ML20024F835

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Issuance of Amendment No. 35 Regarding One-Time Extension of Completion Time for Technical Specification 3.7.8 for Inoperable Essential Raw Cooling Water Train
ML20024F835
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 02/24/2020
From: Kimberly Green
Plant Licensing Branch II
To: Jim Barstow
Tennessee Valley Authority
Green K
References
EPID L-2019-LLA-0020
Download: ML20024F835 (15)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 February 24, 2020 Mr. James Barstow Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801

SUBJECT:

WATTS BAR NUCLEAR PLANT, UNIT 2- ISSUANCE OF AMENDMENT NO. 35 REGARDING ONE-TIME EXTENSION OF COMPLETION TIME FOR TECHNICAL SPECIFICATION 3.7.8 FOR INOPERABLE ESSENTIAL RAW COOLING WATER TRAIN (EPID L-2019-LLA-0020)

Dear Mr. Barstow:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 35 to Facility Operating License No. NPF-96 for the Watts Bar Nuclear Plant (WBN), Unit 2.

This amendment is in response to your application dated February 7, 2019, as supplemented by letters dated October 24, 2019, November 7, 2019, and January 13, 2020.

This amendment revises WBN Unit 2, Technical Specification 3.7.8, "Essential Raw Cooling Water (ERCW) System," to extend the allowed Completion Time to restore one ERCW System train to operable status from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to seven days, on a one-time basis.

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, Kimberly J. Green, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-391

Enclosures:

1. Amendment No. 35 to NPF-96
2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555*0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-391 WATTS BAR NUCLEAR PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 35 License No. NPF-96

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (TVA, the licensee) dated February 7, 2019, as supplemented by letters dated October 24, 2019, November 7, 2019, and January 13, 2020, 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.

Enclosure 1

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 Facility Operating License No. NPF-96 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 35 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA 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 prior to commencement of the Watts Bar Nuclear Plant, Unit 1 spring 2020 refueling outage.

FOR THE NUCLEAR REGULATORY COMMISSION Undine Shoop, Chief Plant Licensing Branch 11-2 Division of operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License and Technical Specifications Date of Issuance: February 2 4, 2 O2 O

ATIACHMENT TO AMENDMENT NO. 35 WATTS BAR NUCLEAR PLANT, UNIT 2 FACILITY OPERATING LICENSE NO. NPF-96 DOCKET NO. 50-391 Replace page 3 of Facility Operating License No. NPF-96 with the attached page 3. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Replace the following page of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain a marginal line indicating the area of change.

Remove Pages Insert Pages 3.7-18 3.7-18 3.7-18a

C. The 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 TVA is authorized to operate the facility at reactor core power levels not in excess of 3411 megawatts thermal.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A as revised through Amendment No. 35 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. TVA shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) TVA shall implement permanent modifications to prevent overtopping of the embankments of the Fort Loudon Dam due to the Probable Maximum Flood by June 30, 2018.

(4) PAD4TCD may be used to establish core operating limits until the WBN Unit 2 steam generators are replaced with steam generators equivalent to the existing steam generators at WBN Unit 1.

(5) By December 31, 2019, the licensee shall report to the NRC that the actions to resolve the issues identified in Bulletin 2012-01, "Design Vulnerability in Electrical Power System," have been implemented.

(6) The licensee shall maintain in effect the provisions of the physical security plan, security personnel training and qualification plan, and safeguards contingency plan, and all amendments made pursuant to the authority of 10 CFR 50.90 and 50.54(p ).

(7) TVA shall fully implement and maintain in effect all provisions of the Commission approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The TVA approved CSP was discussed in NUREG-0847, Supplement 28, as amended by changes approved in License Amendment No. 7.

(8) TVA shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Report for the facility, as described in NUREG-0847, Supplement 29, subject to the following provision:

Unit 2 Facility Operating License No. NPF-96 Amendment No. 35

ERCW 3.7.8

3. 7 PLANT SYSTEMS 3.7.8 Essential Raw Cooling Water (ERCW) System LCO 3.7.8 Two ERCW trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME


NOTES--------------- A.1 ------------NOTES-----------

1. Only applicable during the 1. Enter applicable Unit 1 spring 2020 outage Conditions and (U 1R 16), but no later than Required Actions of May 31, 2020. LCO 3.8.1, "AC Sources - Operating,"
2. Only applicable when Unit 1 for diesel generator is defueled. made inoperable by ERCW.
3. Only applicable during planned maintenance on 2. Enter applicable 6.9 kV shutdown board Conditions and 1A-A and associated 480 V Required Actions of boards and motor control LCO 3.4.6, "RCS centers. Loops - MODE 4," for residual heat removal loops made A. O,ne ERCW train inoperable by ERCW.

inoperable.

Restore ERCW train to 7 days OPERABLE status.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of Condition A entry

.!: 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> concurrent with UHS temperature> 71 °F (continued)
  • Watts Bar - Unit 2 3.7-18 Amendment 35

ERCW 3.7.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2 Verify UHS temperature 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is s: 71 °F.

AND Once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter B. One ERCW train 8.1 ------------NOTES-----------

inoperable for reasons 1. Enter applicable other than Condition A. Conditions and Required Actions of LCO 3.8.1, "AC Sources- Operating,"

for diesel generator made inoperable by ERCW.

2. Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4," for residual heat removal loops made inoperable by ERCW.

Restore ERCW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status.

C. Required Action A.1 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 not met. AND OR 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 /> Required Action and associated Completion Time of Condition B not met.

Watts Bar - Unit 2 3.7-18a Amendment 35

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 35 TO FACILITY OPERATING LICENSE NO. NPF-96 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 2 DOCKET NO. 50-391

1.0 INTRODUCTION

By letter dated February 7, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19038A483), as supplemented by letters dated October 24, 2019, November 7, 2019, and January 13, 2020 (ADAMS Accession Nos. ML19297F537, ML19312A111, and ML20014D230, respectively), the Tennessee Valley Authority (TVA, the licensee) submitted a license amendment request (LAR) for changes to the Watts Bar Nuclear Plant (WBN), Unit 2, Technical Specifications (TSs). The requested changes would revise WBN, Unit 2 TS 3.7.8, "Essential Raw Cooling Water (ERCW) System," to extend the allowed Completion Time (CT} to restore one ERCW system train to operable status from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days, on a one-time basis.

During the WBN, Unit 1 refueling outage in the Spring of 2020, TVA intends to perform maintenance on the 6.9 kilovolt (kV) Shutdown Board (SDBD) 1A-A and associated 480 volt (V) boards and motor control centers (MCCs). Because WBN, Unit 2 would be in power operation, current limitations for the alternating current (AC) electrical power distribution system restrict maintenance with one unit operating. A somewhat longer completion time to restore an ERCW system train to operable status under certain plant conditions would allow flexibility to perform needed maintenance with one unit defueled, while mitigating the additional risk to the operating unit. Without the proposed change, a dual-unit outage would be required to perform the necessary electrical board maintenance activities.

The supplemental letters dated October 24, 2019, November 7, 2019, and January 13, 2020, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staff's original proposed no significant hazards consideration determination as published in the Federal Register on July 16, 2019 (84 FR 33990).

Enclosure 2

2.0 REGULATORY EVALUATION

2.1 Essential Raw Cooling Water System Description As discussed in Section 9.2.1 of the WBN Updated Final Safety Analysis Report (UFSAR)

(ADAMS Accession No. ML19176A145) and in the LAR, the ERCW system is designed to supply cooling water to safety and non-safety-related equipment. Provisions are made to ensure a continuous flow of cooling water to those systems and components necessary for plant safety either during normal operation or under accident conditions. Sufficient redundancy of piping and components is provided to ensure that cooling is maintained to vital loads at all times.

The ERCW draws water from the Tennessee River Chickamauga Reservoir, the ultimate heat sink (UHS). The ERCW system is a two-train shared system between the WBN units consisting of eight SO-percent capacity ERCW pumps, four traveling water screens, four screen wash pumps, four strainers located in the main intake pumping station, and associated piping and valves. Water for the ERCW system enters two separate sump areas of the pumping station through four traveling water screens, two for each sump, and two diver protection barriers, one for each sump. Four ERCW pumping units, on the same plant train, take suction from one of the sumps, and four more on the opposite plant train take suction from the other sump. One set of pumps and associated equipment is designated Train A, and the other Train B. Each set of four pumps discharges into a common manifold, from which two separate headers (1A and 2A for Train A, 1Band 2B for Train B), each with its own automatic backwashing strainer, supply water to the various system loads. Two ERCW headers associated with the same ERCW train (i.e., 1A and 2A, or 1Band 2B) may be cross-connected to provide greater flexibility. Each train can provide the cooling water requirement for both units under any credible plant condition. The safety-related portion of the ERCW system is designed such that total loss of either train or the loss of offsite power (LOOP) and an entire plant shutdown power train will not prevent the safe shutdown of either unit.

The ERCW system receives power from either the offsite power sources or the onsite emergency power sources. The emergency diesel generators (EDGs) are used to supply power for the ERCW pumps and motor-operated valves during a LOOP. Two ERCW pumps are supplied power from each 6.9 kV SDBD and are interlocked such that only one ERCW pump automatically starts on restoration of power to the SDBD by the EOG. During a LOOP, one EOG supplies power to each 6.9 kV SDBD. The following table shows the relationship between 6.9 kV SDBDs, associated EDGs, and supported ERCW system pumps.:

6.9 kV SDBD EDG ERCW Pumps 1A-A 1A-A A-A, C-A 1B-B 1B-B E-B, G-B 2A-A 2A-A B-A, D-A 2B-B 2B-B F-B, H-B 2.2 Requested Technical Specification Changes The proposed changes will temporarily revise the WBN Unit 2, TS Section 3. 7.8 to extend the completion time for restoring an inoperable ERCW system train to operable status from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days to allow for inspection and maintenance on SDBD 1A-A and associated 480 V boards and MCCs. A new condition "A" will be added to allow a 7-day completion time

for the required action to restore the inoperable ERCW train to operable status while verifying the UHS temperature is :5 71 °F within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. If the UHS temperature exceeds 71 °F for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> while in the new condition, the ERCW train would be required to be restored to operable status within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This new condition will be modified by three notes that limit the use of the temporary provision and require plant conditions that mitigate the additional plant risk of having one ERCW train inoperable during the extended CT. The notes above the condition would state:

  • Only applicable during the Unit 1 spring 2020 outage (U 1R 16) but no later than May 31, 2020.
  • Only applicable when Unit 1 is defueled.
  • Only applicable during planned maintenance on 6.9 kV shutdown board 1A-A and associated 480 V boards and motor control centers.

Existing condition A will be reassigned as condition B, applicable for reasons other than the new condition A. Existing condition B will be reassigned as condition C, applicable when the required action of new condition A to restore the ERCW train to operable status, or reassigned condition B, and their associated completion times are not met.

2.3 Regulatory Requirements and Guidance Title 1O of the Code of Federal Regulations (1 O CFR) 50.36, "Technical specifications," requires that the TSs include items in the following five specific categories: ( 1) Safety limits, limiting safety system settings, and limiting control settings; (2) Limiting conditions for operation (LCOs);

(3) Surveillance requirements; (4) Design features; and (5) Administrative controls. In accordance with 10 CFR 50.36(c)(2), LCOs are the lowest functional capability or performance level of equipment required for safe operation of the facility. When LCOs are not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCO can be met. Section 50.36 of 10 CFR does not specify what actions are required or how quickly they must be completed.

Paragraph 50.57(a)(3) of 10 CFR requires, in part, that a license may be issued by the Commission provided that there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public.

Pursuant to 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," paragraph (a)(4) requires, in part, that before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.

The NRC's guidance for the format and content of WBN TSs can be found in NUREG-1431, "Standard Technical Specifications Westinghouse Plants" (ADAMS Accession No. ML12100A222).

The NRC staff's guidance for review of the TSs and TS changes is in Chapter 16, "Technical Specifications," of NUREG-0800, "Standard Review Plan [SRP]," Revision 3, dated March 2010 (ADAMS Accession No. ML100351425).

3.0 TECHNICAL EVALUATION

As described in the WBN UFSAR, the ERWC system consists of two shared trains, each of which is designed to supply 100 percent of the ERWC cooling requirements to both units simultaneously. The design and function of this system is not being permanently changed by the planned maintenance on the 6.9 kV SDBD 1A-A and associated 480 V boards and MCCs.

The purpose of TS CTs is to allow a temporary relaxation of the single failure criterion to perform surveillances or necessary minor maintenance before a reactor shutdown would be required. The requested changes to extend the CT is for a specific one-time occurrence and of relatively limited additional duration to allow planned maintenance on the 6.9 kV shutdown board 1A-A and associated 480 V boards and MCCs. When one ERCW train is inoperable, the system functions are maintained by the operable train. of the LAR includes the following discussion of ERCW train operability:

WBN Units 1 and 2 TS 3.7.8 requires two independent ERCW trains to be operable in Modes 1, 2, 3, and 4 to provide the required redundancy to ensure that the system functions to remove post-accident heat loads, assuming that the worst case single active failure occurs coincident with a LOOP event. An ERCW train is operable when two pumps, aligned to separate SDBDs, are operable and the associated piping, valves, HX, and instrumentation and controls required to perform the safety-related function are operable.

Additionally, a third ERCW pump is required to be available on each ERCW train in Modes 4 and 5 during the first 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after a reactor shutdown. This requirement addresses the potential increased heat loads that may exist immediately after a unit is shut down, concurrent with a LOCA on the operating unit, an assumed LOOP, and a single failure that affects both 6.9 kV SDBDs in one power train. An ERCW train is considered operable during the first 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown with a UHS temperature not exceeding 85°F, two pumps per train, aligned to separate SDBDs, and one additional Train A pump and one additional Train B pump are capable of being aligned to their respective 6.9 kV SDBD and manually placed in service.

The LAR also indicated that a thermal-hydraulic analysis was performed to determine what maximum UHS temperature, for a given system lineup and time since Unit 1 shutdown, would allow for adequate heat removal for both Unit 1 and Unit 2 following a Unit 2 loss-of-coolant accident concurrent with a LOOP and a worst case single active failure. The resulting necessary Unit 1 and UHS conditions are described as:

The planned maintenance requires the removal of two ERCW pumps from service {both powered from 6.9 kV SDBD 1A-A). Removing the ERCW pumps from service to support the planned maintenance leaves one available ERCW pump in Train A. The UHS temperature limit of s 71°F and the requirement for WBN Unit 1 to be shutdown for more than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> and in a defueled condition, significantly reduces the cooling water demands on the ERCW System and CCS to allow the performance of planned maintenance on 6.9 kV SDBD 1A-A and associated 480 V boards and MCCs. Furthermore, in accordance with WBN Unit 1 TS 3.9.10, "Decay Time," WBN Unit 1 will be subcritical for at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to entering the new WBN Unit 1 TS 3.7.8, Condition A.

Assuming the minimum 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> subcritical required by TS 3.9.1 O before defueling can begin is conservative, as that is when fuel transfer from the reactor to the spent fuel pool can commence, and the LAR indicates that the additional duration for completing the defueling operation would be approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

The LAR, as supplemented, also includes a graph showing ERCW intake water temperatures for April and May 2015 to 2019. The graph shows that the maximum temperature reached by the end of May during the last 5 years is 76.4 °F. This historical data suggests that 71 °Fis unlikely to be exceeded until the last week of May when the temperature typically increases about 1 °F per day. If the work is performed earlier in May there would likely be additional heat removal capability provided by the lower intake water temperature.

Section 3.2.3 of Enclosure 1 to the LAR discusses plant procedures directing plant personnel to assess and determine needed defense-in-depth and equipment protection measures during unit outages to ensure key safety functions are maintained. Fleet procedures provide guidance for operating unit work management processes to assess plant risk and maximize plant reliability and determine needed equipment protection measures. Because ERCW is a shared system

  • between the units, it is always addressed for both operating and outage unit. These actions are part of implementing the requirements of 10 CFR 50.65(a)(4). The NRC staff recognizes the importance of preventive maintenance to ensure that systems, structures and components (SSCs) can perform their safety functions. The licensee is required to comply with 10 CFR 50.65 for performance of maintenance activities and to balance maintenance, while minimizing unavailability of SSCs.

The conditional and compensatory actions included in the proposed TS 3.7.8 Condition A change provide reasonable assurance that the limited temporary extension of the CT for ERWC for Unit 2 will not significantly affect plant safety because enough cooling capability would be available in the event of a reactor accident or LOOP.

In Enclosure 1 of the January 13, 2020 supplement, the licensee provided an evaluation of the proposed TS changes and stated:

If UHS temperature exceeds 71°F after 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of continuous ERCW train inoperability, then the specified conditions for crediting the availability of the inoperable ERCW train are no longer met and action must be taken to restore the ERCW train to an Operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Otherwise, the unit must enter WBN Unit 2 TS 3.7.8, Condition C, which requires the unit to be in Mode 3 within six hours and Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. If UHS temperature is discovered to be> 71°F, prior to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of continuous operation in Condition A, then the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time to restore the inoperable ERCW train to Operable status starts after 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of continuous operation in Condition A. However, the proposed change to WBN Unit 2 TS 3.7.8 does not allow continued operation in Condition A for greater than seven days.

The staff reviewed the proposed TS changes along with the licensee's justification and evaluation in the LAR and supplements. The staff determines that while the proposed changes represent a slight departure from the guidance in NUREG-1431, the differences are justified by the evaluation provided by the licensee. Chapter 16 of the SRP allows for such justified differences.

Technical Conclusion The requested CT duration extension is limited and temporary. The operable ERCW train maintains full system capability, and the risk management required plant conditions and compensatory actions listed in the LAR are invoked via notes in the proposed CT temporary wording changes. Based on the preceding technical evaluation, the NRC staff concludes that TS 3.7.8, as amended by the proposed change, will continue to provide reasonable assurance of adequate protection of public health and safety. Therefore, the NRC has determined the proposed change is acceptable.

Paragraph 50.36(b) of 10 CFR requires TSs to be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto. The licensee provided an evaluation and justification of the proposed change to WBN Unit 2 TS 3. 7.8.

The staff reviewed the proposed changes as well as the licensee's justifications for the changes.

The licensee has met the requirements of 10 CFR 50.36(a)(1) because a summary statement of the reasons for the TS was provided. The staff determined that the regulatory requirements of 10 CFR 50.36(b) will continue to be met because the technical specifications will continue to be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto. The staff determined that the regulatory requirements of 10 CFR 50.36(c)(2) will continue to be met because the LCO will continue to describe the lowest functional capability or performance level of equipment required for safe operation of the facility and the remedial actions permitted by the TSs until the LCOs can be met have been deemed acceptable to the staff. Finally, while the format of the proposed changes is a slight departure from the guidance in NUREG-1431, the differences are justified by the evaluation provided by the licensee, in accordance with Chapter 16 of the SRP. Therefore, the staff finds that the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendment on January 15, 2020. 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, "Standards for Protection Against Radiation." 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 previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on July 16, 2019 (84 FR 33990).

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: J. Bettle, NRR M. Hamm, NRR Da~: February 24, 2020

ML20024F835 *b e-mail NRR/D0RL/LPL2-2/P /SCPB/BC* NRR/DSS/STSB/

KGreen VCusumano 01/28/2020 01/27/2020 01/14/2020 01/24/2020 NRR/DEX/EEOB/BC* OGC (NLO w/edits) NRR/D0RL/LPL2-2 D0RL/LPL2-2/PM BTitus w/comments RAugustus UShoop KGreen DATE 01/27/2020 02/12/2020 02/24/2020 02/24/2020