NRR-058 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA SCVB DE/SCVB/BC OGC NRR/LPL2-1/BC NAME RMartin SRohrer HWalker RDennig DRoth MWong DATE 4/15/09 4/9/09 3/16/09 3/16/09 3/20/09 4/10/09