ML23005A122
| ML23005A122 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/22/2023 |
| From: | V Sreenivas Plant Licensing Branch 1 |
| To: | Rhoades D Constellation Energy Generation |
| Sreenivas V, NRR/DORL/LPL1, 415-2596 | |
| References | |
| EPID L-2022-LLA-0031 | |
| Download: ML23005A122 (1) | |
Text
February 22, 2023 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
R. E. GINNA NUCLEAR POWER PLANT - ISSUANCE OF AMENDMENT NO. 152 RE: ADOPT TSTF-315-REVISE TECHNICAL SPECIFICATION 3.1.8, PHYSICS TESTS EXCEPTIONS - MODE 2 (EPID L-2022-LLA-0031)
Dear Mr. Rhoades:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 152 to Renewed Facility Operating License No. DPR-18 for the R. E. Ginna Nuclear Power Plant in response to your application dated February 21, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22052A013.
The amendment revised the technical specification (TS) to the Renewed Facility Operating License to TS 3.1.8, PHYSICS TESTS Exceptions - MODE 2, to allow one power range neutron flux channel to be bypassed when that channel is used during the performance of physics testing in MODE 2.
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/
V. Sreenivas, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosures:
- 1. Amendment No. 152 to Renewed License No. DPR-18
- 2. Safety Evaluation cc: Listserv
CONSTELLATION GENERATION COMPANY, LLC DOCKET NO. 50-244 R. E. GINNA NUCLEAR POWER PLANT AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 152 Renewed License No. DPR-18
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Exelon Generation Company, LLC dated February 21, 2022, 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 as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-18 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 152, are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.
3.
This license amendment is effective as of its date of issuance and shall be implemented within 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION Hipólito J. González, Chief Plant Licensing Branch I 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 22, 2023 Richard V.
Guzman Digitally signed by Richard V. Guzman Date: 2023.02.22 14:22:54
-05'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 152 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-18 R. E. GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244 Replace the following pages of Renewed Facility Operating License No. DPR-18 with the attached revised pages. The revised pages are identified by amendment number and contain a marginal line indicating the area of change.
Remove Insert 4
4 Replace the following page of the Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment numbers and marginal lines indicating the area of change.
Remove Insert 3.1.8-1 3.1.8-1
R. E. Ginna Nuclear Power Plant Amendment No. 152 (2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 152, are hereby incorporated in the renewed license.
Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications.
(3)
Fire Protection Constellation Energy Generation, LLC 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 March 28, 2013, supplemented by letters dated December 17, 2013; January 29, 2014; February 28, 2014; September 5, 2014; September 24, 2014; December 4, 2014; March 18, 2015; June 11, 2015; August 7, 2015; and as approved in the safety evaluation report dated November 23, 2015. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
(a)
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact.
- 1.
Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
PHYSICS TESTS Exceptions - MODE 2 3.1.8 3.1 REACTIVITY CONTROL SYSTEMS 3.1.8 PHYSICS TESTS Exceptions - MODE 2 LCO 3.1.8 During the performance of PHYSICS TESTS, the requirements of LCO 3.1.3, "Moderator Temperature Coefficient (MTC)";
LCO 3.1.4, "Rod Group Alignment Limits";
LCO 3.1.5, "Shutdown Bank Insertion Limit";
LCO 3.1.6, "Control Bank Insertion Limits";
LCO 3.4.2, "RCS Minimum Temperature for Criticality" may be suspended, and the number of required channels for LCO 3.3.1, "RTS Instrumentation," Functions 2, 5, and 16.e, may be reduced to 3 required channels provided:
a.
THERMAL POWER is maintained 5% RTP; b.
RCS lowest loop average temperature is 530F; and c.
SDM is within the limits specified in the COLR.
APPLICABILITY:
During PHYSICS TESTS.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.
SDM not within limit.
A.1 AND A.2 Initiate boration to restore SDM to within limit.
Suspend PHYSICS TESTS exceptions.
15 minutes 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> B.
THERMAL POWER not within limit.
B.1 Open reactor trip breakers.
Immediately C.
RCS lowest loop average temperature not within limit.
C.1 Restore RCS lowest loop average temperature to within limit.
15 minutes R.E. Ginna Nuclear Power Plant 3.1.8-1 Amendment No. 152
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 152 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-18 CONSTELLATION GENERATION COMPANY, LLC R. E. GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244
1.0 INTRODUCTION
By application dated February 21, 2022, Constellation Energy Generation, LLC (the licensee) requested changes to the technical specifications (TSs) for the R. E. Ginna Nuclear Power Plant (Ginna) by license amendment request (LAR, application). The proposed changes would revise TS 3.1.8, PHYSICS TESTS Exceptions - MODE 2, to allow one power range neutron flux channel to be bypassed when that channel is used during the performance of physics testing in MODE 2.
The licensee proposed adding the phrase in bold text to the current limiting conditions for operations (LCO) statement for TS 3.1.8, which would appear as follows:
During the performance of PHYSICS TESTS, the requirements of LCO 3.1.3, Moderator Temperature Coefficient (MTC);
LCO 3.1.4, Rod Group Alignment Limits; LCO 3.1.5, Shutdown Bank Insertion Limit; LCO 3.1.6, Control Bank Insertion Limits; LCO 3.4.2, RCS Minimum Temperature for Criticality may be suspended, and the number of required channels for LCO 3.3.1, "RTS Instrumentation," Functions 2, 5, and 16.e, may be reduced to 3 required channels provided:
- a. THERMAL POWER is maintained 5% RTP;
- b. RCS lowest loop average temperature is 530 °F; and
1.1 LCO 3.1.8 The current LCO statement for TS 3.1.8 allows the reactor parameters of Moderator Temperature Coefficient and minimum temperature for criticality to be outside their specified limits to conduct PHYSICS TESTS in MODE 2, to verify certain core physics parameters. In addition, it allows selected control and shutdown rods to be positioned outside of their specified alignment and insertion limits. Operation beyond specified limits is permitted for the purpose of performing PHYSICS TESTS and poses no threat to fuel integrity, provided the associated surveillance requirements are met.
For context, MODE 2 is defined in Ginna TS Table 1.1-1 MODES as reactor power 5% RTP and reactivity.99 keff. The definition of PHYSICS TESTS appears in Section 1.1 of Ginna TS as:
PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. These tests are:
- a.
Described in Chapter 14, Initial Test Program of the UFSAR;
- b.
Authorized under the provisions of 10 CFR [Title 10 of the Code of Federal Regulations] 50.59; or
- c.
Otherwise approved by the Nuclear Regulatory Commission (NRC).
Functions 2.a and 2.b in TS Table 3.3.1-1 are the Power Range Neutron Flux - High; and Power Range Neutron Flux - Low reactor trips. Function 5 is the Overtemperature T reactor trip. Function 16.e is the Power Range Neutron Flux P-10 Reactor Trip System Interlock.
Functions 2.a and 2.b ensure that protection is provided against an uncontrolled bank rod withdrawal accident. The Nuclear Instrumentation System (NIS) power range detectors (N-41, N-42, N-43, and N-44) are located external to the reactor vessel and measure neutrons leaking from the core. The NIS power range detectors provide input to the Control Rod Drive System for determination of automatic rod speed and direction.
Function 5 is provided to ensure that the design limit departure from nucleate boiling ratio (DNBR) is met. The inputs to the Function 5 trip include pressure, Tavg, axial power distribution, and reactor power as indicated by loop T assuming full reactor coolant flow. Protection from violating the DNBR limit is assured for those transients that are slow with respect to delays from the core to the measurement system. The Function monitors both variation in power and flow since a decrease in flow has the same effect on T as a power increase. The trip Function uses the T of each loop as a measure of reactor power and is compared with a setpoint that is automatically varied with reactor coolant average temperature, pressurizer pressure and axial power distribution.
Reactor protection interlocks like Function 16.e are provided to ensure reactor trips are in the correct configuration for the current plant status. They back up operator actions to ensure protection system Functions are not bypassed during plant conditions under which the safety analysis assumes the Functions are not bypassed. Therefore, the interlock Functions do not need to be OPERABLE when the associated reactor trip functions are outside the applicable MODES.
2.0 REGULATORY EVALUATION
The NRC staff considered the following regulatory requirements, guidance, and licensing and design-basis information during its review of the proposed changes.
Section 50.36, Technical specifications, of 10 CFR establishes the regulatory requirements related to the content of TSs. Paragraph 50.36(a)(1) requires an application for an operating license to include proposed TSs. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the TSs.
Paragraph (b) of 10 CFR 50.36 requires TSs to be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to § 50.34.
Paragraph 50.36(c)(2) of 10 CFR states that LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility, and when an LCO 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 NRC staffs guidance for the review of TSs is in Chapter 16, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (SRP), dated March 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared Standard Technical Specifications (STSs) for each of the light-water reactor nuclear designs. NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Revision 5.0, Volume 1, Specifications and Volume 2, Bases, dated September 2021 (ML21259A155 and ML21259A159, respectively) are the applicable guidance for Ginna. Chapter 16 of NUREG-800 specifies that the staff review whether content and format of proposed TS are consistent with the applicable STS. Where TS provisions depart from the reference TSs, the staff determines whether proposed differences are justified by uniqueness in plant design or other considerations.
3.0 TECHNICAL EVALUATION
The NRC staff reviewed the proposed changes to the Ginna TS to determine whether the regulatory requirements in Section 2.0 would continue to be met and whether the TS, as amended by the proposed change, would continue to conform to the staffs guidance for TS format and content.
In the February 21, 2022, request, the licensee provided an analysis, evaluation, and justification for the proposed change. The staff reviewed the licensees statements. On pages 3 and 4 of 9, the licensee stated:
Startup operation or a power increase requires a permissive signal from the higher range instrumentation channels before the lower range level trips can be manually blocked by the operator. A one-of-two Intermediate Range permissive signal (P6) is required before Source Range level trip blocking can be initiated by the plant operator. The Intermediate Range level trip and low-range Power Range level trip can only be blocked by the plant operator after satisfactory operation and permissive information are obtained from two-of-four Power Range channels. Individual blocking switches are provided at the control board so that the low-range Power Range trip and Intermediate Range trip can be independently blocked.
These trips are automatically reactivated when any three of the four Power Range channels are below the permissive (P10) level, thus ensuring automatic activation of more restrictive trip protection. The reactor plant protection afforded by the high-range Power Range trips is never blocked. As stated previously, one of the steps currently taken to prepare for a physics test is placing a Power Range channel in a tripped condition and a one-out-of-three logic scheme. Due to this logic configuration, reactor trips are known to have occurred when spurious signals were generated. Implementation of the proposed amendment will result in one power range channel being in a bypassed state during physics testing. In this configuration, there will be three available channels with a two-out-of-three coincidence logic required to actuate the reactor trip functions associated with power range neutron flux. As required by LCO 3.1.8, physics testing will be performed while the reactor is in MODE 2 at a power level of less than or equal to 5% RATED THERMAL POWER (RTP).
On page 4 of 9 the licensee further stated:
Other factors that should also be considered are that the reactor trip function of the intermediate range detectors will be unaffected by the proposed amendment and, therefore, will be available to mitigate a reactivity transient at low power.
The low trip function for the power range monitors (setpoint of 24%) will still be present with three available channels at a two-out-of-three coincidence logic for a reactor trip. Further, the high trip setpoints for the power range monitors are decreased during startup of the reactor from the normal 108% setpoint to a value less than or equal to 85%. This setpoint reduction provides an additional measure to limit a reactivity excursion.
On page 5 of 9 the licensee stated:
During physics testing, LCO 3.1.8 requires that the reactor power level be kept at less than or equal to 5% RTP, the lowest operating reactor coolant system loop average temperature be kept at greater than or equal to 530°F, and SHUTDOWN MARGIN (SDM) be kept within the limits specified in the CORE OPERATING LIMITS REPORT (COLR) so that the fuel design criteria are not violated. Under the proposed change, the power range neutron flux trip would remain available and functional in a two-out-of-three coincidence logic configuration. In addition, the intermediate range neutron flux trip provides back-up protection during low power operation. During physics testing the plant is held in a stable state with minimal changes in steam or feed flow. LCO 3.1.8 is applicable for physics testing that is typically performed at the beginning of the fuel cycle with minimum fuel burnup and decay heat. The SDM is maintained above the required values and procedural controls are in place for monitoring plant parameters.
The NRC staff reviewed the licensees analysis, evaluations, and justifications for the proposed change. The staff noted the change in coincidence logic configuration for PHYSICS TESTS in MODE 2 from a one out of three arrangement to a two out of three arrangement. The staff determined that even though the coincidence logic would be changed, safe operation of the plant will not be impacted because of the requirement to perform the associated tests with core power, reactor coolant system temperature and SDM restricted to the limits listed in items a, b, and c of LCO 3.1.8. Therefore, the staff determined the LCO, as modified by the proposed change, will continue to meet the requirement of 50.36(c)(2) because the LCO will continue to contain the lowest functional capability or performance levels of equipment required for safe operation of the facility. The staff determined the licensee met the regulatory requirements of 10 CFR 50.36(a)(1) and 50.36(b) because the application provided reasons for the proposed change and the proposed change was based on the analysis and evaluation in the LAR.
The TSTF-315 change to STS was incorporated into Revision 2 of NUREG-1431 and maintained in each successive revision. The staff compared the licensees TS, as amended by the proposed change, to NUREG-1431, Rev 5. The staff determined the content and format of the Ginna TS, as amended by the proposed change, are consistent with that document.
Therefore, the staff has determined that the proposed change is acceptable because the regulatory requirements in Section 2.0 will continue to be met and the TS, as amended by the proposed change, continue to conform to the staffs guidance for TS format and content.
4.0 TECHNICAL CONCLUSION Based on the technical evaluation provided above, the NRC staff finds the LCO, as modified by the proposed change, will continue to meet the requirement of 10 CFR 50.36(c)(2) because the LCO will continue to contain the lowest functional capability or performance levels of equipment required for safe operation of the facility. The TS, as amended by the proposed change, continue to conform to the staffs guidance for TS format and content. Therefore, the staff determined the licensee met the regulatory requirements of 10 CFR 50.36(a)(1) and 50.36(b).
5.0 STATE CONSULTATION
In accordance with the Commissions regulations, the staff notified the New York State official on October 25, 2022, of the proposed issuance of the amendments. The State official had no comments.
6.0 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 inspections or 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, which was published in the Federal Register on June 14, 2022 (87 FR 36008), that the amendments involve no significant hazards consideration, 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) and (10). 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 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: M. Hamm, NRR/STSB Date: February 22, 2023
- by memorandum OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NAME VSreenivas KZeleznock (KEntz for)
VCusumano DATE 01/04/2023 01/11/2023 10/17/2022 OFFICE OGC/NLO NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME KDowling HGonzález (R. Guzman for) VSreenivas DATE 01/24/2023 02/02/2023 02/22/2023