ML14030A374

Issuance of Amendment for Technical Specification Change Related to Control Room Emergency Filtration System

ML14030A374
Person / Time
Site:	Summer
Issue date:	03/11/2014
From:	Shawn Williams Plant Licensing Branch II
To:	Gatlin T South Carolina Electric & Gas Co
Williams, Shawn NRR/DORL 415-1009
References
TAC MF1387
Download: ML14030A374 (12)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 11, 2014 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 -ISSUANCE OF AMENDMENT FOR THE TECHNICAL SPECIFICATION CHANGE RELATED TO CONTROL ROOM EMERGENCY FILTRATION SYSTEM (TAC NO. MF1387)

Dear Mr. Gatlin:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 197 to Renewed Facility Operating License No. NPF-12 for the Virgil C. Summer Nuclear Station, Unit 1 (VCSNS), in response to your letter dated April 3, 2013. This amendment will revise VCSNS control room emergency filtration system Technical Specification (TS) 3/4.7.6.

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

Docket No. 50-395

Enclosures:

1. Amendment No. 197 to NPF-12

2. Safety Evaluation cc w/encls: Distribution via Listserv Sincerely, Shawn Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY DOCKET NO. 50-395 VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 197 Renewed License No. NPF-12

1.

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

A The application for amendment to the Virgil C. Summer Nuclear Station, Unit 1, (the facility) Renewed Facility Operating License NPF-12 filed by the South Carolina Electric & Gas Company (the licensee}, dated April 3, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;

B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations as 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.

2.

Accordingly, the license is 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-12 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 197, and the Environmental Protection Plan contained in Appendix 8, are hereby incorporated in the license. South Carolina Electric & Gas Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

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

Attachment:

Changes to Renewed Facility Operating License No. NPF-12 and the Technical Specifications FOR THE NUCLEAR REGULA TORY COMMISSION

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Robert J. Pascarelli, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: March 11, 2014

(3)

SCE&G, pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage amounts required for reactor operation, as described in the Final Safety Analysis Report, as amended through Amendment No. 33; (4)

SCE&G, pursuant to the Act and 10 CFR Part 30, 40 and 70 to receive, possess and use at any time byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed neutron sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)

SCE&G, 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 of components; and (6)

SCE&G, pursuant to the Act and 10 CFR P arts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as my 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 Commission's regulations set forth in 1 0 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 SCE&G is authorized to perathe the facility at reactor core power levels not in excess of 2900 megawatts thermal in accordance with the conditions specified herein and in Attachment 1 to this renewed license.

The preoccupation tests, startup tests and other items identified in to this renewed license shall be completed as specified. is hereby incorporated into this renewed license.

(2)

Technical Specifications and Environmental Protection Plant The Technical Specifications contained in Appendix A, as revised through Amendment No. 197 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the renewed license. South Carolina Electric & Gas Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

Renewed Facility Operating License No. NPF-12 Amendment No. 197

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM CCREFS)

LIMITING CONDITION FOR OPERATION 3.7.6 Two CREFS trains shall be OPERABLE.*

APPLICABILITY:

ALL MODES ACTION:

a.

MODES 1, 2, 3 and 4:

1.

With one CREFS train inoperable for reasons other than ACTION 3.7.6.a.2, restore the inoperable train to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

2.

With one or more CREFS trains inoperable due to an inoperable control room envelope (CRE) boundary, immediately initiate action to implement mitigating actions and verify within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that the mitigating actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits and restore CRE boundary to OPERABLE status within 90 days. Otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

3.

With both CREFS trains inoperable for reasons other than ACTION 3. 7.6.a.2, immediately enter LCO 3.0.3.

b.

MODES 5 and 6:

1.

With one CREFS train inoperable for reasons other than an inoperable CRE boundary, restore the inoperable train to OPERABLE status within 7 days, or immediately place the OPERABLE CREFS train in the emergency mode of operation or immediately suspend movement of irradiated fuel assemblies.

2.

With both CREFS trains inoperable or one or more CREFS trains inoperable due to an inoperable CRE boundary, immediately suspend movement of irradiated fuel assemblies.

3.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.7.6 Each CREFS train shall be demonstrated OPERABLE:

a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air temperature is less than or equal to 85°F.

b.

At least once per 31 days by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the CREFS train operates for at least 15 minutes.

c.

By performing required CREFS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).

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

SUMMER-UNIT 1 3/4 7-14 Amendment No. 161, 171, 180,197

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 RELATED TO AMENDMENT NO. 197 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-12 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 DOCKET NO. 50-395

1.0 INTRODUCTION

By letter dated April 3, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13095A111 ), South Carolina Electric & Gas Company (SCE&G, the licensee) submitted a request for a change to the Virgil C. Summer Nuclear Station, Unit 1 (VCSNS) Technical Specifications (TSs) 3/4.7.6, "Control Room Emergency Filtration System (CREFS)." The proposed TS change would add an exception toTS 3.0.4 that would modify system requirements for operations during MODES 5 and 6.

2.0 REGULATORY EVALUATION

The CREFS provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The CREFS is designed to maintain a habitable environment in the control room envelope (CAE) for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5 rem whole body dose or its equivalent to any part of the body. The licensee proposed the addition of TS Action "b.3" to the TS requirements for the CREFS. Proposed TS Action "B.3" would allow the licensee to enter MODES 5 and 6 when the CREFS is inoperable. A more detailed description of the proposed change is contained below in Section 3.0.

Title 10 of the Code of Federal Regulations (10 CFR) 50.36, "Technical Specifications," provides the regulatory requirements for the contents in a licensee's TSs. Section 50.36(c) requires that the TSs include items in the following categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCO); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. The regulation does not specify the particular requirements to be included in a plant's TSs. 10 CFR 50.36(c)(3) notes that SRs are requirements relating to test, calibration, or inspection to assure that 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.

Licensees may revise the technical specifications provided that plant-specific 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.

The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to 10 CFR 50.34. The Commission may include such additional technical specifications as the Commission finds appropriate. In determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate.

In determining the acceptability of revising TS 3/4.7.7, the staff used the approved guidance in NUREG-1431, "Standard Technical Specifications, Westinghouse Plants, Revision 4.0," dated April2012.

3.0 TECHNICAL EVLAUATION Technical Specifications Task Force Travelers (TSTF)-448 proposed changes to Standard Technical Specifications (STS) 3.7.10 and addition of a Control Room Habitability program in NUREG-1431. NRC approved plant-specific adoption of TSTF-448 on January 17, 2007 (72 FR 2022). The VCSNS TS corresponding to STS 3.7.10 is TS 3/4.7.6, "Control Room Emergency Filtration System."

TS 3/4.7.6 contains requirements for the operation of the CREFS. The CREFS is required to be operable in all MODES. Actions "a.1" through "a.3" describe the required actions for cases when the CREFS is inoperable in MODES 1 through 4. Action "b" contains required actions for cases when the CREFS is inoperable in MODES 5 and 6. By letter dated October 23, 2008 (ADAMS Accession No. ML082970002), NRC Amendment 180 adopted TSTF-448 changes to VCSNS TS.

Along with other changes to adopt TSTF-448, Action "b.3" which stated "the provisions of Specification 3.0.4 are not applicable" was deleted from Action b. of TS 3/4.7.6.

The text of VCSNS TS 3.0.4 differs from the text of STS 3.0.4. VCSNS TS 3.0.4 states:

Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION requirements. This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements. Exceptions to these requirements are stated in the individual specifications.

The changes made to STS by TSTF-448 assumed a text for STS 3.0.4 which states:

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification. This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

The STS 3.0.4 text is less restrictive compared to VCSNS TS 3.0.4. STS 3.0.4 allows applicable MODE entry and continued operation when the associated Actions permit it for an unlimited period of time. VCSNS TS 3.0.4 does not allow this unless an exception is stated in the individual TS. Prior to TSTF-448 adoption, VCSNS TS contained an exception toTS 3.0.4 for cases when the CREFS is inoperable in MODES 5 and 6. This exception allowed the licensee to enter MODES 5 and 6 with inoperable CREFS similar to the STS allowance. TSTF-448 changes did not contain such an exception because the STS 3.0.4 text made such an exception unnecessary.

In the license amendment request, the licensee proposed adding back Action "b.3," which would state: "the provisions of Specification 3.0.4 are not applicable." This would restore the licensee's ability to transition to MODES 5 and 6 with the CREFS inoperable.

TS 3/4.7.6 Actions "b.1" and "b.2" apply when the CREFS is inoperable in MODES 5 and 6.

Action "b.1" states:

With one CREFS train inoperable for reasons other than an inoperable CRE boundary, restore the inoperable train to OPERABLE status within 7 days, or immediately place the OPERABLE CREFS train in the emergency mode of operation or immediately suspend movement of recently irradiated fuel assemblies.

Accordingly, in MODES 5 or 6, or during movement of recently irradiated fuel assemblies, if the inoperable CREFS train cannot be restored to OPERABLE status within the required allowed outage time, the licensee must immediately place the OPERABLE CREFS train in the emergency mode. This ensures that the remaining train is OPERABLE, prevents failures of automatic actuation, and ensures that any active failure will be readily detected. Alternatively, the licensee may immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position. Once these actions are completed, operation in MODE 5 or 6 can continue indefinitely since either the safety function has been ensured, or the risk of the fuel handling accident has been removed.

Action "b.2" states:

With both CREFS trains inoperable or one or more CREFS trains inoperable due to an inoperable CRE boundary, immediately suspend movement of recently irradiated fuel assemblies.

As stated in this requirement, in MODE 5 or 6, or during movement of recently irradiated fuel assemblies, with two CREFS trains inoperable or with one or more CREFS trains inoperable due to an inoperable CRE boundary, the licensee must immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

The licensee justified the proposed Action "b.3" addition by stating:

The proposed change restores the original licensing basis for VCSNS TS 3/4.7.6, "Control Room Emergency Filtration System (CREFS)" as approved by the NRC prior to Amendment 180. The proposed change does not alter the Limiting Condition for Operation, the Applicability, or the remedial Actions that provide for the safe operation of the plant when the Limiting Condition for Operation is not met.

As discussed in the Background Section above, the restoration of the VCSNS TS 3/4.7.6 exception to Specification 3.0.4 is based solely on the different ways Specification 3.0.4 is applied to the TS in TSTF-448 and in the VCSNS TS. As such, the proposed change does not adversely affect the technical requirements of VCSNS TS 3/4.7.6 as approved in Amendment 180.

The staff reviewed the proposed change as well as the licensee's justification for the change. The staff categorized the change as less restrictive since it reduces the restrictions on operations, given that the current VCSNS TS, without a TS 3.0.4 exception, do not allow entry into MODE 5 or 6 when LCO 3/4.7.6 is not met due to inoperable CREFS. While the change is less restrictive, the staff noted that the change still affords adequate assurance of safety when judged against current regulatory standards. For example, similar to STS 3.0.4 in conjunction with STS 3. 7.1 0, continued operation in MODES 5 and 6 is allowed when CREFS trains are inoperable because STS 3. 7.10 Actions D and E permit continued operation in the MODES 5 and 6 for an unlimited period of time and therefore allow entry into MODES 5 and 6 with inoperable CREFS. The safety basis for this allowance in both STS 3. 7.10 and VCSNS TS 3/4.7.6 is that the required actions place the unit in a condition that minimizes the accident risk. Accordingly, the staff concludes that it is acceptable for the licensee to transition into MODES 5 or 6 with an inoperable CREFS because compliance with the Required Actions will ensure safe operation until the inoperable CREFS are restored to an operable condition. Therefore, the staff determined that the proposed addition of the exception toTS 3.0.4 in Action "b.3" is acceptable.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes 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 amendment involves 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 amendment involves no significant hazards consideration, and there has been no public comment on such finding (78 FR 47791, August 6, 2013). Accordingly, the amendment meets 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 amendment.

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) there is reasonable assurance that 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:

Matthew Hamm, NRR/DSS/STSB Date: March 11, 2014

March 11, 2014 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 800 Jenkinsville, SC 29065

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 -ISSUANCE OF AMENDMENT FOR THE TECHNICAL SPECIFICATION CHANGE RELATED TO CONTROL ROOM EMERGENCY FILTRATION SYSTEM (TAC NO. MF1387)

Dear Mr. Gatlin:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 197 to Renewed Facility Operating License No. NPF-12 for the Virgil C. Summer Nuclear Station, Unit 1 (VCSNS), in response to your letter dated April 3, 2013. This amendment will revise VCSNS control room emergency filtration system Technical Specification (TS) 3/4.7.6.

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

Docket No. 50-395

Enclosures:

1. Amendment No. 197 to NPF-12

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

Sincerely, IRA!

Shawn Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Public LPL2-1 R/F RidsNrrDssStsb Resource RidsNrrPMSummer Resource RidsNrrDraApla Resource MHamm, NRR RidsAcrs_AcnwMaiiCTR Resource RidsNrrLASFigueroa Resource RidsNrrDoriDpr Resource RidsRgn2MaiiCenter Resource SWilliams, NRR ADAMS A ccess1on N M 1 030A374 o.:

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