ML14279A275

Issuance of Amendment No. 277, Revise Technical Specification Surveillance Requirement 3.2, Table 3-5, Item 3, for One-Time Extension of Frequency to Maximum of 28 Months

ML14279A275
Person / Time
Site:	Fort Calhoun
Issue date:	11/06/2014
From:	Lyon C Plant Licensing Branch IV
To:	Cortopassi L Omaha Public Power District
Lyon C
References
TAC MF3466
Download: ML14279A275 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 6, 2014 Mr. Louis P. Cortopassi Site Vice President and Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station 9610 Power Lane, Mail Stop FC-2-4 Omaha, NE 68008

SUBJECT:

FORT CALHOUN STATION, UNIT NO. 1 -ISSUANCE OF AMENDMENT RE:

REVISE TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT FOR THE PRESSURIZER SAFETY VALVES TO BE CONSISTENT WITH THE INSERVICE TESTING PROGRAM (TAC NO. MF3466)

Dear Mr. Cortopassi:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 277 to Renewed Facility Operating License No. DPR-40 for the Fort Calhoun Station, Unit No. 1.

The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated February 10, 2014, as supplemented by letter dated June 9, 2014.

The amendment revises Technical Specification Surveillance Requirement 3.2, "Equipment and Sampling Tests," Table 3-5, "Minimum Frequencies for Equipment Tests," Item 3 for the pressurizer safety valves from a refueling frequency (i.e., 18 months +/- 25 percent) to be consistent with the lnservice Testing Program.

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

Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-285

Enclosures:

1. Amendment No. 277 to DPR-40

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

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 OMAHA PUBLIC POWER DISTRICT DOCKET NO. 50-285 FORT CALHOUN STATION. UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 277 Renewed License No. DPR-40

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

A. The application for amendment by the Omaha Public Power District (the licensee), dated February 10, 2014, as supplemented by letter dated June 9, 2014, 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 license 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.

Enclosure 1

2. Accordingly, Renewed Facility Operating License No. DPR-40 is amended by changes as indicated in the attachment to this license amendment, and paragraph 3. B. of Renewed Facility Operating License No. DPR-40 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 277, are hereby incorporated in the license. Omaha Public Power District shall operate the facility in accordance with the Technical Specifications.

3. The license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULA TORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-40 and Technical Specifications Date of Issuance: November 6 2014

ATTACHMENT TO LICENSE AMENDMENT NO. 277 RENEWED FACILITY OPERATING LICENSE NO. DPR-40 DOCKET NO. 50-285 Replace the following pages of the Renewed Facility Operating License No. DPR-40 and the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

License Page REMOVE INSERT Technical Specifications REMOVE INSERT 3.2- Page 8 3.2- Page 8 3.2- Page 9 3.2- Page 9 3.2- Page 10 3.2- Page 10 3.2- Page 11 3.2- Page 11 3.2- Page 12 3.2-Page12 3.2-Page13 3.2- Page 13 3.2- Page 14 3.2- Page 14 3.2-Page15

(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 when associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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:

A. Maximum Power Level Omaha Public Power District is authorized to operate the Fort Calhoun Station, Unit 1, at steady state reactor core power levels not in excess of 1500 megawatts thermal (rate power).

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 277 are hereby incorporated in the license. Omaha Public Power District shall operate the facility in accordance with the Technical Specifications.

C. Security and Safeguards Contingency Plans The Omaha Public Power District shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Fort Calhoun Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan," submitted by letter dated May 19, 2006.

OPPD shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The OPPD CSP was approved by License Amendment No. 266.

Renewed Operating License No. DPR-40 Amendment No. 277

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference

1. Control Element Drop times of all full-length CEA's Prior to reactor criticality after each 7.5.3 Assemblies removal of the reactor vessel closure head

2. Control Element Partial movement of all CEA's Q 7 Assemblies (Minimum of 6 in)

3. Pressurizer Safety Verify each pressurizer safety valve In accor~ance with the lnservice Testing 7 Valves is OPERABLE in accordance with Program the lnservice Testing Program.

Following testin~, lift settings shall be 2485 psig +/-1 Yo and 253D psig +/-1%

respectively.

4. Main Steam Safety Set Point R 4 Valves

5. DELETED

6. DELETED

7. DELETED 8a. Reactor Coolant Evaluate D2 4 System Leakage 3 8b. Primary to Secondary Continuous process D2 4 Leakage4 radiation monitors or radiochemical grab sampling 9a Diesel Fuel Supply Fuel Inventory M 8.4 9b. Diesel Lubricating Oil Lube Oil Inventory M 8.4 Inventory 9c. Diesel Fuel Oil Test Properties In accordance with the Diesel Fuel 8.4 Properties Oil Testing Program 9d. Required Diesel Air Pressure M 8.4 Generator Air Start Receiver Bank Pressure 3.2- Page 8 Amendment No. 15,24,128, 160,166,169,171,219, 229,246,

~277

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 9e. Check for and Check for Water and Remove Q BA Remove Accumulated Water from Each Fuel Oil Storage Tank 5

10a. Charcoal and HEPA 1_ In-Place Testinq 9.10 Filters for Control Charcoal adsorbers and HEPA On a refueling frequency or every 720 Room Air Filteration filter banks shall be leak hours of system operation or after each System (CRAFS) tested and show ~99.95% complete or partial replacement of the Freon(R-11 orR-112)and charcoal adsorber/HEPA filter banks. or cold DOP particulates after any major structural maintenance on removal, respectively. the system housing or following significant painting, fire or chemical releases in a ventilation zone communicating with the system.

5

2. Laboratory Testing Verify, within 31 days after removal. On a refueling frequency or every 720 that a laboratory test of a sample of hours of system operation or after any the charcoal adsorber, when obtained structural maintenance on the HEPA filter or in accordance with Regulatory charcoal adsorber housing .QI following Position C.6.b of Regulatory Guide significant painting. fire or chemical release in 1.52, Revision 2, March 1978, shows a ventilation zone communicating with the methyliodide penetration less than system.

0.175% when tested in accordance with ASTM 03803-1989 at a temperature of 30"C (86"F) and a relative humidity of70%.

3.2- Page 9 Amendment No. 15,24,128,16Q,1Q8,:012Q,24i, 257 277

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 10a. (continued) 3. Overall System Operation

a. Each train shall be operated. Ten continuous hours every month with heaters operating.

b. The pressure drop across the R combined HEPA filters and charcoal adsorber banks shall be demonstrated to be less than 9 inches of water at system design flow rate.

c. Fan shall be shown to operate R within:!. 10% design flow.

4. Automatic and manual initiation of each R train shall be demonstrated.

5 1Ob. Charcoal Adsorbers 1. In-Place Testing for Spent Fuel Charcoal adsorbers shall be On a refueling frequency or every 720 6.2 Storage Pool Area leak tested and shall show hours of system operation. or after 9.10

~99% Freon (R-11 or R-112) each complete or partial replacement of removal. the charcoal adsorber bank, or after any major structural maintenance on the system housing or following significant painting, fire or chemical release in a ventilation zone communicating with the system.

2. Laboratory Testing Verify, within 31 days after removal. On a refueling frequency or every 720 that a laboratory test of a sample of hours of system operation or after any the charcoal adsorber, when obtained structural maintenance on the HEPA filter or in accordance with Regulatory charcoal adsorber housing or following Position C.6.b of Regulatory Guide significant painting, fire or chemical release in 1.52, Revision 2, March 1978, shows a ventilation zone communicating with the methyliodide penetration less than system.

10% when tested in accordance with ASTM 03803-1989 at a temperature of 3o*c (86.F) and a relative humidity of95%.

3.2- Page 10 Amendment No. 15,2'1 52.128,154,H~Q.1913,229,246, 2-a+

277

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 10b. (continued) ~Overall System Operation

a. Operation of each circuit Ten hours every month.

shall be demonstrated.

b. Volume flow rate through R charcoal filter shall be shown to be between 4500 and 12,000 cfm.

4. Manual initiation of the R system shall be demon-strated.

5 1Oc. Charcoal Adsorbers 1. In-Place Testing On a refueling frequency or every 9.10 for S.l. Pump Room Charcoal adsorbers shall be 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, or 6.2 leak tested and shall show after each complete or partial

.:::_99% Freon (R-11 or R-112) replacement of the charcoal adsorber bank, removal. or after any major structural maintenance on the system housing or following significant painting, fire or chemical release in any ventilation zone communicating with the system.

2. Laboratory Testing Verify, within 31 days after removal, On a refueling frequency or following 720 that a laboratory test of a sample of hours of system operatton or after any the charcoal adsorber, when obtained structural maintenance on the HEPA filter or in accordance with Regulatory charcoal adsorber housing or following Position C.6.b of Regulatory Guide significant painting, fire or chemical release in 1.52, Revision 2, March 1978, shows a ventilation zone communicating with the system.

methyliodide penetration less than 10% when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86°F) and a relative humidity of 95%.

3. Overall System Operation

a. Operation of each circuit Ten hours every month.

shall be demonstrated.

b. Volume flow rate shall be R shown to be between 3000 and 6000 cfm.

3.2- Page 11 Amendment No. 15,2~.52,128,1e9,198, 229,24e, ~

277

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference 1Oc. (continued) 4. Automatic and/or manual initi- R ation of the system shall be demonstrated.

11. Containment 1. Demonstrate damper action. 1 year, 2 years. 5 years, and every 5 9.10 Ventilation System years thereafter.

Fusible Linked Dampers 2. Test a spare fusible link.

12. Diesel Generator Calibrate R 8.4.3 Under-Voltage Relays

13. Motor Operated Verify the contactor pickup value at R Safety Injection .:::_85% of 460 V.

Loop Valve Motor Starters (HCV-311, 314,317,320,327, 329, 331' 333, 312, 315, 318, 321}

14. Pressurizer Heaters Verify control circuits operation R for post-accident heater use.

15. Spent Fuel Pool Test neutron poison samples for 1, 2. 4, 7. and 10 years after Racks dimensional change, weight, neutron installation. and every 5 years attenuation change and specific thereafter.

gravity change.

16. Reactor Coolant 1. Verify all manual isolation During each refueling outage JUSt Gas Vent System valves in each vent path are prior to plant start-up.

in the open position.

2. Cycle each automatic valve in the R vent path through at least one complete cycle of full travel from the control room. Verification of valve cycling may be determined by observation of position indicating lights.

3. Verify flow through the reactor R coolant vent system vent paths.

3.2- Page 12 Amendment No. 41,§4 6G.7a.77 BO.I5a,1e9,182,218,22Q,246, ~

277

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference

17. DELETED

18. Shutdown Cooling 1. Verify required shutdown cooling loops are S (when shutdown cooling is OPERABLE and one shutdown cooling loop is IN required by TS 2.8).

OPERATION.

2. Verify correct breaker alignment and indicated W (when shutdown cooling is power is available to the required shutdown cooling required by TS 2.8).

pump that is not IN OPERATION.

19. Refueling Water Level Verify refueling water level is <: 23 ft. above Prior to commencmg, and daily during the top of the reactor vessel flange. CORE ALTERATIONS and/or REFUELING OPERATIONS inside conta1nmE:nt.

20. Spent Fuel Pool Level Verify spent fuel pool water level is ~ 23 ft. Prior to commencing, and weeki] during above the top of irradiated fuel assemblies seated REFUELING OPERATIONS in the in the storage racks. the spent fuel pool.

21. Containment Penetrations Verify each required containment penetration is Prior to commencing, and weekly during in the required status. CORE ALTERATIONS and/or REFUELING OPERATIONS in containment.

22. Spent Fuel Assembly Verify by administrative means that initial Prior to storing the fuel assembly in Storage enrichment and burn up of the fuel assembly is in Region 2 (including peripheral cells).

accordance with Figure 2-1 0.

23. P-T Limit Curve Verify RCS Pressure, RCS temperature, and This test is only required during RCS RCS heatup and cooldown rates are within heatup and cooldown operations and RCS the limits specified by the P-T limit Figure(s) inservice leak and hydrostatic testing. While shown in the PTLR. these operations are occumng. this test shall be performed every 30 minutes.

24. Spent Fuel Cask Loading Verify by administrative means that initial Prior to placing the fuel assembly in a spent enrichment and burn up of the fuel assembly fuel cask in the spent fuel pooL is in accordance with Figure 2-11.

3.2- Page 13 Amendment No. +38,169,188, 246,2§0,257.2-74 277

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS Test Frequency USAR Section Reference

25. River Level Verify water level is within limits by measurement 0 9.8 at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, when the water level is less than 1004 feet and greater than or equal to 976 feet 9 inches above mean sea levels.

1 The provisions of Technical Specification 3.0.1 and 3.0.5 do not apply.

2 Whenever the system is at or above operating temperature and pressure.

3 Not applicable to primary to secondary LEAKAGE.

4 Verify primary to secondary LEAKAGE is::> 150 gallons per day through any one SG. This surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

5 Tests shall be performed in accordance with applicable section(s) of ANSI N510-1980.

3.2- Page 14 Amendment No. 188, 221, 239,246,297. 274 277

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 277 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-40 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 DOCKET NO. 50-285

1.0 INTRODUCTION

By application dated February 10, 2014, as supplemented by letter dated June 9, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML14041A408 and ML14163A417, respectively), Omaha Public Power District (OPPD) requested changes to the Technical Specifications (Appendix A to Renewed Facility Operating License No. DPR-40) for the Fort Calhoun Station, Unit No. 1 (FCS).

The proposed amendment revises Technical Specification (TS) Surveillance Requirement (SR) 3.2, "Equipment and Sampling Tests," Table 3-5, "Minimum Frequencies for Equipment Tests," Item 3 for the pressurizer safety valves from a refueling frequency (i.e., 18 months

+/- 25 percent) to be consistent with the lnservice Testing Program.

The licensee proposed the following specific changes to the TSs:

SR 3.2. Table 3-5, Item 3

• Change the frequency from "R" to "In accordance with the lnservice Testing Program 1 "

• Add footnote "1The provisions of Technical Specification 3.0.1 and 3.0.5 do not apply."

The asterisks currently used as footnotes in Table 3-5 are being revised to numbers and appear at the end of the table. As a result, text currently on 3.2 - Page 10 and subsequent pages is pulled forward.

Enclosure 2

2.0 REGULATORY EVALUATION

2.1 Description of the Pressurizer Safety Valves The two safety valves located on the pressurizer provide overpressure protection for the reactor coolant system (RCS). They are totally enclosed, back-pressure-compensated, spring-loaded safety valves meeting American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) requirements. The valves are described in the FCS Updated Safety Analysis Report (USAR; not publicly available) Section 4.3.1 0, "Pressurizer Safety Valves."

2.2 Description of the Proposed Changes Technical Specification (TS) 3.2, Table 3-5, Item 3, requires that the pressurizer safety valves be tested to "Verify each pressurizer safety valve is OPERABLE in accordance with the lnservice Testing Program. Following testing, lift settings shall be 2485 psig [pounds per square inch gage]+/- 1% and 2530 psig +/- 1% respectively." The table specifies a frequency of "R,"

designating a "Refueling" interval, which is defined in TS 3.0.1 as every 18 months +/- 25 percent allowing for a maximum of 22.5 months between tests. The licensee proposed revising the frequency to "In accordance with the In service Testing Program 1". The superscript 1 references a new footnote which would state: "The provisions of Technical Specification 3.0.1 and 3.0.5 do not apply." The licensee also proposed revising the footnote reference scheme from a system that uses multiple asterisks to refer to different footnotes to a system that uses superscript numbers to reference the different footnotes.

2.3 Regulatory Review The U.S. Nuclear Regulatory Commission (NRC) staff considered the following regulatory requirements, guidance, and licensing and design basis information during its review of the proposed change.

The regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities," provide the regulatory requirements for the licensing of production and utilization facilities. Section 50.92, "Issuance of amendment," of 10 CFR, paragraph 50.92(a), states, in part, that "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."

Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the application for a license. These TSs are derived from the plants' safety analyses. The regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36, "Technical specifications." Section 50.36 of 10 CFR requires TSs to include the following categories related to station operation: (1) safety limits, limiting safety systems settings and control settings; (2) limiting conditions for operation (LCOs);

(3) surveillance requirements (SRs); (4) design features; (5) administrative controls; (6) decommissioning; (7) initial notification; and (8) written reports.

Section 50.36(a)(1) of 10 CFR requires each applicant for a license to include a summary statement of the bases or reasons for proposed TSs; however, the bases shall not become part of the TSs.

Section 50.36(c)(2) of 10 CFR states that LCOs "are the lowest functional capability or performance level of equipment required for safe operation of the facility," and when LCOs are not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCO can be met.

Section 50.36(c)(3) of 10 CFR states that SRs "are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met."

The pressurizer safety valve SR ensures that RCS overpressure protection is available. The NRC staff reviewed the proposed SR changes for compliance with 10 CFR 50.36.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the licensee's proposed changes against the regulations, design basis information, and guidance referenced in Section 2 of this safety evaluation. The NRC staff reviewed the acceptability of the licensee's proposed changes to the SR by evaluating whether the proposed changes continue to provide reasonable assurance of public health and safety.

The NRC staff also verified that the proposed change to SRs continues to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

3.1 Changes to Pressurizer Safety Valve SR In its initial application, the licensee proposed a one-time extension of the SR to allow testing of the valves during the next scheduled refueling outage in April 2015. Following discussion with the NRC staff, the licensee concluded that using a frequency other than "In accordance with the lnservice Testing [1ST] Program" for a SR that is performed in accordance with the 1ST Program creates the potential for confusion as to when the test is required to be performed. In its supplement dated June 9, 2014, the licensee revised its request to propose a SR frequency that is consistent with 1ST Program requirements.

FCS TS 3.0.1 allows up to a 25 percent extension to a surveillance frequency, and FCS TS 3.0.5 allows an extension to the surveillance frequency if the test is missed. As documented in NRC Regulatory Issue Summary 2012-10, "NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests," dated August 23, 2012 (ADAMS Accession No. ML12079A393), the NRC staff has determined that delay periods normally allowed under FCS TS 3.0.1 and TS 3.0.5 do not apply to components tested under 10 CFR 50.55a(f), that is, components tested in accordance with the 1ST Program. Therefore, the licensee proposed a footnote to Item 3 stating: "The provisions of Technical Specification 3.0.1 and 3.0.5 do not apply" for the SR frequency. The licensee also submitted a request for relief, dated May 16, 2014 (ADAMS Accession No. ML14136A466), from the ASME Code requirement to conduct testing at a 24-month frequency, in order to perform the 1ST during the

next refueling outage, which is currently scheduled to begin in April 2015. The NRC staff's review of the relief request will be provided under separate correspondence.

The licensee does not propose to change the acceptance criteria for the pressurizer safety valve testing, but to revise the testing frequency to clarify the SR. Based on the above, the proposed changes to the TSs are acceptable because the SR will continue to provide assurance that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCO will be met. Therefore, the NRC staff concludes that the proposed SR frequency change continues to meet the requirements of 10 CFR 50.36(c)(3).

The licensee also proposed to revise the asterisks currently used as footnotes in Table 3-5 to numbers at the end of the table. As a result, text currently on 3.2- Page 10 and subsequent pages is pulled forward. The proposed changes are editorial and are acceptable to the NRC staff.

The licensee also submitted TS Bases changes corresponding to the proposed TS changes.

The TS Bases changes are consistent with the proposed TS changes and provide the purpose for each requirement in the specification as required by 10 CFR 50.36(a)(1 ). The proposed Bases changes are consistent with the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, dated July 2, 1993 (58 FR 39132).

Therefore, the NRC staff has no objection to the proposed changes to the TS Bases.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a surveillance requirement and makes editorial changes. 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 published in the Federal Register on July 8, 2014 (79 FR 38592). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(1 O)(v). 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: M. Hamm, NRR/DSS/STSB Date: November 6, 2014

ML14279A275 OFFICE NRR/DORLILPL4-1/PM N RR/DORLILPL4-1/LA NRRIDSS/STSB/BC NRRIDSS/SRXB/BC NAME FLyon JBurkhardt REIIiott US hoop DATE 10/9/14 10/7/14 10/28/14 10/20/14 OFFICE NRRIDE/EPNB/BC OGC/NLO NRR/DORLILPL4-1/BC NRRIDORL!LPL4-1/PM NAME DAiley BMizuno MMarkley FLyon DATE 10/23/14 11/5/14 11/6/14 11/6/14