ML14058A825

Issuance of Amendment No. 181 to Adopt TSTF-522, Revision 0, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month

ML14058A825
Person / Time
Site:	Monticello
Issue date:	05/02/2014
From:	Beltz T Plant Licensing Branch III
To:	Fili K Northern States Power Co
Beltz T
References
TAC MF0477
Download: ML14058A825 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 2, 2014 Karen D. Fili Site Vice President Monticello Nuclear Generating Plant Northern States Power Company - Minnesota 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT -ISSUANCE OF AMENDMENT TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE (TSTF) TRAVELER TSTF-522, REVISION 0, "REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH" (TAC NO. MF0477)

Dear Mrs. Fili:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 181 to Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating Plant (MNGP). The amendment co11sists of changes to the technical specifications (TS) in response to your application dated January 4, 2013, as supplemented on December 27.

2013.

The amendment revises surveillance requirements (SRs) which currently require testing of the standby gas treatment (SGT) and control room emergency filtration (CREF) systems, with heaters in operation, for a continuous 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> penod every 31 days. The change to the SRs requires operat1on of the systems for at least 15 continuous minutes, without heaters. every 31 days. Additionally, the amendment removes Item e from TS 5.5.6, "Ventilation Filter Testing Program (VFTP)," concerning testing of the SGT and CREF heaters, since this SR would no longer be required for determining operability of the SGT and CREF systems.

K. Fili A copy of our related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Terry A. Beltz, Senior Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263

Enclosures:

1. Amendment No. 181 to DPR-22

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

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 NORTHERN STATES POWER COMPANY- MINNESOTA DOCKET NO. 50-263 MONTICELLO NUCLEAR GENERATING PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 181 License No. DPR-22

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

A. The application for amendment by Northern States Power Company - Minnesota (NSPM, the licensee), dated January 4, 2013, as supplemented on December 27, 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; 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 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. OPR-22 is hereby amended to read as follows:

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 181, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

Enclosure 1

3. This license amendment is effective as of its date of issuance and shall be implemented within 120 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Robert D. Carlson, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Attachment Changes to Renewed Facility Operating License No. DPR-22 and Technical Specifications Date of Issuance: May 2, 2014

ATTACHMENT TO LICENSE AMENDMENT NO. 181 RENEWED FACILITY OPERATING LICENSE NO. DPR-22 DOCKET NO. 50-263 Replace the following page of Renewed Facility Operating License No. DPR-22 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

REMOVE INSERT 3 3 Replace the following pages of 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.

REMOVE INSERT 3.6.4.3-2 3.6.4.3-2 3.7.4-3 3.7.4-3 5.5-5 5.5-5 5.5-6 5.5-6 5.5-7 5.5-7

2. Pursuant to the Act and 10 CFR Part 70, NSPM to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operations, as described in the Final Safety Analysis Report, as supplemented and amended, and the licensee=s filings dated August 16, 197 4 (those portions deallng with handling of reactor fuel);

3. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required;

4. Pursuant to the Act and 10 CFR Parts 30, 40 and 70, NSPM 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 and 70, NSPM to possess, but not separate, such byproduct and special nuclear material as may be produced by operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission=s regulations 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 NSPM is authorized to operate the facility at steady state reactor core power levels not in excess of 2004 megawatts (thermal).

2. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 181, are hereby incorporated in the license. NSPM shall operate the facility in accordance with the Technical Specifications.

3. Physical Protection NSPM shall implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Renewed License No. DPR-22 Amendment No.~ 181

SGT System 3.6.4.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.2.2 Initiate action to suspend Immediately OPDRVs.

D. Two SGT subsystems D.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, or 3.

E. Two SGT subsystems E.1 ---------------NOTE-------------

inoperable during LCO 3.0.3 is not applicable.

movement of recently -------------------------------------

irradiated fuel assemblies in the Suspend movement of Immediately secondary containment recently irradiated fuel or during OPDRVs. assemblies in secondary containment.

AND E.2 Initiate action to suspend Immediately OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for 2 15 continuous 31 days minutes.

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

Monticello 3.6.4.3-2 Amendment No. 446, 181

CREF System 3.7.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Two CREF subsystems -------------------N 0 TE -------------------

inoperable during LCO 3.0.3 is not applicable.

movement of recently irradiated fuel assemblies in the F.1 Suspend movement of Immediately secondary containment recently irradiated fuel or during OPDRVs. assemblies in the secondary containment.

AND One or more CREF subsystems inoperable F.2 Initiate action to suspend Immediately due to an inoperable OPDRVs.

CRE boundary during movement of recently irradiated fuel assemblies in the secondary containment or during OPDRVs.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Operate each CREF subsystem for::::-: 15 continuous 31 days minutes.

SR 3.7.4.2 Perform required CREF filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.7.4.3 Verify each CREF subsystem actuates on an actual 24 months or simulated initiation signal.

SR 3.7.4.4 Perform required CRE unfiltered air in-leakage In accordance testing in accordance with the Control Room with the Control Envelope Habitability Program. Room Envelope Habitability Program Monticello 3.7.4-3 Amendment No. 146, 160, 179, 181

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.6 Ventilation Filter Testing Program (VFTP) (continued)

The test described in Specification 5.5.6.a shall be performed after any maintenance or testing that could affect the leak tight integrity of the HEPA filters.

The test described in Specification 5.5.6.b shall be performed after any maintenance or testing that could affect the leak tight integrity of the charcoal adsorber banks.

Tests described in Specification 5.5.6.c shall be performed once per 24 months; at least once per 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation; following painting, fire, or chemical release in any ventilation zone communicating with the subsystem while it is in operation that could adversely affect the charcoal adsorber capability.

The tests described in Specification 5.5.6.d shall be performed once per 92 days for the Standby Gas Treatment (SGT) System and once per 24 months for the Control Room Emergency Filtration (CREF) System.

(Deleted)

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

a. Demonstrate for each of the ESF systems that an in place test of the HEPA filters shows a penetration and system bypass specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1989 at the system flowrate specified below.

ESF Ventilation System Penetration (%) Flowrate (cfm)

SGT System ,; 1.0 > 3,150 and <; 3,850 CREF System ..,:; 1.0 for each individual > 900 and,; 1,100 HEPA filter and..,:; 0.05 for each pair of HEPA filters Monticello 5.5-5 Amendment No . .:t-46, 181

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.6 Ventilation Filter Testing Program (VFTP) (continued)

b. Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510~1989 at the system flowrate specified below.

ESF Ventilation System Penetration(%) Flowrate (cfm)

SGT System s 1.0 > 3,150 and s 3,850 CREF System  :::; 1.0 for each individual > 900 and s 1,100 charcoal adsorber section and:::; 0.05 for each pair of charcoal adsorber sections

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 Position C.6.b of Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration specified below when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below.

ESF Ventilation System Penetration (%) RH (%)

SGT System ~ 5.0 95 CREF System s0.5 95

d. Demonstrate for each of the ESF systems that the pressure drop across the combined filters is as specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510~1989 at the system flowrate specified below.

ESF Ventilation Delta P {inches water System gauge) Flowrate (cfm)

SGT System ~6 ~ 3,150 and <; 3,850 CREF System ~900 and<; 1,100

e. (Deleted)

Monticello 5.5-6 Amendment No. 44, 181

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Offgas Treatment System, the quantity of radioactivity contained in gas storage tanks or fed into the Offgas Treatment System, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The quantity of radioactivity after 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> holdup contained in each gas storage tank shall be

.:::_ 22,000 Ci of noble gases (considered as dose equivalent Xe-133). The quantity of liquid radioactive waste contained in each unprotected outdoor liquid storage tank shall be.:::_ 10 Ci, excluding tritium and dissolved or entrained noble gases.

The program shall include:

a. The limits for concentrations of hydrogen and oxygen in the Offgas Treatment System and a Surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion);

b. A Surveillance program to ensure that the quantity of radioactivity contained in each gas storage tank and fed into the Offgas Treatment System is less than the amount that would result in a whole body exposure of 2 0.5 rem to any individual in an unrestricted area, in the event of an uncontrolled release of the tanks' contents: and

c. A Surveillance program to ensure that the quantity of radioactivity contained in aU outdoor liquid radwaste tanks that are not surrounded by liners, dikes, or walls, capable of holding the tanks' contents and that do not have tank overflows and surrounding area drains connected to the Liquid Radwaste Treatment System is less than the amount that would result in concentrations less than the limits of 10 CFR 20, Appendix B, Table 2, Column 2, at the nearest potable water supply and the nearest surface water supply in an unrestricted area, in the event of an uncontrolled release of the tanks' contents.

Monticello 5.5-7 Amendment No. -Me, 181

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555.0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 181 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-22 NORTHERN STATES POWER COMPANY- MINNESOTA MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263

1.0 INTRODUCTION

By application dated January 4, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13008A329), as supplemented on December 27, 2013 (ADAMS Accession No. ML14002A165), Northern States Power Company- Minnesota (NSPM, the licensee), doing business as Xcel Energy, Inc., requested changes to the Technical Specifications (TSs) for the Monticello Nuclear Generating Plant (MNGP). Specifically, the licensee requested to adopt U.S. Nuclear Regulatory Commission (NRC or Commission)-

approved Technical Spec.lfications Task Force (TSTF) Standard Technical Specifications (STS)

Change Traveler TSTF-522, Revision 0, "Revise 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" (ADAMS Accession No. ML100890316), dated March 30, 2010. The availability of this TS improvement was announced in the Federal Register on September 20, 2012 (77 FR 58421) as part of the Consolidated Line Item Improvement Process (CLIIP).

Changes were proposed forTS 3.6.4.3, "Standby Gas Treatment (SGT) System," and TS 3.7.4 "Control Room Emergency Filtration (CREF) System." In particular, the proposed changes would revise Surveillance Requirement (SR) 3.6.4.3.1 and SR 3.7.4.1, which currently require operating the respective ventilation systems for at least 10 continuous hours with heaters operating every 31 days. The SRs would be changed to require at least 15 continuous minutes of ventilation system operation without heaters operating every 31 days.

The licensee stated that the license amendment is consistent with NRC-approved TSTF-522, Revision 0, with two proposed variations. One variation is the licensee's proposed removal of TS 5.5.6, Item e, concerning operation of the SGT and CREF heaters since this SR would no longer be required for demonstrating operability of the SGT and CREF systems.

The licensee's supplemental letter dated December 27, 2013, provided additional information that clarified the application, did not expand the scope of the application as originally noticed.

Enclosure 2

and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on March 4, 2013 (78 FR 14134).

2.0 REGULATORY EVALUATION

The SGT system is designed to ensure that radioactive materials that leak from the primary containment into the secondary containment following a design basis accident (DBA) are filtered and adsorbed prior to exhausting to the environment. The SGT system consists of two fully redundant subsystems, each with its own set of ductwork, dampers, charcoal filter trains, and controls. Each charcoal filter train consists of the following components, listed in order of the direction of air flow: a demister; an electric heater; a high efficiency particulate (HEPA) filter; a charcoal adsorber; a second HEPA filter; and a centrifugal fan.

The CREF System provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The safety-related function of the CREF system includes two independent and redundant high efficiency air filtration subsystems for emergency treatment of outside supply air and a control room envelope (CRE) boundary that limits the air in-leakage of unfiltered air. Each CREF subsystem consists of the following components: a low efficiency filter; an electric heater; a HEPA filter; two activated charcoal adsorber sections; a second HEPA filter; an emergency filter fan; an air handling unit; an exhaust/recirculation fan; and the associated ductwork, valves, dampers, doors, barriers, and instrumentation.

As discussed above, 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 dose to plant operators and members of the public in the event of a design basis event. A typical ventilation system consists of 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 overall system response, as well as individual components. Laboratory tests of charcoal adsorbers are also performed to ensure that the charcoal adsorbs an acceptable amount of radioactive gasses.

Current testing requirements at MNGP for the air filtration and adsorption systems state that the systems should be operated for at least 10 continuous hours with heaters operating at a frequency of every 31 days. These requirements are based on NRC staff guidance for testing air filtration and adsorption systems that has been superseded. The latest NRC staff guidance states that testing may performed for at least 15 continuous minutes of ventilation system operation with heaters operating at a frequency of every 31 days, and that this is acceptable to justify operability of the system and all its components. Additionally, plants that test ventilation system adsorption at a relative humidity of at least 95 percent do not require heaters for the ventilation system to perform its specified safety function and the phrase "with heaters operating" is not included in the SRs.

The licensee proposed revising its SRs which currently require operating the ventilation system for at least 10 continuous hours with the heaters operating at a frequency of every 31 days, to

require at least 15 continuous minutes of ventilation system operation without heater operation at a frequency of every 31 days.

The regulatory requirements for the 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 [GDC] for Nuclear Power Plants," GDCs 19, 41, 42, 43, and 61. MNGP was designed largely before publishing of the 70 GDCs for Nuclear Power Plant Construction Permits proposed by the Atomic Energy Agency (AEC) for public comment in July 1967, and was constructed prior to publication of the Appendix A GDCs in 1971. As such, MNGP was not licensed to the Appendix A GDCs. The MNGP Updated Safety Analysis Report (USAR), Section 1.2, lists the Principal Design Criteria for the design, construction, and operation of the plant. Appendix E of the MNGP USAR provides a plant comparative evaluation with the 70 proposed AEC design criteria.

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), published in June 2001, provides guidance and criteria acceptable to the NRC staff for licensees to implement the regulations in 10 CFR Part 50 related to certain air filtration and adsorption systems.

Regulatory Position 4.d of Revision 2 to RG 1.52 (ADAMS Accession No. ML003740139) states 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 filters." However, revision 3 to RG 1.52, Regulatory Position 6.1, states that, "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 aU its components."

One reason for the previous 10-hour requirement of ventilation system operation with heaters operating was to minimize the effects of moisture on the adsorber's ability to capture gaseous activity. However, these effects are already accounted for in the Ventilation Filter Testing Program by performing testing at a relative humidity of 95 percent. The MNGP TS 5.5.6, "Ventilation Filter Testing Program (VFTP)," requires testing charcoal adsorbers in a manner to account for the effects of moisture on the adsorber's ability to capture gaseous activity.

Therefore, the licensee proposed to remove the requirement to operate heaters from SRs 3.6.4.3.1 and 3.7.4.1.

The NRC issued Generic Letter (GL) 99-02, "Laboratory Testing of Nuclear-Grade Activated Charcoal," on June 3, 1999, to alert addressees of the NRC's determination that testing of nuclear-grade activated charcoal to standards other than the American Society for Tesing and Materials (ASTM) D3803-1989, "Standard Test Method for Nuclear-Grade Activated Carbon,"

does not provide assurance for complying with the current licensing basis as it relates to the dose limits of GDC 19 of Appendix A to 10 CFR Part 50, and Subpart A of 10 CFR Part 100, and to request that all addressees determine whether their technical specifications reference ASTM D3803-1989 for charcoal filters (ADAMS Accession No. ML082350935 and errata sheet at Accession No. ML031110094).

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 system 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 LCOs will be met. Further guidance pertaining to the format and content of licensee TSs can be found in NUREG-1433, "Standard Technical Specifications

[STS] General Electric BWRI4 Plants".

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the licensee's proposed changes against the applicable regulatory guidance in RG 1.52, Revision 3; guidance in the STS, as modified by TSTF-522; and the regulatory requirements of 10 CFR 50.36.

The NRC staff evaluated the licensee's proposed changes against the applicable regulatory guidance in RG 1.52, Revision 3. The proposed changes would require at least 15 minutes of system operation. Therefore, the NRC staff finds that the proposed changes are consistent with guidance in RG 1.52, Revision 3.

The NRC staff evaluated the licensee's proposed changes against the applicable regulatory guidance in the STS, as modified by TSTF-522. The proposed changes adopt the TS format and content, to the extent practicable, contained in the changes made to NUREG-1433, "Standard Technical Specifications General Electric BWR/4 Plants," by TSTF-522. Therefore, the NRC staff finds that the proposed changes are consistent with guidance in the STS, as modified by TSTF-522.

The NRC staff compared the proposed changes to the existing SRs, as well as the regulatory requirements of 10 CFR 50.36. The existing SRs provide assurance that the necessary quality of ventilation systems and components will be maintained and that the LCOs will be met. The proposed changes reduce the amount of required system operational 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. The 1 0-hour operational requirement for heaters was based on eliminating moisture in the charcoal adsorbers and thus ensuring that the adsorbers would capture gaseous activity. As discussed in Section 2.0, the effects of moisture on the adsorber's ability to capture gaseous activity are now accounted for in the licensee's VFTP by performing testing at a relative humidity of 95 percent. Since the SRs are no longer relied upon to ensure that the effects of moisture on the adsorber's ability to capture gaseous activity are accounted for, the 10-hour heater operational requirement is unnecessary. The NRC staff determined that the reduction in the required minimum system operation time to 15 minutes, consistent with RG 1.52, Revision 3, in conjunction with the VFTP, is sufficient to justify operability of the system and all its components. The NRC staff agrees that the proposed SR continues to meet the regulatory requirements of 1 0 CFR 50.36, because it provides 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 that the proposed changes are acceptable.

The regulation at 10 CFR 50.36 states: "A summary statement of the bases or reasons for such specifications ... shall also be included in the application, but shall not become part of the

technical specifications." The licensee may make changes to these TS Bases without prior NRC staff review and approval in accordance with the TS 5.5.9, "Technical Specification (TS)

Bases Control Program." Accordingly, along with the proposed TS changes, the licensee also submitted TS Bases changes corresponding to the proposed TS changes. The NRC staff determined that these TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification consistent with the Commission's "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors,"

dated July 22, 1993 (58 FR 39132).

3.1 Variations from TSTF-522 The licensee identified the following two variations from the TS changes described in TSTF-522, Revision 0, or the applicable parts of the NRC staff's model safety evaluation, dated September 13, 2012:

1. The MNGP TS 3.7.4 is entitled "Control Room Emergency Filtration (CREF) System,"

instead of "Main Control Room Environmental Control (MCREC) System," as contained in the NUREG-1433, on which TSTF-522, Revision 0, is based.

2. The licensee proposed to remove TS 5.5.6, Item e, concerning operation of the heaters since this SR is no longer required for operability of the SGT and CREF Systems.

The NRC staff concludes that the difference in titles is an administrative variation and does not affect the applicability of TSTF-522 as it relates to the MNGP TS.

With respect to MNGP TS 5.5.6, "Ventilation Filter Testing Program (VFTP)," Item e, the licensee proposed to remove the electric heater output test requirement for the SGT and CREF systems. TS 5.5.6, Item c, which requires laboratory testing of the SGT and CREF systems charcoal adsorber samples at a relative humidity of 95 percent, in accordance with the ASTM 03803-1989, remains unchanged.

The NRC staff concludes that with the implementation of TSTF-522, and the licensee's adoption of the more stringent charcoal testing requirements from ASTM 03803-1989, specifically, charcoal sample testing to the temperature of 30 degrees Celsius (86 degrees Fahrenheit) and 95 percent relative humidity, that the requirement for performing an electric heater output test is no longer necessary.

The NRC staff concludes that testing the SGT and CREF systems for 15 minutes without heaters, and performing the charcoal testing at a relative humidity of 95 percent, is sufficient to verify that the safety function of the SGT and CREF systems will continue to be met, and that these changes do not reduce the safety function of the systems.

Based on the above, the NRC staff finds that the proposed changes maintain safe plant operation and follow the guidance as specified in NRC Generic Letter 99-02, "Laboratory Testing of Nuclear-Grade Activated Charcoal," dated June 3, 1999; ASTM D3803-1989; and RG 1.52, Revision 3, dated June 2001. Therefore, the NRC staff concludes that the proposed changes are acceptable.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes requirements with respect to the use of facility components located within the restricted area as defined in 10 CFR Part 20 or changes surveillance requirements.

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 as published in the Federal Register on March 4, 2013 (78 FR 14134). 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Roberto Torres, NRR Dateofissuance: May 2, 2014

ML14058A825

• Safety evaluation transmitted by memo dated Februa 19, 2014 OGC (NLO OFFICE LPL3-1/PM LPL3-1/LA SCVB/BC

• STSB/BC LPL3-1/BC LPL3-1/PM wlcomments)

NAME TBeltz MHenderson RDennig REIIiott JWachutka RCarlson TBeltz DATE 04/04/2014 03/2512014 02/19/2014 04/0712014 04/2212014 0413012014 0512114