ML20294A076
| ML20294A076 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/07/2020 |
| From: | John Lamb Plant Licensing Branch II |
| To: | Gayheart C Southern Nuclear Operating Co |
| Lamb J | |
| References | |
| EPID L-2020-LLA-0194 | |
| Download: ML20294A076 (40) | |
Text
December 7, 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. 308 AND 253, REGARDING APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-582, RPV WIC ENHANCEMENTS (EPID L-2020-LLA-0194)
Dear Ms. Gayheart:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 308 to Renewed Facility Operating License No. DPR-57 and Amendment No. 253 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 August 28, 2020.
Southern Nuclear Operating Company, Inc. (the licensee) requested that the NRC process the proposed amendment under the Consolidated Line Item Improvement Process (CLIIP). The proposed changes revise the TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force (TSTF) Traveler TSTF-582, Revision 0, RPV WIC Enhancements, and the associated NRC staff safety evaluation for TSTF-582.
C. Gayheart A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly 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. 308 to DPR-57
- 2. Amendment No. 253 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. 308 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 August 28, 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 Enclosure 1
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. 308, 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. Digitally signed by Michael T. Markley Markley Date: 2020.12.07 11:40:05
-05'00' 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: December 7, 2020
ATTACHMENT TO LICENSE AMENDMENT NO. 308 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 1.1-3 1.1-3 3.3-44 3.3-44 3.3-45 3.3-45 3.3-46 3.3-46 3.3-70 3.3-70 3.5-7 3.5-7 3.5-8 3.5-8 3.5-9 3.5-9 3.6-9 3.6-9 3.8-22 3.8-22
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. 308 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 Renewed License No. DPR-57 Amendment No. 308
Definitions 1.1 1.1 Definitions (continued)
DRAIN TIME susceptible to a common mode failure, for all penetration flow (continued) paths below the TAF except:
- 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;
- 2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or
- 3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.
- c. The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;
- d. No additional draining events occur; and
- e. Realistic cross-sectional areas and drain rates are used.
A bounding DRAIN TIME may be used in lieu of a calculated value.
(continued)
HATCH UNIT 1 1.1-3 Amendment No. 308
RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.
APPLICABILITY: According to Table 3.3.5.2-1.
ACTIONS
NOTE------------------------------------------------------------
Separate Condition entry is allowed for each channel.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Initiate action to place Immediately inoperable. channel in trip.
OR A.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.
AND A.2.2 Initiate action to Immediately calculate DRAIN TIME.
HATCH UNIT 1 3.3-44 Amendment No. 308
RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS
NOTE-----------------------------------------------------------
These SRs apply to each Function in Table 3.3.5.2-1.
SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program HATCH UNIT 1 3.3-45 Amendment No. 308
RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)
RPV Water Inventory Control Instrumentation APPLICABLE MODES OR OTHER REQUIRED SPECIFIED CHANNELS ALLOWABLE FUNCTION CONDITIONS PER FUNCTION VALUE
- 1. RHR System Isolation
- a. Reactor Vessel Water (a) 2 in one trip system 0 inches Level - Low, Level 3
- 2. Reactor Water Cleanup (RWCU) System Isolation
- a. Reactor Vessel Water (a) 2 in one trip system -47 inches Level - Low Low, Level 2 (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.
HATCH UNIT 1 3.3-46 Amendment No. 308
LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE for each diesel generator (DG) required by LCO 3.8.1, AC Sources - Operating.
APPLICABILITY: When associated DG is required to be OPERABLE by LCO 3.8.1.
ACTIONS
NOTE--------------------------------------------------------------
Separate Condition entry is allowed for each channel.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore channel to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> channels inoperable. OPERABLE status.
B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.
Time not met.
HATCH UNIT 1 3.3-70 Amendment No. 308
RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.3 Verify required standby gas 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> treatment (SGT) subsystem(s) are capable of being placed in operation in less than the DRAIN TIME.
D. DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. D.1 ------------NOTE---------
Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.
Initiate action to establish Immediately an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
AND D.2 Initiate action to establish Immediately secondary containment boundary.
AND D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.
AND D.4 Initiate action to verify Immediately required SGT subsystem(s) are capable of being placed in operation.
(continued)
HATCH UNIT 1 3.5-7 Amendment No. 308
RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to 36 Time of Condition C or D hours.
not met.
OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required LPCI subsystem, the In accordance with suppression pool water level is 146 inches. the Surveillance Frequency Control Program SR 3.5.2.3 Verify, for a required Core Cpray (CS) subsystem, In accordance with the: the Surveillance Frequency Control
- a. Suppression pool water level is Program 146 inches; or
- b. Condensate storage tank water level is 13 ft.
(continued)
HATCH UNIT 1 3.5-8 Amendment No. 308
RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, locations susceptible to gas the Surveillance accumulation are sufficiently filled with water. Frequency Control Program SR 3.5.2.5 Deleted SR 3.5.2.6 ---------------------------NOTES------------------------------
- 1. Operation may be through the test return line.
- 2. Credit may be taken for normal system operation to satisfy this SR.
Operate the required ECCS injection/spray In accordance with subsystem for 10 minutes. the Surveillance Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically In accordance with isolating a penetration flow path actuates to the the Surveillance isolation position on an actual or simulated Frequency Control isolation signal. Program SR 3.5.2.8 ---------------------------NOTE--------------------------------
Vessel injection/spray may be excluded.
Verify the required ECCS injection/spray In accordance with subsystem can be manually operated. the Surveillance Frequency Control Program HATCH UNIT 1 3.5-9 Amendment No. 308
PCIVs 3.6.1.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. ---------------NOTE------------- C.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> except for Only applicable to penetration flow path by excess flow check penetration flow paths with use of at least one valve (EFCV) line and only one PCIV. closed and de-activated penetrations with a
automatic valve, closed closed system manual valve, or blind One or more penetration flange. AND flow paths with one PCIV inoperable except due to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for leakage not within limits. AND EFCV line and penetrations with a C.2 -----------NOTES---------- closed system
- 1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.
- 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.
Verify the affected Once per 31 days penetration flow path is isolated.
D. One or more penetration D.1 Restore leakage to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> flow paths with leakage not within limit.
within limit.
E. Required Action and E.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 /> associated Completion Time of Condition A, B, C, AND or D not met.
E.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> HATCH UNIT 1 3.6-9 Amendment No. 308
AC Sources - Shutdown 3.8.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Suspend CORE Immediately DG(s) inoperable. ALTERATIONS.
AND B.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.
AND B.3 Initiate action to restore Immediately required DG(s) to OPERABLE status.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 -----------------------------NOTE------------------------------
The following SRs are not required to be performed: SR 3.8.1.2.b, SR 3.8.1.7, SR 3.8.1.8, SR 3.8.1.12, and SR 3.8.1.14.
The following SRs are applicable for AC sources In accordance with required to be OPERABLE: applicable SRs SR 3.8.1.1 SR 3.8.1.4 SR 3.8.1.12 SR 3.8.1.2 SR 3.8.1.7 SR 3.8.1.14 SR 3.8.1.3 SR 3.8.1.8 SR 3.8.1.19 SR 3.8.2.2 For required Unit 2 AC sources, SR 3.8.2.1 of In accordance with Unit 2 Specification 3.8.2 is applicable. Unit 2 SR 3.8.2.1 HATCH UNIT 1 3.8-22 Amendment No. 308
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. 253 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 August 28, 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 Enclosure 2
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. 253 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. Digitally signed by Michael T. Markley Markley Date: 2020.12.07 11:42:10 -05'00' 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: December 7, 2020
ATTACHMENT TO LICENSE AMENDMENT NO. 253 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 1.1-3 1.1-3 3.3-44 3.3-44 3.3-45 3.3-45 3.3-46 3.3-46 3.3-70 3.3-70 3.5-8 3.5-8 3.5-9 3.5-9 3.5-10 3.5-10 3.6-9 3.6-9 3.8-22 3.8-22
(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. 253 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.
Renewed License No. NPF-5 Amendment No. 253
Definitions 1.1 1.1 Definitions (continued)
DRAIN TIME susceptible to a common mode failure, for all penetration flow (continued) paths below the TAF except:
- 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;
- 2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to the TAF when actuated by RPV water level isolation instrumentation; or
- 3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the TAF by a dedicated operator trained in the task, who in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.
- c. The penetration flow paths required to be evaluated per paragraph b) are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory;
- d. No additional draining events occur; and
- e. Realistic cross-sectional areas and drain rates are used.
A bounding DRAIN TIME may be used in lieu of a calculated value.
(continued)
HATCH UNIT 2 1.1-3 Amendment No. 253
RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.
APPLICABILITY: According to Table 3.3.5.2-1.
ACTIONS
NOTE------------------------------------------------------------
Separate Condition entry is allowed for each channel.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Initiate action to place Immediately inoperable. channel in trip.
OR A.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.
AND A.2.2 Initiate action to calculate Immediately DRAIN TIME.
HATCH UNIT 2 3.3-44 Amendment No. 253
RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS
NOTES------------------------------------------------------------
These SRs apply to each Function in Table 3.3.5.2-1.
SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program HATCH UNIT 2 3.3-45 Amendment No. 253
RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 1)
RPV Water Inventory Control Instrumentation APPLICABLE MODES OR OTHER REQUIRED SPECIFIED CHANNELS ALLOWABLE FUNCTION CONDITIONS PER FUNCTION VALUE
- 1. RHR System Isolation
- a. Reactor Vessel Water (a) 2 in one trip system 0 inches Level - Low Level 3
- 2. Reactor Water Cleanup (RWCU) System Isolation
- a. Reactor Vessel Water (a) 2 in one trip system -47 inches Level - Low Low, Level 2 (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.
HATCH UNIT 2 3.3-46 Amendment No. 253
LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE for each diesel generator (DG) required by LCO 3.8.1, AC Sources - Operating.
APPLICABILITY: When associated DG is required to be OPERABLE by LCO 3.8.1.
ACTIONS
NOTE--------------------------------------------------------------
Separate Condition entry is allowed for each channel.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore channel to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> channels inoperable. OPERABLE status.
B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.
Time not met.
HATCH UNIT 2 3.3-70 Amendment No. 253
RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) AND C.3 Verify required standby 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> gas treatment (SGT) subsystem(s) are capable of being placed in operation in less than the DRAIN TIME.
D. DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. D.1 ------------NOTE-----------
Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.
Initiate action to Immediately establish an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
AND D.2 Initiate action to Immediately establish secondary containment boundary.
AND D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.
(continued)
HATCH UNIT 2 3.5-8 Amendment No. 253
RPV Water Inventory Control 3.5.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. (continued) AND D.4 Initiate action to verify Immediately required SGT subsystem(s) are capable of being placed in operation.
E. Required Action and E.1 Initiate actin to restore Immediately associated Completion DRAIN TIME to 36 Time of Condition C or D hours.
not met.
OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. In accordance with the Surveillance Frequency Control Program SR 3.5.2.2 Verify, for a required LPCI subsystem, the In accordance with suppression pool water level is 146 inches. the Surveillance Frequency Control Program SR 3.5.2.3 Verify, for a required Core Spray (CS) subsystem, In accordance with the: the Surveillance Frequency Control
- a. Suppression pool water level is Program 146 inches; or
- b. Condensate storage tank water level is 15 ft.
(continued)
HATCH UNIT 2 3.5-9 Amendment No. 253
RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, locations susceptible to gas the Surveillance accumulation are sufficiently filled with water. Frequency Control Program SR 3.5.2.5 Deleted.
SR 3.5.2.6 ---------------------------NOTES------------------------------
- 1. Operation may be through the test return line.
- 2. Credit may be taken for normal system operation to satisfy this SR.
Operate the required ECCS injection/spray In accordance with subsystem for 10 minutes. the Surveillance Frequency Control Program SR 3.5.2.7 Verify each valve credited for automatically In accordance with isolating a penetration flow path actuates to the the Surveillance isolation position on an actual or simulated Frequency Control isolation signal. Program SR 3.5.2.8 ---------------------------NOTE-------------------------------
Vessel injection/spray may be excluded.
Verify the required ECCS injection/spray In accordance with subsystem can be manually operated. the Surveillance Frequency Control Program HATCH UNIT 2 3.5-10 Amendment No. 253
PCIVs 3.6.1.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C. --------------NOTE--------------- C.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> except for Only applicable to penetration flow path by excess flow check penetration flow paths with use of at least one valve (EFCV) line and only one PCIV. closed and de-activated penetrations with a
automatic valve, closed closed system manual valve, or blind One or more penetration flange. AND flow paths with one PCIV inoperable except due to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for leakage not within limits. AND EFCV line and penetrations with a C.2 ----------NOTES----------- closed system
- 1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.
- 2. Isolation devices that are locked, sealed, or otherwise secured may be verified by administrative means.
Verify the affected Once per 31 days penetration flow path is isolated.
D. One or more penetration D.1 Restore leakage to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> flow paths with leakage not within limit.
within limit.
E. Required Action and E.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 /> associated Completion Time of Condition A, B, C, AND or D not met.
E.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> HATCH UNIT 2 3.6-9 Amendment No. 253
AC Sources - Shutdown 3.8.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. One or more required B.1 Suspend CORE Immediately DG(s) inoperable. ALTERATIONS.
AND B.2 Suspend movement of Immediately irradiated fuel assemblies in secondary containment.
AND B.3 Initiate action to restore Immediately required DG(s) to OPERABLE status.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 ---------------------------NOTE--------------------------------
The following SRs are not required to be performed: SR 3.8.1.2.b, SR 3.8.1.7, SR 3.8.1.8, SR 3.8.1.12, and SR 3.8.1.14.
The following SRs are applicable for AC sources In accordance with required to be OPERABLE: applicable SRs SR 3.8.1.1 SR 3.8.1.4 SR 3.8.1.12 SR 3.8.1.2 SR 3.8.1.7 SR 3.8.1.14 SR 3.8.1.3 SR 3.8.1.8 SR 3.8.1.19 SR 3.8.2.2 For required Unit 1 AC sources, SR 3.8.2.1 of In accordance with Unit 1 Specification 3.8.2 is applicable. Unit 1 SR 3.8.2.1 HATCH UNIT 2 3.8-22 Amendment No. 253
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 308 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-57 AND AMENDMENT NO. 253 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
Southern Nuclear Operating Company (SNC, the licensee) requested changes to the technical specifications (TSs) for Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2 by license amendment request (LAR), dated August 28, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20241A240). In its application, the licensee requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) process the proposed LAR under the Consolidate Line Item Improvement Process (CLIIP). The proposed changes would revise the TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force (TSTF)-582, Revision 0, RPV WIC Enhancements, (TSTF-582) (ADAMS Accession No. ML19240A260) and the associated NRC staff safety evaluation (SE) of TSTF-582 (ADAMS Accession No. ML20219A333).
The boiling water reactor (BWR) RPV design includes multiple penetrations located below the top of active fuel (TAF). These penetrations provide entry for control rods, recirculation flow, reactor water cleanup (RWCU), and shutdown cooling. Since these penetrations are below the TAF, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling. The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release. Drain Time is the time it would take for the water inventory in and above the RPV to drain to the TAF.
1.1 Proposed TS Changes to Adopt TSTF-582 In accordance with NRC approved TSTF-582, the licensee proposed changes that would revise the TSs related to RPV WIC to incorporate operating experience and to correct errors and omissions that the licensee incorporated into the Hatch TSs when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (ADAMS Accession No. ML16074A448).
Specifically, the licensee proposed the following changes to adopt TSTF-582:
Enclosure 3
The Drain Time definition in TS 1.1 would be revised to move the examples of common mode failure mechanisms to the Bases and delete seismic events.
In TS 1.1, Drain Time definition, the exception from considering the Drain Time for penetration flow paths isolated with manual or automatic valves that are that are locked, sealed, or otherwise secured would be revised to apply the exception for manual or automatic valves that are closed and administratively controlled.
The Actions of TS 3.3.5.2 would be revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.
TS 3.3.5.2, Required Action B.2 requires calculating Drain Time with a Completion Time of immediately. The Required Action would be renumbered as A.2.2 and revised to state, Initiate action to calculate Drain Time.
In TS 3.5.2, the first use of the acronym SGT [standby gas treatment] would be defined in Required Action C.3 and the acronym SGT would be used in Required Action D.4.
TS 3.5.2 and TS 3.3.5.2 would be revised to eliminate the requirement for a manual emergency core cooling system (ECCS) initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start. TS 3.5.2 Surveillance Requirements (SRs) related to manual initiation using the ECCS signal (such as verifying automatic alignment of valves on an initiation signal) would be eliminated. Related to this change, the TS 3.3.5.2 functions, Surveillance Requirements, and Actions that only support manual initiation using an ECCS signal (including interlocks and minimum flow instruments) would be eliminated.
A redundant definition of LPCI [low pressure coolant injection] in SR 3.5.2.2 would be eliminated.
Surveillance Requirement (SR) 3.5.2.6, that requires operating the required ECCS injection/spray subsystem for at least 10 minutes through the recirculation line, would be modified by the addition of two notes. The first Note would replace the existing SR that the ECCS subsystem be run through the recirculation line with a Note that states that operation may be through the test return line. The second Note would permit crediting normal operation of the low-pressure ECCS subsystem for performance of the SR.
TS 3.8.2, AC [Alternating Current] Sources - Shutdown, SR 3.8.2.1, would be revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and 5. TSTF-542 eliminated the automatic ECCS initiation in Modes 4 and 5.
1.2 Additional Proposed TS Changes 1.2.1 Proposed TS Changes to Adopt TSTF-583-T The licensee proposed to make the following changes in accordance with TSTF-583-T, TSTF-582 Diesel Generator Variation (ADAMS Accession No. ML20248H330):
TS 3.3.8.1, Loss of Power (LOP) Instrumentation, would be revised to delete and LCO 3.8.2, AC Sources - Shutdown and add to by LCO 3.8.1. to the Applicability of LCO 3.3.8.1.
SR 3.8.2.1 would be revised to add SR 3.8.1.6, SR 3.8.1.15, and SR 3.8.2.18 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1. The format of SR 3.8.2.1 would also be restructured to list the SRs that are still applicable, instead of listing the SRs that are not applicable.
1.2.2 Editorial Variations The licensee noted that Hatch TSs have different numbering than standard technical specifications (STSs) for the RPV WIC related TS. Specifically:
o Hatch TS 3.6.1.3 Condition E. corresponds to the STS 3.6.1.3 Condition F.
o Hatch TS 3.8.2 Surveillance Requirement (SR) 3.8.2.1 NOTE contains changes to SR 3.8.1.9, SR 3.8.1.11, and SR 3.8.1.17 which correspond to the STS SR 3.8.2.1 changes to SR 3.8.1.11, SR 3.8.1.13, and SR 3.8.1.19, respectively.
o Hatch TS 3.8.2 SR 3.8.2.1 contains additions of SR 3.8.1.9, SR 3.8.1.10, SR 3.8.1.11, and SR 3.8.1.17 which correspond to the STS SR 3.8.2.1 additions of SR 3.8.1.11, SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.19, respectively.
The licensee proposed to identify TS SR 3.5.2.5 as Deleted in order to avoid renumbering SRs 3.5.2.6, 3.5.2.7, and 3.5.2.8.
The licensee proposed to delete Footnote (c) to the Table 3.3.5.2-1 LPCI low pressure coolant injection pump discharge flow - low (bypass) Function 2.b.
2.0 REGULATORY EVALUATION
The regulation at 10 CFR 50.36(c)(2) requires that TSs include LCOs. Per 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation also requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.
The regulation at 10 CFR 50.36(c)(3) requires that TSs include items in the category of SRs, which 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 LCOs will be met.
The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the Standard Technical Specifications, General Electric, BWR/4 Plants, NUREG 1433,
Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193), as modified by NRC-approved travelers.
Traveler TSTF-582 revised the STSs related to RPV WIC to incorporate operating experience and to correct editorial errors in TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (ADAMS Accession No. ML16074A448). The NRC approved TSTF-542, Revision 2, on December 20, 2016 (ADAMS Package Accession No. ML16343B066). The NRC staff approved TSTF-582 under the CLIIP in letter dated August 13, 2020 (ADAMS Accession No. ML20219A333). The TSTF-582 SE states that a licensee may adopt the STS changes approved in TSTF-582, if the licensee has already adopted the STS changes approved in TSTF-542.
3.0 TECHNICAL EVALUATION
3.1 Proposed TS Changes to Adopt TSTF-582 The NRC staff compared the licensees proposed TS changes in Section 1.0 of this SE against the changes approved in TSTF-582. In accordance with the SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-582 are applicable to Hatch, Units 1 and 2, TSs because Hatch is a BWR/4 design and the NRC staff approved the TSTF-582 changes for BWR/4 designs. The licensee meets the TSTF-582 SE provision for adoption of TSTF-582 since the licensee adopted Traveler TSTF-542 on May 31, 2018 (ADAMS Accession No. ML18123A368) in Amendment Nos. 290 and 235, for Hatch, Units 1 and 2. Therefore, the NRC staff concludes that the licensees proposed changes to the Hatch TSs in Section 1.0 of this SE are acceptable in that they are consistent with TSTF-582 and the terms for use stated in the NRC staffs SE of TSTF-582.
The NRC staff finds that proposed changes to the TS 1.1 definition and LCOs 3.3.5.2, 3.5.2, and 3.8.2 correctly specify the lowest functional capability or performance levels of equipment required for safe operation of the facility in accordance with 10 CFR 50.36(c)(2)(i). Also, the NRC staff finds that proposed changes to the Actions of LCOs 3.3.5.2A, 3.3.5.2B, 3.3.8.1, 3.5.2, 3.6.1.3, and 3.8.2 are adequate remedial actions to be taken until each LCO can be met provide protection to the health and safety of the public, thereby satisfying 10 CFR 50.36(c)(2)(i).
The NRC staff finds that the proposed revisions to the SRs in TS 3.3.5.2, 3.5.2, 3.6.1.3, and 3.8.2 continue to provide 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 LCOs will be met in accordance with 10 CFR 50.36(c)(3).
Thus, the proposed changes continue to meet the requirements of 10 CFR 50.36(c)(2)(i) and 10 CFR 50.36(c)(3) as discussed in Section 3.0 of the NRC staffs SE of TSTF-582.
3.2.1 Proposed TS Changes to Adopt TSTF-583-T Refer to Section 1.2 of this SE for proposed changes.
3.2.1.1 TS 3.3.8.1, Applicability The licensee stated that TS 3.8.2 does not require automatic start and loading of a DG within 12 seconds on an ECCS initiation signal or a loss of offsite power signal. Currently, TS 3.3.8.1, Loss of Power (LOP) Instrumentation, is applicable in Modes 1, 2, and 3, and when the
associated DG is required to be operable by TS 3.8.2. The NRC staff confirmed that TS 3.8.2 no longer requires automatic start and loading of a DG on an LOP signal. The NRC staff finds it acceptable to revise the Applicability of LCO 3.3.8.1 by deleting When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown, because the LOP instrumentation that generates the LOP signal does not need to be operable when the DG is required to be operable by TS 3.8.2. Therefore, the NRC staff concludes that the LCO applicability changes will continue to provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility and, therefore, meet the LCO requirements of 10 CFR 50.36(c)(2).
3.2.1.2 SR 3.8.2.1 LCO 3.8.2, AC Sources - Shutdown, requires one offsite circuit and one DG capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8, Distribution Systems-Shutdown, to be operable in shutdown conditions. The existing SR 3.8.2.1 lists the TS 3.8.1 SRs that are applicable in shutdown conditions with some exceptions.
TS SR 3.8.1.7 and SR 3.8.1.15 require that the DG starts from standby or hot conditions, respectively, and achieve required voltage and frequency within 12 seconds and required steady state voltage and frequency ranges. The 12-second start requirement associated with the DG automatic start supports the assumptions in the design basis LOCA analysis. The NRC staff confirmed that 12-second timing is not required during a manual DG start to respond to a draining event, which has a minimum Drain Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. In addition, SR 3.8.1.2, which requires the DG to start from standby conditions and achieve the required steady state voltage and frequency ranges, is applicable under SR 3.8.2. The NRC staff finds that the SR 3.8.1.7 and SR 3.8.1.15 testing for the DGs capability to achieve required steady state voltage and frequency ranges will be performed in SR 3.8.1.2 since SR 3.8.1.2 provides the test for this DG capability. Therefore, the NRC staff finds it acceptable to add SR 3.8.1.7 and SR 3.8.1.15 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.
TS SR 3.8.1.16 states, Verify interval between each sequenced load block is within
+/- 10% of design interval for each load sequencer timing device. This SR verifies the 10-percent load sequence time interval tolerance between each sequenced load block when loads are sequentially connected to the engineered safety features (ESF) bus by an automatic sequencer relay logic schemes that perform a function equivalent to a load sequencer while the DG is tied to the ESF bus. TS 3.5.2 requires manual starting of the equipment for water injection to respond to a draining event so that the DG will be manually loaded during a draining event. No other postulated events require automatic loading of the DG during shutdown conditions. The NRC staff confirmed that with respect to SR 3.8.16, the load sequencer relay logic schemes that perform a function equivalent to a load sequencer are used for the automatic loading of the DG and are not used during a manual loading of the DG. Therefore, the NRC staff finds it acceptable to add SR 3.8.1.16 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.
Additionally, the licensee proposed to recast SR 3.8.2.1 from a listing of exceptions (i.e., a list of TS 3.8.1 SRs that do not need to be performed) to a listing the SRs that need to be performed to demonstrate the operability of the offsite and onsite AC power sources during shutdown conditions. The NRC staff confirmed that the list of SRs that need to be performed during shutdown conditions are correctly listed in SR 3.8.2.1. The NRC staff finds that the proposed revision of SR 3.8.2.1 is acceptable because it is an editorial clarification and does not
substantively change TS requirements.
The NRC staff finds that the proposed changes to revise SR 3.8.2.1 are acceptable because the remaining applicable SRs will continue to demonstrate the operability of the required AC power sources and, as such, ensure the availability of the AC power required to operate the plant in a safe manner and mitigate postulated events during shutdown conditions. Therefore, the NRC staff finds the proposed changes to SR 3.8.2.1 are acceptable because the changes continue to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the associated LCO will continue to be met in accordance with 10 CFR 50.36(c)(3).
3.2.2 Editorial The licensee noted that Hatch TSs have different numbering than STS for the RPV WIC related TS. The NRC staff finds that the different TS numbering changes are acceptable, because they are editorial clarifications and do not substantively change TS requirements.
The licensee proposed to identify TS SR 3.5.2.5 as Deleted in order to avoid renumbering SRs 3.5.2.6, 3.5.2.7, and 3.5.2.8. The NRC staff finds this variation acceptable because it is editorial and does not substantively change the TS requirements.
The licensee proposed to delete Footnote (c) to the Table 3.3.5.2-1 LPCI low pressure coolant injection pump discharge flow - low (bypass) Function 2.b. The footnote states Function not required to be OPERABLE while associated pump is operating in decay heat removal when minimum flow valve is closed and deactivated. The NRC staff finds this change acceptable because it is editorial and does not substantively change the TS requirements. TSTF-582 deletes the requirements for Function 2.b, therefore the footnote is no longer needed.
Finally, the NRC staff reviewed the proposed TS changes for technical clarity and consistency with the existing requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with Chapter 16 of the SRP and are therefore acceptable.
4.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
The NRCs regulation in 10 CFR 50.92(c) states that the NRC may make a final determination, under the procedures in 10 CFR 50.91, that a license amendment involves no significant hazards consideration if operation of the facility, in accordance with the amendment, would not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
An evaluation of the issue of no significant hazards consideration is presented below:
SNC has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control.
Draining of RPV water inventory in Mode 4 (i.e., cold shutdown) and Mode 5 (i.e., refueling) is not an accident previously evaluated and, therefore, revising the existing TS controls to prevent or mitigate such an event has no effect on any accident previously evaluated. RPV water inventory control in Mode 4 or Mode 5 is not an initiator of any accident previously evaluated. The existing and revised TS controls are not mitigating actions assumed in any accident previously evaluated.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control.
The event of concern under the current requirements and the proposed change is an unexpected draining event. The TS have contained requirements related to an unexpected draining event during shutdown for over 40 years and this event does not appear as an analyzed event in the Updated Final Safety Analysis Report (UFSAR) for any plant or in the NRC's Standard Review Plan (NUREG-0800). Therefore, an unexpected draining event is not a new or different kind of accident not considered in the design and licensing bases that would have been considered a design basis accident in the UFSAR had it been previously identified.
None of the equipment affected by the proposed change has a design function described in the UFSAR to mitigate an unexpected draining event in Modes 4 or 5, although the equipment may be used for that purpose.
Therefore, the proposed amendment will not change the design function of the affected equipment. The proposed change will affect the operation of certain equipment, such as the manual initiation function and related instrumentation to permit initiation of the required ECCS injection/spray subsystem, and the control of valves credited for preventing a draining event.
However, these changes provide adequate protection to prevent or mitigate an unexpected draining event and do not create the possibility of a new or different kind of accident due to credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change incorporates operating experience and corrects errors and omissions that were incorporated into the plant TS when adopting TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control.
The safety basis for the RPV WIC requirements is to protect Safety Limit 2.1.1.3. The proposed change does not affect any specific values that define a safety margin as established in the licensing basis. The proposed change does not affect a design basis or safety limit, or any controlling value for a parameter established in the UFSAR or the license. Therefore, the proposed change does not significantly reduce the margin of safety.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above evaluation, the NRC staff concludes that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff has made a final determination that no significant hazards consideration is involved for the proposed amendment and that the amendment should be issued as allowed by the criteria contained in 10 CFR 50.91.
5.0 STATE CONSULTATION
In accordance with the Commissions regulations, the State of Georgia official was notified of the proposed issuance of the amendment on October 18, 2020. The State official had no comments.
6.0 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 published in the Federal Register on November 3, 2020 (85 FR 69656). 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 amendments.
7.0 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 Contributor: Tarico Sweat, NRR Date: December 7, 2020
ML20294A076 *via email **via memo OFFICE NRR/DORL/LPL2-1/PM* NRR/DORL/LPL2-1/LA* NRR/DSS/STSB/BC**
NAME JLamb KGoldstein (JBurkhardt for) VCusumano DATE 11/03/2020 10/21/2020 11/12/2020 OFFICE OGC (NLO)* NRR/DORL/LPL2-1/BC* NRR/DORL/LPL2-1/PM*
NAME JScro MMarkley JLamb DATE 12/1/2020 12/7/2020 12/7/2020