ML16125A165

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Issuance of Amendment Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-523, Revision 2 Generic Letter 2008-01, Managing Gas Accumulation
ML16125A165
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 06/21/2016
From: Robert Kuntz
Plant Licensing Branch III
To: Gardner P
Northern States Power Company, Minnesota
Kuntz R, NRR-DORL 415-3733
References
CAC MF6479
Download: ML16125A165 (23)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 21, 2016 Mr. Peter A. Gardner Site Vice President Monticello Nuclear Generating Plant Northern States Power Company - Minnesota (NSPM) 2807 West County Road 75 Monticello, MN 55362-9637

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT - ISSUANCE OF AMENDMENT RE: TECHNICAL SPECIFICATIONS TASK FORCE STANDARD TECHNICAL SPECIFICATIONS CHANGE TRAVELER TSTF-523, REVISION 2, "GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION" (CAC NO. MF6479)

Dear Mr. Gardner:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 189 to Renewed Facility Operating License No. DPR-22 for the Monticello Nuclear Generating Plant.

The amendment consists of changes to the technical specifications in response to your application dated July 25, 2015.

The amendment adopts NRG-approved Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation."

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

Robert F. Ku enior 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. 189 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 DOCKET NO. 50-263 MONTICELLO NUCLEAR GENERATING PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 189 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 (NSPM, the licensee), dated July 25, 2015, 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 ttie Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.2 of Renewed Facility Operating License No. DPR-22 is hereby amended to read as follows:

Enclosure 1

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 189, are hereby incorporated in the license. NSPM 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 prior to the startup from the 2017 outage.

FOR THE NUCLEAR REGULATORY COMMISSION c)Jq_rJ ~

David J. Wrona, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Operating License No. DPR-22 and Technical Specifications Date of Issuance: June 21 , 2O1 6

ATTACHMENT TO LICENSE AMENDMENT NO. 189 RENEWED FACILITY OPERATING LICENSE NO. DPR-22 DOCKET NO. 50-263 Replace the following page of Renewed Facility Operating License 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 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 3.4.7-2 3.4.7-2 3.4.7-3 3.4.8-2 3.4.8-2 3.5.1-5 3.5.1-5 3.5.2-3 3.5.2-3 3.5.3-2 3.5.3-2 3.6.1.8-2 3.6.1.8-2 3.6.2.3-2 3.6.2.3-2 3.9.7-2 3.9.7-2 3.9.8-2 3.9.8-2

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, 1974 (those portions dealing 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.189, 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. 189

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. No RHR shutdown B.1 Initiate action to restore one Immediately cooling subsystem in RHR shutdown cooling operation. subsystem or one recirculation pump to AND operation.

No recirculation pump in AND operation.

B.2 Verify reactor coolant 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery circulation by an alternate of no reactor coolant method. circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND B.3 Monitor reactor coolant Once per hour temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 -------------------------------NOTE------------------------------

Not required to be met until 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after reactor steam dome pressure is less than the RHR shutdown cooling supply isolation interlock.

Verify one RHR shutdown cooling subsystem or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> recirculation pump is operating.

Monticello 3.4.7-2 Amendment No. 449, 189

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 SURVEILLANCE REQUIREMENTS continued SURVEILLANCE FREQUENCY SR 3.4.7.2 -------------------------------N 0 TE------------------------------ 31 days 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 reactor steam dome pressure is less than the RHR shutdown cooling supply isolation interlock.

Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.4.7-3 Amendment No. 189

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2 Monitor reactor coolant Once per hour temperature and pressure.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR shutdown cooling subsystem or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> recirculation pump is operating.

SR 3.4.8.2 Verify RHR shutdown cooling subsystem locations 31 days susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.4.8-2 Amendment No. 449, 189

ECCS - Operating 3.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.1.1 Verify, for each ECCS injection/spray subsystem, 31 days locations susceptible to gas accumulation are sufficiently filled with water.

SR 3.5.1.2 -------------------------------N 0 TE------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS injection/spray subsystem 31 days manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.1.3 Verify ADS pneumatic pressure is as follows for 31 days each required ADS pneumatic supply:

a. S/RV Accumulator Bank header pressure
2: 88.3 psig; and
b. Alternate Nitrogen System pressure is
2: 410 psig.

SR 3.5.1.4 -------------------------------NOTE------------------------------

Only required to be met in MODE 1.

Verify the RHR System intertie return line isolation 31 days valves are closed.

SR 3.5.1.5 Verify correct breaker alignment to the LPCI swing 31 days bus.

SR 3.5.1.6 Verify each recirculation pump discharge valve In accordance cycles through one complete cycle of full travel or is with the lnservice de-energized in the closed position. Testing Program Monticello 3.5.1-5 Amendment No. 146, 155, 162, 189

ECCS - Shutdown 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for each required ECCS injection/spray 31 days subsystem, locations susceptible to gas accumulation are sufficiently filled with water.

SR 3.5.2.3 -------------------------------N 0 TE------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each required ECCS injection/spray 31 days subsystem manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.2.4 Verify each required ECCS pump develops the In accordance specified flow rate against a system head with the Inservice corresponding to the specified reactor to Testing Program containment pressure.

System Head Corresponding to a Reactor to No. of Containment System Flow Rate Pumps Pressure of Core Spray  ;::: 2835 gpm 1  ;::: 130 psi LPCI 2 3870 gpm 1 2 20 psi SR 3.5.2.5 -------------------------------N 0 TE------------------------------

Vesse I injection/spray may be excluded.

Verify each required ECCS injection/spray 24 months subsystem actuates on an actual or simulated automatic initiation signal.

Monticello 3.5.2-3 Amendment No. 146, 167, 189

RCIC System 3.5.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 -------------------------------NOTE------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each RCIC System manual, power operated, 31 days and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.5.3.2 -------------------------------N 0 TE------------------------------

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 reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure :<: :; 1025.3 psig and In accordance

~ 950 psig, the RCIC pump can develop a flow rate with the Inservice

~ 400 gpm against a system head corresponding to Testing Program reactor pressure.

SR 3.5.3.3 -------------------------------N 0 TE------------------------------

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 reactor steam pressure and flow are adequate to perform the test.

Verify, with reactor pressure:<:::; 165 psig, the RCIC 24 months pump can develop a flow rate ~ 400 gpm against a system head corresponding to reactor pressure.

SR 3.5.3.4 -------------------------------NOTE------------------------------

Vessel injection may be excluded.

Verify the RCIC System actuates on an actual or 24 months simulated automatic initiation signal.

SR 3.5.3.5 Verify the RCIC System locations susceptible to gas 31 days accumulation are sufficiently filled with water.

Monticello 3.5.3-2 Amendment No. +4e, 189

RHR Drywell Spray 3.6.1.8 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.1.8.2 Verify each drywell spray header and nozzle is 10 years unobstructed.

SR 3.6.1.8.3 Verify RHR drywell spray subsystem locations 31 days susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.6.1.8-2 Amendment No. +49, 189

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.2.3.2 Verify each required RHR pump develops a flow In accordance rate ~ 3870 gpm through the associated heat with the Inservice exchanger while operating in the suppression pool Testing Program cooling mode.

SR 3.6.2.3.3 Verify RHR suppression pool cooling subsystem 31 days locations susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.6.2.3-2 Amendment No. -Me, 189

RHR - High Water Level 3.9.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.3 Initiate action to restore one Immediately standby gas treatment subsystem to OPERABLE status.

AND B.4 Initiate action to restore Immediately isolation capability in each required secondary containment penetration flow path not isolated.

C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery cooling subsystem in circulation by an alternate of no reactor coolant operation. method. circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.7.1 Verify one RHR shutdown cooling subsystem is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> operating.

SR 3.9.7.2 Verify required RHR shutdown cooling subsystem 31 days locations susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.9.7-2 Amendment No. 449, 189

RHR - Low Water Level 3.9.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.3 Initiate action to restore Immediately isolation capability in each required secondary containment penetration flow path not isolated.

C. No RHR shutdown C.1 Verify reactor coolant 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery cooling subsystem in circulation by an alternate of no reactor coolant operation. method. circulation AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.8.1 Verify one RHR shutdown cooling subsystem is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> operating.

SR 3.9.8.2 Verify RHR shutdown cooling subsystem locations 31 days susceptible to gas accumulation are sufficiently filled with water.

Monticello 3.9.8-2 Amendment No. 449, 189

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 189 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-22 NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263

1.0 INTRODUCTION

By application dated July 15, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15196A576), Northern States Power Company (NSPM, the licensee), requested changes to the technical specifications (TSs) for Monticello Nuclear Generating Plant (MNGP). 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.

The proposed change would revise surveillance requirements (SRs) related to gas accumulation for the emergency core cooling system (ECCS) and reactor core isolation cooling (RCIC) system. The proposed change would also add new SRs related to gas accumulation for the residual heat removal (RHR) systems. The TS Bases changes associated with these SRs would also be made.

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 is consistent with the NRC-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 effects may result in the subject system being unable to perform its specified safety function. The NRC issued Generic Letter Enclosure 2

(GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray [CS] 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 TS would be necessary to address some issues discussed in GL 2008-01. The 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 MNGP TS using a plant-specific adoption of the TSTF-523 changes.

2.2 Technical Specification Changes Changes were proposed for SRs 3.5.1.1, 3.5.1.2, 3.5.2.2, 3.5.2.3, and 3.5.3.1, as well as the addition of new SRs 3.4.7.2, 3.4.8.2, 3.5.3.5, 3.6.1.8.3, 3.6.2.3.3, 3.9.7.2, and 3.9.8.2 to TS 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown,"

TS 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown,"

TS 3.5.1, "ECCS - Operating," TS 3.5.2, "ECCS - Shutdown, TS 3.5.3, "RCIC System,"

TS 3.6.1.8, "Residual Heat Removal (RHR) Drywell Spray, TS 3.6.2.3, "Residual Heat Removal (RHR) Suppression Pool Cooling," TS 3.9.7, "Residual Heat Removal (RHR) - High Water Level," and TS 3.9.8, "Residual Heat Removal (RHR) - Low Water Level," respectively.

2.3 Regulatory Review The regulations in Appendix A to Title 10 of the Code of Federal Regulations (1 O CFR) Part 50 or similar plant-specific principal design criteria 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 10 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, in part, 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.

The plant design criteria for Monticello are listed in the Updated Safety Analysis Report (USAR)

Section 1.2, "Principal Design Criteria." The AEC published the final rule that added Appendix A to 10 CFR Part 50, "General Design Criteria for Nuclear Power Plants," in the Federal Register (36 FR 3255) on February 20, 1971, with the rule effective on May 21, 1971. In accordance with an NRC staff requirements memorandum from S. J. Chilk to J. M. Taylor, "SECY-92-223 -

Resolution of Deviations Identified During the Systematic Evaluation Program," dated September 18, 1992 {ADAMS Accession No. ML003763736), the Commission decided not to apply the final GDC to plants with construction permits issued prior to May 21, 1971, which includes Monticello. Monticello was not licensed to the 10 CFR 50, Appendix A GDC. The MNGP USAR provides an assessment against the proposed GDC in Appendix E. Similar to the GDC 1, and 35-40 requirements discussed above, the MNGP USAR Section E.2.1, states that "the reactor facility's essential components and systems are designed, fabricated, erected, and perform in accordance with the specified quality standards which are, as a minimum, in

accordance with applicable codes and regulations." Similar to the GDC 34 requirements discussed above, the MNGP USAR states in Section E.2.7 that '1he emergency core cooling systems (ECCS) are designed such that at least two different ECCSs of different phenomena are provided to prevent clad melt over the entire spectrum of postulated breaks. Such capability is available even with the loss of all off-site AC [alternate current] power."

Quality assurance criteria provided in 10 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 10 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 perform 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 10 CFR 50.36(c). Section 10 CFR 50.36(c) requires 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. Typically, TS Section 5 requires that licensees establish, implement, and maintain written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide (RG) 1.33, Revision 2, "Quality Assurance Program Requirements (Operation)." Appendix A to RG 1.33, Revision 2, identifies instructions for filling and venting the ECCS and decay heat removal system, as well as for draining and refilling heat exchangers. Standard TSs and most licensee TSs 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 is in NUREG-1433, "Standard Technical Specifications General Electric BWR/4 Plants" (ADAMS Accession Nos.

ML12104A192 and ML12104A193).

Regulatory guidance for the NRC 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 for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR Edition" (SRP) during the review.

  • Revision 5 of the 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.

3.0 TECHNICAL EVALUATION

The proposed changes adopted 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-523.

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 3.4.7.2, which states, "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water" together with a note that states "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 reactor steam dome pressure is less than the RHR shutdown cooling supply isolation interlock" and a frequency of 31 days.

(2) Add SR 3.4.8.2, which states, "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of 31 days.

(3) Revise the language for SR 3.5.1.1, from "Verify, for each low pressure ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve" to "Verify, for each ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water."

(4) Add a note to SR 3.5.1.2, which states, "Not required to be met for system vent flow paths opened under administrative control."

(5) Revise the language for SR 3.5.2.2, from "Verify, for each ECCS injection/spray subsystem, the piping is filled with water from the pump discharge valve to the injection valve" to "Verify, for each ECCS injection/spray subsystem, locations susceptible to gas accumulation are sufficiently filled with water."

(6) Add a note to SR 3.5.2.3, which states, "Not required to be met for system vent flow paths opened under administrative control."

(7) Add a note to SR 3.5.3.1, which states, "Not required to be met for system vent flow paths opened under administrative control."

(8) Add SR 3.5.3.5, which states "Verify the RCIC System locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of 31 days.

(9) Add SR 3.6.1.8.3, which states, "Verify RHR drywell spray subsystem locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of 31 days.

(10) Add SR 3.6.2.3.3, which states, "Verify RHR suppression pool cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of 31 days.

(11) Add SR 3.9.7.2, which states, "Verify required RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of 31 days.

(12) Add SR 3.9.8.2, which states, "Verify RHR shutdown cooling subsystem locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of 31 days.

The new language for the SRs was developed using licensee responses to GL 2008-01 and the NRC staff 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" dated October 21, 2008 (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 staff stated that the intent of the 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 TS, "sufficiently filled with water" is understood to mean "sufficiently filled with water to support Operability." Section 50.36(c)(3) of 10 CFR 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 proposed frequency of 31 days for SRs 3.4.7.2, 3.4.8.2, 3.5.3.5, 3.6.1.8.3, 3.6.2.3.3, 3.9.7.2, and 3.9.8.2 is consistent with the changes made to NUREG-1433, "Standard Technical Specifications General Electric BWR/4 Plants" by TSTF-523. The 31 day frequency takes into consideration the gradual nature of gas accumulation in the RHR Shutdown Cooling System, RHR Drywell Spray, RHR Suppression Pool Cooling, and RCIC system piping and the procedural controls governing system operation. Therefore, the proposed 31 day frequency for the new SRs is acceptable.

The addition of the note to TS 3.4.7.2, which 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 reactor steam dome pressure is less than the RHR shutdown cooling supply isolation interlock, provides a limited time to perform the surveillance after entering the applicability of the LCO. The note allows sufficient time to verify all RHR shutdown cooling

subsystem locations susceptible to gas accumulation are sufficiently filled with water upon entering the mode of applicability during a rapid shutdown. In addition MNGP TS Section 1.4 contains usage rules that define the proper use and application of frequency requirements and ensures the requirement to manage gas accumulation is not affected. Because the note (as controlled by TS 1.4) allows sufficient time to take actions necessary to maintain safety and is consistent with STS Section 1.4, the note is acceptable.

The addition of the notes that allow the SRs to not be met for system vent flow paths opened under administrative control is necessary to allow the licensee to use administratively controlled manual action to close the system vent flow path in order to maintain system Operability during system venting and performance of the proposed gas accumulation SR. Therefore, these notes are acceptable.

The NRC staff finds that the proposed SRs meet the regulatory requirements of 10 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 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 a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes surveillance requirements. The 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 (80 FR 61484). 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: M. Hamm, NRR Date: June 21, 2016

ML16125A165 *via memo OFFICE LPL3-1/PM LPL3-1/LA ST SB/BC OGC/NLO LPL3-1/BC LPL3-1/PM NAME RKuntz MHenderson AKlein* MYoung DWrona RKuntz DATE 05/12/16 05/10/16 04/14/16 06/16/16 06/21/16 06/21/16

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