ML16063A475

Issuance of Amendments

ML16063A475
Person / Time
Site:	Vogtle   (NPF-068, NPF-081)
Issue date:	03/21/2016
From:	Martin B Plant Licensing Branch II
To:	Pierce C Southern Nuclear Operating Co
Bob Martin, NRR/DORL
References
CAC MF6213, CAC MF6214
Download: ML16063A475 (16)

Text

UNITED STATES. '

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. C. R. Pierce Regulatory Affairs Director M3:rdl 21, 2016 Southern Nuclear Operating Company, Inc.

P. 0. Box 1295 I Bin - 038 Birmingham, AL 35201-1295

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2, ISSUANCE OF AMENDMENTS (CAC NOS. MF6213 AND MF6214)

Dear Mr. Pierce:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 178 to Renewed Facility Operating License No. NPF-68 and Amendment No. 159 to Renewed Facility Operating License No. NPF-81 for the Vogtle Electric Generating Plant, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated May 12, 2015, as supplemented on September 21, 2015,

. November 25, 2015; and January 28, 2016.

The changes revise and add Surveillance Requirements to verify that the system locations susceptible to gas accumulation are sufficiently filled with water and to provide allowances that

• permit performance of the verification. The changes are consistent with TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Docket Nos. 50-424 and 50-425

Enclosures:

1. Amendment No. 178 to NPF-68

2. Amendment No. 159 to NPF-81

3. Safety Evaluation cc w/encls: Distribution via Listserv Sincerely,

//? o-1-/!1. ~

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:::;:,~- -

~ob Martin, 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 SOUTHERN NUCLEAR OPERATING COMPANY. INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-424 VOGTLE ELECTRIC GENERATING PLANT. UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 178 Renewed License No. NPF-68

1.

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

A.

The application for amendment to the Vogtle Electric Generating Plant, Unit 1, Renewed Facility Operating License No. NPF-68, filed by Southern Nuclear Operating Company, Inc. (the licensee), dated May 12, 2015, as supplemented by letter dated September 21, 2015, November 25, 2015; and January 28, 2016, 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 1 O 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.

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. NPF-68, is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 178, are hereby incorporated in the renewed facility operating license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

3.

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

Attachment:

Changes to License No. NPF-68 And the Technical Specifications Date of Issuance: ~

21, 2016 FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

UNITED STATES NUCLEAR REGULATORYCOMMISSION WASHINGTON, D.C. 20555-0001 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-425 VOGTLE ELECTRIC GENERATING PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 159 Renewed License No. NPF-81

1.

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

A.

The application for amendment to the Vogtle Electric Generating Plant, Unit 2, Renewed Facility Operating License No. NPF-81, filed by Southern Nuclear Operating Company, Inc. (the licensee), dated May 12, 2015, as supplemented by letter dated September 21, 2015, November 25, 2015, and January 28, 2016, 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.

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. NPF-81 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained. in Appendix A, as revised through Amendment No. 159, are hereby incorporated in the renewed facility operating license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications.

3.

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

Attachment:

Changes to License No. NPF-81 And the Technical Specifications Date of Issuance: M:rrd1 21, 2016.

FOR THE NljCLEAR REGULATORY COMMISSION jifc..I'"

~v~

Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation*

ATTACHMENT TO LICENSE AMENDMENT NO. 178 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-68 DOCKET NO. 50-424 AND LICENSE AMENDMENT NO. 159 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-81 DOCKET NO. 50-425 Replace the following pages of the Renewed. Facility Operating License and Appendix "A" Technical Specifications (TSs) with the enclosed pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove License NPF-68, page 4 NPF-81, page 3 TSs 3.4.6-3 3.4.7-3 3.4.8-3 3.5.2-2 3.6.6-2 3.6.6-3 3.9.5-2 3.9.6-2 License NPF-68, page 4 NPF-81, page 3 TSs 3.4.6-3 3.4.7-3*

3.4.8-3 3.5.2-2 3.6.6-2 3.6.6-3 3.9.5-2 3.9.6-2 (1)

Maximum Power Level

-~

Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 178, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the environmental Protection Plan.

(3)

Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4)

(5)

(6)

(7)

(8)

(9)

(10)

Deleted Deleted Deleted Deleted Deleted Deleted Mitigation Strateg~ License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a)

Fire fighting response strategy with the following elements:

1.

Pre-definea coordinated fire response strategy and guidance

2.

Assessment of mutual aid fire fighting assets

3.

Designated staging areas for equipment and materials

4.

Command and control

5.

Training and response personnel (b}

Operations to mitigate fuel damage considering the following:

1.

Protection and use of personnel assets

2.

Communications

3.

Minimizing fire spread

4.

Procedures for Implementing integrated fire response strategy

5.

Identification of readily-available pre-staged equipment

6.

Training on integrated fire response strategy Renewed Operating License NPF-68 Amendment No. 178 (2)

Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia, pursuant to the Act and 1 O CFR Part 50, to possess but not operate the facility at the designated location in Burke County, Georgia, in accordance with the procedures and limitations set forth in this license; (3)

Southern Nuclear, pursuant to the Act and 1 O CFR Part 70, 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 re.actor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4)

Southern Nuclear, pursuant to the Act and 1 O CFR Parts 30, 40, and 70 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; (5)

Southern Nuclear, pursuant to the Act and 1 O 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; (6)

Southern Nuclear, pursuant to the Act and 1 O CFR Parts 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 authorized herein.

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 1 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 Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 159 and the Environmental Protection Rian contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance requirements (SRs) contained in the Appendix A Technical Specifications and listed below are not required to be performed immediately upon implementation of Amendment No. 7 4. The SRs listed below shall be Renewed Operating License NPF-81 Amendment No. 159

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 178 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-68 AND AMENDMENT NO. 159 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-81 SOUTHERN NUCLEAR OPERATING COMPANY. INC.

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1.AND 2 DOCKET NOS. 50-424 AND 50-425

1.0 INTRODUCTION

By application dated May 12, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15132A662), as supplemented by letters dated September 21, '

2015 (ADAMS Accession No. ML15264A738), November 25, 2015 (ADAMS Accession No. ML15329A249), and January 28, 2016, (ADAMS Accession No. ML16028A475) Southern Nuclear Operating Company (SNC, the licensee) submitted a request to change the Vogtle Electric Generating Plant (VEGP), Units 1 and 2, Technical Specifications (TSs). The supplements dated September 21, 2015, November 25, 2015, and January 28, 2016, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on June 23, 2015 (80 FR 35984).

Specifically, the licensee requested to adopt U.S. Nuclear Regulatory Commission (NRC)-

approved Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS)

Change Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" (ADAMS Accession No. ML13053A075), dated February 21, 2013. The availability of this TS improvement was announced in the Federal Register on January 15, 2014 (79 FR 2700) as part of the consolidated line item improvement process (CLllP).

The proposed change would add new and revise existing surveillance requirements (SRs) related to gas accumulation for the emergency core cooling system (ECCS), residual heat removal (RHR) system, and containment spray (CS) system. TS Bases associated with these SRs would also be revised.

Enclosed within its license amendment request, the licensee provided its TS Bases changes for the proposed'changes to the TSs. These changes were presented for information only because these changes are controlled through TS 5.5.14, "Technical Specification (TS) Bases Control Program." The NRC staff reviewed the changes to verify that they are consistent with the changes in the TSTFs and are technically correct.

The licensee stated that it has reviewed the information contained in the model safety evaluation dated December 23, 2013 (ADAMS Accession No. ML13255A169) and that the license amendment request (LAR) is consistent with NRG-approved TSTF-523.

2.0 REGULATORY EVALUATION

2.1 Background

Gas accumulation in reactor systems can result in water hammer, pump cavitation, and pumping of non-condensible gas into the reactor vessel. These e.ffects may result in the subject system being unable to perform its specified safety function. The NRC issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal

[OHR], and Containment Spray Systems," in January 2008 to address the issue of gas accumulation in ECCS, OHR, and CS systems (ADAMS Accession No. ML072910759}. The industry and NRC staff agreed that a change to the STS and plant-specific TSs would b~

necessary to address some issues discussed in GL 2008-01. TSTF-523 contains changes to the TS SRs and TS Bases to address some of the concerns in GL 2008-01. The licensee proposed amending the VEGP TSs using a plant-specific adoption of the TSTF-523 changes.

2.2 Technical Specification Changes Changes were proposed for SRs 3.5.2.2, 3.5.2.3, 3.6.6.1, as well as the addition of new S~s 3.4.6.4, 3.4.7.4, 3.4.8.4, 3.6.6.9, 3.9.5.2, and 3.9.6.2 to TS 3.4.6, "RCS Loops - MODE 4," TS

(

3.4. 7, "RCS Loops - MODE 5, Loops Filled, TS 3.4.8, "RCS. Loops - MODE 5, Loops Not Filled," TS 3.5.2, "ECCS-Operating," TS 3.6.6, "Containment Spray and Cooling Systems," TS 3.9.5, "RHR and Coolant Circulation - High Water Level," and TS 3.9.6, "RHR and Coolant Circulation_ - Low Water Level," respectively.

2.3 Regulatory Review The regulations in Appendix A to Title 1 O of the Code of Federal Regulations (10 CFR) Part 50 provide design requirements. Appendix B to 10 CFR Part 50, the TSs, and the licensee quality assurance programs provide operating requirements. The regulatory requirements of 1 O CFR Part 50, Appendix A, that are applicable to gas management in the subject systems include:

General Design Criteria (GDC) 1, 34, 35, 36, 37, 38, 39 and 40. GDC 1 requires that the subject systems be designed, fabricated, erected, and tested to quality standards. GDC 34 requires an RHR system designed to maintain specified acceptable fuel design limits and to.

• meet design conditions that are not exceeded if a single failure occurs and specified electrical power systems fail. GDC 35, 36, and 37 require an ECCS design that meets performance, inspection, and testing requirements. Additionally, the regulations in 10 CFR 50.46 provide specified ECCS performance criteria. GDC 38, 39, and 40 require a containment heat removal system design that meets performance, inspection, and testing requirements.

. Quality assurance criteria provided in 1 O CFR Part 50, Appendix B, that apply to gas management in the subject systems include: Criteria Ill, V, XI, XVI, and XVII. Criteria Ill and V require measures to ensure that applicable regulatory requirements and the design basis, as defined in 1 O CFR 50.2, "Definitions," and as specified in the license application, are correctly translated into controlled specifications, drawings, procedures, and instructions. Criterion XI requires a test program to ensure that the subject systems will perfqrm satisfactorily in service and requires that test results shall be documented and evaluated to ensure that test requirements have been satisfied. Criterion XVI requires measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected, and that significant conditions adverse to quality are documented and reported to management.

Criterion XVII requires maintenance of records of activities affecting quality.

The NRC's regulatory requirements related to the content of the TSs are contained in 1 O CFR 50.36(c). The regulations at 10 CFR 50.36 require that the TSs include items in the following categories: {1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCO); (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. Section 5 from the VEGP.

TSs requires the licensee to establish, implement, and maintain written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements (Operation)." Appendix A to RG 1.33 identifies instructions for filling and venting the ECCS and OHR system, as well as for draining and refilling heat exchangers. STS include SRs to verify that at least some of the subject systems piping is filled with water.

The NRC's guidance for the format and content of licensee TSs can be found in NUREG-1431, "Standard Technical Specifications Westinghouse Plants."

Regulatory guidance for the NRG staff's review of containment heat removal systems, ECCS,

. and RHR systems is provided in the following revisions and sections of, NUREG-0800,

. "Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition."

• Revision 3 of SRP, Section 6.2.2, "Containment Heat Removal Systems," dated March 2007 (ADAMS Accession No. ML070160661 ), provides the procedures concerning the review of containment heat removal under post-accident conditions to help ensure compliance with GDC 38, 39, and 40.

Revision 3 of SRP, Section 6.3, "Emergency Core Cooling System," dated March 2007 (ADAMS Accession No. ML070550068), provides the procedures concerning the review of ECCS to help ensure compliance with GDC 35, 36, and 37.

Revision 5 of SRP, Section 5.4.7, "Residual Heat Removal (RHR) System," dated May 201 O (ADAMS Accession Number ML100680577), provides the procedures concerning the review of the RHR system as it is used to cool the reactor coolant system (RCS) during and following shutdown to help ensure compliance with GDC 34.

3.0 TECHNICAL EVALUATION

The proposed change adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1431, "Standard Technical Specifications Westinghouse Plants" by TSTF-523.

The deviations between the licensee's submittal and TSTF-523 are listed below along with their reconcili?tion.

. (1) Numbering differences were identified between the VEGP TSs and TSTF-523.'

These differences are administrative and do not affect the applicability of TSTF-523 to the VEGP TSs.

(2) A note was added to the RHR SRs (i.e., 3.4.6.4, 3.4.7.4, 3.4.8.4, 3.9.5.2, and 3.9.6.2) to allow an operating RHR loop to be credited for meeting the SR. The evaluation of this deviation is provided below.

The NRC staff compared the proposed changes to the existing SRs, as well as the regulatory requirements of 10 CFR 50.36(c).

The licensee proposed the following TS changes:

(1) Add SR 3.4.6.4, which states, "Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water" with two notes that state "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 entering MODE 4" and "An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation." The stated frequency is "In accordance with the Surveillance Frequency Control Program."

(2) Add SR 3.4.7.4, which states, "Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water" with a note that states, "An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation" and a stated frequency of "In accordance with the Surveillance Frequency Control Program."

(3) Add SR 3.4.8.4, which states "Verify RHR loop locations susceptible to gas

. accumulation are sufficiently filled with water" with a note that states, "An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation" and a stated frequency of In accordance with the Surveillance Frequency Control Program."

(4) Add a note to SR 3.5.2.2,. which states, "Not required to be met for system vent flow paths opened under administrative control."

(5) Revise the language for SR 3.5.2.3 from "Verify ECCS piping is full of water" to "Verify ECCS locations susceptible to gas accumulation are sufficiently filled with water."

(6) Add a note to SR 3.6.6.1, which states, "Not required to be met for system vent flow paths opened under administrative control."

(7) Add SR 3.6.6.9, which states, "Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water" with a stated frequency of "In accordance with the Surveillance Frequency Control Program."

(8) Add SR 3.9.5.2, which states, "Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water" with a note that states, "An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation" and a stated frequency of "In accordance with the Surveillance Frequency Control Program."

(9) Add SR 3.9.6.2, which states, "Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water" with a note that states, "An operating RHR loop will meet this requirement for the RHR loop running* unless the RHR loop is in a low flow system operation" and a stated frequency of "In accordance with the Surveillance Frequency Control Program."

The language for the new SRs was developed using licensee responses to GL 2008-01 and the NRC discussion contained in Task Interface Agreement (TIA) 2008-03, "Emergency Core Cooling System (ECCS) Voiding Relative To Compliance With Surveillance Requirements (SR) 3.5.1.1, 3.5.2.3, and 3.5.3.1" (ADAMS Accession No. ML082560209). Many of the GL 2008-01 responses stated that licensees identified system locations susceptible to gas accumulation. In the TIA, the NRC stated that the intent of existing TS SRs, which state "full of water, may be met if the licensee can establish, through an Operability Determination, that there is a reasonable expectation that the system in question will perform its specified safety function. Therefore the phrase, "sufficiently filled with water" was recommended for the proposed TS changes. In the TSs, "sufficiently filled with water" is understood to mean "sufficiently filled with water to support Operability." The regulation at 1 O CFR 50.36(c)(3) states that one of the purposes of the SR is to verify that the LCO is met. Therefore, the new SR language, "Verify the [system name] locations susceptible to gas accumulation are sufficiently filled with water," is acceptable since this language will allow the licensee to make a conclusion as to whether or not a system is operable.

The first note for TS 3.4.6.4 states that the SR does not have 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 entering Mode 4. The NRC staff finds that this note is acceptable because it provides a limited time to perform the surveillance after entering the applicability of the LCO. In addition, the note is acceptable because, under the STS usage rules (STS Sectioh 1.4), the requirement to manage gas accumulation is not affected by the allowance provided by the note. The licensee must have confidence that the SR can be met or the LCO must be declared not met..

The licensee added notes to SRs 3.4.6.4, 3.4.7.4, 3.4.8.4,3.9.5.2, and 3.9.6.2 that state: "An operating RHR loop will meet this requirement for the RHR loop running unless the RHR loop is in a low flow system operation." These notes allow the licensee to credit an RHR loop operating under normal conditions for meeting the SRs. The intent of the SRs associated with these notes is to verify gas accumulation in the RHR system has not increased to a point that would challenge its operability (i.e., the system is not sufficiently filled with water). The NRC staff reviewed the licensee's justification for crediting the SR as being met and finds that it is acceptable. The licensee's justification in this circumstance is twofold. First, an RHR loop operating under normal conditions (i.e., not low flow system operation) is performing its specified safety function of removing decay heat from the reactor core and providing proper boron mixing. The operating system, therefore, provides evidence that it is currently "sufficiently filled with water." However, this alone is not sufficient justification for crediting the SR as being met because the system must be able to continue to operate for an extended period even if challenged by gradual gas accumulation, such as could occur during mid-loop operation. This is why the second part of the licensee's justification is important, which is the RHR loop operating under normal cc:mditions will provide proper circulation (i.e., not low flow system operation). This will ensure that gas voids are transported through the system, thereby preventing gas accumulation. Also, acting as an additional safeguard while the RHR system is in operation, the plant operators monitor the RHR system parameters (e.g., pressure, flow rate, pump motor current). If gas voids are detected, then the plant staff wilf enter appropriate response procedures and will enter the issue into the VEGP corrective action program and respond appropriately. Therefore, the staff finds that it is acceptable for the licensee to credit an operating RHR loop with high enough flow for proper circulation as meeting the associated SR.

The licensee added notes that allow the SRs 3.5.2.2 and :3.6.6.1 to not be met for system vent flow paths opened under administrative control. These notes are necessary to allow the licensee to credit administratively controlled manual action to close the system vent flow path in qrder to maintain system operability during system venting and performance of the proposed gas accumulation SR. The TS bases state that "The administrative control should be

• proceduralized and include stationing an individual who can rapidly close the system vent flow path if directed." Therefore, the staff finds that these notes are acceptable.

Based on its review as described above; the NRC staff found that the proposed SR~ meet the regulatory requirements of 1 O CFR 50.36 because they provide assurance that the necessary

, quality of systems and components will be maintained and that the LCO will be met. Therefore, the NRC staff finds the proposed amendment acceptable.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to installation or use of a facility component located within the reptricted area as defined in 1 O CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public

.comment on such finding (80 FR 35984, June 23, 2015). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 1 O CFR 51.22(c)(9). Pursuant to 1 O CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

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:

. Williams Satterfield, NRR/DSS/STSB Warren Lyon, NRR/DSS/SRXB Date: Mm:h 21, 2016

ML16063A475

• By memo dated WSatterfield, NRR Wlyon, NRR MHamm, NRR OFFICE LPL2-1/PM LPL2-1/LA DSS/STSB/BC DSS/SRXB/BC NAME BMartin SFigueroa RElliott EOesterie DATE 03/21/16 03/07/16 02/10/16 02/10/16 OFFICE OGC LPL2-1/BC LPL2-1/PM NAME A Ghosh MMarkley (SWilliams for)

BMartin DATE 02/22/16 03/21/16 03/21/16