ML19050A297
| ML19050A297 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, Harris, Robinson, McGuire |
| Issue date: | 04/18/2019 |
| From: | Michael Mahoney Plant Licensing Branch II |
| To: | Capps C Duke Energy Carolinas |
| Mahoney M | |
| References | |
| EPID L-2018-LLA-0134 | |
| Download: ML19050A297 (72) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 18, 2019 Mr. Steven Capps Senior Vice President - Nuclear Operation Duke Energy Carolinas, LLC.
526 South Church Street, EC-07H Charlotte, NC 28202
SUBJECT:
CATAWBA NUCLEAR STATION, UNITS 1 AND 2, MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1, H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 -
ISSUANCE OF AMENDMENTS REGARDING REMOVAL OF HEATERS FROM VENTILATION SYSTEM TECHNICAL SPECIFICATIONS (EPID NO. L-2018-LLA-0134)
Dear Mr. Capps:
The U.S. Nuclear Regulatory Commission (NRC) has issued the following amendments:
Amendment No. 301 to Renewed Facility Operating License No. NPF-35 and Amendment No. 297 to Renewed Facility Operating License No. NPF-52 for the Catawba Nuclear Station, Units 1 and 2, respectively.
Amendment No. 313 to Renewed Facility Operating License No. NPF-9 and Amendment No. 292 to Renewed Facility Operating License No. NPF-17 for the McGuire Nuclear Station, Units 1 and 2, respectively.
Amendment No.170 to Renewed Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit No. 1.
Amendment No. 262 to Renewed Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2.
The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated May 10, 2018 (Agencywide Documents Access and Management System Accession No. ML18131A068), from Duke Energy Progress, LLC. and Duke Energy Carolinas, LLC. (together, Duke Energy or the licensees). The application proposes TS changes for the Catawba Nuclear Station (Catawba), Units 1 and 2; McGuire Nuclear Station (McGuire), Units 1 and 2; Shearon Harris Nuclear Power Plant (Harris), Unit No. 1; and H.B. Robinson Steam Electric Plant (Robinson), Unit No. 2.
The proposed amendments would modify the TSs for Catawba, McGuire, Harris and Robinson.
Specifically, ventilation system heaters will be removed from Catawba TSs 3.6.10, "Annulus Ventilation System (AVS)," 3.7.10, "Control Room Area Ventilation System (CRAVS)," 3.7.12, "Auxiliary Building Filtered Ventilation Exhaust System (ABFVES}," 3.7.13, "Fuel Handling Ventilation Exhaust System (FHVES)," 3.9.3, "Containment Penetrations," 5.5.11, "Ventilation Filter Testing Program (VFTP)," and 5.6.6, "Ventilation Systems Heater Report."
Ventilation system heaters will be removed from McGuire TSs 3.6.10, "Annulus Ventilation System (AVS)," 3.7.9, "Control Room Area Ventilation System (CRAVS}," 5.5.11, "Ventilation Filter Testing Program (VFTP)," and 5.6.6, "Ventilation Systems Heater Failure Report." The
specified relative humidity for charcoal testing in the ventilation system Surveillance Requirement (for Harris) and Ventilation Filter Testing Program (for Robinson) is revised from 70 percent to 95 percent and the ventilation system heaters will be removed from the Harris TSs 3/4.7.6, "Control Room Emergency Filtration System," 3/4.7.7, "Reactor Auxiliary Building (RAB) Emergency Exhaust System," and 3/4.9.12, "Fuel Handling Building Emergency Exhaust System," and Robinson TSs 3.7.11, "Fuel Building Air Cleanup System (FBACS}," and 5.5.11, "Ventilation Filter Testing Program (VFTP)." The proposed changes are consistent with Technical Specifications Task Force (TSTF) Traveler TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month," Revision 0. Additionally, an administrative error is being corrected in McGuire's TS 5.5.11, "Ventilation Filter Testing Program (VFTP)."
A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
If you have any questions, please contact me at (301) 415-3867 or by e-mail at Michael.Mahoney@nrc.gov 1u-Michael Mahoney, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.
50-413, 50-414, 50-369, 50-370, 50-400, and 50-261
Enclosures:
- 1. Amendment No. 301 to NPF-35
- 2. Amendment No. 297 to NPF-52
- 3. Amendment No. 313 to NPF-9
- 4. Amendment No. 292 to NPF-17
- 5. Amendment No. 170 to DPR-63
- 6. Amendment No. 262 to DPR-23
- 7. Safety Evaluation cc:
Mr. Tom Simril Site Vice President Catawba Nuclear Station, Units 1 and 2 Duke Energy Carolinas, LLC 4800 Concord Road York, SC 29545 Mr. Ernest J. Kapopoulos, Jr.,
H.B. Robinson Steam Electric Plant, Unit 1 Site Vice President Duke Energy Progress, LLC 3581 West Entrance Road, RNPA01 Hartsville, SC 29550 Additional Distribution via Listserv Mr. Tom Ray Vice President McGuire Nuclear Station, Units 1 and 2 Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078 Ms. Tanya Hamilton Site Vice President Shearon Harris Nuclear Power Plant, Unit 1 Duke Energy 5413 Shearon Harris Road New Hill, NC 27562-0165
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC NORTH CAROLINA MUNICIPAL POWER AGENCY NO. 1 PIEDMONT MUNICIPAL POWER AGENCY DOCKET NO. 50-413 CATAWBA NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 301 Renewed License No. NPF-35
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to the Catawba Nuclear Station, Unit 1 (the facility) Renewed Facility Operating License No. NPF-35 filed by the Duke Energy Carolinas, LLC, acting for itself, and North Carolina Electric Membership Corporation (licensees), dated May 10, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 set forth in 10 CFR Chapter I; 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 hereby amended by page 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-35 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 301, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC, 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-35 and Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION
~r(}<.,.A, 0,)JJ)~ ~,r Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance:
Apr i 1 1 8, 2 o 1 9
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC NORTH CAROLINA MUNICIPAL POWER AGENCY NO. 1 PIEDMONT MUNICIPAL POWER AGENCY DOCKET NO. 50-414 CATAWBA NUCLEAR STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 297 Renewed License No. NPF-52
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to the Catawba Nuclear Station, Unit 2 (the facility) Renewed Facility Operating License No. NPF-52 filed by the Duke Energy Carolinas, LLC, acting for itself, North Carolina Municipal Power Agency No. 1 and Piedmont Municipal Power Agency (licensees), dated May 10, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 set forth in 10 CFR Chapter I; 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 hereby amended by page 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-52 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 297, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC, 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-52 and the Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION CZJ~Aor Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: Apr i 1 1 8, 2 O 1 9
ATTACHMENT TO CATAWBA NUCLEAR STATION, UNITS 1 AND 2 LICENSE AMENDMENT NO. 301 RENEWED FACILITY OPERATING LICENSE NO. NPF-35 DOCKET NO. 50-413 AND LICENSE AMENDMENT NO. 297 RENEWED FACILITY OPERATING LICENSE NO. NPF-52 DOCKET NO. 50-414 Replace the following pages of the Renewed Facility Operating Licenses with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Pages NPF-35, page 4 NPF-52, page 4 Insert Pages NPF-35, page 4 NPF-52, page 4 Replace the following pages of the 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 Pages 3.6.10-1 3.7.10-2 3.7.10-3 3.7.12-1 3.7.13-1 3.9.3-1 3.9.3-2 5.5-14 5.6-5 Insert Pages 3.6.10-1 3.7.10-2 3.7.10-3 3.7.12-1 3.7.13-1 3.9.3-1 3.9.3-2 5.5-14 5.6-5
(2)
(3) TECHNICAL SPECIFICATIONS The Technical Specifications contained in Appendix A, as revised through Amendment No. 301, which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.
Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation. Duke shall complete these activities no later than December 6, 2024, and shall notify the NRG in writing when implementation of these activities is complete and can be verified by NRG inspection.
The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4),
following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 1 O CFR 50.59 and otherwise complies with the requirements in that section.
(4)
Antitrust Conditions Duke Energy Carolinas, LLC shall comply with the antitrust conditions delineated in Appendix C to this renewed operating license.
(5)
Fire Protection Program Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that complies with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2013; as supplemented by letters dated January 13, 2015; January 28, 2015; February 27, 2015; March 30, 2015; April 28, 2015; July 15, 2015; August 14, 2015; September 3, 2015; December 11, 2015; January 7, 2016; March 23, 2016; June 15, 2016; August 2, 2016; September 7, 2016; and, January 26, 2017, as approved in the SE dated February 8, 2017. Except where NRG approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRG approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Renewed License No. NPF-35 Amendment No. 301 (2)
TECHNICAL SPECIFICATIONS (3)
The Technical Specifications contained in Appendix A, as revised through Amendment No. 297 which are attached hereto, are hereby incorporated into this renewed operating license. Duke Energy Carolinas, LLC shall operate the facility in accordance with the Technical Specifications.
Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation. Duke shall complete these activities no later than December 6, 2024, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50. 71 (e)(4), following issuance of this renewed operating license. Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 1 O CFR 50.59 and otherwise complies with the requirements in that section.
(4)
Antitrust Conditions (5)
Duke Energy Carolinas, LLC shall comply with the antitrust conditions delineated in Appendix C to this renewed operating license.
Fire Protection Program Duke Energy Carolinas, LLC shall implement and maintain in effect all provisions of the approved fire protection program that complies with 10 CFR 50.48(a) and 1 O CFR 50.48(c), as specified in the licensee amendment request dated September 25, 2013; as supplemented by letters dated January 13, 2015; January 28, 2015; February 27, 2015; March 30, 2015; April 28, 2015; July 15, 2015; August 14, 2015; September 3, 2015; December 11, 2015; January 7, 2016; March 23, 2016; June 15, 2016; August 2, 2016; September 7, 2016; and, January 26, 2017, as approved in the SE dated February 8, 2017. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Renewed License No. NPF-52 Amendment No. 297
3.6 CONTAINMENT SYSTEMS 3.6.1 O Annulus Ventilation System (AVS)
LCO 3.6.10 Two AVS trains shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION A.
One AVS train A.1 Restore AVS train to inoperable.
OPERABLE status.
B.
Required Action and B.1 Be in MODE 3.
associated Completion Time not met.
AND B.2 Be in MODE 5.
Catawba Units 1 and 2 3.6.10-1 AVS 3.6.10 COMPLETION TIME 7 days 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours Amendment Nos. 301/297
REQUIRED ACTIONS (continued, CONDITION C.
Required Action and associated Completion Time of Condition A or B not met in MODE 1, 2, 3, or 4.
D.
Required Action and associated Completion Time of Condition A not met in MODE 5 or 6 or during movement of irradiated fuel assemblies.
E.
Two CRAVS trains inoperable in MODE 5 or 6, or during movement of irradiated fuel assemblies.
OR One or more CRAVS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies.
F.
Two CRAVS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition 8.
Catawba Units 1 and 2 C.1 AND C.2 D. 1 OR 0.2 E.1 F.1 REQUIRED ACTION Be in MODE 3.
Be in MODE 5.
Place OPERABLE CRAVS train in operation.
Suspend movement of irradiated fuel assemblies.
Suspend movement of irradiated fuel assemblies.
Enter LCO 3.0.3.
CRAVS 3.7.10 COMPLETION TIME 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours Immediately Immediately Immediately Immediately 3.7.10-2 Amendment Nos. 301/297
SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3. 7.10.1 Operate each CRAVS train for~ 15 continuous minutes.
SR 3. 7.10.2 Perform required CRAVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
SR 3.7.10.3 Verify each CRAVS train actuates on an actual or simulated actuation signal.
SR 3.7.10.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
CRAVS 3.7.10 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with VFTP In accordance with the Surveillance Frequency Control Program In accordance with the Control Room Envelope Habitability Program Catawba Units 1 and 2 3.7.10-3 Amendment Nos. 301/297
3.7 PLANT SYSTEMS
- 3. 7.12 Auxiliary Building Filtered Ventilation Exhaust System (ABFVES)
LCO 3.7.12 Two ABFVES trains shall be OPERABLE.
ABFVES 3.7.12
NOTE--------------------------------------------------
The ECCS pump rooms pressure boundary may be opened intermittently under administrative controls.
APPLICABILITY:
MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
One ABFVES train A.1 Restore ABFVES train to 7 days inoperable.
OPERABLE status.
- 8.
Two ABFVES trains 8.1 Restore ECCS pump 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inoperable due to rooms pressure boundary inoperable ECCS pump to OPERABLE status.
rooms pressure boundary.
C.
Required Action and C. 1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or B AND not met.
C.2 Be in MODE 5.
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Catawba Units 1 and 2 3.7.12-1 Amendment Nos. 301/297
- 3. 7 PLANT SYSTEMS FHVES 3.7.13
- 3. 7.13 Fuel Handling Ventilation Exhaust System (FHVES)
LCO 3.7.13 Two FHVES trains shall be OPERABLE and one train in operation.
APPLICABILITY:
During movement of recently irradiated fuel assemblies in the fuel building.
ACTIONS A.
CONDITION One or more FHVES trains inoperable.
Catawba Units 1 and 2 REQUIRED ACTION
NO TE-------------------
L CO 3.0.3 is not applicable.
A.1 Suspend movement of recently irradiated fuel assemblies in the fuel building.
COMPLETION TIME Immediately 3.7.13-1 Amendment Nos. 301/297
Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:
- a.
The equipment hatch closed and held in place by a minimum of four bolts;
- b.
A minimum of one door in each air lock closed; and
- c.
Each penetration providing direct access from the containment atmosphere to the outside atmosphere either:
- 1.
closed by a manual or automatic isolation valve, blind flange, or equivalent,.or
- 2.
exhausting through an OPERABLE Containment Purge Exhaust System (CPES) HEPA filter and carbon adsorber.
APPLICABILITY:
During movement of recently irradiated fuel assemblies within containment.
ACTIONS A.
CONDITION One or more containment penetrations not in required status.
Catawba Units 1 and 2 A.1 REQUIRED ACTION Suspend movement of recently irradiated fuel assemblies within containment.
COMPLETION TIME Immediately 3.9.3-1 Amendment Nos. 301/297
Containment Penetrations 3.9.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.9.3.1 Verify each required containment penetration is in the required status.
SR 3.9.3.2 Operate each CPES for~ 15 continuous minutes.
SR 3.9.3.3 Perform required CPES filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the VFTP Catawba Units 1 and 2 3.9.3-2 Amendment Nos. 301/297
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 5.5.12 Ventilation Filter Testing Program (VFTP} (continued)
- d.
Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the carbon adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1980 at the flowrate specified below+/- 10%.
ESF Ventilation System Annulus Ventilation Control Room Area Ventilation Aux. Bldg. Filtered Exhaust Containment Purge (non-ESF) (2 fans)
Fuel Bldg. Ventilation
- e.
Deleted Delta P 8.0 in wg 8.0 in wg 8.0 in wg 8.0 in wg 8.0 in wg Flowrate 9000 cfm 6000 cfm 30,000 cfm 25,000 cfm 16,565 cfm The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.
Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in gas storage tanks or fed into the offgas treatment system, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure". The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures".
(continued)
Catawba Units 1 and 2 5.5-14 Amendment Nos. 301/297
Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.6 5.6.7 Not used.
PAM Report When a report is required by LCO 3.3.3, "Post Accident Monitoring (PAM)
Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.
Catawba Units 1 and 2 5.6-5 (continued)
Amendment Nos. 301/297
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY CAROLINAS, LLC DOCKET NO. 50-369 MCGUIRE NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 313 Renewed License No. NPF-9
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to the McGuire Nuclear Station, Unit 1 (the facility), Renewed Facility Operating License No. NPF-9, filed by the Duke Energy Carolinas, LLC (licensee), dated May 10, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 set forth in 10 CFR Chapter I; 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 hereby amended by page 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-9 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 313, are hereby incorporated into this renewed operating license. The licensee 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-9 and the Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION
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Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: Apr i 1 1 8, 2 O 1 9
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 DUKE ENERGY CAROLINAS. LLC DOCKET NO. 50-370 MCGUIRE NUCLEAR STATION. UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 292 Renewed License No. NPF-17
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to the McGuire Nuclear Station, Unit 2 (the facility), Renewed Facility Operating License No. NPF-17, filed by the Duke Energy Carolinas, LLC (the licensee), dated May 10, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 set forth in 10 CFR Chapter I; 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 1 O CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is hereby amended by page 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-17 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 292, are hereby incorporated into this renewed operating license. The licensee 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-17 and the Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION
~/
~-1,,1) J)~N)_,Q_.
Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: April 18, 201 9
ATTACHMENT TO MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 LICENSE AMENDMENT NO. 313 RENEWED FACILITY OPERATING LICENSE NO. NPF-9 DOCKET NO. 50-369 AND LICENSE AMENDMENT NO. 292 RENEWED FACILITY OPERATING LICENSE NO. NPF-17 DOCKET NO. 50-370 Replace the following pages of the Renewed Facility Operating Licenses with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Pages NPF-9, page 3 NPF-17, page 3 Insert Pages NPF-9, page 3 NPF-17, page 3 Replace the following pages of the 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 Pages 3.6.10-1 3.7.9-2 3.7.9-3 5.5-10 5.5-11 5.6-5 Insert Pages 3.6.10-1 3.7.9-2 3.7.9-3 5.5-10 5.5-11 5.6-5 (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 associated with radioactive apparatus or components; (5) Pursuant to the Act and 1 O CFR Parts 30, 40 and 70, to possess, but not separate, such byproducts and special nuclear materials as may be produced by the operation of McGuire Nuclear Station, Units 1 and 2, and; (6) Pursuant to the Act and 1 O CFR Parts 30 and 40, to receive, possess and process for release or transfer such byproduct material as may be produced by the Duke Training and Technology Center.
B.
This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth 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 The licensee is authorized to operate the facility at a reactor core full steady state power level of 3469 megawatts thermal (100%).
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 313, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3) Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d), as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation.
Duke shall complete these activities no later than June 12, 2021, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4), following issuance of this renewed operating license.
Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 1 O CFR 50.59 and otherwise complies with the requirements in that section.
Renewed License No. NPF-9 Amendment No. 313 (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 associated with radioactive apparatus or components; (5)
Pursuant to the Act and 1 O CFR Parts 30, 40 and 70, to possess, but not separate, such byproducts and special nuclear materials as may be produced by the operation of McGuire Nuclear Station, Units 1 and 2; and, (6)
Pursuant to the Act and 1 O CFR Parts 30 and 40, to receive, possess and process for release or transfer such byproduct material as may be produced by the Duke Training and Technology Center.
B.
This renewed operating license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth 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 The licensee is authorized to operate the facility at a reactor core full steady state power level of 3469 megawatts thermal (100%).
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 292, are hereby incorporated into this renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3)
Updated Final Safety Analysis Report The Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21(d}, as revised on December 16, 2002, describes certain future activities to be completed before the period of extended operation.
Duke shall complete these activities no later than March 3, 2023, and shall notify the NRC in writing when implementation of these activities is complete and can be verified by NRC inspection.
The Updated Final Safety Analysis Report supplement as revised on December 16, 2002, described above, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 1 O CFR 50.71 (e)(4}, following issuance of this renewed operating license.
Until that update is complete, Duke may make changes to the programs described in such supplement without prior Commission approval, provided that Duke evaluates each such change pursuant to the criteria set forth in 1 O CFR 50.59, and otherwise complies with the requirements in that section.
Renewed License No. NPF-17 Amendment No. 292
3.6 CONTAINMENT SYSTEMS 3.6.10 Annulus Ventilation System (AVS)
LCO 3.6.10 Two AVS trains shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3, and 4.
ACTIONS AVS 3.6.10 CONDITION REQUIRED ACTION COMPLETION TIME A.
One AVS train A.1 Restore AVS train to 7 days inoperable.
OPERABLE status.
B.
Required Action and 8.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.
AND 8.2 Be in MODE 5.
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> McGuire Units 1 and 2 3.6.10-1 Amendment Nos. 313/292
CONDITION D.
Required Action and associated Completion Time of Condition A not met in MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE AL TERA TIONS.
E.
Two CRAVS trains inoperable in MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS.
OR One or more CRAVS trans inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies, or during CORE ALTERATIONS.
F.
Two CRAVS trains inoperable in MODE 1, 2, 3, or 4 (for reasons other than Condition B).
McGuire Units 1 and 2 REQUIRED ACTION D. 1 Place OPERABLE CRAVS train in emergency mode.
OR D.2.1 Suspend CORE AL TERA TIONS.
AND D.2.2. Suspend movement of irradiated fuel assemblies.
E.1 Suspend CORE ALTERATIONS.
AND E.2 Suspend movement of irradiated fuel assemblies.
F.1 Enter LCO 3.0.3.
CRAVS 3.7.9 COMPLETION TIME Immediately Immediately Immediately Immediately Immediately Immediately 3.7.9-2 Amendment Nos. 313/292
CRAVS 3.7.9
.--------------------NOTE-------------------------------------------------------------
- 'A' Train CRAVS is allowed to be inoperable for a total of 14 days to address a non-conforming condition on the 'A' Train supply piping from the Standby Nuclear Service Water Pond (SNSWP). The 14 days may be taken consecutively or in parts until completion of the activity, or by March 31, 2019, whichever occurs first. During the period in which the 'A' Train NSWS supply piping from the SNSWP is not available, the 'A' Train NSWS will remain aligned to Lake Norman until the system is ready for post maintenance testing. Any maintenance that is performed on the remaining portions of 'A' Train NSWS during the period in which the 'A' NSWS from the SNSWP supply piping is not available will be limited to a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time. The latter will not count against the 14 day completion time. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures as described in MNS LAR submittal correspondence letter M NS-17-031.
McGuire Units 1 and 2 3.7.9-3 Amendment Nos. 313/292
Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.11 Ventilation Filter Testing Program (VFTP) (continued)
ESF Ventilation System Annulus Ventilation Control Area Ventilation Aux. Bldg. Filtered Exhaust (2 fans)(Unit 1)
Aux. Bldg. Filtered Exhaust (2 fans)(Unit 2)
Containment Purge (non-ESF) (2 fans)
Fuel Bldg. Ventilation (non-ESF)
< 1%
< 0.05%
< 1%
< 1%
< 1%
< 1%
Flowrate 8000 cfm 2000 cfm 45,700 cfm 40,500 cfm 21,000 cfm 35,000 cfm
- b.
Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows the following penetration and system bypass when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 (N510-1980 for Auxiliary Building Filtered Exhaust) at the flowrate specified below+/- 10%.
ESF Ventilation System Annulus Ventilation Control Area Ventilation Aux. Bldg. Filtered Exhaust (2 fans)(Unit 1)
Aux. Bldg. Filtered Exhaust (2 fans)(Unit 2)
Containment Purge (non-ESF) (2 fans)
Fuel Bldg. Ventilation (non-ESF)
< 1%
< 0.05%
< 1%
< 1%
< 1%
< 1%
Flowrate 8000 cfm 2000 cfm 45,700 cfm 40,500 cfm 21,000 cfm 35,000 cfm
- c.
Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at the temperature and relative humidity (RH) specified below.
ESF Ventilation System Penetration RH Annulus Ventilation
<4%
95%
Control.Area Ventilation
< 0.95%
95%
Aux. Bldg. Filtered Exhaust
<4%
95%
Containment Purge (non-ESF)
<4%
95%
Fuel Bldg. Ventilation (non-ESF)
<4%
95%
Temp.
30°c 30°c 30°c 30°c 30°c
- d.
Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ANSI N510-1975 at the flowrate specified below +/- 10%.
(continued)
McGuire Units 1 and 2 5.5-10 Amendment Nos. 313/292
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 5.5.12 Ventilation Filter Testing Program (VFTP) (continued)
ESF Ventilation System Annulus Ventilation Control Area Ventilation Aux. Bldg. Filtered Exhaust (2 fans)(Unit 1)
Aux. Bldg. Filtered Exhaust (2 fans)(Unit 2)
Containment Purge (non-ESF) (2 fans)
Fuel Bldg. Ventilation (non-ESF)
- e.
Deleted Delta P 6.0 in wg 5.0 in wg 6.0 in wg 6.0 in wg 6.0 in wg 6.0 in wg Flowrate 8000 cfm 2000 cfm 45,700 cfm 40,500 cfm 21,000 cfm 35,000 cfm The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.
Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in gas storage tanks or fed into the offgas treatment system, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure". The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures".
The program shall include:
- a.
The limits for concentrations of hydrogen and oxygen in the Waste Gas Holdup System and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate to the system's design criteria (i.e., whether or not the system is designed to withstand a hydrogen explosion);
(continued)
McGuire Units 1 and 2 5.5-11 Amendment Nos. 313/292
5.6 Reporting Requirements Reporting Requirements 5.6 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)
- 14.
DPC-NE-2009-P-A, 'Westinghouse Fuel Transition Report," (DPC Proprietary).
- 15.
WCAP-12945-P-A, Volume 1 and Volumes 2-5, "Code Qualification Document for Best-Estimate Loss of Coolant Analysis," 0!:::!.... Proprietary).
- 16.
DPC-NE-1005P-A, "Duke Power Nuclear Design Methodology Using CASM0-4/SIMULATE-3 MOX," (DPC Proprietary).
- 17.
DPC-NE-1007-PA, "Conditional Exemption of the EOC MTC Measurement Methodology" (Duke and Westinghouse Proprietary).
- 18.
WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," April 1995. (Westinghouse Proprietary).
- 19.
WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO'," July 2006. (Westinghouse Proprietary).
The COLR will contain the complete identification for each of the Technical Specifications referenced topical reports used to prepare the COLR (i.e., report number, title, revision number, report date or NRC SER date, and any supplements).
- c.
The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SOM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
- d.
The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.
5.6.6 Not Used.
5.6.7 PAM Report When a report is required by LCO 3.3.3, "Post Accident Monitoring (PAM)
Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.
(continued)
McGuire Units 1 and 2 5.6-5 Amendment Nos. 313/292
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-400 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 170 Renewed License No. NPF-63
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Duke Energy Progress, LLC (the licensee),
dated May 10, 2018, 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;
- 8.
The facility will operate in conformity with the application, the pro~isions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-63 is hereby amended to read as follows:
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 170, are hereby incorporated into this license. Duke Energy Progress, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This license amendment is effective as of the date of its issuance and shall be implemented within 120 days of issuance.
Attachment:
Changes to the Renewed License and the Technical Specifications FOR THE NUCLEAR REGULATORY COMMISSION
~
1.J~s;c,,,-
Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: April 18, 2019
A TI ACHMENT TO LICENSE AMENDMENT NO. 170 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. NPF-63 DOCKET NO. 50-400 Replace the following page of the Renewed Facility Operating License with the revised page.
The revised page is identified by amendment number and contains a line in the margin indicating the area of change.
Remove Pages NPF-63, Page 4 Insert Pages NPF-63, Page 4 Replace the following pages of the Appendix A, Technical Specifications (TS) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Pages 3/4 7-15 3/4 7-16 3/47-17 3/47-18 3/4 9-14 3/4 9-15 Insert Pages 3/4 7-15 3/4 7-16 3/4 7-17 3/4 7-18 3/4 9-14 3/4 9-15 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 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.
Carolina Power & Light Company is authorized to operate the facility at reactor core power levels not in excess of 2900 megawatts thermal ( 100 percent rated core power) in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 170, are hereby incorporated into this license. Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Antitrust Conditions (4)
Carolina Power & Light Company shall comply with the antitrust conditions delineated in Appendix C to this license.
Initial Startup Test Program (Section 14)1 Any changes to the Initial Test Program described in Section 14 of the FSAR made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.
(5)
Steam Generator Tube Rupture (Section 15.6.3)
Prior to startup following the first refueling outage, Carolina Power & Light Company shall submit for NRC review and receive approval if a steam generator tube rupture analysis, including the assumed operator actions, which demonstrates that the consequences of the design basis steam generator tube rupture event for the Shearon Harris Nuclear Power Plant are less than the acceptance criteria specified in the Standard Review Plan, NUREG-0800, at 15.6.3 Subparts 11(1) and (2) for calculated doses from radiological releases. In preparing their analysis Carolina Power &
Light Company* will not assume that operators will complete corrective actions within the first thirty minutes after a steam generator tube rupture.
1The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.
- on April 29, 2013, the name of "Carolina Power & light Company" (CP&L) was changed to "Duke Energy Progress, Inc." On August 1, 2015, the name "Duke Energy Progress, Inc." was changed to "Duke Energy Progress, LLC."
Renewed License No. NPF-63 Amendment No. 170
PLANT SYSTEMS.
3/4.7.6 CONTROL ROOM EMERGENCY FILTRATION SYSTEM.
LIMITING CONDITION FOR OPERATION (Continued)
- c.
During movement of irradiated fuel assemblies or movement of loads over spent fuel pools.
- 1.
With one CREFS train inoperable for reasons other than an inoperable CRE boundary, restore the inoperable CREFS train to OPERABLE status within 7 days or immediately initiate and maintain operation of the remaining OPERABLE CREFS train in the recirculation mode; or immediately suspend movement of irradiated fuel.
- 2.
With both CREFS trains inoperable for reasons other than an inoperable CRE boundary, or with the OPERABLE CREFS train required to be in the recirculation mode by Action c.1., not capable of being powered by an OPERABLE emergency power source, immediately suspend all operations involving movement of irradiated fuel assemblies or movement of loads over spent fuel pools.
- 3.
With one or more CREFS trains inoperable due to inoperable CRE boundary, immediately suspend movement of irradiated fuel assemblies or movement of loads over spent fuel pools.
SURVEILLANCE REQUIREMENTS 4.7.6 Each CREFS train shall be demonstrated OPERABLE:
- a.
At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes;
- b.
At the frequency specified in the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following significant painting, fire, or chemical release in any ventilation zone communicating with the system by:
- 1. Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Position C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is 4000 cfm +/- 10% during system operation when tested in accordance with ANSI N510-1980; and SHEARON HARRIS - UNIT 1 3/4 7-15 Amendment No. 170
PLANT SYSTEMS CONTROL ROOM EMERGENCY FILTRATION SYSTEM SURVEILLANCE REQUIREMENTS (CONTINUED)
- 2. Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of S0.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM 03803 -1989.
- c.
After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of S0.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM 03803-1989.
- d.
At the frequency specified in the Surveillance Frequency Control Program by:
- 1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 5.1 inches water gauge while operating the system at a flow rate of 4000 cfm +/- 10%;
- 2. Verifying that, on either a Safety Injection or a High Radiation test signal, the system automatically switches into an isolation with recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks;
- 3. Deleted.
- 4. Deleted.
- 5. Deleted.
- e.
After each complete or partial replacement of a HEPA filter bank, by verifying that the unit satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the system at a flow rate of 4000 cfm +/- 10%; and
- f.
After each complete or partial replacement of a charcoal adsorber bank, by verifying that the cleanup system satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 4000 cfm +/- 10%.
- g.
Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
SHEARON HARRIS - UNIT 1 3/4 7-16 Amendment No. 170
PLANT SYSTEMS.
3/4.7.7 REACTOR AUXILIARY BUILDING (RAB) EMERGENCY EXHAUST SYSTEM.
LIMITING CONDITION FOR OPERATION 3.7.7 Two independent RAB Emergency Exhaust Systems shall be OPERABLE.*
APPLICABILITY: MODES 1, 2, 3, and 4.
ACTION:
- a.
With one RAB Emergency Exhaust System inoperable, restore the inoperable system to OPERABLE status within 7 days** or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- b.
With two RAB Emergency Exhaust Systems inoperable due to an inoperable RAB Emergency Exhaust System boundary, restore the RAB Emergency Exhaust System boundary to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE REQUIREMENTS
- 4. 7. 7 Each RAB Emergency Exhaust System shall be demonstrated OPERABLE:
- a.
At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes;
- b.
At the frequency specified in the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following significant painting, fire, or chemical release in any ventilation zone communicating with the system by:
- 1.
Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the unit flow rate is 6800 cfm +/- 10% during system operation when tested in accordance with ANSI N510-1980;
- 2.
Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodine penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM D3803-1989.
- The RAB Emergency Exhaust Systems boundary may be opened intermittently under administrative controls.
- The 'A' Train RAB Emergency Exhaust System is allowed to be inoperable for a total of 14 days only to allow for the implementation of design improvements on the 'A' Train ESW pump.
The 14 days will be taken one time no later than October 29, 2016. During the period in which the 'A' Train ESW pump supply from the Auxiliary Reservoir or Main Reservoir is not available, Normal Service Water will remain available and in service to supply the 'A' Train ESW equipment loads until the system is ready for post maintenance testing. Allowance of the extended Completion Time is contingent on meeting the Compensatory Measures and Conditions described in HNP LAR submittal correspondence letter HNP-16-056.
SHEARON HARRIS - UNIT 1 3/4 7-17 Amendment No. 170
.PLANT SYSTEMS
.REACTOR AUXILIARY BUILDING (RAB) EMERGENCY EXHAUST SYSTEM SURVEILLANCE REQUIREMENTS (CONTINUED)
- c.
After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM 03803-1989.
- d.
At the frequency specified in the Surveillance Frequency Control Program by:
- 1.
Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber bank is less than 4.1 inches water gauge while operating the unit at a flow rate of 6800 cfm +/- 10%,
- 2.
Verifying that the system starts on a Safety Injection test signal,
- 3.
Verifying that the system maintains the areas served by the exhaust system at a negative pressure of greater than or equal to 1/8 inch water gauge relative to the outside atmosphere,
- 4.
Verifying that the filter cooling bypass valve is locked in the balanced position, and
- 5.
Deleted.
- e.
After each complete or partial replacement of a HEPA filter bank, by verifying that the unit satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the unit at a flow rate of 6800 cfm +/- 10%; and
- f.
After each complete or partial replacement of a charcoal adsorber bank, by verifying that the unit satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the unit at a flow rate of 6800 cfm +/- 10%.
SHEARON HARRIS - UNIT 1 3/4 7-18 Amendment No. 170
REFUELING OPERATIONS 3/4.9.12 FUEL HANDLING BUILDING EMERGENCY EXHAUST SYSTEM.
LIMITING CONDITION FOR OPERATION 3.9.12 Two independent Fuel Handling Building Emergency Exhaust System Trains shall be OPERABLE.*
APPLICABILITY:
Whenever irradiated fuel is in a storage pool.
ACTION:
- a.
With one Fuel Handling Building Emergency Exhaust System Train inoperable, fuel movement within the storage pool or crane operation with loads over the storage pool may proceed provided the OPERABLE Fuel Handling Building Emergency Exhaust System Train is capable of being powered from an OPERABLE emergency power source and is in operation and discharging through at least one train of HEPA filters and charcoal adsorber.
- b.
With no Fuel Handling Building Emergency Exhaust System Trains OPERABLE, suspend all operations involving movement of fuel within the storage pool or crane operation with loads over the storage pool until at least one Fuel Handling Building Emergency Exhaust System Train is restored to OPERABLE status.
- c.
The provisions of Specification 3.0.3 are not applicable.
SURVEILLANCE REQUIREMENTS 4.9.12 The above required Fuel Handling Building Emergency Exhaust System trains shall be demonstrated OPERABLE:
- a.
At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes;
- b.
At the frequency specified in the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following significant painting, fire, or chemical release in any ventilation zone communicating with the system by:
1.
Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the unit flow rate is 6600 cfm +/- 10% during system operation when tested in accordance with ANSI N510-1980.
- The Fuel Handling Building Emergency Exhaust System boundary may be opened intermittently under administrative controls.
SHEARON HARRIS - UNIT 1 3/4 9-14 Amendment No.
170
REFUELING OPERATIONS.
FUEL HANDLING BUILDING EMERGENCY EXHAUST SYSTEM.
SURVEILLANCE REQUIREMENTS (CONTINUED) 4.9.12 (Continued)
- 2.
Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM D3803-1989.
- c.
After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, has a methyl iodide penetration of s 2.5% when tested at a temperature of 30°C and at a relative humidity of 95% in accordance with ASTM D3803-1989.
- d.
At the frequency specified in the Surveillance Frequency Control Program by:
- 1.
Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber bank is not greater than 4.1 inches water gauge while operating the unit at a flow rate of 6600 cfm +/- 10%,
- 2.
Verifying that, on a High Radiation test signal, the system automatically starts and directs its exhaust flow through the HEPA filters and charcoal adsorber banks,
- 3.
Verifying that the system maintains the spent fuel storage pool area at a negative pressure of greater than or equal to 1/8 inch water gauge, relative to the outside atmosphere, during system operation at a flow rate of 6600 cfm +/- 10%,and
- 4.
Deleted
- 5.
Deleted.
- e.
After each complete or partial replacement of a HEPA filter bank, by verifying that the unit satisfies the in-place penetration leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the unit at a flow rate of 6600 cfm +/- 10%.
SHEARON HARRIS - UNIT 1 3/4 9-15 Amendment No. 170
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 DUKE ENERGY PROGRESS, LLC DOCKET NO. 50-261 H. 8. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 262 Renewed License No. DPR-23
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Duke Energy Progress, LLC (the licensee),
dated May 10, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 3.B. of Renewed Facility Operating License No. DPR-23 is hereby amended to read as follows:
B.
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 262 are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
- 3.
This license amendment is effective as of the date of its issuance and shall be implemented within 120 days.
Attachment:
FOR THE NUCLEAR REGULATORY COMMISSION Ii Sor*-
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Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Changes to Operating License No. DPR-23 and the Technical Specifications Date of Issuance: April 18, 201 9
ATTACHMENT TO LICENSE AMENDMENT NO. 262 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.
Remove Page DPR-23, page 3 Insert Page DPR-23, page 3 Replace the following pages of the 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 Pages 3.7-28 5.0-17 5.0-18 Insert Pages 3.7-28 5.0-17 5.0-18
3 D.
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 and equipment calibration or associated with radioactive apparatus or components; E.
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: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR 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 The licensee is authorized to operate the facility at a steady state reactor core power level not in excess of 2339 megawatts thermal.
B.
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 262 are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
( 1)
For Surveillance Requirements (SRs) that are new in Amendment 176 to Final Operating License DPR-23, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 176. For SRs that existed prior to Amendment 176, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the Surveillance was last performed prior to implementation of Amendment 176.
Renewed Facility Operating License No. DPR-23 Amendment No. 262
3.7 PLANT SYSTEMS 3.7.11 Fuel Building Air Cleanup System (FBACS)
LCO 3. 7.11 The FBACS shall be OPERABLE and operating.
FBACS 3.7.11 APPLICABILITY:
During movement of irradiated fuel assemblies in the fuel building.
ACTIONS CONDITION A.
The FBACS inoperable A.1 during movement of irradiated fuel assemblies in the fuel building.
SURVEILLANCE REQUIREMENTS REQUIRED ACTION Suspend movement of irradiated fuel assemblies in the fuel building.
SURVEILLANCE COMPLETION TIME Immediately FREQUENCY SR 3.7.11.1 Operate the FBACS for c!! 15 continuous minutes.
31 days SR 3.7.11.2 Perform required FBACS filter testing in accordance In accordance with with the Ventilation Filter Testing Program (VFTP).
the VFTP (continued)
HBRSEP Unit No. 2 3.7-28 Amendment No. 262
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 HBRSEP Ventilation Filter Testing Program (VFTP) (continued)
- c.
Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°) and the relative humidity specified below.
ESF Filter System Penetration RH.
Control Room S2.5%
70%
Emergency Spent Fuel Building S10%
95%
Containment Purge S10%
95%
(continued) 5.0-17 Amendment No. 262
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.11 5.5.12 HBRSEP Ventilation Filter Testing Program CVFTP) (continued)
- d.
Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, and the charcoal adsorbers is less than the value specified below when tested at the system flowrate specified below.
ESF Filter System
.Delta P Flowrate Control Room
~3.4 inches 3300 - 4150 ACFM Emergency water gauge Spent Fuel
<6inches 12300 CFM :!:,10%
Building water gauge Containment
<6inches 35000 CFM :!:,10%
Purge water gauge
- e.
Deleted.
The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.
Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Decay Tanks, the quantity of radioactivity contained in The Waste Gas Decay Tanks and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks.
The program shall include:
- a.
The limits for concentrations of hydrogen and oxygen in the Waste Gas Decay Tanks and a surveillance program to ensure the limits are maintained. Such limits shall be appropriate (continued) 5.0-18 Amendment No. 262
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 301 TO RENEWED FACILITY OPERATING LICENSE NPF-35, AMENDMENT NO. 297 TO RENEWED FACILITY OPERATING LICENSE NPF-52, AMENDMENT NO. 313 TO RENEWED FACILITY OPERATING LICENSE NPF-9, AMENDMENT NO. 292 TO RENEWED FACILITY OPERATING LICENSE NPF-17, AMENDMENT NO. 170 TO RENEWED FACILITY OPERATING LICENSE NPF-63, AND AMENDMENT NO. 262 TO RENEWED FACILITY OPERATING LICENSE DPR-23, DUKE ENERGY PROGRESS, LLC AND DUKE ENERGY CAROLINAS, LLC CATAWBA NUCLEAR STATION, UNITS 1 AND 2, MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1, H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NOS. 50-413, 50-414, 50-369, 50-370, 50-400, and 50-261
1.0 INTRODUCTION
By letter dated May 10, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18131A068), Duke Energy Progress, LLC., and Duke Energy Carolinas, LLC. (together, Duke Energy or the licensees), submitted license amendment requests (LAR) to the U.S. Nuclear Regulatory Commission (NRC, the Commission). The application proposed Technical Specification (TS) changes for the Catawba Nuclear Station, Units 1 and 2 (Catawba); McGuire Nuclear Station, Units 1 and 2 (McGuire); Shearon Harris Nuclear Power Plant, Unit No. 1 (Harris); and H.B. Robinson Steam Electric Plant, Unit No. 2 (Robinson).
The proposed amendments would modify the TSs for Catawba, McGuire, Harris and Robinson.
Specifically, ventilation system heaters will be removed from Catawba TSs 3.6.10, "Annulus Ventilation System (AVS)," 3.7.10, "Control Room Area Ventilation System (CRAVS)," 3.7.12, "Auxiliary Building Filtered Ventilation Exhaust System (ABFVES)," 3. 7.13, "Fuel Handling Ventilation Exhaust System (FHVES)," 3.9.3, "Containment Penetrations," 5.5.11, "Ventilation Filter Testing Program (VFTP)," and 5.6.6, "Ventilation Systems Heater Report," and McGuire TSs 3.6.10, "Annulus Ventilation System (AVS}," 3.7.9, "Control Room Area Ventilation System (CRAVS}," 5.5.11, "Ventilation Filter Testing Program (VFTP}," and 5.6.6, "Ventilation Systems Heater Failure Report."
The specified relative humidity (RH) for charcoal testing in the ventilation system Surveillance Requirement (SR) [for Harris] and Ventilation Filter Testing Program [for Robinson] is revised from 70 percent to 95 percent and the ventilation system heaters will be removed from the Harris TSs 3/4.7.6, "Control Room Emergency Filtration System," 3/4.7.7, "Reactor Auxiliary Building (RAB) Emergency Exhaust System," and 3/4.9.12, "Fuel Handling Building Emergency Exhaust System," and Robinson TSs 3. 7.11, "Fuel Building Air Cleanup System (FBACS)," and 5.5.11, "Ventilation Filter Testing Program (VFTP)." The proposed changes are consistent with Technical Specifications Task Force (TSTF) Traveler TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month," Revision 0. Additionally, an administrative error is being corrected in McGuire's TS 5.5.11, "Ventilation Filter Testing Program (VFTP)."
2.0
2.1 REGULATORY EVALUATION
System Descriptions and Requirements In Section 2.1, "System Design and Operation," of its letter dated May 10, 2018, the licensees provided the following description for Catawba:
The AVS is required by [Title] 10 [of the Code of Federal Regulations] CFR 50, Appendix A, GDC [General Design Criteria] 41, "Containment Atmosphere Cleanup", to ensure that radioactive materials that leak from the primary containment into the reactor building (secondary containment) following a Design Basis Accident (OBA) are filtered and adsorbed prior to exhausting to the environment.
The AVS establishes a negative pressure in the annulus between the reactor building and the steel containment vessel. Filters in the system then control the release of radioactive contaminants to the environment.
The CRAVS ensures that the Control Room Envelope (CRE) will remain habitable for occupants during and following all credible accident conditions.
This function is accomplished by pressurizing the CRE to 2:: 1 /8 (0. 125) inch water gauge with respect to all surrounding areas, filtering the outside air used for pressurization, and filtering a portion of the return air from the CRE to clean up the control room environment.
The ABFVES is a subsystem of the Auxiliary Building Ventilation System that helps maintain a suitable environment for the operation, maintenance and testing of equipment; and maintains a suitable environment for personnel access during normal plant operation and shutdown. During accident conditions the Auxiliary Building Ventilation System is designed to minimize the release of radioisotopes from the Emergency Core Cooling System (ECCS) pump rooms. ABFVES serves areas of the Auxiliary Building that are subject to potential contamination.
The FHVES filters airborne radioactive particulates from the area of the fuel pool following a fuel handling accident. The FHVES, in conjunction with other normally operating systems, also provides environmental control of temperature and humidity in the fuel pool area.
The Containment Purge Exhaust System (CPES) is designed to maintain the environment of the containment within acceptable limits for personnel access during inspection, testing, maintenance, and refueling operations; and to limit the release of any contamination to the environment.
The VFTP is in the Administrative Controls section of the [Catawba] CNS TS. It is a program to implement required testing of ESF [engineered safety feature] filter ventilation systems in accordance with [NRC Regulatory Guide] RG 1.52, Revision 2 [... ], and [American National Standards Institute] ANSI N510-1980.
TS Section 5.5.11.e specifically addresses the requirement to perform heater output testing for AVS, CRAVS, ABFVES, CPES, and FHVES.
In Section 2.1, "System Design and Operation," of its letter dated May 10, 2018, the licensees provided the following description for McGuire:
The AVS establishes a negative pressure in the annulus between the reactor building and the steel containment vessel. Filters in the system then control the release of radioactive contaminants to the environment. Reactor building OPERABILITY is required to ensure retention of primary containment leakage and proper operation of the AVS.
The CRA VS provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The CRA VS consists of two independent, redundant trains that draw filtered outside air and mix this air with conditioned air recirculating through the CRE.
The VFTP is in the Administrative Controls section of the [McGuire] MNS TS. It is a program to implement required testing of ESF filter ventilation systems in accordance with RG 1.52, Revision 2 [... ], and ANSI N510-1975. TS Section 5.5.11.e specifically addresses the requirement to perform heater output testing for AVS and CRAVS.
In Section 2.1, "System Design and Operation," of its letter dated May 10, 2018, the licensees provided the following description for Harris, Unit 1:
The Control Room Emergency Filtration System (CREFS) provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.
The RAB Emergency Exhaust System serves to limit the post-accident radiological releases from selected potentially contaminated portions of the RAB.
The system is provided to ensure that airborne leakage is filtered prior to release to the environment.
The Fuel Handling Building Emergency Exhaust System (FHBEES) ensures that all radioactive material released from an irradiated fuel assembly will be filtered through the HEPA [high-efficiency particulate air] filters and charcoal adsorber prior to discharge to the atmosphere.
In Section 2.1, "System Design and Operation," of its letter dated May 10, 2018, the licensees provided the following description for Robinson:
2.2 The FBACS filters airborne radioactive particulates from the area of the spent fuel pool following a fuel handling accident in the Fuel Building. The FBACS, in conjunction with other normal operating systems, also provide environmental control of temperature and humidity in the spent fuel pool area.
The VFTP is in the Administrative Controls section of the RNP TS. It is a program to implement required testing of ESF filter ventilation systems in accordance with RG 1.52, Revision 2 [... ], and ANSI N510-1975 or N510-1980.
TS Section 5.5.11.e specifically addresses the requirement to perform heater output testing for FBACS.
Licensee's Proposed Changes 2.2.1 Catawba Proposed TS Changes Current TS Limiting Condition for Operation (LCO) 3.6.10, Condition B, "One or more Annulus Ventilation System (AVS) train(s) heater inoperable," is deleted.
Current TS LCO 3.6.10, Condition C is renamed to Condition B, and unchanged.
Current TS LCO 3.6.10, Condition C, Required Actions C.1 and C.2 are renamed to B.1 and B.2, and unchanged.
Current TS LCO 3. 7.10, Condition G, "One or more CRAVS train(s) heater inoperable," is deleted.
Current TS LCO 3.7.12, Condition D, "One or more ABFVES train(s) heater inoperable," is deleted.
Current TS LCO 3. 7.13, Condition B, "Required FHVES train heater inoperable," is deleted Current TS LCO 3.9.3, Condition B, "One or more CPES train(s) heater inoperable," is deleted Current Surveillance Requirement (SR) 3.9.3.2, states:
Operate each CPES for ~ 10 continuous hours with the heaters operating.
Revised SR 3.9.3.2, will state:
Operate each CPES for ~ 15 continuous minutes.
Current TS 5.5.11.e (of 5.5.11, "Ventilation Filter Testing Program (VFTP)"), is deleted.
Current TS 5.6.6, "Ventilation Systems Heater Report," is deleted (and changed to "not used" for numbering considerations)
Note: TS Pages 3.7.10-2 and 3.9.3-1 have been revised for an administrative change, which was not provided in the licensee's application. The word "continued" has been removed from bottom of the respective Actions tables, since the following page does not have any continued conditions, as they have been deleted.
2.2.2 McGuire Proposed TS Changes Current TS LCO 3.6.10, Condition B, "One or more AVS train(s) heater inoperable," is deleted.
Current TS LCO 3.6.10, Condition C is renamed to Condition B, and unchanged.
Current TS LCO 3.6.10, Condition C, Required Actions C.1 and C.2 are renamed to B.1 and B.2, and unchanged.
Current TS LCO 3. 7.10, Condition G, "One or more CRA VS train(s) heater inoperable," is deleted.
Current TS 5.5.11.c (of 5.5.11, "Ventilation Filter Testing Program (VFTP)"), is revised to change the temperature of the "Containment Purge (non-ESF)" and "Fuel Bldg. Ventilation (non-ESF), from 80 degrees Celsius (°C) to 30°C.
Current TS 5.5.11.e (of 5.5.11, "Ventilation Filter Testing Program (VFTP)"), is deleted.
Current TS 5.6.6, "Ventilation Systems Heater Failure Report," is deleted (and changed to "not used" for numbering considerations)
Note: TS Page 3.7.9-2 has been revised for an administrative change, which was not provided in the licensee's application. The word "continued" has been removed from bottom of the respective Actions tables, since the following page does not have any continued conditions, as it has been deleted.
2.2.3 Harris Proposed TS Changes Current SR 4.7.6.a, states:
At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes with the heaters operating; Revised SR 4. 7.6.a, will state:
At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes; Current SR 4.7.6.b.2, referenced RH of 70% is revised to 95%.
Current SR 4.7.6.c, referenced RH of 70% is revised to 95%.
Current SR 4.7.6.d.4, is deleted.
Current SR 4.7.7.a, states:
At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes with the heaters operating; Revised SR 4.7.6.a, would state:
At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes; Current SR 4.7.7.b.2, referenced RH of 70% is revised to 95%.
Current SR 4.7.7.c, referenced RH of 70% is revised to 95%.
Current SR 4. 7.6.d.5, is deleted.
Current SR 4.9.12.a, states:
At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes with the heaters operating; Revised SR 4.7.6.a, would state:
At the frequency specified in the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 continuous minutes; Current SR 4.9.12.b.2, referenced RH of 70% is revised to 95%.
Current SR 4.9.12.c, referenced RH of 70%is revised to 95%.
Current SR 4.9.12.d.5, is deleted.
2.2.4 Robinson Proposed TS Changes Current SR 3. 7.11, states: Operate each FBACS for;::; 15 continuous minutes with the heaters operating automatically.
Revised SR 3. 7.11, would state:
Operate each FBACS for ;::; 15 continuous minutes.
TS 5.5.11.c, referenced RH for the "Spent Fuel Building" is revised from 70% to 95%.
TS 5.5.11.e, is deleted.
2.3 Applicable Regulations and Regulatory Guidance Section 50.36 of 10 CFR "Technical specifications,".establishes the requirements related to the content of the TS. Paragraph 10 CFR 50.36{c)(2}, states, in part:
Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.
Paragraph 10 CFR 50.36(c)(3), states:
Surveillance requirements 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.
Paragraph 10 CFR 50.36(c)(5), states:
Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. Each licensee shall submit any reports to the Commission pursuant to approved technical specifications as specified in § 50.4.
10 CFR Part 50, Appendix A, General Design Criterion (GDC) 19, "Control room," states, in part, that a control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident.
10 CFR Part 50, Appendix A, GDC 41 "Containment atmosphere cleanup", GDC 42 "Inspection of containment atmosphere cleanup systems", and GDC 43 "Testing of containment atmosphere cleanup systems" discuss respectively the design, the inspection and the testing of containment atmosphere cleanup systems. GDC 41 states, in part, that these systems shall be provided as necessary to "reduce, consistent with the functioning of other associated systems, the concentration and quality of fission products released to the environment following postulated accidents, and to control the concentration of hydrogen or oxygen and other substances in the containment atmosphere following postulated accidents to assure that containment integrity is maintained." GDC 43 states, in part, that "The containment atmosphere cleanup systems shall be designed to permit appropriate periodic pressure and functional testing to assure... (2) the operability and performance of the active components of the systems such as fans, filters, dampers, pumps, and valves... "
10 CFR Part 50, Appendix A, GDC 61, "Fuel storage and handling and radioactivity control,"
states that "The fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions. These systems shall be designed ( 1) with a capability to permit appropriate periodic inspection and testing of components important to safety, (2) with suitable shielding for radiation protection, (3) with appropriate containment, confinement, and filtering systems, (4) with a residual heat removal capability having reliability and testability that reflects the importance to safety of decay heat and other residual heat removal, and (5) to prevent significant reduction in fuel storage coolant inventory under accident conditions.
Regulatory Guide (RG) 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System in Light-Water-Cooled Nuclear Power Plants," Revision 3 (ADAMS Accession No. ML011710176).
Regulatory Position 4.d of Revision 2 of RG 1.52 (ADAMS Accession No. ML003740139),
stated that "Each ESF atmosphere cleanup train should be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month, with the heaters on (if so equipped), in order to reduce the buildup of moisture on the adsorbers and HEPA filters." The purpose of this position is to minimize the moisture content in the system and thereby enhance efficiency in the event the system is called upon to perform its design basis function. Standard Technical Specification (STS) SRs 3.6.4.3.1 and 3.7.4.1 currently require operating the heaters in the respective ventilation and filtering systems for at least 10 continuous hours. The current STS Bases explain that operation of heaters for 1 O hours would eliminate moisture on the charcoal adsorbers and HEPA filters.
The NRC staff issued NRC Generic Letter (GL) 99-02: "Laboratory Testing of Nuclear-Grade Activated Charcoal" (ADAMS Accession No. ML082350935 and errata sheet at Accession No. ML031110094). GL 99-02 requested licensees to confirm their charcoal testing protocols accurately reflect the adsorber gaseous activity capture capability. GL 99-02 also requested the licensees to account for the effects of moisture accumulation in adsorbers. The NRC staff then issued a draft revision of RG 1.52, to solicit comments on changes to the RG. The NRC staff received comments from the Nuclear HVAC Utilities Group (NHUG), among others. NHUG stated that 1 O continuous hours of system operation would dry out the charcoal adsorber for a brief period of time but, following heater de-energization, the level of moisture accumulation in adsorbers would rapidly return to the pre-test level.
Therefore, the NRC staff updated RG 1.52 to include the new information. RG 1.52, Revision 3, Regulatory Position 6.1 states, "Each ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with the heaters on (if so equipped), to justify the operability of the system and all its components."
The NRC's guidance for the format and content of TSs can be found in NUREG-1431, "Standard Technical Specifications [STS], Westinghouse Plants, Revision 4.0," (WOG STS) (ADAMS Accession No. ML12100A222)
3.0 TECHNICAL EVALUATION
3.1 Background
Air filtration and adsorption systems are required at nuc:lear power plants to lower the concentration of airborne radioactive material that may be released from the site to the environment due to a design basis event. Lowering thei concentration of airborne radioactive materials can mitigate doses to plant operators and members of the public in the event of a design basis event. A typical system consists of ventilation ductwork, fans, dampers, valves, instrumentation, pre-filters or demisters, HEPA filters, heaters, and activated charcoal adsorbers. These systems are tested by operating the systems and monitoring the response of the overall system as well as individual components. Laboratory tests of charcoal adsorbers are also performed to ensure the charcoal adsorbs an acceiptable amount of radioactive gases.
Current testing requirements for the air filtration and adsorption systems state that the systems should be operated for at least 10 continuous hours with heaters operating every 31 days or at a frequency controlled by the surveillance frequency control program (SFCP) for plants with a SFCP. These requirements are based on NRC staff guidance for testing air filtration and adsorption systems that has been superseded. New NRC staff guidance states at least 15 continuous minutes of ventilation system operation with heaters operating is acceptable for those plants that test ventilation system adsorption at a RH of less than 95%. Plants that test ventilation system adsorption at a RH of 95% do not require heaters for the ventilation system to perform its specified safety function and the bracketed phrase "with heaters operating" is not included in the SRs. One of the reasons for the previous 10-hour requirement for ventilation system operation with heaters operating was to minimize the effects of moisture on the adsorber's ability to capture gaseous activity. However, these effects are accounted for in a ventilation filter testing program (VFTP) by performing testing at a RH of 95%.
3.2 NRC Staff's Evaluation Proposed TS Changes The NRC staff evaluated the licensee's proposed change against the applicable regulatory guidance in RG 1.52, Revision 3, and the regulatory requirements of 10 CFR 50.36. The proposed change would require at least 15 minutes of system operation. The NRC staff found that the proposed change is consistent with guidance in RG 1.52, Revision 3.
The NRC staff evaluated the licensee's proposed change against the applicable regulatory guidance in the WOG STS, as modified by TSTF-522, Revision 0. 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", Revision 4.0, modified by TSTF-522, Revision 0.
The NRC endorsed TSTF-522, Revision O on September 12, 2012 (ADAMS Accession No. ML12158A490).
3.2.1 Evaluation of Catawba Proposed TS Changes The following table summarizes the differences between the WOG STS numbering and titles and the corresponding Catawba TS.
Table 3.2.1-1 WOG STS Catawba TS STS 3.6.13 - Shield Building Air TS 3.6.10 - Annulus Ventilation Cleanup System (SBACS)(Dual System (AVS) and Ice Condenser)
STS 3.7.10- Control Room TS 3. 7.10 - Control Room Area Emergency Filtration System Ventilation System (CRAVS)
(CREFS)
STS 3. 7.12-Emergency Core TS 3. 7.12 - Auxiliary Building Cooling System (ECCS) Pump Filtered Ventilation Exhaust Room Exhaust Air Cleanup System (ABFVES)
System (PREACS)
STS 3.7.13-Fuel Building Air TS 3.7.13 - Fuel Handling Cleanup System (FBACS)
Ventilation Exhaust System (FHVES)
STS 3.9.4-Containment TS 3.9.3 - Containment Penetrations Penetrations The current Catawba TS contain Conditions related to heater inoperability that do not appear in the WOG STS. In order to better align the Catawba TS with the WOG STS, the licensee proposes to remove from TS, Conditions related to heater inoperability.
Catawba TS 5.5.11.c, "VFTP" demonstrates for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in RG 1.52, Revision 2, shows the methyl iodide penetration less than the value specified when tested in accordance with (American Society for Testing and Materials (ASTM) 03803-1989 at the temperature and RH specified.
RG 1.52, Revision 3, Section B, "Discussion," indicates that ESF atmosphere cleanup systems required to operate outside the primary containment under postulated-OBA (design-basis accident) conditions that are generally less severe, are designated as "secondary systems."
Therefore, the Catawba AVS, CRAVS, ABFVES and FHVES are all ESF secondary systems.
Due to their similarity and since the following four TS changes are associated with secondary ESF atmosphere cleanup systems, these changes are evaluated collectively:
Current Catawba TS 3.6.10 includes a Condition B where if one or more Annulus Ventilation System train(s) heater is(are) inoperable, that train must be restored to Operable status within 7 days or initiate action in accordance with TS 5.6.6, "Ventilation Systems Heater Report" within 7 days. The licensee proposes to delete in its entirety the Condition, the Required Action (RA) and the Completion Time (CT) associated with Condition B of TS 3.6.10.
Current Catawba TS 3.7.10 includes a Condition G where if one or more CRAVS train(s) heater is(are) inoperable, that train must be restored to Operable status within 7 days or initiate action in accordance with TS 5.6.6, "Ventilation Systems Heater Report" within 7 days. The licensee proposes to delete in its entirety the Condition, the RA and the CT associated with Condition G of TS 3.7.10.
Current Catawba TS 3.7.12 includes a Condition D where if one or more ABFVES train(s) heater is(are) inoperable, that train must be restored to Operable status within 7 days or initiate action in accordance with TS 5.6.6, "Ventilation Systems Heater Report'"
within 7 days. The licensee proposes to delete in its entirety the Condition, the RA and the CT associated with Condition D of TS 3. 7.12.
Current Catawba TS 3. 7.13 includes a Condition B where if one or more FHVES train heaters is(are) inoperable, that train heater must be restored to Operable status within 7 days or initiate action in accordance with TS 5.6.6, "Ventilation Systems Heater Report'"
within 7 days. The licensee proposes to delete in its entirety the Condition, the RA and the CT associated with Condition B of TS 3.7.13.
As indicated by TS 5.5.11c, for all four systems, AVS, CRAVS, ABFVES and FHVES, the licensee conduct laboratory testing of the carbon adsorber samples in accordance with ASTM D3803-1989 at a temperature of 30 degrees Celsius (°C) and greater than or equal to 95% RH.
The NRC staff issued License Amendment Nos. 289 and 285 for Catawba, Units 1 and 2, respectively on May 8, 2017 (ADAMS Accession No. ML17055A647). The NRC staff stated that the amendments were consistent with NRC-approved TSTF-522, Revision 0, as published in the Federal Register on September 20, 2012 (77 FR 58421), with variations due to plant-specific differences. These amendments revised the surveillance requirements for the Catawba AVS, CRAVS, ABFVES and FHVES by changing the requirement to operate "In accordance with the Surveillance Frequency Control Program" each system train from "for ~ 10 continuous hours." to "for~ 15 continuous minutes." These amendments were approved on the basis that they were consistent with the guidance in RG 1.52, Revision 3.
Section 4.0 "Technical Analysis" of TSTF-522, Revision O (ADAMS Accession No. ML100890316), states, in part:
... These plants may eliminate the reference to heaters in the Surveillance Requirements and Bases. These plants may also subsequently pursue elimination of the heaters from the plant design under 10 CFR 50.59.
Based on the above, the NRC staff concludes that an inoperable filter train heater of the AVS, CRAVS, ABFVES and FHVES has no impact on each system's operability for Catawba.
Given that the test protocol of TS 5.5.11 c verifies the capability of each system filter train's iodine adsorber to maintain the requisite "Decontamination Efficiency," the NRC staff concludes that maintaining the operability of each ESF secondary system filter train's heater is not required to maintain the lowest functional capability or performance levels of equipment required for safe operation of the facility, in accordance with 10 CFR 50.36(c). Accordingly, the NRC staff finds that the licensees' proposed changes to Catawba TS 3.6.10, 3. 7.10, 3. 7.12, and 3. 7.13 are acceptable.
Due to their association with TS 3.9.3 "Containment Penetrations," the following changes are evaluated together:
Current TS 3.9.3 includes a Condition B where if one or more CPES train(s) heater is(are) inoperable, that train must be restored to Operable status within 7 days or initiate action in accordance with TS 5.6.6, "Ventilation Systems Heater Report" within 7 days.
The licensee proposes to delete in its entirety the Condition, the RA and the CT associated with Condition B of TS 3.9.3; Current SR 3.9.3.2 of TS 3.9.3 states "Operate each CPES for;'::: 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters operating" at a frequency that states "In accordance with the Surveillance Frequency Control Program". The licensee proposes to revise SR 3.9.3.2 to read "Operate each CPES for;'::: 15 minutes" with no change to the frequency.
As indicated above, the CPES is a non-ESF system. Catawba's Updated Final Safety Analysis Report (UFSAR), Section 15.7.4.2.2 "Postulated Fuel Handling Accident Inside Containment,"
does not credit CPES for filtration of the releases from this accident. Nonetheless, per the requirements of TS 5.5.11 c, the licensee conservatively maintain CPES as an ESF system by obtaining filter train carbon adsorber samples consistent with the guidance of RG 1.52, Revision 2 and performing laboratory testing of the carbon adsorber samples at 30°C and at a RH of ;':::
95% per the test protocol of ASTM D-3803-1989. The NRC staff notes that the RG 1.52 provisions for carbon bed filter train sample canisters were in essence the same between Revision 2 and Revision 3.
Based on the arguments and conclusions put forth in Section 4.0 of TSTF-522, Revision 0, and the Regulatory Positions of RG 1.52, Revision 3, the NRC staff concludes that an inoperable filter train heater(s) of the CPES has no impact on the system's operability for Catawba.
Given that the test protocol of TS 5.5.11 c verifies the capability of each CPES filter train's iodine adsorber to maintain the requisite "Decontamination Efficiency," the NRC staff concludes that maintaining the operability of each CPES filter train's heater is not required to maintain the lowest functional capability or performance levels of equipment required for safe operation of the facility, in accordance with 10 CFR 50.36(c). Therefore, the NRC staff finds that the licensees' proposed changes to Catawba TS 3.9.3 is acceptable.
As noted above the licensee propose to change the current SR 3.9.3.2 which states "Operate each CPES for ;'::: 1 O hours with the heaters operating." to read "Operate each CPES for ;'::: 15 continuous minutes." with no change to the frequency.
The NRC staff notes that the test conditions of ASTM D3803-1989 conservatively address the effects of moisture on the charcoal adsorber. Accordingly, performance of charcoal adsorber testing in accordance with this ASTM standard permits removal of the monthly operation of the ESF systems with the heaters in operation while still maintaining adequate factors of safety.
Section 3.0 of the NRC's model safety evaluation for TSTF-522, Revision O (ADAMS Accession No. ML12158A464), states, in part:
... the effects of moisture on the adsorber's ability to capture gaseous activity are now accounted for in the licensee's Ventilation Filter Testing Program by performing testing at a relative humidity of 95 percent. Since the SR's are no longer relied upon to ensure the effects of moisture on the adsorber's ability to capture gaseous activity are accounted for, the 10-hour heater operational requirement is unnecessary. The NRC staff found that reducing the required minimum system operation time to 15 minutes, consistent with RG 1.52, Revision 3, in conjunction with the Ventilation Filter Testing Program, is sufficient to justify operability of the system and all its components.
Based on the above, the NRC staff concludes that the requirements of 10 CFR Part 50.36(c)(3) will continued to be satisfied with the proposed change to SR 3.9.3.2.
The licensee proposes to revise TS 5.5.11 "Ventilation Filter Testing Program (VFTP)"
TS 5.5.11e currently requires performance based testing (i.e., kilowatt power dissipation) in accordance with American National Standards Institute (ANSI)
N510-1980 for all the heaters installed upstream of each filter train's carbon bed adsorber. The subject heaters are associated with the filter trains of the AVS, CRA VS, ABFVES, FHVES and CPES. The licensee proposes to delete, in its entirety, part "e" of TS 5.5.11.
The NRC staff concludes, that the deletion of TS 3.6.10, Condition B, TS 3. 7.10, Condition G, TS 3. 7.12, Condition D, TS 3. 7.13, Condition B, and TS 3.9.3, Condition B are acceptable based on the fact that the operability of the AVS, CRA VS, ABFVES, FHVES and CPES is no longer linked to the functional status of the upstream heater associated with each filter train's carbon bed adsorber. Succinctly, in the absence of a functional upstream heater the operable status of each filter train's carbon bed adsorber is verified by the performance of TS 5.5.11 c.
Since each respective heater delineated in TS 5.5.11 e is no longer associated with an LCO, there is no need to keep the SR as part of the TSs.
Based on the above, the NRC staff concludes that the requirements of 10 CFR Part 50.36(c)(3) will continued to be satisfied with the proposed deletion of TS 5.5.11 e.
The licensee proposes to delete the action required per TS 5.6.6, "Ventilation Systems Heater Report."
TS 5.6.6 currently requires that when the Required Action of: LCO 3.6.10 Condition B.1; LCO 3.7.10 Condition G.1; LCO 3.7.12 Condition D.1; LCO 3.7.13 Condition B.1; or LCO 3.9.3 Condition B.1 are not met (i.e., restoration of the heater to an Operable status within seven days) that the licensee "Initiate action in accordance with Specification 5.6.6." within 7 days. TS 5.6.6 requires that a report be submitted within the following 30 days that outlines "... the reason for the inoperability and the planned actions to return the systems to OPERABLE status." The licensee proposes to delete the entire text associated with TS 5.6.6 (i.e., Ventilation Systems Heater Report... When a report... et cetera) and insert the text "Not Used."
The NRC staff notes that this reporting requirement does not appear in the WOG STS (i.e.,
Since each respective heater of the LCOs specified in TS 5.6.6 is no longer associated with the LCO, there is no longer a need to retain these reporting requirements as part of the Catawba 2 TS.
Based on the above, the NRC staff concludes that the requirements of 10 CFR Part 50.36 will continued to be satisfied with the proposed deletion of TS 5.6.6.
3.2.2 Evaluation of McGuire Proposed TS Changes The following table summarizes the differences between the WOG STS numbering and titles and the corresponding McGuire TS.
Table 3.1.2-1 Technical Specification (WOG)
McGuire TS STS 3.6.13 - Shield Building Air Cleanup TS 3.6.10 - "Annulus Ventilation System (SBACS)(Dual and Ice System (AVS)"
Condenser)
STS 3.7.10- Control Room Emergency TS 3.7.9 - "Control Room Area Filtration System (CREFS)
Ventilation System (CRAVS)"
Current McGuire TS contain Conditions related to heater inoperability that do not appear in the WOG STS. In order to better align the McGuire TS with the WOG STS, the licenses proposes to remove from TS, Conditions related to heater inoperability.
TS 5.5.11.c currently specifies laboratory testing of the carbon adsorber samples from the non-ESF filters of the Containment Purge Exhaust System (CPES) and the Fuel Handling Ventilation Exhaust System (FHVES) be performed at a temperature of 80 °C. The licensee proposes to revise TS 5.5.11.c, to specify that laboratory testing of the carbon adsorber samples be performed at a temperature of 30 °C.
The licensee proposes the following change (shown in double strike-through) to TS 5.5.11.c, which states, in part:
5.5.11 Ventilation Filter Testing Program (VFTP)
- c. Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at the temperature and relative humidity (RH) specified below.
ESF Ventilation System Penetration RH Temp.
Annulus Ventilation
<4%
95%
30°c Control Area Ventilation
< 0.95%
95%
30°c Aux. Bldg. Filtered Exhaust
<4%
95%
30°c Containment Purge (non-ESF)
<4%
95%
SG30°C Fuel Bldg. Ventilation (non-ESF)
<4%
95%
SG30°C In Section 2.3, "Reason for the Proposed Change" of the letter dated May 10, 2018, the licensee states, in part:
During the processing of the license amendment application to Revise Technical Specifications to Adopt TSTF-522, Revision 0, dated September 27, 2016 (ADAMS Accession No. ML16273A042), it was identified that an administrative error affecting MNS TS 5.5.11, "Ventilation Filter Testing Program (VFTP}," had been inadvertently introduced during processing of a prior license amendment.
Specifically, on November 2, 2000, the NRC issued MNS License Amendment Numbers 196 and 177, which, in part, revised the laboratory test temperature of the charcoal adsorber samples for the Containment Purge and the Fuel Building Ventilation systems, as specified in TS 5.5.11.c, from 80°C to 30°C.
Subsequently, on March 1, 2007, with associated correction letter dated September 18, 2007, the NRC issued MNS License Amendment Numbers 237 and 218. These license amendments inadvertently changed the aforementioned laboratory test temperatures back to 80°C.... The Containment Purge and Fuel Building Ventilation systems testing has been performed per ASTM-D3803-1989 at 30°C since 2000. The proposed changes correcting the laboratory test temperatures of the charcoal adsorber samples for these systems in MNS TS 5.5.11.c is administrative only.
After NRC staff review of the sequence of events associated with the NRC's issuance of McGuire, Unit 1 License Amendment Numbers 196 and 237 and McGuire, Unit 2 License Amendment Numbers 177 and 218 (ADAMS Accession Nos. ML003766934, ML070320068, and ML072600328), the NRC staff concludes that the correction of the inadvertent errors introduced to McGuire TS 5.5.11.c, is administrative in nature.
McGuire TS 5.5.11.c demonstrates for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in RG 1.52, Revision 2, shows the methyl iodide penetration less than the value specified when tested in accordance with ASTM D3803-1989 at the temperature and RH specified.
RG 1.52, Revision 3 Section B "Discussion," indicates that ESF atmosphere cleanup systems required to operate outside the primary containment under postulated-OBA conditions that are generally less severe, are designated as "secondary systems." Therefore, the AVS and CRAVS are both ESF secondary systems.
Due to their similarity and since the following two TS changes are associated with secondary ESF atmosphere cleanup systems, these changes are evaluated collectively:
Current McGuire TS 3.6.10 includes a Condition B where if one or more AVS train(s) heater is(are) inoperable, that train must be restored to Operable status within 7 days or initiate the action in accordance with TS 5.6.6, "Ventilation Systems Heater Report'"
within 7 days. The licensee proposes to delete in its entirety the Condition, the RA and the CT associated with Condition B of TS 3.6.10.
Current McGuire TS 3.7.9 includes a Condition G where if one or more CRAVS train(s) heater is(are) inoperable, that train must be restored to Operable status within 7 days or initiate the action in accordance with TS 5.6.6 within 7 days. The licensee proposes to delete in its entirety the Condition, the RA and the CT associated with Condition G of TS 3.7.9.
As indicated above, for both the AVS and the CRAVS, the licensee conducts laboratory testing of the carbon adsorber samples in accordance with ASTM D3803-1989 at a temperature of 30°C and greater than or equal to 95% RH.
The NRC staff issued Amendment Nos. 296 and 275 for McGuire, Units 1 and 2, respectively on May 8, 2017 (ADAMS Accession No. ML17055A647). The NRC staff stated that the amendments were consistent with NRC-approved Technical Specifications Task Force (TSTF)
Traveler TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month," as published in the Federal Register on September 20, 2012 (77 FR 58421 ), with variations due to plant-specific differences. Succinctly, these amendments revised the surveillance requirements for the McGuire AVS and CRA VS by changing the requirement to operate "In accordance with the Surveillance Frequency Control Program" each system train from "for;;:: 10 continuous hours." to "for;;:: 15 continuous minutes."
These amendments were approved on the basis that they were consistent with the guidance in RG 1.52, Revision 3.
Section 4.0 of TSTF-522, Revision O (ADAMS Accession No. ML100890316), states, in part:
... These plants may eliminate the reference to heaters in the Surveillance Requirements and Bases. These plants may also subsequently pursue elimination of the heaters from the plant design under 1 O CFR 50.59.
Based on the above, the NRC staff concludes that an inoperable filter train heater(s) of the AVS and the CRAVS has no impact on each system's operability for McGuire.
Given that the test protocol of TS 5.5.11.c verifies the capability of each system filter train's iodine adsorber to maintain the requisite "Decontamination Efficiency," the NRC staff concludes that maintaining the operability of each ESF secondary system filter train's heater is not required to maintain the lowest functional capability or performance levels of equipment required for safe operation of the facility, in accordance with 10 CFR 50.36(c). Accordingly, the NRC staff finds that the licensees' proposed changes to Catawba TS 3.6.10 and 3.7.9, are acceptable.
The licensee proposes to revise TS 5.5.11, "Ventilation Filter Testing Program (VFTP)"
TS 5.5.11.e currently requires performance-based testing (i.e., kilowatt power dissipation) in accordance with ANSI N510-1975 for all the heaters installed upstream of each filter train's carbon bed adsorber. The subject heaters are associated with the filter trains of the AVS and the CRA VS. The licensee proposes to delete, in its entirety, part "e" of TS 5.5.11.
The following McGuire SRs have a Frequency of "In accordance with the VFTP":
SR 3.6.10.2, "Perform required AVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP)".
SR 3.7.9.2, "Perform required CRAVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP)".
The NRC staff concludes that the deletion of TS 3.6.10, Condition B and TS 3. 7.9, Condition G, are acceptable based on the fact that the operability of the AVS and the CRAVS is no longer linked to the functional status of the upstream heater associated with each filter train's carbon bed adsorber. Succinctly, in the absence of a functional upstream heater the operable status of each filter train's carbon bed adsorber is maintained and verified by the performance of TS 5.5.11.c. Since each respective heater delineated in TS 5.5.11.e, is no longer associated with an LCO, there is no need to keep the SRs as part of the Catawba TS.
Based on the above, the NRC staff concludes that the requirements of 10 CFR 50.36(c)(3) will continued to be satisfied with the proposed deletion of TS 5.5.11.e.
The licensee proposes to delete the action required per TS 5.6.6, "Ventilation Systems Heater Report":
TS 5.6.6 currently requires that when the Required Action of LCO 3.6.1 O Condition B.1 and LCO 3.7.9 Condition G.1 are not met (i.e., restoration of the heater to an Operable status within seven days) that the licensee "Initiate action in accordance with Specification 5.6.6" within 7 days. TS 5.6.6 requires that a report be submitted within the following 30 days that outlines "... the reason for the inoperability and the planned actions to return the systems to OPERABLE status." The licensee proposes to delete the entire text associated with TS 5.6.6 (i.e., "Ventilation Systems Heater Report...
When a report... et cetera") and insert the text "Not Used."
The NRC staff notes that this reporting requirement does not appear in the WOG STS (i.e.,
Since each respective heater of the LCOs specified in TS 5.6.6 is no longer associated with the LCO, there is no longer a need to keep these reporting requirements as part of the McGuire TS.
Based on the above, the NRC staff concludes that the requirements of 10 CFR Part 50.36 will continued to be satisfied with the proposed deletion of TS 5.6.6.
3.2.3 Evaluation of Harris Proposed TS Changes The Harris TS do not incorporate the format and structure of the WOG STS. The Harris TS utilize different numbering and titles than the STS. The following table summarizes the differences between the WOG STS numbering and titles and the corresponding Harris TS.
Table 3.1.3-1 Technical Specification (WOG)
Harris TS STS 3. 7.10 - Control Room TS 3/4.7.6-Control Room Emergency Filtration System Emergency Filtration System (CREFS)
(CREFS)
STS 3. 7.12-Emergency Core TS 3/4.7.7 - Reactor Auxiliary Cooling System (ECCS) Pump Building (RAB) Emergency Room Exhaust Air Cleanup Exhaust System System (PREACS)
STS 3. 7.13 - Fuel Building Air Cleanup System (FBACS) TS 3/4.9.12 - Fuel Handling Building Emergency Exhaust System (FHBEES)
Due to the near symmetry of structural format and similar technical content, the following changes are evaluated collectively.
Revise TS 3/4.7.6 "Control Room Emergency Filtration System" by:
o Deleting the words "... with the heaters operating from SR 4.7.6.a.;
o Changing SR 4. 7.6.b.2 to test the representative carbon sample at a RH of 95%
in accordance with ASTM D3803-1989 instead of the current 70% RH; o
Changing SR 4.7.6.c to test the representative carbon sample at a RH of 95% in accordance with ASTM D3803 -1989 instead of the current 70% RH; and o
Deleting in its entirety SR 4. 7.6.d.4 which demonstrates each filter train heater's heat dissipation capability to be within TS limits.
Revise TS 3/4.7.7 "Reactor Auxiliary Building (RAB) Emergency Exhaust System" by:
o Deleting the words "... with the heaters operating" from SR4.7.7.a; o
Changing SR 4.7.7.b.2 to test the representative carbon sample at a RH of 95%
in accordance with ASTM D3803-1989 instead of the current 70% RH; o
Changing SR 4.7.7.c to test the representative carbon sample at a RH of 95% in accordance with ASTM D3803-1989 instead of the current 70% RH; and o
Deleting in its entirety SR 4.7.7.d.5 which demonstrates each filter train heater's heat dissipation capability to be within TS limits.
Revise 3/4.9.12 "Fuel Handling Building Emergency Exhaust System" by:
o Deleting the words "... with the heaters operating" from SR 4.9.12.a; o
Changing SR 4.9.12.b.2 to test the representative carbon sample at a RH of 95%
in accordance with ASTM D3803-1989 instead of the current 70% RH; o
Changing SR 4.9.12.c to test the representative carbon sample at a RH of 95%
in accordance with ASTM D3803-1989 instead of the current 70% RH; and o
Deleting in its entirety SR 4.9.12.d.5 which demonstrates each filter train heater's heat dissipation capability to be within TS limits.
For the CREFS, RAB Emergency Exhaust System and FHBEES, the licensee proposes to change the laboratory analysis requirements for the representative carbon samples obtained from each filter train's carbon adsorber. These samples are currently tested at a temperature of 30°C and at a RH of 70% in accordance with ASTM D3803-1989. These samples are obtained from each filter train's carbon adsorber bed in accordance with Regulatory Position C.6.b of RG 1.52, Revision 2.
The licensee proposes to change SRs 4.7.6.b.2, 4.7.6.c, 4.7.7.b.2, 4.7.7.c, 4.9.12.b.2 and 4.9.12.c to test each sample at the more stringent requirement of 95% RH, with all other test requirements and test frequencies unchanged.
Section B of RG 1.52, Revision 3, states, in part:
Secondary systems include such systems as the standby gas treatment system (SGTS) and the atmosphere cleanup systems for the spent fuel handling building, control room, shield or annulus building, secondary containment, as well as emergency core cooling system (ECCS) pump leakage.
The NRC staff finds that CREFS, RAB Emergency Exhaust System and FHBEES all fit the description of a secondary system.
Regulatory Position 4.9 of RG 1.52, Revision 3, states, in part:
Humidity control promotes the long-term retention of radioiodine in the iodine adsorbers (minimizing the potential for early desorption and release) by maintaining the relative humidity at less than or equal to 70 percent. For secondary systems, humidity control may be provided by either safety-related heaters or an analysis that demonstrates that the air entering the adsorbers is maintained at less than or equal to 70 percent relative humidity under all design basis accident conditions.
Therefore, with NRC staff approval of the proposed changes to SRs 4.7.6.b.2, 4.7.6.c, 4.7.7.b.2, 4.7.7.c, 4.9.12.b.2 and 4.9.12.c, the operability of the CREFS, RAB Emergency Exhaust System and FHBEES, will no longer be linked to the functional status of the upstream heater associated with each filter train's carbon bed adsorber.
The licensee proposes to delete in their entirety, SRs 4.7.6.d.4, 4.7.6.d.5 and 4.9.12.d.5. These SRs each demonstrate the respective system's filter train heaters' heat dissipation capability to be within TS limits.
Section 4.0, of TSTF-522, Revision O (ADAMS Accession No. ML180090316), invokes the guidance of RG 1.52, Revision 3, and states, in part:
Plants which test ventilation system adsorption at a relative humidity of 95% do not require heaters for the ventilation system to perform its specified safety function consistent with Regulatory Position 4.9,... These plants may eliminate the reference to heaters in the Surveillance Requirements and Bases.
The licensee proposes to increase the testing requirement on the charcoal filters from the current 70% RH to a more stringent requirement of 95% RH. With an increased 95% RH, the ventilation heaters will no longer be needed to reduce the humidity of the incoming air to below 70% for the charcoal filters. Therefore, the NRC staff finds that with the change from 70% to 95% RH, the ventilation heaters can be deleted from the TSs.
And lastly, the licensee proposes to revise SRs 4.7.6.a, 4.7.7.a and 4.9.12.a by deleting the words "... with the heaters operating" from each surveillance requirement. SRs 4.7.6.a, 4.7.7.a, and 4.9.12.a, would no longer require the ventilation heaters be operated during the test with the change from 70% to 95% RH. The NRC staff notes that this deletion is also consistent with the guidance invoked from Section 4.0 of TSTF-522, Revision 0, as it states that plants which test ventilation systems adsorption at a RH of 95% do not require ventilation heaters to perform its specified safety function.
Based on the above, the NRC staff concludes that the proposed Harris TS changes are technically justified and consistent with the regulatory requirements of 10 CFR 50.36(c)(3).
3.2.4 Evaluation of Robinson Proposed TS Changes The Robinson TS utilize different numbering and titles than the WOG STS. These differences are administrative. The following table summarizes the differences between the WOG STS numbering and titles and the corresponding Robinson TS.
Technical Specification (WOG)
Robinson TS STS 3.7.13 - Fuel Building Air TS 3. 7.11 - Fuel Building Air Cleanup System (FBACS)
Cleanup System (FBACS)
Due to the near symmetry of structural format and similar technical content, the following changes are evaluated collectively.
Revise TS 5.5.11.c, "Ventilation Filter Testing Program (VFTP)" by:
o Changing the VFTP to test the representative carbon sample from the FBACS at a RH of 95% in accordance with ASTM D3803-1989 instead of the current 70% RH Delete TS 5.5.11.e, in its entirety:
o TS 5.5.11 e currently requires demonstrating that the FBACS filter train heaters can maintain the air entering the carbon adsorber bed at s 70% RH.
Revise TS 3.7.11 "Fuel Building Air Cleanup System (FBACS)" by:
o Deleting the words"... with the heaters operating automatically" from SR 3.7.11.1 The licensee proposes to change the laboratory analysis requirements for the representative carbon samples obtained from the FBACS filter train's carbon adsorber. These samples are currently tested at a temperature of 30°C and at a RH of 70%, in accordance with ASTM D3803-1989. These samples are obtained from the filter train's carbon adsorber bed and tested in accordance with Regulatory Position C.6.b and Table 2, "Laboratory Tests for Activated Carbon" of RG 1.52, Revision 2.
The licensee proposes to change the VFTP (i.e., TS 5.5.11.c) to test each FBACS filter train carbon bed sample at the more stringent requirement of 95% RH, with all other test requirements and test frequencies unchanged.
Section B of RG 1.52, Revision 3, states, in part:
Secondary systems include such systems as the standby gas treatment system (SGTS) and the atmosphere cleanup systems for the spent fuel handling building, control room, shield or annulus building, secondary containment, as well as emergency core cooling system (ECCS) pump leakage.
The NRC staff finds that FBACS fits the description of a secondary system.
Regulatory Position 4.9 of RG 1.52, Revision 3, states, in part:
Humidity control promotes the long-term retention of radioiodine in the iodine adsorbers (minimizing the potential for early desorption and release) by maintaining the relative humidity at less than or equal to 70%. For secondary systems, humidity control may be provided by either safety-related heaters or an analysis that demonstrates that the air entering the adsorbers is maintained at less than or equal to 70% relative humidity under all design basis accident conditions.
Therefore, with NRC staff approval of the proposed changes to TS 5.5.11.c, the operability of the FBACS will no longer be linked to the functional status of the upstream heater associated with the filter train's carbon bed adsorber.
The licensee proposes to increase the testing requirement on the charcoal filters from the current 70% RH to a more stringent requirement of 95% RH. With an increased 95% RH, the ventilation heaters will no longer be needed to reduce the humidity of the incoming air to below 70% for the charcoal filters. Therefore, the NRC staff finds that with the change from 70% to 95% RH, the ventilation heaters can be deleted from the TSs.
The licensee proposes to delete in its entirety TS 5.5.11.e. This VFTP requirement demonstrates the FBACS system's filter train heater is capable of maintaining the air entering the carbon adsorber bed at::. 70% RH. The NRC staff finds that this deletion is acceptable since with the increase to 95% RH, there is no longer a need to have the heaters to reduce the humidity of the FBACS carbon adsorbers incoming air to below 70% RH.
And lastly, the licensee proposes to revise SR 3. 7.11.1 by deleting the words "... with the heaters operating automatically" from the surveillance requirement. SR 3.7.11.1 would no longer require the ventilation heaters be operated during the test with the change from 70% to 95% RH. The NRC staff notes that this deletion is also consistent with the guidance invoked from Section 4.0 of TSTF-522, Revision 0, as it states that plants which test ventilation systems adsorption at a RH of 95% do not require ventilation heaters to perform its specified safety function.
Based on the above, the NRC staff concludes that the proposed Robinson TS changes are technically justified and consistent with the regulatory requirements of 10 CFR 50. 36( c)(3).
3.3 Technical Evaluation Summary In summary, the licensee proposes to remove the ventilation system heaters from the Catawba, McGuire, Harris, and Robinson TSs. In addition, the licensee proposes to revise the Harris and Robinson, Unit 2, TSs by increasing the laboratory analysis testing requirement from 70% to 95% RH for the representative carbon bed samples.
The proposed changes contained in the licensee's application dated May 10, 2018, will better align the Catawba, McGuire, Harris, and Robinson, TSs to the guidance found in the WOG STS (NUREG-1431).
The proposed TS changes will continue to comply with the requirements of 10 CFR 50.36(c)(2) and (c)3 and do not alter the manner in which the subject systems are operated and maintained, consistent with 10 CFR 50, Appendix A, GDCs 19, 41, 42, 43, and 61. The NRC staff concludes that all applicable regulatory requirements will continue to be satisfied as a result of the proposed changes.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the North Carolina State official and South Carolina State official were notified of the proposed issuance of the amendments on February 25, 2019. The NRC confirmed on April 8, 2019, that the North Carolina State official had no comments and confirmed on April 5, 2019, that the South Carolina State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. 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 published in the Federal Register on October 23, 2018 (83 FR 53511 ). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(10). Pursuant to 10 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: D. Nold, NRR M. Mahoney, NRR Date: April 18, 2019
- via Memorandum +via E-mail OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1 /LA NRR/DSS/SCPB/BC*
NAME MMahoney KGoldstein SAnderson DATE 03/04/19 02/22/19 01/10/19 OFFICE NRR/DRA/ARCB/BC+
NRR/DSS/STSB/BC OGC-NLO+
NAME KHsueh VCusamano AGhosh DATE 03/04/19 03/04/19 04/09/19 OFFICE NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MMarkley (SWilliams for)
MMahoney DATE 04/17/19 04/18/19