ML20322A428
| ML20322A428 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/06/2021 |
| From: | Scott Wall Plant Licensing Branch III |
| To: | Gebbie J Indiana Michigan Power Co |
| Wall S | |
| References | |
| EPID L-2020-LLA-0109, GSI-191 | |
| Download: ML20322A428 (31) | |
Text
January 6, 2021 Mr. Joel P. Gebbie Senior Vice President and Chief Nuclear Officer Indiana Michigan Power Company Nuclear Generation Group One Cook Place Bridgman, MI 49106
SUBJECT:
DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS NOS. 355 AND 335 REGARDING REVISION TO TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATION TASK FORCE TRAVELER 567, REVISION 1, ADD CONTAINMENT SUMP TS TO ADDRESS
[GENERIC SAFETY ISSUES] GSI-191 ISSUES (EPID L-2020-LLA-0109)
Dear Mr. Gebbie:
The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment Nos. 355 and 335 to Renewed Facility Operating License Nos. DPR-58 and DPR-74, for the Donald C. Cook Nuclear Plant (CNP), Unit Nos. 1 and 2, respectively. The amendments consist of changes to the License and Technical Specifications (TSs) in response to your application dated April 30, 2020.
The amendments revise certain TSs to adopt Traveler Technical Specification Task Force (TSTF)-567, Add Containment Sump TS to Address GSl-191 Issues.
A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Scott P. Wall, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-315 and 50-316
Enclosures:
- 1. Amendment No. 355 to DPR-58
- 2. Amendment No. 335 to DPR-74
- 3. Safety Evaluation cc: Listserv
INDIANA MICHIGAN POWER COMPANY DOCKET NO. 50-315 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 355 License No. DPR-58
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Indiana Michigan Power Company dated April 30, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-58 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 355, are hereby incorporated in this license. The licensee 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 90 days of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: January 6, 2021 Nancy L.
Salgado Digitally signed by Nancy L. Salgado Date: 2021.01.06 15:19:27 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 355 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE DOCKET NO. 50-315 Renewed Facility Operating License No. DPR-58 Replace the following page of the Renewed Facility Operating License No. DPR-58 with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.
REMOVE INSERT Technical Specifications Replace the following page of the Renewed Facility Operating License, Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.
REMOVE INSERT 3.5.2-3 3.5.2-3 3.5.3-2 3.5.3-2 3.6.15-1 3.6.15-2 3.6.15-3 Renewed License No. DPR-58 Amendment No:
354, 355 and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)
Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; and (5)
Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:
Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not to exceed 3304 megawatts thermal in accordance with the conditions specified herein.
(2)
Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 355, are hereby incorporated in this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Less than Four Loop Operation The licensee shall not operate the reactor at power levels above P-7 (as defined in Table 3.3.1-1 of Specification 3.3.1 of Appendix A to this renewed operating license) with less than four reactor coolant loops in operation until (a) safety analyses for less than four loop operation have been submitted, and (b) approval for less than four loop operation at power levels above P-7 has been granted by the Commission by amendment of this license.
(4)
Fire Protection Program Indiana Michigan Power Company shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensees amendment request dated July 1, 2011, as supplemented by letters dated September 2, 2011, April 27, 2012, June 29, 2012, August 9, 2012, October 15, 2012, November 9, 2012, January 14, 2013, February 1, 2013,
ECCS - Operating 3.5.2 Cook Nuclear Plant Unit 1 3.5.2-3 Amendment No. 287, 299, 331, 334, 355 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.2.6 Verify, for each ECCS throttle valve listed below, each position stop is in the correct position.
Valve Number 1-SI-121 N 1-SI-121 S 1-SI-141 L1 1-SI-141 L2 1-SI-141 L3 1-SI-141 L4 In accordance with the Surveillance Frequency Control Program SR 3.5.2.7 DELETED SR 3.5.2.8 Verify ECCS locations susceptible to gas accumulation are sufficiently filled with water.
In accordance with the Surveillance Frequency Control Program
ECCS - Shutdown 3.5.3 Cook Nuclear Plant Unit 1 3.5.3-2 Amendment No. 287, 331, 355 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1
NOTE------------------------------
For SR 3.5.2.2, the SR is modified to allow the valves to not be in the correct position, provided they can be aligned to the correct position.
The following SRs are applicable for all equipment required to be OPERABLE:
SR 3.5.2.2, SR 3.5.2.6, and SR 3.5.2.3, SR 3.5.2.8 In accordance with applicable SRs
Containment Recirculation Sump 3.6.15 Cook Nuclear Plant Unit 1 3.6.15-1 Amendment No. 355 3.6 CONTAINMENT SYSTEMS 3.6.15 Containment Recirculation Sump LCO 3.6.15 The containment recirculation sump shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment recirculation sump inoperable due to containment accident generated and transported debris exceeding the analyzed limits.
A.1 Initiate action to mitigate containment accident generated and transported debris.
AND A.2 Perform SR 3.4.13.1.
AND A.3 Restore the containment recirculation sump to OPERABLE status.
Immediately Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 90 days (continued)
Containment Recirculation Sump 3.6.15 Cook Nuclear Plant Unit 1 3.6.15-2 Amendment No. 355 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. Containment recirculation sump inoperable for reasons other than Condition A.
B.1
NOTES-------------
- 1. Enter applicable Conditions and Required Actions of LCO 3.5.2, ECCS - Operating, and LCO 3.5.3 ECCS -
Shutdown, for emergency core cooling trains made inoperable by the containment recirculation sump.
- 2. Enter applicable Conditions and Required Actions of LCO 3.6.6, Containment Spray System, for containment spray trains made inoperable by the containment sump.
Restore the containment recirculation sump to OPERABLE status.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> C. Required Action and associated Completion Time not met.
C.1 Be in MODE 3.
AND C.2 Be in MODE 5.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours
Containment Recirculation Sump 3.6.15 Cook Nuclear Plant Unit 1 3.6.15-3 Amendment No. 355 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.15.1 Verify, by visual inspection, the containment recirculation sump does not show structural damage, abnormal corrosion, or debris blockage.
In accordance with the Surveillance Frequency Control Program
INDIANA MICHIGAN POWER COMPANY DOCKET NO. 50-316 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 335 License No. DPR-74
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Indiana Michigan Power Company dated April 30, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-74 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 335, are hereby incorporated into this license. The licensee 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 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: January 6, 2021 Nancy L.
Salgado Digitally signed by Nancy L. Salgado Date: 2021.01.06 15:21:56 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 335 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE DOCKET NO. 50-316 Renewed Facility Operating License No. DPR-74 Replace the following page of the Renewed Facility Operating License No. DPR-74 with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.
REMOVE INSERT Technical Specifications Replace the following page of the Renewed Facility Operating License, Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the area of change.
REMOVE INSERT 3.5.2-3 3.5.2-3 3.5.3-2 3.5.3-2 3.6.15-1 3.6.15-2 3.6.15-3 Renewed License No. DPR-74 Amendment No. 334, 335 and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)
Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components; and (5)
Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.
This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:
Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not to exceed 3468 megawatts thermal in accordance with the conditions specified herein and in Attachment 1 to the renewed operating license. The preoperational tests, startup tests and other items identified in to this renewed operating license shall be completed. is an integral part of this renewed operating license.
(2)
Technical Specifications The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 335, are hereby incorporated in this license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Additional Conditions (a) Deleted by Amendment No. 76 (b) Deleted by Amendment No. 2 (c) Leak Testing of Emergency Core Cooling System Valves Indiana Michigan Power Company shall prior to completion of the first inservice testing interval leak test each of the two valves in series in the
ECCS - Operating 3.5.2 Cook Nuclear Plant Unit 2 3.5.2-3 Amendment No. 269, 282, 312, 316, 335 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.2.6 Verify, for each ECCS throttle valve listed below, each position stop is in the correct position.
Valve Number 2-SI-121 N 2-SI-121 S 2-SI-141 L1 2-SI-141 L2 2-SI-141 L3 2-SI-141 L4 In accordance with the Surveillance Frequency Control Program SR 3.5.2.7 DELETED SR 3.5.2.8 Verify ECCS locations susceptible to gas accumulation are sufficiently filled with water.
In accordance with the Surveillance Frequency Control Program
ECCS - Shutdown 3.5.3 Cook Nuclear Plant Unit 2 3.5.3-2 Amendment No. 269, 312, 335 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1
NOTE------------------------------
For SR 3.5.2.2, the SR is modified to allow the valves to not be in the correct position, provided they can be aligned to the correct position.
The following SRs are applicable for all equipment required to be OPERABLE:
SR 3.5.2.2, SR 3.5.2.6, and SR 3.5.2.3, SR 3.5.2.8 In accordance with applicable SRs
Containment Recirculation Sump 3.6.15 Cook Nuclear Plant Unit 2 3.6.15-1 Amendment No. 335 3.6 CONTAINMENT SYSTEMS 3.6.15 Containment Recirculation Sump LCO 3.6.15 The containment recirculation sump shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3, and 4.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment recirculation sump inoperable due to containment accident generated and transported debris exceeding the analyzed limits.
A.1 Initiate action to mitigate containment accident generated and transported debris.
AND A.2 Perform SR 3.4.13.1.
AND A.3 Restore the containment recirculation sump to OPERABLE status.
Immediately Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 90 days (continued)
Containment Recirculation Sump 3.6.15 Cook Nuclear Plant Unit 2 3.6.15-2 Amendment No. 335 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. Containment recirculation sump inoperable for reasons other than Condition A.
B.1
NOTES-------------
- 1. Enter applicable Conditions and Required Actions of LCO 3.5.2, ECCS - Operating, and LCO 3.5.3 ECCS -
Shutdown, for emergency core cooling trains made inoperable by the containment sump.
- 2. Enter applicable Conditions and Required Actions of LCO 3.6.6, Containment Spray System, for containment spray trains made inoperable by the containment recirculation sump.
Restore the containment recirculation sump to OPERABLE status.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> C. Required Action and associated Completion Time not met.
C.1 Be in MODE 3.
AND C.2 Be in MODE 5.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours
Containment Recirculation Sump 3.6.15 Cook Nuclear Plant Unit 2 3.6.15-3 Amendment No. 335 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.15.1 Verify, by visual inspection, the containment recirculation sump does not show structural damage, abnormal corrosion, or debris blockage.
In accordance with the Surveillance Frequency Control Program
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 355 AND 335 TO RENEWED FACILITY OPERATING LICENSE NOS. DPR-58 AND DPR-74 INDIANA MICHIGAN POWER COMPANY DONALD C. COOK NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-315 AND 50-316
1.0 INTRODUCTION
By application dated April 30, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20132A110), Indiana Michigan Power Company (I&M, the licensee), submitted a license amendment request (LAR) for the Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2 (CNP).
The amendment would revise Technical Specification (TS) 3.5.2, ECCS [emergency core cooling system] - Operating, and TS 3.5.3, ECCS - Shutdown. The proposed changes would also add a new TS 3.6.15, Containment Recirculation Sump, to TS Section 3.6, Containment Systems. The proposed changes are based on Technical Specifications Task Force (TSTF)
Traveler TSTF-567, Revision 1, Add Containment Sump TS to Address GSI [Generic Safety Issue]-191 Issues, dated August 2, 2017 (ADAMS Accession No. ML17214A813). The U.S.
Nuclear Regulatory Commission (NRC or the Commission) issued a final safety evaluation (SE) approving TSTF-567, Revision 1, on July 3, 2018 (ADAMS Accession No. ML18116A606).
The licensee has proposed variations from the TS changes described in TSTF-567, Revision 1.
The variations are described in Section 2.2.4 of this SE and evaluated in Section 3.4 of this SE.
2.0 REGULATORY EVALUATION
2.1
System Description
Limiting condition for operations (LCOs) are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The actions associated with an LCO state conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated condition are required action(s) and completion time(s) (CT).
2.1.1 ECCS - Operating (Modes 1, 2, and 3)
The function of the ECCS is to provide core cooling and negative reactivity to ensure the reactor core is protected after any of the following accidents:
- a. Loss-of-coolant accident (LOCA), coolant leakage greater than the capability of the normal charging system,
- b. Rod ejection accident,
- c. Loss of secondary coolant accident, including uncontrolled steam release or loss of feedwater, and
- d. Steam generator tube rupture.
TS 3.5.2 is applicable in Modes 1, 2, and 3 and requires that two independent ECCS trains be operable to ensure that sufficient ECCS flow is available, assuming a single failure affecting either train.
TS 3.5.2 helps ensure the following acceptance criteria for ECCS, established by Title 10 of the Code of Federal Regulations (10 CFR) 50.46, will be met following a LOCA:
- a. Maximum fuel element cladding temperature is 2200 degrees Fahrenheit (°F),
- b. Maximum cladding oxidation is 0.17 times the total cladding thickness before oxidation,
- c. Maximum hydrogen generation from a zirconium water reaction is 0.01 times the hypothetical amount generated if all of the metal in the cladding cylinders surrounding the fuel, excluding the cladding surrounding the plenum volume, were to react,
- d. Core is maintained in a coolable geometry, and
- e. Adequate long-term core cooling capability is maintained.
LCO 3.5.2 also limits the potential for a post-trip return to power following a main steam line break event and ensures that containment temperature limits are met.
2.1.2 ECCS - Shutdown (Mode 4)
LCO 3.5.3 is applicable in Mode 4 and requires one of the two independent (and redundant)
ECCS trains to be operable to ensure that sufficient ECCS flow is available to the core following a design-basis accident.
2.2 Proposed Changes to the TSs The proposed changes would revise TS 3.5.2, ECCS - Operating, and TS 3.5.3, ECCS - Shutdown. The proposed changes would also add a new TS, Containment Sump to Section 3.6, Containment Systems. The proposed changes are described below.
2.2.1 Proposed Changes to ECCS - Operating (Modes 1, 2, and 3)
TS 3.5.2 currently contains Surveillance Requirement (SR) 3.5.2.7, which requires the following at a frequency in accordance with the surveillance frequency control program (SFCP):
Verify, by visual inspection, each ECCS train containment sump suction inlet is not restricted by debris and suction inlet trash racks and screens show no evidence of structural distress or abnormal corrosion.
The licensee proposed to modify and move SR 3.5.2.7 from TS 3.5.2 and include it in the new containment sump TS.
This change is evaluated in Section 3.1 of this SE.
2.2.2 Proposed Changes to ECCS - Shutdown (Mode 4)
TS 3.5.3 currently contains SR 3.5.3.1 which refers to applicable SRs under LCO 3.5.2. One of those referenced SRs is SR 3.5.2.7, as described in Section 2.2.1 of this SE. Because the licensee proposed to move SR 3.5.2.7 from TS 3.5.2 and include it in the new containment sump LCO, the licensee also proposed to delete the reference to SR 3.5.2.7 in SR 3.5.3.1.
This change is evaluated in Section 3.2 of this SE.
2.2.3 Proposed Addition of a New Containment Sump TS The licensee proposed to add LCO 3.6.15 requiring the containment sump to be operable during Modes 1, 2, 3, and 4. Condition A specifies that if the containment sump is inoperable due to containment accident generated and transported debris exceeding the analyzed limits, Required Actions A.1, A.2, and A.3 require immediate initiation of action to mitigate containment accident generated and transported debris, performing SR 3.4.13.1 once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and restoring the containment sump to operable status in 90 days, respectively. The SR 3.4.13.1 requires verification that the reactor coolant system (RCS) operational leakage is within limits by performance of RCS water inventory balance.
Condition B specifies that if the containment sump is inoperable for reasons other than Condition A, Required Action B.1 requires restoration of the containment sump to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Required Action B.1 is modified by two notes which directs entering the applicable conditions and required actions of LCO 3.5.2, ECCS - Operating, and LCO 3.5.3, ECCS - Shutdown, for ECCS trains made inoperable by the containment sump and entering the applicable conditions and required actions of LCO 3.6.6, Containment Spray and Cooling Systems, for component cooling system (CCS) trains made inoperable by the containment sump.
Condition C specifies that if required action and associated CT under Conditions A and B are not met, Required Actions C.1 and C.2 require licensees to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, respectively.
The licensee proposed to expand and relocate an SR currently located in TS 3.5.2. The new SR requires the licensee to verify, by visual inspection, the containment sump does not show structural damage, abnormal corrosion, or debris blockage in accordance with the SFCP.
This change is evaluated in Section 3.3 of this SE.
2.2.4 Variations from TSTF-567, Revision 1 The licensee is not proposing any variations from the TS changes described in TSTF-567 or the applicable parts of the NRC staffs SE of TSTF-567. The CNP TS utilize different numbering and titles than the Standard Technical Specifications (STSs) on which TSTF-567 was based.
Specifically:
SR 3.5.2.8 in the STSs corresponds to CNP SR 3.5.2.7.
New TS 3.6.19, Containment Sump, will be titled Containment Recirculation Sump in the CNP TS.
The term containment sump will be replaced with containment recirculation sump for all instances.
New TS 3.6.19, Containment Sump, will be numbered TS 3.6.15 in the CNP TS.
TS 3.6.6, Containment Spray and Cooling System, is titled TS 3.6.6, Containment Spray System [CSS], in the CNP TS.
The numbering differences described above are appropriate to reflect the numbering of existing TSs and do not affect the applicability of TSTF-567 or the associated NRC staff SE to the proposed LAR.
2.3 Applicable Regulatory Requirements and Guidance 2.3.1 Technical Specifications Requirements Regulation 10 CFR Section 50.36(a)(1) requires each applicant for a license authorizing operation of a utilization facility to include in the application proposed TSs. That regulation also states, in part, that [a] summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.
The regulation at 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 provided in 10 CFR 50.36(c). As required by 10 CFR 50.36(c)(2)(i), the TSs will include LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation at 10 CFR 50.36(c)(2)(i) 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 TSs until the condition can be met.
The regulation at 10 CFR 50.36(c)(3) requires TSs to include SRs, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, facility operation will be within safety limits, and that the LCOs will be met.
The regulation at 10 CFR 50.36(c)(5) requires TSs to include administrative controls, which are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
2.3.2 Guidance The guidance that the NRC staff considered in its review of this LAR included the following:
NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Chapter 16, Technical Specifications, dated March 2010 (ADAMS Accession No. ML100351425), provides guidance on review of TSs.
NUREG-1431, Revision 4.0, Standard Technical Specifications, Westinghouse Plants, Volume 1, Specifications, and Volume 2, Bases, dated April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively).
3.0 TECHNICAL EVALUATION
3.1 Proposed Changes to TS 3.5.2, ECCS - OPERATING The licensee proposed to modify and move SR 3.5.2.7 from TS 3.5.2 to the new containment sump LCO. Therefore, the licensee proposed deletion of SR 3.5.2.7.
The new SR does not limit the visual inspection to the suction inlet, trash racks and screens as currently required by the TSs, but instead requires inspection of the entire containment sump system. The containment sump system consists of the containment drainage flow paths, any design features upstream of the containment sump that are credited in the containment debris analysis, the containment sump strainers (or screens), the pump suction trash racks, and the inlet to the ECCS and CSS piping.
The NRC staff concludes the proposed change is acceptable since the existing requirements are either unchanged or expanded and will continue to ensure the containment sump is unrestricted (i.e., unobstructed) and stays in proper operating condition. Therefore, the staff finds the proposed change meets the requirements of 10 CFR 50.36(c)(3) because it provides SRs to assure the necessary quality of systems and components are maintained, that facility operation will be within safety limits, and that the LCOs will be met.
3.2 Proposed Changes to TS 3.5.3, ECCS - SHUTDOWN The licensee proposed to delete the reference to SR 3.5.2.7 in SR 3.5.3.1. The NRC staff concludes the proposed change is acceptable since SR 3.5.2.7 was modified and relocated to the new containment sump TS. The existing SR on the containment sump is augmented (by requiring inspection of additional sump components) and moved to the new specification, and a duplicative requirement to perform the SR in TS 3.5.3 is removed. The new specification retains or expands the existing requirements on the containment sump and the actions to be taken
when the containment sump is inoperable with the exception of adding new actions to be taken when the containment sump is inoperable due to containment accident generated and transported debris exceeding the analyzed limits. The new actions provide the licensee time to evaluate and correct the condition instead of requiring an immediate plant shutdown. Therefore, the NRC staff finds that the proposed change meets the requirements of 10 CFR 50.36(c)(3) because it provides SRs to assure the necessary quality of systems and components are maintained, that facility operation will be within safety limits, and that the LCOs will be met.
3.3 Proposed Addition of Containment Sump TS 3.3.1 Evaluation of the New TS The licensee proposed to add a new TS 3.6.6 to address operability requirements of the containment sump.
The containment sump supports the post-accident operation of the ECCS and CSS. However, current ECCS TSs only contain SRs related to the containment sump, and the TS does not specify required actions that specifically address an inoperable containment sump. If the containment sump (an ECCS and CSS support system) were found to be inoperable, those respective LCOs would not be met. In order to address concerns related to containment sump operability due to debris accumulation described in NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, September 13, 2004 (ADAMS Accession No. ML042360586), the licensee proposed to add a new specification to address containment sump inoperability and create a condition for when the sump is inoperable due to analyzed containment accident generated and transported debris.
Based on its evaluation below, the NRC staff determined that proposed TS satisfies the requirements of 10 CFR 50.36(c)(2)(i) because the LCO specifies the lowest functional capability or performance levels of equipment required for safe operation of the facility. There is reasonable assurance that the required actions to be taken when the LCO is not met can be conducted without endangering the health and safety of the public.
3.3.2 Evaluation of the Applicability The new TS requires the containment sump to be operable during Modes 1, 2, 3, and 4. The ECCS and CSS TSs currently are applicable during Modes 1, 2, 3, and 4.
The NRC staff finds the proposed applicability is acceptable because the applicability is consistent with the applicability of the ECCS and CSS TSs, the containment sump supported systems.
3.3.3 Evaluation of Condition A The licensee has analyzed the susceptibility of the ECCS and CSS to the adverse effects of post-accident debris blockage and operation with debris-laden fluids. The licensee has established limits on the allowable quantities of containment accident generated debris that could be transported to the containment sump based on its current plant configuration. In the current TSs, if unanalyzed debris sources are discovered inside containment, if errors are discovered in debris-related analyses, or if a previously unevaluated phenomenon that can affect containment sump performance is discovered, the containment sump, and the supported
ECCS and CSS, may be inoperable and the TSs require an immediate plant shutdown with no time provided to evaluate the condition.
In order to address this situation and to provide sufficient time to evaluate the condition, the licensee proposed Condition A, which is applicable when the containment sump is inoperable due to containment accident generated and transported debris exceeding the analyzed limits.
Under Condition A, the operability of the containment sump with respect to debris is based on a quantity of debris evaluated and determined to be acceptable by the licensee. Emergent nonconforming or degraded conditions affecting the quantity of analyzed debris shall be evaluated using a deterministic process.
Under Condition A, Required Action A.1 mandates immediate action to be initiated to mitigate the condition. The licensee's proposed TS Bases for Required Action A.1 provided the following examples of mitigating actions:
Removing the debris source from containment or preventing the debris from being transported to the containment sump; Evaluating the debris source against the assumptions in the analysis; Deferring maintenance that would affect availability of the affected systems and other LOCA mitigating equipment; Deferring maintenance that would affect availability of primary defense-in-depth systems, such as containment coolers; Briefing operators on LOCA debris management actions; or Applying an alternative method to establish new limits.
The NRC staff finds the proposed Required Action A.1 and its CT are acceptable because they place urgency on the initiation of the appropriate actions that could mitigate or reduce the impact of the identified conditions.
Concurrently, Required Action A.2 mandates SR 3.4.13.1, the RCS water inventory balance, to be performed at an increased frequency of once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. An unexpected increase in RCS leakage could be indicative of an increased potential for an RCS pipe break, which could result in debris being generated and transported to the containment sump.
The NRC staff finds the proposed Required Action A.2 and its CT are acceptable because the more frequent monitoring allows operators to act in a timely fashion to minimize the potential for an RCS pipe break while the containment sump is inoperable.
In addition, Required Action A.3 requires the inoperable containment sump to be restored to operable status in 90 days. The NRC staff finds the proposed Required Action A.3 and its CT are acceptable because they provide a reasonable amount of time for the licensee to diagnose, plan and possibly mitigate the unanalyzed debris condition and prevent a loss of ECCS and CSS safety function. In addition, 90 days is adequate given the conservatisms in the containment debris analysis and the proposed compensatory actions required to be implemented immediately by Required Action A.1. As discussed later in this SE section, the
new SR will also require visual inspection of the containment sump system (including the containment drainage flow paths, any design features upstream of the containment sump that are credited in the containment debris analysis, the containment sump strainers, the pump suction trash racks, and the inlet to the ECCS and CSS piping for evidence of structural degradation, potential for debris bypass, and presence of corrosion or debris blockage) to ensure no loose debris is present and there is no evidence of structural distress or abnormal corrosion.
Based on the above, the NRC staff concludes that CONDITION A and its REQUIRED ACTIONS are acceptable.
3.3.4 Evaluation of Condition B Condition B specifies the actions required when the containment sump is inoperable for reasons other than containment accident generated and transported debris exceeding the analyzed limits.
Required Action B.1 requires restoring the containment sump to operable status and is modified by two notes. These two notes direct entry into the conditions and required actions for the supported systems (ECCS and CSS) upon entering Required Action B.1. Since Required Action B.1 directs entry to the corresponding ECCS and CSS LCOs, these notes retain the existing TS actions for ECCS or CSS trains made inoperable by a containment sump inoperable for reasons other than containment accident generated and transported debris exceeding the analyzed limits. The proposed CT for Required Action B.1 is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This CT is consistent with the less limiting CT for a single inoperable ECCS or CSS train so that the ECCS and CSS TS actions control the licensee's response.
The NRC staff finds the proposed change is acceptable since it continues to provide remedial actions for when the containment sump is inoperable for reasons other than Condition A and ensures safe operation of the plant. In addition, the proposed CT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is acceptable since it provides a reasonable time for repairs, and there is a low probability of an accident occurring during this period necessitating the containment sump.
3.3.5 Evaluation of Condition C If operators are unable to restore the affected containment sump to operable status under Condition A or B, Required Action C.1 requires the unit to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> followed by Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, as required by Required Action C.2.
The NRC staff finds this proposed condition and its required actions are acceptable because the condition is consistent with the STSs and requires the operators to place the unit in a condition in which the LCO no longer applies. In addition, the proposed CTs allow a reasonable amount of time to decrease from full power conditions to the required plant conditions in an orderly manner and without challenging plant systems.
3.3.6 Evaluation of the New SR The licensee proposed a new SR in the new containment sump TS. This SR is currently located in TS 3.5.2 and referred to in TS 3.5.3. The proposed numbering for this new SR is SR 3.6.15.1. The frequency of the new SR is in accordance with the SFCP.
The proposed SR requires verification by visual inspection that the containment sump does not show structural damage, abnormal corrosion, or debris blockage.
The new SR is stated in generic terms and expands the scope of the required visual inspection to include the entire containment sump system. The entire containment sump system consists of the containment drainage flow paths, the containment sump strainers (or screens), the pump suction trash racks, and the inlet to the ECCS and CSS piping.
The NRC staff finds the proposed SR is acceptable since it expands the scope of inspection of the original SR. In addition, the proposed frequency is acceptable since it is the same as that currently required by the TSs. Therefore, the NRC staff finds that, as required by 10 CFR 50.36(c)(3), the necessary quality of systems will be maintained, facility operation will be within safety limits, and that the LCOs will be met.
3.3.7 Conclusion Regarding Proposed Containment Sump TS The new containment sump TS retains and expands the existing TS requirements with the exception of the addition of Condition A. Condition A provides a condition for an inoperable containment sump due to containment accident generated and transported debris exceeding the analyzed limits.
The NRC staff reviewed the proposed changes against the regulations and concludes that, for reasons discussed above, the changes continue to meet the requirements of 10 CFR 50.36(c)(2)(i) and 50.36(c)(3) and thus provide reasonable assurance that the revised TSs will continue to have the requisite requirements and controls to operate safely. Therefore, the NRC staff concludes that the proposed TS changes are acceptable.
3.4 Variations The numbering and naming differences discussed in Section 2.2.4 do not affect the applicability of TSTF-567 or the associated staff SE to the proposed LAR. Therefore, these minor editorial variations are acceptable.
3.5 Technical Evaluation Conclusion
The NRC staff determined that the proposed TS changes meet the standards for TS in 10 CFR 50.36 and are acceptable. As required by 10 CFR 50.36(c)(2), the LCOs specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The proposed changes to the SR 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, to therefore satisfy 10 CFR 50.36(c)(3).
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the State of Michigan official was notified of the proposed issuance of the amendment on November 17, 2020. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes the requirements 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 in the Federal Register on June 16, 2020 (85 FR 36432), 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 Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: S. Wall, NRR C. Tilton, NRR Date of Issuance: January 6, 2021
- via e-mail OFFICE NRR/DORL/LPL3/PM*
NRR/DORL/LPL3/LA*
NRR/DSS/STSB/BC*
NAME SWall SRohrer VCusumano DATE 11/18/2020 11/18/2020 12/02/2020 OFFICE OGC - NLO*
NRR/DORL/LPL3/BC*
NRR/DORL/LPL3/PM*
NAME KGamin NSalgado SWall DATE 12/31/2020 1/6/2021 1/6/2021