ML20202A005
ML20202A005 | |
Person / Time | |
---|---|
Site: | Hatch |
Issue date: | 09/15/2020 |
From: | John Lamb Plant Licensing Branch II |
To: | Gayheart C Southern Nuclear Operating Co |
Lamb J | |
References | |
EPID: L-2020-LLA-0129 | |
Download: ML20202A005 (20) | |
Text
September 15, 2020 Ms. Cheryl A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Co., Inc.
3535 Colonnade Parkway Birmingham, AL 35243
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, ISSUANCE OF AMENDMENTS NOS. 306 AND 251, REGARDING THE APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-568, REVISE APPLICIABILITY OF BWR/4 TS 3.6.2.5 AND TS 3.6.3.2 (EPID L-2020-LLA-0129)
Dear Ms. Gayheart:
The Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 306 to Renewed Facility Operating License No. DPR-57 and Amendment No. 251 to Renewed Facility Operating License No. NPF-5 for the Edwin I. Hatch Nuclear Plant (Hatch), Unit Nos 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 12, 2020, as supplemented September 8, 2020.
Your application requested the adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-568, Revision 2, Revise Applicability of BWR [Boiling Water Reactor]/4 TS 3.6.2.5 and TS 3.6.3.2, using the Consolidated Line Item Improvement Process.
The amendments revise Hatch, Units 1 and 2, TS 3.6.3.2, Primary Containment Oxygen Concentration, and present the requirements in a manner more consistent with the Standard Technical Specifications format and content.
C.
A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions biweekly Federal Register notice.
Sincerely,
/RA/
John G. Lamb, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366
Enclosures:
- 1. Amendment No. 306 to DPR-57
- 2. Amendment No. 251 to NPF-5
- 3. Safety Evaluation cc: Listserv
SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-321 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 306 Renewed License No. DPR-57
- 1.
The Nuclear Regulatory Commission (NRC, the Commission) has found that:
A.
The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit No. 1 (the facility) Renewed Facility Operating License No. DPR-57 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated June 12, 2020, as supplemented September 8, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions 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. DPR-57 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. 306, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This license amendment is effective as of its date of issuance and shall be implemented within 45 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. DPR-57 and Technical Specifications Date of Issuance: September 15, 2020 Glenn E.
Miller Digitally signed by Glenn E. Miller Date: 2020.09.15 11:41:06 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 306 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-57 DOCKET NO. 50-321 Replace the following pages of the License and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Pages Insert Pages License License 4
4 TSs TSs 3.6-33 3.6-33
Renewed License No. DPR-57 Amendment No. 306 for sample analysis or instrumentation calibration, or associated with radioactive apparatus or components (6)
Southern Nuclear, 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 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, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions2 specified or incorporated below:
(1)
Maximum Power Level Southern Nuclear is authorized to operate the facility at steady state reactor core power levels not in excess of 2804 megawatts thermal.
(2)
Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B); as revised through Amendment No. 306, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
The Surveillance Requirement (SR) contained in the Technical Specifications and listed below, is not required to be performed immediately upon implementation of Amendment No. 195. The SR listed below shall be successfully demonstrated before the time and condition specified:
SR 3.8.1.18 shall be successfully demonstrated at its next regularly scheduled performance.
(3)
Fire Protection Southern Nuclear shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Updated Final Safety Analysis Report for the facility, as contained in the updated Fire Hazards Analysis and Fire Protection Program for the Edwin I. Hatch Nuclear Plant, Units 1 and 2, which was originally submitted by letter dated July 22, 1986. Southern Nuclear may make changes to the fire protection program without prior Commission approval only if the changes
Primary Containment Oxygen Concentration 3.6.3.2 HATCH UNIT 1 3.6-33 Amendment No. 306 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be < 4.0 volume percent.
APPLICABILITY:
MODE 1 and 2.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
Primary containment oxygen concentration not within limit.
A.1
NOTE-----------
LCO 3.0.4.c is applicable.
Restore oxygen concentration to within limit.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B.
Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.2.1 Verify primary containment oxygen concentration is within limits.
In accordance with the Surveillance Frequency Control Program
SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-366 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 251 Renewed License No. NPF-5
- 1.
The Nuclear Regulatory Commission (NRC, the Commission) has found that:
A.
The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit No. 2 (the facility) Renewed Facility Operating License No. NPF-5 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated June 12, 2020, as supplemented September 8, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions 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-5 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. 251, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This license amendment is effective as of its date of issuance and shall be implemented within 45 days from the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to Renewed Facility Operating License No. NPF-5 and Technical Specifications Date of Issuance: September 15, 2020 Glenn E.
Miller Digitally signed by Glenn E. Miller Date: 2020.09.15 11:41:53 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 251 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. NPF-5 DOCKET NO. 50-366 Replace the following pages of the License and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Pages Insert Pages License License 4
4 TSs TSs 3.6-31 3.6-31
Renewed License No. NPF-5 Amendment No. 251 (6)
Southern Nuclear, 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 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, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions2 specified or incorporated below:
(1)
Maximum Power Level Southern Nuclear is authorized to operate the facility at steady sate reactor core power levels not in excess of 2,804 megawatts thermal, in accordance with the conditions specified herein.
(2)
Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B); as revised through Amendment No. 251, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the renewed license or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the license supported by a favorable evaluation by the Commission.
(a)
Fire Protection Southern Nuclear shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Updated Final Safety Analysis Report for the facility, as contained 2 The original licensee authorized to possess, use, and operate the facility with Georgia Power Company (GPC). Consequently, certain historical references to GPC remain in certain license conditions.
Primary Containment Oxygen Concentration 3.6.3.2 HATCH UNIT 2 3.6-31 Amendment No. 251 3.6 CONTAINMENT SYSTEMS 3.6.3.2 Primary Containment Oxygen Concentration LCO 3.6.3.2 The primary containment oxygen concentration shall be < 4.0 volume percent.
APPLICABILITY:
MODE 1 and 2.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
Primary containment oxygen concentration not within limit.
A.1
NOTE-----------
LCO 3.0.4.c is applicable.
Restore oxygen concentration to within limit.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B.
Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.3.2.1 Verify primary containment oxygen concentration is within limits.
In accordance with the Surveillance Frequency Control Program
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 306 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-57 AND AMENDMENT NO. 251 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-5 SOUTHERN NUCLEAR OPERATING COMPANY, INC.
EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-321 AND 50-366
1.0 INTRODUCTION
By application dated June 12, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20164A278), as supplemented by letter dated September 8, 2020 (ADAMS Accession No. ML20253A313), Southern Nuclear Operating Company, Inc. (SNC, the licensee), submitted a license amendment request (LAR) for the Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2.
The proposed changes would revise Technical Specification (TS) 3.6.3.2, Primary Containment Oxygen Concentration. The proposed changes simplify and clarify the applicability statements, which if misapplied, could conflict with the corresponding required actions. The proposed changes also remove the undefined term scheduled plant shutdown and provide adequate terminal actions.
The proposed amendment is based on Technical Specifications Task Force (TSTF) Traveler TSTF-568, Revision 2, Revise Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2 (ADAMS Accession No. ML19141A122). The U.S. Nuclear Regulatory Commission (NRC or the Commission) approved TSTF-568, Revision 2, by letter dated December 17, 2019 (ADAMS Package Accession No. ML19325C444). The NRC staffs safety evaluation (SE) of the traveler was enclosed with the NRC staffs approval letter.
The proposed change to TS 3.6.2.5, Drywell-to-Suppression Chamber Differential Pressure, in TSTF-568 is not applicable to Hatch, Units 1 and 2; therefore, SNC did not include it in the application, as specified in the NRC staff model SE (ADAMS Accession No. ML19325C435).
The supplement dated September 8, 2020, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published the Federal Register on July 14, 2020 (85 FR 42442).
2.0 REGULATORY EVALUATION
2.1 Description of Structures, Systems, Components and TS Sections 2.1.1 Current Containment Oxygen Concentration Requirement The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.44, Combustible gas control for nuclear power reactors, defines an inerted containment atmosphere, as a containment with oxygen concentration less than 4 percent by volume. This requirement ensures that an accident that produces hydrogen does not result in a combustible mixture inside the primary containment. The current TS 3.6.3.2 requires primary containment oxygen concentration to be less than 4 percent by volume when in Mode 1 during the period from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the thermal power exceeds 15 percent reactor thermal power (RTP) following startup, and to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing the RTP to less than 15 percent RTP during next scheduled shutdown. TSTF-568, Revision 2, stated that the 24-hour allowance above 15 percent RTP is provided in the primary containment oxygen concentration specification to delay inerting the primary containment in a plant startup and to accelerate de-inerting for a plant shutdown. This allowance is provided so that plant personnel can safely enter the primary containment without breathing apparatus to perform the needed inspections and maintenance adjustments.
The Hatch containment consists of a drywell (in the shape of an inverted light bulb), a suppression chamber (in the shape of a toroid), and a network of vents which extend radially outward and downward from the drywell to the suppression chamber. The containment atmosphere is inerted with nitrogen gas during normal operation to prevent a combustible mixture of hydrogen and oxygen from forming during accident conditions. Long-term control of post-Loss-of-Coolant Accident (LOCA) hydrogen gas concentration is accomplished by adding additional nitrogen gas and then venting the primary containment through the standby gas treatment system.
2.1.2 Pressure Suppression Following a LOCA The drywell is immediately pressurized when a postulated line break occurs within the primary containment. As drywell pressure increases, drywell atmosphere (primarily nitrogen gas) and steam are blown down through the vents into the suppression pool via the downcomers. The steam condenses in the suppression pool which suppresses the peak pressure in the drywell.
Non-condensable gases discharged into the suppression pool collect in the free air volume of the suppression chamber, increasing the suppression chamber pressure. As steam is condensed in the suppression pool and on the structures in the drywell, the pressure decreases until the suppression chamber pressure exceeds the drywell pressure and the suppression chamber-drywell vacuum breakers open and vent non-condensable gases back into the drywell.
2.1.3 TS 3.6.3.2, Primary Containment Oxygen Concentration The primary containment oxygen concentration is maintained to ensure that a LOCA, a postulated event that produces hydrogen, does not result in a combustible mixture inside primary containment. The TS requires that the primary containment oxygen concentration be maintained below 4 volume percent. Below this concentration, the primary containment is inerted and no combustion can occur.
2.2 Description of Proposed Technical Specification Changes 2.2.1 Proposed Changes to TS 3.6.3.2, Primary Containment Oxygen Concentration The Applicability of TS 3.6.3.2, Primary Containment Oxygen Concentration, would be revised as shown below.
Current TS Applicability Proposed TS Applicability MODE 1 during the time period:
- c. From 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is
> 15% RTP following startup, to
- d. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing THERMAL POWER to < 15% RTP prior to the next scheduled reactor shutdown.
MODES 1 and 2.
Required Actions A.1 and B.1 and their associated Completion Times (CTs) are revised as shown below.
The NRC staff understands the overall purpose of the proposed changes is to simplify the applicability statement by adding a new note and revising the CT. This change provides operational flexibility but more closely follows established TS conventions and requires that the plant be in Mode 3 if oxygen concentration cannot be restored to within limits.
2.3 Applicable Regulatory Requirements and Guidance Section 50.90 of 10 CFR, Application for amendment of license, construction permit, or early site permit, requires that whenever a licensee desires to amend the license, application for an
amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
Under 10 CFR 50.92(a), determinations on whether to grant an applied-for license amendment are to be guided by the considerations that govern the issuance of initial licenses or construction permits to the extent applicable and appropriate. Both the common standards for licenses and construction permits in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public.
The regulation, 10 CFR 50.36, Technical specifications, establishes the regulatory requirements related to the content of TSs. Section 50.36(a)(1) requires an application for an operating license to include proposed TSs. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, must also be included in the application but shall not become part of the TSs.
The regulation, 10 CFR 50.36(b), requires:
Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.
The categories of items required to be in the TSs are listed in 10 CFR 50.36(c).
In accordance with 10 CFR 50.36(c)(2), limiting conditions for operation (LCOs) are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When LCOs are not met, the licensee must shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.
In addition, 10 CFR 50.36(c)(2)(ii)(B) requires a TS LCO of a nuclear reactor must be established for a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The regulation, 10 CFR 50.44(b)(2)(i), states that All boiling water reactors with Mark I or Mark II type containments must have an inerted atmosphere. Section 50.44(a)(1) defines [i]nerted atmosphere as a containment atmosphere with less than 4 percent of oxygen by volume.
Chapter 6.2.1.1.C, Revision 7, Pressure-Suppression Type BWR Containments of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2007 (ADAMS Accession No. ML063600403) states: The acceptability of LOCA pool dynamic loads for plants with Mark I containments is based on conformance with NRC acceptance criteria found in NUREG-0661.
The NRC staffs guidance for the review of TSs is in Chapter 16.0, Revision 3, Technical Specifications, of the SRP, March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared Standard Technical Specifications (STSs) for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the
applicable reference STSs (i.e., the current STSs), as modified by NRC-approved travelers.
The STS applicable to Hatch, Units 1 and 2, is NUREG-1433, Revision 4.0, Standard Technical Specifications, General Electric Plants BWR/4, Volume 1, Specifications, and Volume 2, Bases, April 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193, respectively).
3.0 TECHNICAL EVALUATION
The proposed amendments are based on the NRC-approved TSTF-568, Revision 2. The NRC staff also considered the regulations and guidance discussed in Section 2.3 of this SE in its review.
3.1 PROPOSED CHANGE
S TO TS 3.6.3.2 3.1.1 Proposed Changes in the Applicability In accordance with approved Traveler TSTF-568, Revision 2, the licensee proposed to expand the applicability of this LCO to Modes 1 and 2 without exception. The NRC staff finds the proposed change acceptable because it is more restrictive since an unlikely LOCA event leading to a degraded core that could produce hydrogen has the highest probability of occurrence during Modes 1 and 2 conditions.
3.1.2 Proposed Changes in Required Action A.1 In accordance with the NRC-approved Traveler TSTF-568, Revision 2, the licensee proposed to add the following note to Required Action A.1: LCO 3.0.4.c is applicable. TS LCO 3.0.4.c allows entering the mode of applicability of TS LCO 3.6.3.2 with the LCO not met. Therefore, the proposed change would permit entry into Modes 1 and 2 with primary containment oxygen concentration higher than the required limit. The NRC staff concludes the addition of the note is acceptable because it clarifies and simplifies the intent of the current TS LCO 3.6.3.2 applicability statement a. of allowing startup operation with the LCO not met.
3.1.3 Proposed Changes in the CT of Condition A In accordance with Traveler TSTF-568, Revision 2, the licensee proposed changing the CT from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 based on the following sequence of operations: allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to de-inert the containment to permit safe personnel access, allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform the required maintenance or repair work, and allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to inert the containment. The NRC staff determined that the presence of a higher oxygen concentration for the 72-hour CT is appropriate considering the low safety significance of the change for potential accidents and the additional restrictions and conservatisms in the revised applicability.
3.1.4 Proposed Changes in Required Action B.1 In accordance with Traveler TSTF-568, Revision 2, the licensee proposed to change the applicability statement of TS LCO 3.6.3.2 to Modes 1 and 2. If the oxygen concentration cannot be restored within the required limit and CT of Required Action A.1, the reactor should be brought to Mode 3. In this mode, the reactor would be in a hot shutdown condition (control rods fully inserted) with all reactor vessel head bolts fully tensioned.
The NRC staff recognizes that on entering Mode 3, the decay heat is rapidly decreasing. Steam is initially available for operating the reactor core isolation cooling/high pressure coolant
injection steam turbine-driven pumps until the reactor pressure and thus water temperature is substantially reduced. As the decay heat continues to decrease, operators have increased time and options for achieving adequate water injection using the low-pressure emergency core cooling system to avoid core damage and associated generation of combustible gas.
Therefore, the occurrence of a LOCA leading to degraded core is highly unlikely in Mode 3.
The NRC staff finds the proposed change in Required Action B.1 acceptable because it provides a more appropriate terminal action since it requires the plant to be placed in a mode in which the LCO does not apply and the oxygen concentration limit is no longer required. The previous terminal action allowed an indefinite period of operation at < 15 percent RTP.
Due to the low potential for hydrogen generation when the reactor is in Mode 3, inerting of containment in Mode 3 is not needed. Therefore, the NRC staff concludes the proposed change is acceptable because it continues to protect containment integrity and meets 10 CFR 50.36(c)(2) by providing the lowest functional capability of equipment required for safe operation of the plant.
3.1.5 Proposed Changes in the CT of Condition B In accordance with approved Traveler TSTF-568, Revision 2, the licensee proposed to change the Condition B CT from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, stating that 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is a reasonable time to reduce reactor power from full power conditions to Mode 3 in an orderly manner and without challenging plant systems. The proposed change from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for bringing the reactor to a hot shutdown condition from full power is acceptable to NRC staff because it is not a significant change and is based on industry operating experience.
3.1.6 Conclusion for Proposed Changes to TS 3.6.3.2 The NRC staff concludes the proposed changes in the applicability statement for TS 3.6.3.2 are acceptable since they are more restrictive as the applicability now extends to Modes 1 and 2 without exception. In addition, the occurrence of a LOCA that could lead to degraded core conditions with containment de-inerted, while in Mode 3, is unlikely. Therefore, the changes proposed in TS 3.6.3.2 are acceptable and continue to meet 10 CFR 50.36(c)(2).
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Georgia State official was notified of the proposed issuance of the amendments on August 7, 2020. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements 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 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, which was published in the Federal Register on July 14, 2020 (85 FR 42442), and there has been no public comment on such finding. 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 Commissions 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: John G. Lamb, NRR Date: September 15, 2020
C.
SUBJECT:
EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, ISSUANCE OF AMENDMENTS NOS. 306 AND 251, REGARDING THE APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-568, REVISE APPLICIABILITY OF BWR/4 TS 3.6.2.5 AND TS 3.6.3.2 (EPID L-2020-LLA-0129) DATED SEPTEMBER 15, 2020 DISTRIBUTION PUBLIC LPL2-1 R/F RidsNrrPMHatch Resource (hard copy)
RidsACRS_MailCTR Resource RidsNrrLAKGoldstein Resource RidsRgn2Mail Center Resource RidsNrrDorlLpl2-1 Resource RidsNrrDssStsb Resource Amendment No. ML20202A005
- via email OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA*
NRR/DSS/STSB/BC*
NAME JLamb KGoldstein VCusumano DATE 07/19/2020 08/12/2020 07/24/2020 OFFICE OGC - NLO*
NRR/LPL2-1/BC*
NRR/LPL2-1/PM*
NAME CCarson MMarkley JLamb DATE 08/03/2020 8/10/2020 9/15/2020 OFFICIAL RECORD COPY