ML21006A458
| ML21006A458 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/02/2021 |
| From: | Scott Wall Plant Licensing Branch III |
| To: | Gebbie J Indiana Michigan Power Co |
| Wall S | |
| References | |
| EPID L-2020-LLA-0102 | |
| Download: ML21006A458 (23) | |
Text
February 2, 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 AMENDMENT NOS. 358 AND 337 REGARDING REVISION TO TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 541, REVISION 2, ADD EXCEPTIONS TO SURVEILLANCE REQUIREMENTS FOR VALVES AND DAMPERS LOCKED IN THE ACTUATED POSITION (EPID L-2020-LLA-0102)
Dear Mr. Gebbie:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment Nos. 358 and 337 to Renewed Facility Operating License Nos. DPR-58 and DPR-74 for the Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2 (CNP), respectively. These amendments consist of changes to the licenses and Technical Specifications in response to your application dated April 30, 2020.
The amendments revise certain Technical Specification Surveillance Requirements (SRs) to add exceptions that consider the SR to be met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position. The revisions are consistent with Technical Specifications Task Force Traveler 541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position.
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/
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. 358 to DPR-58
- 2. Amendment No. 337 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. 358 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. 358, 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 60 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: February 2, 2021 Nancy L.
Salgado Digitally signed by Nancy L.
Salgado Date: 2021.02.02 14:22:11
-05'00' ATTACHMENT TO LICENSE AMENDMENT NO. 358 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-58 DOCKET NO. 50-315 Renewed Facility Operating License No. DPR-58 Replace the following page of Renewed Facility Operating License No. DPR-58 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change REMOVE INSERT Technical Specifications Replace the following pages of the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
REMOVE INSERT 3.7.10-3 3.7.10-3 3.7.12-2 3.7.12-2 3.7.13-2 3.7.13-2 Renewed License No. DPR-58 Amendment No: 357, 358 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. 358, 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,
CREV System 3.7.10 Cook Nuclear Plant Unit 1 3.7.10-3 Amendment No. 287, 307, 334, 358 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREV train for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.2 Perform required CREV System filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.10.3
NOTE-------------------------------
Only required to be met in MODES 1, 2, 3, and 4.
Verify each CREV System train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
In accordance with the Control Room Envelope Habitability Program
ESF Ventilation System 3.7.12 Cook Nuclear Plant Unit 1 3.7.12-2 Amendment No. 287, 334, 358 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Operate each ESF Ventilation train for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.12.2 Perform required ESF Ventilation System filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.12.3 Verify each ESF Ventilation train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.12.4 Verify one ESF Ventilation train can maintain a negative pressure relative to adjacent areas during the post accident mode of operation at a flow rate of 22,500 cfm.
In accordance with the Surveillance Frequency Control Program
FHAEV System 3.7.13 Cook Nuclear Plant Unit 1 3.7.13-2 Amendment No. 287, 334, 358 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.13.3 Perform required FHAEV System filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.13.4 Verify required FHAEV train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.13.5 Verify required FHAEV train can maintain a pressure 0.125 inches of vacuum water gauge with respect to atmospheric pressure during the accident mode of operation at a flow rate 27,000 cfm.
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. 337 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. 337, 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 60 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: February 2, 2021 Nancy L.
Salgado Digitally signed by Nancy L. Salgado Date: 2021.02.02 14:23:28 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 337 DONALD C. COOK NUCLEAR PLANT, UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-74 DOCKET NO. 50-316 Renewed Facility Operating License No. DPR-74 Replace the following page of Renewed Facility Operating License No. DPR-74 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
REMOVE INSERT Technical Specifications Replace the following pages of the Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
REMOVE INSERT 3.7.10-3 3.7.10-3 3.7.12-2 3.7.12-2 3.7.13-2 3.7.13-2 Renewed License No. DPR-74 Amendment No. 336, 337 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. 337, 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
CREV System 3.7.10 Cook Nuclear Plant Unit 2 3.7.10-3 Amendment No. 269, 289, 316, 337 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CREV train for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.2 Perform required CREV System filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.10.3
NOTE-------------------------------
Only required to be met in MODES 1, 2, 3, and 4.
Verify each CREV System train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.4 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
In accordance with the Control Room Envelope Habitability Program
ESF Ventilation System 3.7.12 Cook Nuclear Plant Unit 2 3.7.12-2 Amendment No. 269, 316, 337 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Operate each ESF Ventilation train for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.12.2 Perform required ESF Ventilation System filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.12.3 Verify each ESF Ventilation train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.12.4 Verify one ESF Ventilation train can maintain a negative pressure relative to adjacent areas during the post accident mode of operation at a flow rate of 22,500 cfm.
In accordance with the Surveillance Frequency Control Program
FHAEV System 3.7.13 Cook Nuclear Plant Unit 2 3.7.13-2 Amendment No. 269, 316, 337 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.7.13.3 Perform required FHAEV System filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.13.4 Verify required FHAEV train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.13.5 Verify required FHAEV train can maintain a pressure 0.125 inches of vacuum water gauge with respect to atmospheric pressure during the accident mode of operation at a flow rate 27,000 cfm.
In accordance with the Surveillance Frequency Control Program
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 358 AND 337 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. ML20126G455), Indiana Michigan Power Company (I&M, the licensee) submitted a license amendment request (LAR) for changes to the Technical Specifications (TSs) for the Donald C. Cook Nuclear Plant, Unit Nos. 1 and 2 (CNP).
Limiting Conditions for Operation (LCOs) in the CNP TSs identify the lowest functional capability or performance levels of equipment required for safe operation of the facility. To ensure that these LCOs will be met, the CNP TSs also include surveillance requirements (SRs) that require, among other things, the licensee to verify that each train of specified trains actuates on an actual or simulated actuation signal. The proposed amendments would revise certain of these SRs by adding except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position to each SR.
The proposed amendments are based on Technical Specifications Task Force (TSTF) Traveler TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position, dated August 28, 2019 (ADAMS Accession No. ML19240A315). The U.S. Nuclear Regulatory Commission (NRC, the Commission) approved TSTF-541, Revision 2, by letter dated December 10, 2019 (ADAMS Package Accession No. ML19323E957). The NRC staffs safety evaluation (SE) of the traveler is included with the NRC staffs approval letter.
The licensee has proposed variations from the TS changes described in TSTF-541, Revision 2.
The variations are described in Section 2.2.1 of this SE and evaluated in Section 3.1.
2.0 REGULATORY EVALUATION
2.1
System Description
Consistent with TSTF-541, Revision 2, the licensee has proposed revising CNP SR 3.7.10.3, SR 3.7.12.3, and SR 3.7.13.4, which concern the control room emergency ventilation (CREV) system, engineered safety features (ESF) ventilation system, and fuel handling area exhaust ventilation (FHAEV) system, respectively.
CNP LCO 3.7.10 requires two CREV trains to be operable in MODES 1, 2, 3, and 4 and during movement of irradiated fuel assemblies in the containment, auxiliary building, and the opposite Unit containment. Currently, CNP SR 3.7.10.3 requires the licensee to [v]erify each CREV System train actuates on an actual or simulated actuation signal. The purpose of SR 3.7.10.3 is to verify that each train/subsystem starts and operates on an actual or simulated actuation signal. The CREV system provides a protected environment from which occupants can control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.
CNP LCO 3.7.12 requires two ESF ventilation trains to be operable in Modes 1, 2, 3, and 4.
Currently, CNP SR 3.7.12.3 requires the licensee to [v]erify each ESF Ventilation train actuates on an actual or simulated actuation signal. The ESF ventilation system consists of two independent and redundant trains. Ductwork, valves or dampers, and instrumentation also form part of the system, as well as demisters functioning to reduce the relative humidity of the air stream. The ESF ventilation system is a standby system, parts of which may also operate during normal unit operations. Upon receipt of the actuating signal(s), the ESF ventilation system dampers are realigned and fans are started to initiate filtration. The prefilters or demisters remove any large particles in the air, and any entrained water droplets present, to prevent excessive loading of the high-efficiency particulate air (HEPA) filters and charcoal adsorbers. The purpose of SR 3.7.12.3 is to verify the proper actuation of all train components, including dampers, on an actual or simulated actuation signal.
CNP LCO 3.7.13 requires one FHAEV train to be operable and in operation during movement of irradiated fuel assemblies in the auxiliary building. Currently, CNP SR 3.7.13.4 requires the licensee to [v]erify required FHAEV train actuates on an actual or simulated actuation signal.
The FHAEV system filters airborne radioactive particulates from the area of the fuel pool following a fuel handling accident or loss-of-coolant accident. The FHAEV system, in conjunction with other normally operating systems, also provides environmental control of temperature and humidity in the fuel pool area. The FHAEV system consists of two independent and redundant trains. Each train consists of a heater, a prefilter or demister, a HEPA filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines), and a fan. Ductwork, valves or dampers, and instrumentation also form part of the system, as well as demisters, functioning to reduce the relative humidity of the airstream. The system initiates filtered ventilation of the fuel handling building following receipt of a high-radiation signal. The FHAEV system is a standby system, parts of which may also be operated during normal plant operations. Upon receipt of the actuating signal, normal air discharges from the building, the fuel handling building is isolated, and the stream of ventilation air discharges through the system filter trains. The purpose of SR 3.7.13.4 is to verify proper actuation of all train components, including dampers, on an actual or simulated actuation signal.
2.2 Description of Proposed Changes The licensee proposed to revise certain SRs by adding exceptions to the SRs for dampers and valves that are locked, sealed, or otherwise secured in the actuated position, consistent with the changes described in TSTF-541, Revision 2. The following list denotes the proposed changes to the SRs. The proposed new text containing the exception is shown in italics.
SR 3.7.10.3: Verify each CREV System train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.7.12.3: Verify each ESF Ventilation train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
SR 3.7.13.4: Verify each FHAEV train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
2.2.1 Variations from TSTF-541, Revision 2 The licensee proposed the following variations from the TS changes described in TSTF-541, Revision 2, or the applicable parts of the NRC staffs SE of TSTF-541, Revision 2. The licensee stated that these variations do not affect the applicability of TSTF-541, Revision 2, or the NRC staffs SE of TSTF-541, Revision 2, to the proposed LAR. These variations are detailed in Section 2.2 of the LAR and are summarized below.
The current CNP TSs contain different numbering or titles as compared to the numbering and titles in TSTF-541, Revision 2. Specifically:
o TSTF-541, Revision 2, TS 3.7.10, Control Room Emergency Filtration System (CREFS), is titled Control Room Emergency Ventilation (CREV) System in the CNP TSs.
o TSTF-541, Revision 2, TS 3.7.12, Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System (PREACS) is titled Engineered Safety Features (ESF) Ventilation System in the CNP TSs.
o TSTF-541, Revision 2, TS 3.7.13, Fuel Building Air Cleanup System (FBACS), is titled Fuel Handling Area Exhaust Ventilation (FHAEV) System in the CNP TSs.
o The SR listed as SR 3.7.13.3 in TSTF-541, Revision 2, to verify that each FBACS (or FHAEV at CNP) train actuates on an actual or simulated actuation signal, is listed as SR 3.7.13.4 in the CNP TSs.
The CNP TSs do not contain several of the SRs equivalent to the SRs affected by TSTF-541, Revision 2.
The CNP TSs contain a Surveillance Frequency Control Program; therefore, the frequency for the affected SRs would remain In accordance with the Surveillance Frequency Control Program.
2.3 Applicable Regulatory Requirements Title 10 of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit, or early site permit, requires that whenever a licensee desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
Under 10 CFR 50.92(a), determinations on whether to grant an applied-for license amendment are guided by the considerations that govern the issuance of initial licenses or construction permits to the extent applicable and appropriate. Both the common standards for operating licenses and construction permits in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public.
The regulation under 10 CFR 50.36, Technical specifications, establishes the regulatory requirements related to the content of TSs. Section 50.36(a)(1) requires an application for an operating license to include proposed TSs. A summary statement of the bases or reasons for such TSs, other than those covering administrative controls, must also be included in the application, but shall not become part of the TSs.
The regulation under 10 CFR 50.36(b) states that:
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.
In accordance with 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. When an LCO is not met, the licensee must shut down the reactor or follow any remedial action permitted by the TSs until the LCO can be met.
SRs are defined in 10 CFR 50.36(c)(3) as 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.
3.0 TECHNICAL EVALUATION
The proposed amendments are based on the NRC-approved TSTF-541, Revision 2. The NRC staffs evaluation of the proposed amendments relies upon the NRC staffs previous approval of TSTF-541, Revision 2. The regulatory framework that the NRC staff used to determine the acceptability of the proposed changes consists of the requirements listed in Section 2.3 of this SE. The NRC staff reviewed the proposed TS changes to determine whether they meet the standards in 10 CFR 50.36(c)(3).
Consistent with TSTF-541, Revision 2, the licensee has proposed revising CNP SR 3.7.10.3, SR 3.7.12.3, and SR 3.7.13.4, which concern the CREV system, ESF ventilation system, and
FHAEV system, respectively. LCO 3.7.10 requires two CREV trains to be operable in MODES 1, 2, 3, and 4, and during movement of irradiated fuel assemblies in the containment, auxiliary building, and the opposite Unit containment. LCO 3.7.12 requires two ESF ventilation trains to be operable in Modes 1, 2, 3, and 4. LCO 3.7.13 requires one FHAEV train to be operable and in operation during movement of irradiated fuel assemblies in the auxiliary building. As stated in CNP TS 1.1, Definitions, a train shall be operable:
when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the train to perform its specified safety function(s) are also capable of performing their related support function(s).
The proposed amended SRs would exclude the need to verify actuation of dampers and valves that do not, in fact, actuate (i.e., change position) in response to an actuation signal. The amended SRs would continue to require the licensee to verify that valves and dampers that must actuate perform their safety functions and support functions by being able to change position. But the NRC staff finds that it is not necessary to verify actuation of valves and dampers that are already in their actuated positions and are locked, sealed, or otherwise secured in those positions. Accordingly, the NRC staff finds that, as amended, the CNP TSs will continue to provide an acceptable way to meet 10 CFR 50.36(c)(3) because the revised SRs will continue to provide assurance that the necessary quality of systems and components is maintained and that the LCOs will be met.
The licensees LAR contains the following statements:
While the proposed exceptions permit automatic valves and dampers that are locked, sealed, or otherwise secured in the actuated position to be excluded from the SR in order to consider the SR met, the proposed changes will not permit a system that is made inoperable by locking, sealing, or otherwise securing an automatic valve or damper in the actuated position to be considered operable.
As stated in the SR 3.0.1 Bases, Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when: a. The systems or components are known to be inoperable, although still meeting the SRs.
I&M acknowledges that under the proposed change, the affected valves and dampers may be excluded from the SR when locked, sealed or otherwise secured in the actuated position. However, if the safety analysis assumes movement from the actuated position following an event, or the system is rendered inoperable by locking, sealing, or otherwise securing the valve or damper in the actuated position, then the system cannot perform its specified safety function and is inoperable regardless of whether the SR is met.
I&M acknowledges for components for which the SR allowance can be utilized, the SR must be verified to have been met within its required Frequency after removing the valve or damper from the locked, sealed or otherwise secured status. If the SR exception is utilized to not test the actuation of a valve or damper and the specified Frequency of the SR is exceeded without testing the
component, the SR must be performed on the component when it is returned to service in order to meet the SR.
Given the statements provided in the LAR to adopt TSTF-541, Revision 2, the NRC staff finds that there is reasonable assurance that the changes will not inadvertently affect the clarity of the CNP licensing basis.
3.1 Variations As discussed in Section 2.2.1 of this SE, the licensee proposed variations from TSTF-541, Revision 2, related to the use of different numbering, titles, and nomenclature and that the CNP TSs do not contain several of the SRs equivalent to the SRs affected by TSTF-541, Revision 2, and contain a Surveillance Frequency Control Program. The NRC staff reviewed these variations and finds that they are acceptable because they do not affect the applicability of TSTF-541, Revision 2, or the NRC staffs SE of TSTF-541, Revision 2, to the CNP TSs.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the State of Michigan official was notified of the proposed issuance of the amendments on November 10, 2020. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 or change surveillance requirements. The NRC staff has determined that the amendments involve 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 amendments involve 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 amendments meet 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.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: S. Wall, NRR J. Wilson, NRR Date: February 2, 2021
- via e-mail OFFICE NRR/DORL/LPL3/PM*
NRR/DORL/LPL3/LA*
NRR/DSS/STSB/BC*
NAME SWall SRohrer VCusumano DATE 01/08/2021 01/07/2021 01/08/2021 OFFICE OGC (NLO)*
NRR/DORL/LPL3/BC*
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NAME JWachutka NSalgado SWall DATE 01/25/2021 02/02/2021 02/02/2021