ML17139D352
| ML17139D352 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/11/2017 |
| From: | Teresa Ray Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ON-2017-039 | |
| Download: ML17139D352 (9) | |
Text
Thomas D. Ray Vice President
(_~ DUKE Oconee Nuclear Station ENERGY~ Duke Energy ON01VP I 7800 Rochester Hwy Seneca, SC 29672
- 0. 864.873.5016 f 864.873. 4208 ON-2017-039 10 CFR 50.90 Tom.Ray@duke-energy.com May 11, 2017 Attn : Document Control Desk U. S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville , MD 20582-2746 Duke Energy Carolinas, LLC Oconee Nuclear Station , Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287, Renewed Operating Licenses DPR-38, DPR-47 , and DPR-55
Subject:
Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, using the Consolidated Line Item Improvement Process; License Amendment Request (LAR) No'. 2015-03; Supplement 1 References : (1) Duke Energy Carolinas, LLC. (Duke Energy) letter to the U. S. Nuclear Regulatory Commission (NRC), "Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, using the Consolidated Line Item Improvement Process; License Amendment Request No. 2015-03," dated March 30, 2017.
(2) NRC letter to Duke Energy, "Oconee Nuclear Station Units 1, 2, and 3 -
Supplemental Information Needed for Acceptance of Requested Licensing Action RE : License Amendment Request to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3 (CAC Nos. MF9555, MF9556 , and MF9557)," dated April 24, 2017.
In accordance with 10 CFR 50.90, Duke Energy is submitting Supplement 1 to a request for an amendment to the Technical Specifications (TS) related to Control Room Envelope Habitability for the Oconee Nuclear Station (ONS). Specifically, the proposed supplement modifies the LAR which was submitted to the NRC on March 30, 2017 (Ref. 1).
The supplement addresses an NRC letter (Ref. 2) which noted that a proposed booster fan runtime change from ~1 hour to ~15 minutes (contained in TS Surveillance Requirement (SR) 3.7.9.1) is not a part of a typical TSTF-448 adoption and had not been appropriately justified as a variance to the TSTF. Duke Energy agrees with the Staff on this issue. This supplement removes the previously proposed change to SR 3.7.9.1.
The revised TS and TS Bases (TSB) pages associated with this proposed change are contained in an attachment to this letter. These pages replace the associated marked up and reprinted printed pages from the original LAR (Ref. 1). In addition, the LAR's no significance hazards justification was reviewed and determined to be unaffected by the proposed change . D{
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Nuclear Regulatory Commission License Amendment Request No. 2015 Supplement 1 May 11 , 2017 Page 2 There are no regulatory commitments made in this submittal. A copy of this LAR supplement was transmitted to the State of South Carolina in accordance with 10 CFR 50.91 requirements .
If you should have any questions regarding this submittal, please contact Stephen C. Newman, Lead Nuclear Engineer, Regulatory Affairs, at (864) 873-4388.
I declare under penalty of perjury that the foregoing is true and correct. Executed on May 11 , 2017.
Sincerely, omas D. Ray j).~
Vice President Oconee Nuclear Station
Attachment:
Revised TS and TSB Page Replacement Instructions
Nuclear Regulatory Commission License Amendment Request No. 2015 Supplement 1 May 11 , 2017 Page 3 xc w/attachment:
Catherine Haney, Administrator, Region II U.S. Nuclear Regulatory Comm ission Marquis One Tower 245 Peachtree Center Ave ., NE, Suite 1200 Atlanta , GA 30303-1257 Mr. Stephen Koenick, Project Manager (ONS)
(by electronic mail only)
U.S. Nuclear Regulatory Comm ission 11555 Rockville Pike Mail Stop OWFN/8F14 Rockville, MD 20852-2738 Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station Susan E. Jenkins, Manager (by electronic mail only: jenkinse@dhec.sc.gov)
Radioactive & Infectious Waste Management SC Dept. of Health and Environmental Control 2600 Bull St.
Columbia , SC 29201
ATTACHMENT REVISED TS AND TSB PAGE REPLACEMENT INSTRUCTIONS:
Replace With Original LAR Attachment 1 Revised LAR Attachment 1 a e 3.7.9-5 a e 3.7.9-5
Revised LAR Attachment 1 CRVS Booster Fans (paQe 3.7.9-5) 3.7.9 GGNQl+IGN ReQldlReQ AG+IGN GGMPbe+IGN +IMe I I D. ReEJl:liFeEl AGtieA aAEl D.1 Be iA MGDe 3. 12 h9l:lFS asseGiateEl GempletieA
+ime Aet FAet iA MGQe ANG 1, 2, 3, 9F 4.
D.2 Be iA MGDe a 30 h9l:lFS E ReEJl:liFeEl AGtieA aAEl E1 ~l:lspeAEl mei.1eFAeAt ef IFAmeEliately asseGiateEl GempletieA FeGeAtly iFFaEliateEl fl:lel
+iFAe Aet met Ell:lFiA§l asseFAblies.
meveFAeAt ef FeGeAtly iFFaEliateEl fl:lel asseFAblies.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Operate each CRVS Booster Fan train for In accordance with the
- 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Surveillance Frequency Control Program SR 3.7.9.2 Perform required CRVS Booster Fan train In accordance with the filter testing in accordance with the Ventilation VFTP Filter Testing Program (VFTP).
SR 3.7.9.3 Verify the control room isolates on a manual In accordance with the actuation signal. Surveillance Frequency Control Program SR 3.7.9.4 Perform required CRE unfiltered air inleakage In accordance with the testing in accordance with the Control Room Control Room Envelope Envelope Habitability Program. Habitability Program (continued)
OCONEE UNITS 1, 2, & 3 3.7.9-5 Amendment Nos. xxx~. xxx~. ~ xxx~
Revised LAR Attachment 1 (page unnumbered)
If both CRVS trains are inoperable in MODE 1. 2. 3, or 4 for reasons other than an inoperable CRE boundary (i.e., Condition B), one
- -- - -- - - train must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In this Condition, the capability to minimize the radiation dose personnel located in the Control Room during and after an accident is unavailable. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is based on the low probability of an accident occurring during this time period.
G.1 If the Required Action and associated Completion Time of Condition F is not met. LCO 3.0.3 must be entered immediately.
SURVEILLANCE SR3.7.9.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train adequately checks this system. The trains need only be operated for ~ one hour and all dampers verified to be OPERABLE to demonstrate .
SURVEILLANCE SR 3.7.9.1 (continued)
REQUIREMENTS the function of the system . This test includes an external visual inspection of the CRVS Booster Fan trains . The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program .
SR 3.7.9.2 This SR verifies that the required CRVS Booster Fan train testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance. carbon absorber efficiency, minimum system flow rate. and the physical properties of the activated carbon.:_CRVS Booster Fan train filter test frequencies are in accordance with Regulatory Guide 1.52 (Ref. 4). The VFTP includes testing HEPA filter performance and carbon adsorber efficiency. Specific test frequencies and additional information are discussed in detail in the VFTP.
SR 3.7.9.3 This SR verifies that the CRE isolates and operates on a manual actuation signal. The Frequency is based on industry operating experience and is consistent with the typical refueling cycle and will be managed in accordance with the Surveillance Frequency Control Program. a integrity of the Control Room enclosure. The Control Room positive pressure, with respect to potentially contaminated adjacent areas, is periodically tested to verify that the CRVS Booster Fan trains
Revised LAR Attachment 2 CRVS Booster Fans (page 3.7.9-3) 3.7.9 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F. Two CRVS Booster Fan F.1 Restore one CRVS 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> trains inoperable in Booster Fan train to MODE 1, 2, 3, or 4 for OPERABLE status.
reasons other than Condition B.
G. Required Action and G.1 Enter LCO 3.0.3. Immediately associated Completion Time of Condition F not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Operate each CRVS Booster Fan train for In accordance with the
~ 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Surveillance Frequency Control Program SR 3.7.9.2 Perform required CRVS Booster Fan train In accordance with the filter testing in accordance with the Ventilation VFTP Filter Testing Program (VFTP).
SR 3.7.9.3 Verify the control room isolates on a manual In accordance with the actuation signal. Surveillance Frequency Control Program SR 3.7.9.4 Perform required CRE unfiltered air inleakage In accordance with the testing in accordance with the Control Room Control Room Envelope Envelope Habitability Program. Habitability Program (continued)
OCONEE UNITS 1, 2, & 3 3.7.9-3 Amendment Nos. xxx, xxx, & xxx
Revised LAR Attachment 2 CRVS Booster Fans (page B 3. 7.9-5) B 3.7.9 BASES (continued)
ACTIONS D.1 and D.2 (continued) to OPERABLE status within the required Completion Time , the OPERABLE CRVS Booster Fan train must be started . This action ensures that the remaining train is OPERABLE, and that any active failure will be readily detected. An alternative to Required Action D.1 is to immediately suspend activities that could release radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.
E.1 In MODE 5 or 6, or during movement of recently irradiated fuel assembles, when two CRVS Booster Fan trains are inoperable, or with one or more CRVS Booster Fan trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimized the accident risk. This does not preclude the movement of fuel to a safe position.
F.1 If both CRVS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e., Condition B), one train must be restored to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In this Condition , the capability to minimize the radiation dose personnel located in the Control Room during and after an accident is unavailable. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is based on the low probability of an accident occurring during this time period .
If the Required Action and associated Completion Time of Condition F is not met, LCO 3.0.3 must be entered immediately.
SURVEILLANCE SR 3.7.9.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. As the environment and normal operating conditions on this system are not severe, testing each train adequately checks this system. The trains need only be operated for ~ one hour and all dampers verified to be OPERABLE to demonstrate OCONEE UNITS 1, 2, & 3 B 3.7.9-5 Rev. 001 I
Revised LAR Attachment 2 CRVS Booster Fans (page B 3.7.9-6) B 3.7.9 BASES (continued)
SURVEILLANCE SR 3.7.9.1 (continued)
REQUIREMENTS the function of the system . This test includes an external visual inspection of the CRVS Booster Fan trains . The Surveillance Frequency is based on operating experience , equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program .
SR 3.7.9.2 This SR verifies that the required CRVS Booster Fan train testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The VFTP includes testing HEPA filter performance , carbon absorber efficiency, minimum system flow rate , and the physical properties of the activated carbon . Specific test frequencies and additional information are discussed in detail in the VFTP.
SR 3.7.9.3 This SR verifies that the CRE isolates and operates on a manual actuation signal. The Frequency is based on industry operating experience and is consistent with the typical refueling cycle and will be managed in accordance with the Surveillance Frequency Control Program .
SR 3.7.9.4 The Surveillance Frequency verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program .
The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of OBA consequences is no more than 5 rem TEOE and the CRE occupants are protected from hazardous chemicals and smoke . This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of OBA consequences . When unfiltered air inleakage is greater than the assumed flow rate , Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 6) which endorses, with exceptions , NEI 99-03 , Section 8.4 and Appendix F (Ref. 7). These compensatory measures may also be used as mitigating actions as OCONEE UNITS 1, 2, & 3 B 3.7.9-6 Rev. 001 I