ML113540250
| ML113540250 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 03/15/2012 |
| From: | John Jolicoeur Licensing Processes Branch (DPR) |
| To: | |
| Honcharik M | |
| Shared Package | |
| ML113550420 | List: |
| References | |
| TSTF-522 | |
| Download: ML113540250 (5) | |
Text
PROPOSED MODEL SAFETY EVALUATION FOR PLANT-SPECIFIC ADOPTION OF TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-522, REVISION 0, AREVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH@ USING THE CONSILIDATED LINE ITEM IMPROVEMENT PROCESS
1.0 INTRODUCTION
By letter dated [DATE], [LICENSEE] (the licensee) requested changes to the technical specifications (TSs) for [PLANT]. Specifically the licensee requested to adopt U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-522, ARevise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month@ (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100890316), dated March 30, 2010.
The proposed change would revise Surveillance Requirements (SRs) which currently require operating the heaters in ventilation systems for at least [10 continuous hours] every 31 days.
The SRs would be changed to require at least 15 continuous minutes of heater operation every 31 days.
{NOTE: Chose one of the following paragraphs, depending on the plant vendor/type.}
{For B&W Plants} Changes were proposed for [TS 3.7.10, "Control Room Emergency Ventilation System (CREVS)," TS 3.7.12, "Emergency Ventilation System (EVS)," and TS 3.7.13, "Fuel Storage Pool Ventilation System (FSPVS)." In particular SRs 3.7.10.1, 3.7.12.1 and 3.7.13.1],
which currently require operating the heaters in the respective systems for at least 10 continuous hours every 31 days, would be changed to require at least 15 continuous minutes of heater operation every 31 days.
{For Westinghouse Plants} Changes were proposed for [TS 3.6.11, "Iodine Cleanup System (ICS) (Atmospheric and Subatmospheric)," TS 3.6.13. "Shield Building Air Cleanup System (SBACS) (Dual and Ice Condenser)," TS 3.7.10, "Control Room Emergency Filtration System (CREFS)," TS 3.7.12, "Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System (PREACS)," TS 3.7.13, "Fuel Building Air Cleanup System (FBACS)," and TS 3.7.14, "Penetration Room Exhaust Air Cleanup System (PREACS)." In particular SRs 3.6.11.1, 3.6.13.1, 3.7.10.1, 3.7.12.1, 3.7.13.1, and 3.7.14.1], which currently require operating the heaters in the respective systems for at least 10 continuous hours every 31 days, would be changed to require at least 15 continuous minutes of heater operation every 31 days.
{For Combustion Engineering Plants} Changes were proposed for [TS 3.6.8, "Shield Building Exhaust Air Cleanup System (SBEACS) (Dual)," TS 3.6.10, "Iodine Cleanup System (ICS)
(Atmospheric and Dual)," TS 3.7.11 , "Control Room Emergency Air Conditioning System (CREACS)," TS 3.7.13, "Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System (PREACS)," TS 3.7.14, "Fuel Building Air Cleanup System (FBACS)," and TS 3.7.15, "Penetration Room Exhaust Air Cleanup System (PREACS)." In particular SRs 3.6.8.1, 3.6.10.1, 3.7.11.1, 3.7.13.1, 3.7.14.1 and 3.7.15.1], which currently require operating the heaters in the respective systems for at least 10 continuous hours every 31 days, would be changed to require at least 15 continuous minutes of heater operation every 31 days.
{For General Electric BWR/4 Plants} Changes were proposed for [TS 3.6.4.3, "Standby Gas Treatment (SGT) System," and TS 3.7.4, "Main Control Room Environmental Control (MCREC)]
System." In particular SRs 3.6.4.3.1 and 3.7.4.1], which currently require operating the heaters
in the respective systems for at least 10 continuous hours every 31 days, would be changed to require at least 15 continuous minutes of heater operation every 31 days.
{For General Electric BWR/6 Plants} Changes were proposed for [TS 3.6.4.3, "Standby Gas Treatment (SGT) System," and TS 3.7.3, "Control Room Fresh Air (CRFA) System." In particular SRs 3.6.4.3.1 and 3.7.3.1], which currently require operating the heaters in the respective systems for at least 10 continuous hours every 31 days, would be changed to require at least 15 continuous minutes of heater operation every 31 days.
The licensee stated that the license amendment request (LAR) is consistent with NRC-approved TSTF Traveler TSTF-522. The availability of this TS improvement was announced in the Federal Register on [Date] ([ ] FR [ ]) as part of the consolidated line item improvement process (CLIIP).
2.0 REGULATORY EVALUATION
One of the reasons air filtration and adsorption systems are required at nuclear power plants is to lower the concentration of airborne radioactive material that may be released from the site to the environment due to a design basis event. Lowering the concentration of airborne radioactive materials can mitigate doses to plant operators and members of the public in the event of a design basis event. A typical system consists of ventilation ductwork, fans, dampers, valves, instrumentation, prefilters or demisters, HEPA filters, heaters, and activated charcoal adsorbers.
These systems are tested by operating the systems and monitoring the response of the overall system as well as individual components. Laboratory tests of charcoal adsorbers are also performed to ensure the charcoal adsorbs an acceptable amount of radioactive gasses.
Current testing requirements for the air filtration and adsorption systems state that heaters in the systems should be operated for at least 10 continuous hours every 31 days. These requirements are based on outdated NRC staff guidance for testing air filtration and adsorption systems. New NRC staff guidance states at least 15 continuous minutes of heater operation every 31 days is acceptable.
The regulatory requirements for design and testing of these systems are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.67 and Part 100, as well as Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," General Design Criteria (GDC) 19, 41, 42, 43 and 61.
Regulatory Guide (RG) 1.52, Revision 3, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants (ADAMS Accession No. ML011710176), provides updated guidance and criteria acceptable to the NRC staff for licensees to implement the regulations in 10 CFR related to these air filtration and adsorption systems.
The NRC=s regulatory requirements related to the content of the TS are contained in 10 CFR 50.36. The regulations at 10 CFR 50.36 require that the TS include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls. SRs are 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.
The NRCs guidance for the format and content of licensee TSs can be found in [NUREG-1430, Standard Technical Specifications Babcock and Wilcox Plants][NUREG-1431, Standard Technical Specifications Westinghouse Plants][NUREG-1432, Standard Technical Specifications Combustion Engineering Plants][NUREG-1433, Standard Technical Specifications General Electric Plants BWR/4][NUREG-1434, Standard Technical Specifications General Electric Plants, BWR/6].
3.0 TECHNICAL EVALUATION
Regulatory Position 4.d of Revision 2 of RG 1.52 (ADAMS Accession No. ML003740139) stated that Each ESF [engineered safety feature] atmosphere cleanup train should be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month, with the heaters on (if so equipped), in order to reduce the buildup of moisture on the adsorbers and HEPA [high efficiency particulate air] filters. The purpose of this position is to minimize the moisture content in the system and thereby enhance efficiency in the event the system is called upon to perform its design basis function. SRs {for B&W Plants}[3.7.10.1, 3.7.12.1 and 3.7.13.1] {for Westinghouse Plants}[3.6.11.1 3.6.13.1, 3.7.10.1, 3.7.12.1, 3.7.13.1, and 3.7.14.1] {for Combustion Engineering Plants}[3.6.8.1, 3.6.10.1, 3.7.11.1, 3.7.13.1, 3.7.14.1 and 3.7.15.1] {for General Electric Plants}[3.6.4.3.1 and 3.7.4.1] currently require operating the heaters in the respective ventilation and filtering systems for at least 10 continuous hours every 31 days. The current STS Bases explain that operation of heaters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> would {for Westinghouse, Combustion Engineering, and General Electric Plants}[eliminate moisture] {for B&W Plants}[dry out any moisture that may have accumulated]
on the charcoal adsorbers and HEPA filters. In RG 1.52, Revision 3, the NRC staff has changed its guidance for system operation time.
Before RG 1.52, Revision 3, was published, the NRC staff was informed that 10 continuous hours of system operation would dry out the charcoal adsorber for a brief period of time but, following heater de-energization, the level of moisture accumulation in adsorbers would rapidly return to the pre-test level. The NRC staff found this information persuasive and subsequently issued NRC Generic Letter (GL) 99-02: Laboratory Testing of Nuclear-Grade Activated Charcoal (ADAMS Accession No. ML082350935 and errata sheet at Accession No. ML031110094). GL 99-02 requested licensees to confirm their charcoal testing protocols accurately reflect the adsorber gaseous activity capture capability. GL 99-02 also requested the licensees account for the effects of moisture accumulation in adsorbers.
RG 1.52, Revision 3, Regulatory Position 6.1 states, Each ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with the heaters on (if so equipped), to justify the operability of the system and all its components. The licensee stated that operating the heating element for 15 minutes is sufficient to demonstrate the operability of the heaters. Operating heaters for longer than 15 minutes provides no more assurance than a 15 minute period.
One of the reasons for the previous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> requirement for heater operation was to minimize the effects of moisture on the adsorbers ability to capture gaseous activity. However, these effects are already accounted for in Ventilation and Filter Testing Programs. The [PLANT]
TS [5.5.11] Ventilation Filter Testing Program requires testing charcoal adsorbers in a manner to
account for the effects of moisture on the adsorbers ability to capture gaseous activity.
Therefore, the licensee proposed to remove the moisture elimination purpose from SRs {for B&W Plants}[3.7.10.1, 3.7.12.1 and 3.7.13.1] {for Westinghouse Plants}[3.6.11.1 3.6.13.1, 3.7.10.1, 3.7.12.1, 3.7.13.1, and 3.7.14.1] {for Combustion Engineering Plants}[3.6.8.1, 3.6.10.1, 3.7.11.1, 3.7.13.1, 3.7.14.1 and 3.7.15.1] {for General Electric Plants}[3.6.4.3.1 and 3.7.4.1].
The licensee also submitted TS Bases changes corresponding to the proposed TS changes.
The NRC staff generally does not approve TS Bases changes; however the staff does review the changes for consistency with proposed TS changes. The NRC staff determined that TS Bases changes are consistent with the proposed TS changes.
The NRC staff evaluated the licensees proposed change against the applicable regulatory guidance in RG 1.52, Revision 3, and the change made to STS by TSTF-522. The NRC staff compared the proposed change to the existing SRs, as well as the regulatory requirements of 10 CFR 50.36. The NRC staff found that the proposed change is consistent with guidance in RG 1.52, Revision 3, and the TSTF-522 changes. The NRC staff found that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they will still provide assurance that the necessary quality of ventilation systems and components will be maintained and that the LCOs will be met. Therefore, the NRC staff finds the proposed change acceptable.
4.0 STATE CONSULTATION
{NOTE: Per LIC-101, the PM is responsible for contacting the state official and verifying that this statement is correct.}
In accordance with the Commission's regulations, the [Name of State] State official was notified of the proposed issuance of the amendment. The State official had [no] comments. [If comments were provided, they should be addressed here].
5.0 ENVIRONMENTAL CONSIDERATION
{NOTE: Caution per LIC-101: The environmental consideration discussed below is written for a categorical exclusion based on 10 CFR 51.22(c)(9). The PM is responsible to ensure that this is accurate for the specific amendment being issued.}
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
([ ] FR [ ]). 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
{NOTE: the PM is responsible for ensuring the current LIC-101 wording is used.}
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 amendment will not be inimical to the common defense and security or to the health and safety of the public.
7.0 REFERENCES
[Insert list of references]
Principal Contributor: [M. Hamm]
Date: