ML19189A084
| ML19189A084 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/19/2019 |
| From: | Samson Lee Plant Licensing Branch 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Parker C | |
| References | |
| EPID L-2019-LLA-0052 | |
| Download: ML19189A084 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 19, 2019 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT- ISSUANCE OF AMENDMENT NO. 326 RE: ADOPTION OF TSTF-522, REVISION 0, "REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH" (EPID L-2019-LLA-0052)
Dear Mr. Hanson:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 326 to Renewed Facility Operating License No. DPR-59 for the James A.
FitzPatrick Nuclear Power Plant. The amendment consists of changes to the technical specifications in response to your application dated March 7, 2019.
The amendment revises the James A. FitzPatrick Nuclear Power Plant Technical Specification requirements regarding ventilation system testing in accordance with 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." Specifically, Surveillance Requirement 3.6.4.3.1 of Technical Specification 3.6.4.3, "Standby Gas Treatment (SGT) System," was revised to require operating the ventilation system for at least 15 continuous minutes with the heaters operating at a frequency controlled in accordance with the Surveillance Frequency Control Program.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
~~~
Samson S. Lee, Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333
Enclosures:
- 1. Amendment No. 326 to DPR-59
- 2. Safety Evaluation cc: Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON FITZPATRICK, LLC AND EXELON GENERATION COMPANY, LLC DOCKET NO. 50-333 JAMES A. FITZPATRICK NUCLEAR POWER PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 326 Renewed Facility Operating License No. DPR-59
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Exelon FitzPatrick, LLC and Exelon Generation Company, LLC (collectively, the licensees) dated March 7, 2019, 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 2.C.(2) of Renewed Facility Operating License No. DPR-59 is hereby amended to read as follows:
Enclosure 1
- 2. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 326, are hereby incorporated in the renewed operating 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 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION ct;'~
Ja es G. Danna, Chief Pl nt Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License and Technical Specifications Date of Issuance: August 1 9, 201 9
ATTACHMENT TO LICENSE AMENDMENT NO. 326 JAMES A. FITZPATRICK NUCLEAR POWER PLANT RENEWED FACILITY OPERATING LICENSE NO. DPR-59 DOCKET NO. 50-333 Replace the following page of the License with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Remove Page Insert Page Page 3 Page 3 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Remove Page Insert Page 3.6.4.3-3 3.6.4.3-3
(4) Exelon Generation Company pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use, at any time, any byproduct, source and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration; or associated with radioactive apparatus, components or tools.
(5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:
Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1) Maximum Power Level Exelon Generation Company is authorized to operate the facility at steady state reactor core power levels not in excess of 2536 megawatts (thermal).
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 326, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.
(3) Fire Protection Exelon Generation Company shall implement and maintain in effect all provisions of the approved fire protections program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated November 20, 1972; the SER Supplement No. 1 dated February 1, 1973; the SER Supplement No. 2 dated October 4, 1974; the SER dated August 1, 1979; the SER Supplement dated October 3, 1980; the SER Supplement dated February 13, 1981; the NRC Letter dated February 24, 1981; Technical Specification Amendments 34 (dated January 31, 1978), 80 (dated May 22, 1984), 134 (dated July 19, 1989),
135 (dated September 5, 1989), 142 (dated October 23, 1989), 164 (dated August 10, 1990), 176 (dated January 16, 1992), 177 (dated February 10, 1992), 186 (dated February 19, 1993), 190 (dated June 29, 1993), 191 (dated July 7, 1993), 206 (dated February 28, 1994), and 214 (dated June 27, 1994); and NRC Exemptions and associated safety evaluations dated April 26, 1983, July 1, 1983, January 11, 1985, Amendment 326 Renewed License No. DPR-59
SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for ~ 15 continuous In accordance minutes with heaters operating. with the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required SGT filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual In accordance or simulated initiation signal. with the Surveillance Frequency Control Program SR 3.6.4.3.4 Manually cycle each SGT subsystem filter cooling In accordance cross-tie valve. with the Surveillance Frequency Control Program JAFNPP 3.6.4.3-3 Amendment 326
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 326 EXELON FITZPATRICK, LLC EXELON GENERATION COMPANY, LLC DOCKET NO. 50-333 JAMES A. FITZPATRICK NUCLEAR POWER PLANT TO RENEWED FACILITY OPERATING LICENSE NO. DPR-59
1.0 INTRODUCTION
By letter dated March 7, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19066A251 ), Exelon Generation Company, LLC (the licensee) submitted a request for changes to the James A. FitzPatrick Nuclear Power Plant (FitzPatrick)
Technical Specifications (TSs). Specifically, the licensee requested to adopt U.S. Nuclear Regulatory Commission (NRC or the Commission)-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," dated March 30, 2010 (ADAMS Accession No. ML100890316).
The licensee proposed changes to TS 3.6.4.3, "Standby Gas Treatment (SGT) System," in particular, Surveillance Requirement (SR) 3.6.4.3.1, which currently requires operating the ventilation system for at least 10 continuous hours with heaters operating at a frequency controlled in accordance with the Surveillance Frequency Control Program (SFCP). The licensee proposed to change SR 3.6.4.3.1 to require at least 15 continuous minutes of ventilation system operation with the heaters operating at a frequency controlled in accordance with the SFCP.
2.0 REGULATORY EVALUATION
2.1 Description of Systems One of the reasons air filtration and adsorption systems are required at nuclear power plants is 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 the 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, prefilters or demisters, high-efficiency particulate air (HEPA)
Enclosure 2
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 acceptable amount of radioactive gases.
2.2 Description of Proposed Change The licensee proposed changes to TS 3.6.4.3, in particular, SR 3.6.4.3.1, which currently requires operating the ventilation system for at least 10 continuous hours with heaters operating at a frequency controlled in accordance with the SFCP. The licensee proposed to change SR 3.6.4.3.1 to require at least 15 continuous minutes of ventilation system operation with the heaters operating at a frequency controlled in accordance with the SFCP.
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 at a frequency controlled by the SFCP. These requirements are based on NRC staff guidance for testing air filtration and adsorption systems that have been superseded. New NRC staff guidance states at least 15 continuous minutes of ventilation system operation with heaters operating every 31 days is acceptable for those plants that test ventilation system adsorption at a relative humidity of less than 95 percent. Plants that test ventilation systems adsorption at a relative humidity of 95 percent do not require heaters for the ventilation system to perform its safety function, and therefore "with heater operating" is not included in the respective SRs.
2.3 Description of Applicable Regulatory Requirements and Guidance 2.3.1 Requirements The regulatory requirements for design and testing of these systems are contained in Title 10 of the Code of Federal Regulations ( 10 CFR) Section 50.67; 10 CFR Part 100; and 10 CFR Part 50 Appendix A, "General Design Criteria for Nuclear Power Plants," specifically, General Design Criteria 19, 41, 42, 43, and 61.
The following explains the use of general design criteria for FitzPatrick. The construction permit for FitzPatrick was issued by the Atomic Energy Commission (AEC) on May 20, 1970, and the operating license was issued on October 17, 1974. The plant design criteria for the construction phase is listed in the Updated Final Safety Analysis Report (UFSAR), Chapter 1.5, "Principal Design Criteria." The AEC published the final rule that added Appendix A to 10 CFR Part 50 in the Federal Register(36 FR 3255) on February 20, 1971, with the rule effective on May 21", 1971.
In accordance with an NRC staff requirements memorandum from S. J. Chilk to J. M. Taylor, "SECY-92-223 - Resolution of Deviations Identified During the Systematic Evaluation Program,"
dated September 18, 1992 (ADAMS Accession No. ML003763736), the Commission decided not to apply the final GDC to plants with construction permits issued prior to May 21, 1971, which includes FitzPatrick. However, the FitzPatrick UFSAR, Chapter 16.6, "Conformance to AEC Design Criteria," evaluates FitzPatrick against the 10 CFR 50 Appendix A GDC. Also, the initial AEC safety evaluation of FitzPatrick, dated November 20, 1972 (ADAMS Accession No. ML19182A200), Chapter 14.0, states:
Based on our evaluation of the design and design criteria for the James A.
FitzPatrick Nuclear Power Plant, we conclude that there is reasonable assurance that the intent of the General Design Criteria for Nuclear Power Plants, published
in the Federal Register on May 21, 1971 as Appendix A to 10 CFR Part 50, will be met.
Therefore, the NRC staff reviews amendments to the FitzPatrick license using the 10 CFR 50 Appendix A GDC unless there are specific criteria identified in the UFSAR.
The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36, Technical specifications." The regulations in 10 CFR 50.36 require that the TSs include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation; (3) SRs; (4) design features; and (5) administrative controls. Section (c)(2)(i) of 10 CFR 50.36 states, in part, that limiting conditions for operation "are the lowest functional capability or performance levels of equipment required for safe operation of the facility." Paragraph (c)(3) of 10 CFR 50.36 states that SRs "are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met."
2.3.2 Guidance Regulatory Guide (RG) 1.52, Revision 2, "Design, Testing, and Maintenance Criteria for Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorbtion Units of Light-Water-Cooled Nuclear Power Plants" (ADAMS Accession No. ML003740139), was published in March 1978 to provide guidance and criteria acceptable to the NRC staff for licensees to implement the regulations in 10 CFR related to air filtration and adsorption systems. Regulatory Position 4.d of Revision 2 of RG 1.52 states:
Each ESF [engineered safety feature] 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 guidance is to minimize the effects of moisture on the ability of the adsorbers to capture gaseous activity and, thereby, enhance efficiency in the event the system is called upon to perform its design basis function.
Following subsequent industry experience and testing, the NRC staff determined that 10 continuous hours of system operation would dry out the charcoal adsorber for a brief period of time, but following heater deenergization, the level of moisture accumulation in adsorbers would rapidly return to the pre-test level. The NRC staff subsequently issued Generic Letter (GL) 99-02, "Laboratory Testing of Nuclear-Grade Activated Charcoal," dated June 30, 1999 (ADAMS Accession No. ML082350935), and errata sheet dated August 23, 1999 (Accession No. ML031110094}. GL 99-02 requested licensees to confirm that their charcoal testing protocols accurately demonstrate the capability of the charcoal to adsorb gaseous activity. In GL 99-02, the NRC staff also requested the licensees to account for the effects of moisture accumulation in absorbers.
The NRC staff addressed the new information in RG 1.52, Revision 3, issued in June 2001 (ADAMS Accession No. ML011710176). 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.
As noted above, 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. These effects can be accounted for in the Ventilation Filter Testing Programs of U.S. nuclear plants by performing testing in accordance with ASTM 03803-1989. FitzPatrick TS 5.5.8, "Ventilation Filter Testing Program (VFTP)," requires testing the charcoal adsorbers in a manner to account for the effect of moisture on the adsorber's ability to capture gaseous activity in accordance with ASTM 03803-1989. Therefore, the licensee proposed to remove the requirement to operate heaters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> from SR 3.6.4.3.1.
The NRC's guidance for the format and content of licensee TSs can be found in the Standard Technical Specifications (STS). The applicable STS for FitzPatrick are NUREG-1433, "Standard Technical Specifications General Electric Plants BWR/4" (ADAMS Accession No. ML12104A192).
TSTF-522, Revision 0, provided guidance on revising the SRs for ventilation system operation.
The licensee stated that the license amendment request is consistent with TSTF-522, Revision 0. The availability of the TSTF for use was announced in the Federal Register on September 20, 2012 (77 FR 58421 ), as part of the consolidated line item improvement process.
3.0 TECHNICAL EVALUATION
SR 3.6.4.3.1 currently requires operating each standby gas treatment filter train for at least 10 continuous hours with heaters operating at a frequency controlled in accordance with the SFCP and would be changed to require at least 15 continuous minutes of standby gas treatment filter train operation with heaters operating at a frequency controlled in accordance with the SFCP.
Section 2.2, "Optional Changes and Variations," in the licensee's application states:
JAF [FitzPatrick] has implemented the Surveillance Frequency Control Program (SFCP) and therefore the 31-day requirement will be incorporated into the SFCP and the Frequency in the TS will state, "In accordance with the Surveillance Frequency Control Program" for SR 3.6.4.3.1. Additionally, JAF TS 3. 7.3, "Control Room Emergency Ventilation Air Supply (CREVAS)" relates to the TSTF-522 Section 3.7.4, "Main Control Room Environmental Control (MCREC)
System." However, the JAF CREVAS system does not have installed heaters and the current duration required by SR 3.7.3.1 is already consistent with this TSTF. There are no changes recommended to TS 3.7.3.
The NRC staff evaluated the licensee's proposed change and the variation discussed above against the applicable regulatory guidance in RG 1.52, Revision 3, the applicable STS (as modified by TSTF-522), and the regulatory requirements of 10 CFR 50.36.
The proposed change would require at least 15 minutes of continuous system operation with the heaters on. The NRC staff found that the proposed change is consistent with RG 1.52, Revision 3.
The NRC staff evaluated the licensee's proposed change against the applicable regulatory guidance in the STS, as modified by TSTF-522. The proposed change adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1433 by
and content, to the extent practicable, contained in the changes made to NUREG-1433 by TSTF-522. The NRC staff found that the proposed change is consistent with guidance in the STS, as modified by TSTF-522.
The NRC staff compared the proposed change to the existing SR, as well as the regulatory requirements of 10 CFR 50.36. The existing SR provides assurance that the necessary quality of ventilation systems and components will be maintained and that the limiting conditions for operation will be met. The proposed change reduces the amount of required system operational time from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 minutes. The 10-hour operational requirement for heaters was based on using the SR to eliminate moisture in the adsorbers and thus ensure the adsorbers would capture gaseous activity. 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 in a manner to account for the effects of moisture on the adsorber's ability to capture gaseous activity. The Ventilation Filter Testing Program requirements are contained in FitzPatrick TS 5.5.8 and require testing at a specific temperature and relative humidity value to account for the effects of moisture. Since SR 3.6.4.3.1 is no longer relied upon to ensure the effects of moisture on the adsorber's ability to capture gaseous activity are accounted for, reducing the operational time of the system from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 minutes is acceptable.
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. The NRC staff found that the proposed SR meets the regulatory requirements of 10 CFR 50.36(c)(3) because the change provides assurance that the necessary quality of ventilation systems and components will be maintained and that the limiting conditions for operation will be met. Therefore, the NRC staff finds the proposed change acceptable.
Exelon Generation Company, LLC's application dated March 7, 2019, also provided proposed changes to the TS Bases to be implemented with the associated TS changes discussed above.
The TS Bases pages were provided for information only and will be revised in accordance with the TS Bases Control Program.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment on June 18, 2019. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (April 23, 2019; 84 FR 16893). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22( c )(9 ). Pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the prc;>posed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Ravi Grover Da~: August 19, 2019
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - ISSUANCE OF AMENDMENT NO. 326 RE: ADOPTION OF TSTF-522, REVISION 0, "REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH" (EPID L-2019-LLA-0052)
DATED AUGUST 19, 2019 DISTRIBUTION:
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ADAMS A ccess1on N o.: ML19189A084 *b1y memo **b1y e-ma1*1 OFFICE DORL/LPL 1/PM DORL/LPL 1/LA OGC-NLO** DSS/STSB/BC(A)*
NAME CParker LRonewicz JScro PSnyder DATE 07/15/2019 07/11/2019 08/05/2019 6/28/2019*
OFFICE DORL/LPL 1/BC DORL/LPL 1/PM ..
NAME JDanna Slee .... ..
DATE 08/16/2019 08/19/2019 OFFICIAL RECORD COPY