ML12338A020

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Issuance of Amendment Nos. 213 and 215, Revise Technical Specification 3.7.10, Control Room Ventilation System (Crvs), Required Action A.1 Completion Time (Emergency Circumstances)
ML12338A020
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 12/04/2012
From: Joseph Sebrosky
Plant Licensing Branch IV
To: Halpin E
Pacific Gas & Electric Co
Sebrosky J
References
TAC MF0317, TAC MF0318
Download: ML12338A020 (19)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 December 4, 2012 Mr. Edward D. Halpin Senior Vice President and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424

SUBJECT:

DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS RE: REVISION TO TECHNICAL SPECIFICATION 3.7.10, "CONTROL ROOM VENTILATION SYSTEM (CRVS)" (EMERGENCY CIRCUMSTANCES) (TAC NOS. MF0317 AND MF0318)

Dear Mr. Halpin:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 213 to Facility Operating License No. DPR-80 and Amendment No. 215 to Facility Operating License No. DPR-82 for the Diablo Canyon Power Plant, Unit Nos. 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated December 2, 2012.

The amendments make a one-time change to TS 3.7.10, "Control Room Ventilation System (CRVS)," to modify the Completion Time for Required Action A.1, from 7 days to 13 days. This change will allow completion of a modification and required testing to restore the CRVS actuation relays and both CRVS trains to OPERABLE status. TS 3.7.10 Condition A Required Action A.1 was entered on November 27, 2012, at 20:38 Pacific Standard Time (PST), due to the inoperable CRVS actuation relays and the associated Completion Time will expire on December 4, 2012, at 20:38 PST.

The license amendment is issued under emergency circumstances as provided in the provisions of paragraph 50.91 (a)(5) of Title 10 of the Code of Federal Regulations due to the time critical nature of the amendment. In this instance, an emergency situation exists in that the proposed amendment is needed to allow the licensee to preclude a plant shutdown.

E. Halpin

- 2 A copy of the related Safety Evaluation is also enclosed. The safety evaluation describes the emergency circumstances under which the amendment was issued and the final no significant hazards determination. A Notice of Issuance addressing the final no significant hazards determination and opportunity for a hearing associated with the emergency circumstances, will be included in the Commission's next biweekly Federal Register notice.

Sincerely, Docket Nos. 50-275 and 50-323

Enclosures:

1. Amendment No. 213 to DPR-80
2. Amendment No. 215 to DPR-82
3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PACIFIC GAS AND ELECTRIC COMPANY DOCKET NO. 50-275 DIABLO CANYON NUCLEAR POWER PLANT, UNIT NO.1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 213 License No, DPR-80

1.

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

A.

The application for amendment by Pacific Gas and Electric Company (the licensee), dated December 2, 2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's regulations and all applicable requirements have been satisfied.

- 2

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-80 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. 213, are hereby incorporated in the license. Pacific Gas &Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3.

This license amendment is effective as of its date of issuance and shall be implemented prior to the expiration of the 7-day Technical Specification Completion Time, or December 4, 2012, at 20:38 Pacific Standard Time.

FOR THE NUCLEAR REGULATORY COMMISSION

Attachment:

Changes to the Facility Operating License No. DPR-80 and Technical Specifications Date of Issuance:

December 4, Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 2012

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PACIFIC GAS AND ELECTRIC COMPANY DOCKET NO. 50-323 DIABLO CANYON NUCLEAR POWER PLANT, UNIT NO.2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 215 License No. DPR-82

1.

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

A.

The application for amendment by Pacific Gas and Electric Company (the licensee), dated December 2,2012, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's regulations and all applicable requirements have been satisfied.

- 2

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-82 is hereby amended to read as follows:

(2)

Technical Specifications (SSER 32, Section 8)* and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 215, are hereby incorporated in the license. Pacific Gas & Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3.

This license amendment is effective as of its date of issuance and shall be implemented prior to the expiration of the 7-day Technical Specification Completion Time, or December 4, 2012, at 20:38 Pacific Standard Time.

FOR THE NUCLEAR REGULATORY COMMISSION

~-;'A~

Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. DPR-82 and Technical Specifications Date of Issuance: December 4, 2012

ATTACHMENT TO LICENSE AMENDMENT NO. 213 TO FACILITY OPERATING LICENSE NO. DPR-80 AND AMENDMENT NO. 215 TO FACILITY OPERATING LICENSE NO. DPR-82 DOCKET NOS. 50-275 AND 50-323 Replace the following pages of the Facility Operating License Nos. DPR-80 and DPR-82, and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating License No. DPR-80 REMOVE INSERT -3 Facility Operating License No. DPR-82 REMOVE INSERT

-3

-3 Technical Specifications REMOVE INSERT 3.7-18 3.7-18 3.7-18a 3.7-18a

-3 (4)

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)

Pursuant to the Act and 10 CFR Parts 30,40, 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 License shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level The Pacific Gas and Electric Company is authorized to operate the facility at reactor core power levels not in excess of 3411 megawatts thermal (100% rated power) in accordance with the conditions specified herein.

(2)

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 213, are hereby incorporated in the license.

Pacific Gas & Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3)

Initial Test Program The Pacific Gas and Electric Company shall conduct the post-fuel-Ioading initial test program (set forth in Section 14 of Pacific Gas and Electric Company's Final Safety Analysis Report, as amended), without making any major modifications of this program unless modifications have been identified and have received prior NRC approval. Major modifications are defined as:

a.

Elimination of any test identified in Section 14 of PG&E's Final Safety Analysis Report as amended as being essential; Amendment No. 213

-3 (4)

Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)

Pursuant to the Act and 10 CFR Parts 30, 40, 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 License shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to a" applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level The Pacific Gas and Electric Company is authorized to operate the facility at reactor core power levels not in excess of 3411 megawatts thermal (100% rated power) in accordance with the conditions specified herein.

(2)

Technical Specifications (SSER 32, Section 8)* and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 215, are hereby incorporated in the license.

Pacific Gas & Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3)

Initial Test Program (SSER 31, Section 4.4.1)

Any changes to the Initial Test Program described in Section 14 of the FSAR made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b} within one month of such change.

  • The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. 2'15

CRVS 3.7.10 3.7 PLANT SYSTEMS 3.7.10 Control Room Ventilation System (CRVS)

LCO 3.7.10 Two CRVS trains shall be OPERABLE.


NOTE------------------------------------------------------------

The control room envelope (CRE) boundary may be opened intermittently under administrative controls.

APPLICABILITY:

MODES 1, 2, 3, 4, 5, and 6.

During movement of recently irradiated fuel assemblies.

ACTIONS


N0TE --------------------------------------------------------

ACTIONS apply simultaneously to both units.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One CRVS train inoperable for reasons other than Condition B.

A.1 Restore CRVS train to 7 days (1)

OPERABLE status.

B.

One or more CRVS trains inoperable due to inoperable CRE boundary in MODE 1, 2, 3, or4.

B.1 AND B.2 AND B.3 Initiate action to Immediately implement mitigating actions.

Verify mitigating actions 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensure CRE occupant exposures to radiological hazards will not exceed limits, and CRE occupants are protected from smoke and chemical hazards.

Restore CRE boundary

. 90 days to OPERABLE status.

I (continued)

(1) The Completion Time that one CRVS train can be inoperable as specified by Required Action A.1 may be extended beyond the 7 day completion time up to 13 days to support repair and restoration of the CRVS actuation instrumentation which required TS 3.7.10 Condition A entry per TS 3.3.7 Required Action B.1.2. Upon completion of the repair and restoration, this footnote is no longer applicable and will expire at 20:38 PST on December 10, 2012.

DIABLO CANYON - UNITS 1 &2 3.7-18 Unit 1 - Amendment No. ~,4W,-i84,2Q4, 213 Unit 2 - Amendment No. ~,4e§,4-89,200, 215

CRVS 3.7.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TI ME C.

Required Action and associated Completion Time of Condition A or B not met in MODE 1. 2. 3, or

4.

C.1 AND C.2 Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours D.

Required Action and associated Completion Time of Condition A not met in MODE 5 or 6, or during movement of recently irradiated fuel assemblies.

D.1.1 D.1.2 OR D.2 Place OPERABLE CRVS train in pressurization mode.

AND Verify that the OPERABLE CRVS train is capable of being powered by an OPERABLE emergency power source.

Suspend movement of recently irradiated fuel assemblies.

Immediately Immediately Immediately (continued)

DIABLO CANYON - UNITS 1 &2 3.7-18a Unit 1 - Amendment No. 43§.493A*84. 213 Unit 2 - Amendment No. 43§,..fM.486, 215

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 213 TO FACILITY OPERATING LICENSE NO. DPR-80 AND AMENDMENT NO. 215 TO FACILITY OPERATING LICENSE NO. DPR-82 PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-275 AND 50-323

1.0 INTRODUCTION

By application dated December 2, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML123380142, Pacific Gas and Electric Company (PG&E, or the licensee) requested changes to the Technical Specifications (TSs), Appendix A to Facility Operating License Nos. DPR-80 and DPR-82) for the Diablo Canyon Power Plant, Unit Nos. 1 and 2.

The amendments would make a one-time change to TS 3.7.10, "Control Room Ventilation System (CRVS)," to modify the Completion Time for Required Action A.1, from 7 days to 13 days. This change will allow completion of a modification and required testing to restore the CRVS actuation relays and both CRVS trains to OPERABLE status. TS 3.7.10 Condition A Required Action A.1 was entered on November 27,2012, at 20:38 Pacific Standard Time (PST),

due to the inoperable CRVS actuation relays and the associated Completion Time will expire on December 4, 2012, at 20:38 PST.

2.0 REGULATORY EVALUATION

In Section 50.36, "Technical specifications," of Title 10 of the Code of Federal Regulations (10 CFR), the Commission established its regulatory requirements related to the content of TSs.

Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. The rule does not specify the particular requirements to be included in a plant's TS.

Licensees may propose revisions to the TSs. The U.S. Nuclear Regulatory Commission (NRC) staff reviews proposed changes and will generally issue changes provided that the plant-specific

- 2 review supports a finding of continued adequate safety because: (1) the change is editorial, administrative or provides clarification (I.e., no requirements are materially altered), (2) the change is more restrictive than the licensee's current requirement, or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The detailed application of this general framework, and additional specialized guidance, are discussed in Section 3.0 in the context of specific proposed changes

3.0 TECHNICAL EVALUATION

3.1 Description The CRVS provides a protected environment from which occupants can control the units from the common control room following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The CRVS consists of two independent, redundant trains that recirculate and filter the air in the control room envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air (one train from each unit). Each CRVS train consists of a heater, a prefilter, a high-efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and one pressurization supply fan, one filter booster fan, and one main supply fan. Ductwork, valves or dampers, doors, barriers, and instrumentation also form part of the system.

The CRVS is an emergency system, parts of which may also operate during normal unit operations. Upon receipt of an actuating signal, the normal air supply to the CRE is isolated, and the stream of outside ventilation air from the pressurization system and recirculated control room air is passed through the system filter. The pressurization system automatically draws outside air from either the north end or the south end of the turbine building, based upon which unit has a safety injection signal or which end of the building has high radiation conditions at the pressurization duct inlet. Manual or automatic actuation of the CRVS places the system in pressurization mode.

TS 3.3.7, CRVS Actuation Instrumentation, Condition B (one or more Functions with two channels or two trains inoperable) was entered on November 27,2012, because the licensee determined that the CRVS actuation instrumentation logic is not capable of properly maintaining the CRVS operation in the pressurization mode when actuated from a high radiation or Containment Phase A Isolation signal. Required Action B.1.1, to place one CRVS train in pressurization mode, and Required Action B.1.2, to enter the applicable conditions and required actions for one CRVS train made inoperable by inoperable CRVS actuation instrumentation, were entered immediately. To meet TS 3.3.7 Required Action B.1.2, TS 3.7.10 Condition A Required Action A.1 was entered on November 27,2012, at 20:38 PST. The Completion Time for TS 3.7.10 Condition A Required Action A.1 will expire on December 4, 2012, at 20:38 PST.

The licensee will be required to shut down both units if the CRVS is not restored to OPERABLE status before the end of the Completion Time.

- 3

3.2 Proposed TS Changes

The current TS 3.7.10 Completion Time for Condition A, Required Action A.1 states "7 days."

The license proposed a one-time amendment to add a footnote to the current Completion Time which would state:

(1)

The Completion Time that one CRVS train can be inoperable as specified by Required Action A.1 may be extended beyond the 7 day completion time up to 13 days to support repair and restoration of the CRVS actuation instrumentation which required TS 3.7.10 Condition A entry perTS 3.3.7 Required Action B.1.2.

Upon completion of the repair and restoration, this footnote is no longer applicable and will expire at 20:38 PST on December 10, 2012.

3.3

NRC Staff Evaluation

The NRC staff reviewed the proposed footnote and determined that the change is less restrictive than current TS requirements because the Completion Time for TS 3.7.10 Required Action A.1 would be extended from 7 to 13 days. In its letter dated December 2, 2012, the licensee provided the following justification for the proposed change:

Placing one CRVS train in pressurization mode accomplishes the actuation instrumentation function that is lost and places the unit in a conservative mode of operation. In the event of any accident condition which would challenge the CRVS function, having one CRVS train in pressurization mode ensures that the system function is accomplished. The second available standby CRVS train can also be manually aligned in the event of an accident in this configuration.

Therefore, a" design basis accident requirements continue to be met, even assuming a single failure, by the pre-existing alignment of one CRVS train in pressurization mode and by operator action to manually start the available standby CRVS train, if necessary. Only one CRVS train is normally placed in the pressurization mode at any time, with the other train in the recirculation mode.

With one CRVS train manually placed in the pressurization mode, if an automatic actuation due to a high radiation or Containment Phase A Isolation signal occurs, the CRVS train wi" remain in the pressurization mode and will not change to the recirculation mode. In addition, the other CRVS train will not go into pressurization mode since the control system logic wi" not allow it. The pressure switch interlocks (indicating a running fan on the opposite unit) prevent the opposite unit from starting either of its pressurization fans.

An operations shift order has been put in place to ensure the CRVS train placed in the pressurization mode to meet TS 3.3.7 Required Action B.1.1 is maintained in the pressurization mode. This shift order will remain in place, except as required for restoration testing, until the completion of the modification and required testing to restore the CRVS actuation relays and both CRVS trains to OPERABLE status.

-4 The NRC staff reviewed the licensee's justification for the change and determined that the change ensures that the CRVS's specified safety function will be met and will afford adequate assurance of safety when judged against current regulatory standards for the short period of time the amendment will be applicable, provided the operations shift order to maintain the CRVS in the pressurization mode is maintained. Based on the above, the NRC staff concludes that the proposed change is acceptable.

4.0 EMERGENCY CIRCUMSTANCES In its letter dated December 2,2012, the licensee requests that the amendment be treated as an emergency amendment.

The license amendment is issued under emergency circumstances as provided in the provisions of 10 CFR 50.91 (a}(5) due to the time critical nature of the amendment. The NRC staff evaluated whether the licensee took reasonable action to avoid the situation and submitted its request in a timely manner. The cause of the inoperability of the CRVS actuation circuitry was determined to be due to a recent CRVS modification, which included system flow balancing, that added backflow dampers on October 4 and October 6, 2012, and rebalanced the system, which increased the operating pressure of the CRVS. The identification that the CRVS actuation relays are not capable of properly maintaining the CRVS operation in the pressurization mode when automatically actuated was not identified by PG&E until November 27,2012. A review of the history by PG&E since the last successful performance of the CRVS automatic actuation relay surveillance identified that the installation of the backdraft dampers in the CRVS along with a rebalance of the system flows resulted in an increase in static pressure of the pressurization and discharge header and an adverse impact on the operation of the pressurization fan discharge pressure switches.

The staff reviewed the licensee's explanation and found it acceptable because the condition was due to the recent plant modification and the complexity of the modification problem was not identified until the CRVS was tested. The NRC staff concludes that the licensee's actions were reasonable and that the identification of the problem, the development of the design change to address the problem (i.e., modification to the pressurization fan discharge pressure logic), the implementation of the design change, and the testing of the design change are being addressed in a reasonable amount of time and that the emergency situation could not have been avoided.

5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

The Commission may issue license amendments before the expiration of the 60-day period provided that its final determination is that the amendments involve no significant hazards consideration. This amendment is being issued prior to the expiration of the 60-day period.

Therefore, a final finding of no significant hazards consideration follows.

The Commission has made a final determination that the amendment request involves no significant hazards consideration. Under the Commission's regulations in 10 CFR 50.92, this means that operation of the facility in accordance with the proposed amendment does not (1) involve a Significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

- 5 ~

As required by 10 CFR 50.91 (a), in its letter dated December 2,2012, the licensee has provided its analysis of the issue of no Significant hazards consideration which is presented below:

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The requested change does not physically alter any plant structures, systems, or components, and does not affect or create new accident initiators or precursors. The completion time (CT) to perform a required action is not an accident initiator; therefore, there is no effect on the probability of accidents previously evaluated.

The control room ventilation system (CRVS) is required to maintain a habitable environment in the control room envelope for the duration of the most severe Design Basis Accident (DBA) without exceeding a 5 rem whole body dose or its equivalent to any part of the body. The requested change to allow one CRVS train to be inoperable for up to 13 days does not significantly increase the consequences of those accidents due to the low probability of an accident occurring during the time of CRVS train inoperability. Additionally, the redundant CRVS train remains OPERABLE and in the pressurization mode required to perform its required function. The requested change does not affect the types or amounts of radionuclides released following an accident, or the initiation and duration of their release.

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

2.

Does the proposed change create the possibility of a new or different accident from any accident previously evaluated?

Response: No.

The proposed change to allow one CRVS train to be inoperable for up to 13 days does not introduce new failure modes or mechanisms associated with plant operation. Furthermore, the 13 day CT associated with the restoration of the CRVS train would not create a new accident type.

Therefore, the proposed change does not create the possibility of a new or different accident from any accident previously evaluated.

- 6

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change to completion time requirement for one inoperable CRVS train in TS 3.7.10 does not affect any safety limits, other operational parameters, or setpoints in the TS, nor does it affect any margins assumed in the accident analyses. The redundant CRVS train is OPERABLE and can perform the required design function.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Accordingly, the Commission has determined that this amendment involves no significant hazards determination.

6.0 REGULATORY COMMITMENTS In its letter dated December 2, 2012, the licensee made the following regulatory commitments:

Commitment 1 An operations shift order has been put in place to ensure the CRVS train placed in the pressurization mode to meet TS 3.3.7 Required Action B.1.1 is maintained in the pressurization mode. This shift order will remain in place, except as required for restoration testing, until the completion of the modification and required testing to restore the CRVS actuation relays and both CRVS trains to OPERABLE status.

Commitment 2 The following compensatory actions are being taken and will continue until the maintenance and post-maintenance testing are complete, in order to minimize the increase in risk during the 13-day period when one CRVS train is inoperable.

During the repair of the CRVS actuation circuitry, no other planned maintenance or testing will be performed that would render the CRVS or associated support systems inoperable.

Any planned CRVS maintenance and surveillance testing will be suspended until the repair and testing of the CRVS actuation Circuitry is completed and both CRVS trains are returned to service.

No planned increased PRA risk configuration (yellow risk or higher) will be allowed during the repair of the CRVS actuation circuitry.

- 7 Emergent increased PRA risk configuration (yellow risk or higher) will require additional risk mitigation actions.

A standing order will be prepared for the control room operators to provide a written instruction to place the standby CRVS train in the pressurization mode in the event that the running CRVS train becomes inoperable.

The NRC staff concludes that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are best provided by the licensee's administrative processes, including its commitment management program. The above regulatory commitments do not warrant the creation of regulatory requirements (items requiring prior NRC approval of subsequent changes).

7.0 STATE CONSULTATION

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

8.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the 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 off site, and that there is no significant increase in individual or cumulative occupational radiation exposure. 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.

10.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) the amendments do not (a) involve a significant increase in the probability or consequences of an accident previously evaluated; or (b) create the possibility of a new or different kind of accident from any accident previously evaluated; or (c) involve a significant reduction in a margin of safety; (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (3) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (4) 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 Contributor: Matthew Hamm Date: December 4, 2012

E. Halpin

- 2 A copy of the related Safety Evaluation is also enclosed. The safety evaluation describes the emergency circumstances under which the amendment was issued and the final no significant hazards determination. A Notice of Issuance addressing the final no significant hazards determination and opportunity for a hearing associated with the emergency circumstances, will be included in the Commission's next biweekly Federal Register notice.

Docket Nos. 50-275 and 50-323

Enclosures:

1. Amendment No. 213 to DPR-80
2. Amendment No. 215 to DPR-82
3. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

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. NAME f-----.

JThorp LSubin MMarkley JSebrosky

  • DATE 12/04/2012 12/04/12 12/04/12 12/04/12 OFFICIAL RECORD COpy