ML23131A424
| ML23131A424 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/23/2023 |
| From: | Richard Guzman NRC/NRR/DORL/LPL1 |
| To: | Rhoades D Constellation Energy Generation |
| References | |
| EPID L-2022-LLA-0117 | |
| Download: ML23131A424 (1) | |
Text
June 23, 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:
NINE MILE POINT NUCLEAR STATION, UNIT 1 - ISSUANCE OF AMENDMENT NO. 249 REGARDING THE REVISION TO TECHNICAL SPECIFICATION 3.3.1 TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-568 (EPID L-2022-LLA-0117)
Dear Mr. Rhoades:
The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment No. 249 to Renewed Facility Operating License No. DPR-63 for the Nine Mile Point Nuclear Station, Unit 1 (Nine Mile Point 1). The amendment consists of changes to the technical specifications (TSs) in response to your application dated August 12, 2022, as supplemented by letter dated April 4, 2023.
The amendment revises Technical Specification 3.3.1, Oxygen Concentration, to adopt the inerting/de-inerting requirements of Technical Specifications Task Force (TSTF) Traveler TSTF-568, Revision 2, Revise Applicability of BWR [Boiling Water Reactor]/4 TS 3.6.2.5 and TS 3.6.3.2, which require inerting the primary containment to less than 4 percent by volume oxygen concentration within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> while in the power operating condition.
A copy of the related safety evaluation is enclosed. Notice of Issuance will be included in the next Commissions monthly Federal Register notice.
Sincerely,
/RA/
Richard V. Guzman, Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220
Enclosures:
- 1. Amendment No. 249 to DPR-63
- 2. Safety Evaluation cc: Listserv
NINE MILE POINT NUCLEAR STATION, LLC CONSTELLATION ENERGY GENERATION, LLC DOCKET NO. 50-220 NINE MILE POINT NUCLEAR STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 249 Renewed License No. NPF-63
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Constellation Energy Generation, LLC dated August 12, 2022, as supplemented by letter dated April 4, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 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-63 is hereby amended to read as follows:
2.C.(2)
Technical Specifications The Technical Specifications contained in Appendix A, which is attached hereto, as revised through Amendment No. 249, is hereby incorporated into this license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications.
- 3.
This amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance.
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 Technical Specifications and Renewed Facility Operating License Date of Issuance: June 23, 2023 Hipolito J.
Gonzalez Digitally signed by Hipolito J. Gonzalez Date: 2023.06.23 12:22:59 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 249 NINE MILE POINT NUCLEAR STATION, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-63 DOCKET NO. 50-220 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.
Remove Page Insert Page 4
4 Replace the following page of Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.
Remove Page Insert Page 125 125 Renewed License No. DPR-63 Revised by letter dated February 21, 2007 Amendment No. 195, 209, 214, 219, 220, 247, 249 (1)
Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 1850 megawatts (thermal).
(2)
Technical Specifications The Technical Specifications contained in Appendix A, which is attached hereto, as revised through Amendment No. 249, is hereby incorporated into this license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications.
(3)
Deleted D.
This license is subject to the following additional conditions:
(1)
NMP LLC will complete construction of a new radwaste facility in conformance with the design defined and evaluated in the FES, to be operational no later than June 1976.
(2)
Deleted by License Amendment No. 51 (3)
Deleted by License Amendment No. 51 (4)
Security, Training and Qualification and Safeguards Contingency Plans Constellation Energy Generation, LLC shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans, including amendments made pursuant to the provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21 is entitled Nine Mile Point Nuclear Station, LLC Physical Security, Safeguards Contingency, and Security Training and Qualification Plan, Revision 1, and was submitted by letter dated April 26, 2006.
Constellation Energy Generation, LLC shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensees CSP was approved by License Amendment No. 209 and modified by License Amendment No. 219. The licensee has obtained Commission authorization to use Section 161A preemption authority under 42 U.S.C 2201a for weapons at its facility.
(5)
Paragraph 2.D(5) of the license has been combined with paragraph 2.D(4) as amended above into a single paragraph.
LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT b.
If the containment oxygen concentration is greater than or equal to the four percent by volume limit while in the power operating condition then restore oxygen concentration to within limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
c.
If Specifications "a" or "b" above are not met, exit the power operating condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
AMENDMENT NO. 142, 185, 237, 249 125
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE REVISION TO TECHNICAL SPECIFICATION 3.3.1 TO PARTIALLY ADOPT TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-568, REVISION 2, REVISE APPLICABILITY OF BWR/4 TS/ 3.6.2.5 AND TS 3.6.3.2 AMENDMENT NO. 249 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-63 CONSTELLATION ENERGY GENERATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT 1 DOCKET NO. 50-220
1.0 INTRODUCTION
By application dated August 12, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22224A001), as supplemented by letter dated April 4, 2023 (ML23094A003), Constellation Energy Generation, LLC (CEG, the licensee) submitted a license amendment request (LAR) for the Nine Mile Point Nuclear Station, Unit 1 (NMP-1).
The proposed changes would revise Technical Specification (TS) 3.3.1, Oxygen Concentration, based on Technical Specifications Task Force (TSTF) Traveler TSTF-568, Revision 2, Revise Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2 (ML19141A122). The U.S. Nuclear Regulatory Commission (NRC or the Commission) approved TSTF-568, Revision 2, by letter dated December 17, 2019 (ML19325C444). The NRC staffs safety evaluation (SE) of the traveler was enclosed with the NRC staffs approval letter. Specifically, the licensee proposed to modify the language of TS 3.3.1.b to be consistent with the changes identified in TSTF-568. The licensee also proposed variations from the TS changes described in TSTF-568. The proposed TS change and variations are described in section 2.2 of this SE and evaluated in section 3.3.
The supplemental letter dated April 4, 2023, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published the Federal Register on November 1, 2022 (87 FR 65833).
2.0 REGULATORY EVALUATION
2.1 Description of Structures, Systems, Components and TS Sections The NMP-1 containment consists of a drywell (in the shape of an inverted light bulb), a suppression chamber (in the shape of a toroid), and a network of vents which extend radially outward and downward from the drywell to the suppression chamber. The containment atmosphere is inerted with nitrogen gas during normal operation to prevent a combustible mixture of hydrogen and oxygen from forming during accident conditions. Long-term control of post-loss-of-coolant activity (LOCA) hydrogen gas concentration is accomplished by adding additional nitrogen gas and then venting the primary containment through the standby gas treatment system.
2.1.1 Current Containment Oxygen Concentration Requirement Title 10 of the Code of Federal Regulations (10 CFR) Section 50.44, Combustible gas control for nuclear power reactors, states that for a plant with an inerted containment atmosphere, the oxygen concentration in the primary containment is required to be maintained below 4 percent by volume. NMPs TS specify that this inerted atmosphere requirement applies when the plant is in the power operating condition. This requirement ensures that an accident that produces hydrogen does not result in a combustible mixture inside the primary containment. Prior to the approval of TSTF-568, the Standard Technical Specifications (STS) TS 3.6.3.2 required primary containment oxygen concentration to be less than 4 percent by volume when in Mode 1 during the period from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the thermal power exceeds 15 percent rated thermal power (RTP) following startup, and to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to reducing the RTP to less than 15 percent RTP during next scheduled shutdown. TSTF-568, Revision 2, stated that the 24-hour allowance above 15 percent RTP is provided in the primary containment oxygen concentration specification to delay inerting the primary containment in a plant startup and to accelerate de-inerting for a plant shutdown. This allowance is provided so that plant personnel can safely enter the primary containment without breathing apparatus to perform the needed inspections and maintenance adjustments.
The licensee has not converted the NMP-1 TSs to the format and content of the STS. The NMP-1 TS provide the oxygen concentration requirement in the format of their plant-specific TS.
The equivalent TS to STS 3.6.3.2 for NMP 1 is TS 3.3.1, Oxygen Concentration. NMP-1 TS 3.3.1 was previously revised by License Amendment No. 2371 to change the Completion Time (CT) from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> while in the power operating condition and for transitory conditions during startup, shutdown, and maintenance activities. NMP-1 TS 3.3.1 requires containment oxygen concentration to be maintained less than 4 percent by volume whenever in the power operating condition. The power operating condition for NMP-1 is the equivalent of the combination of Mode 1, Power Operation, and Mode 2, Startup, in the STS. The NMP-1 TS allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore oxygen concentration to within limits while in the power operating condition and for transitory conditions during startup, shutdown and maintenance activities. The licensees TS Bases state that the 72-hour period is allowed when the containment is not inerted to accommodate transitory conditions during startup, shutdown, and maintenance activities. The 72-hour period is a reasonable amount of time and is based on 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to de-inert containment prior to shutdowns or in preparation for maintenance, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform 1 Issuance of License Amendment No. 237 Regarding Changes to Containment Oxygen Concentration Requirements dated July 30, 2019 (ML19176A086) work inside containment and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to re-inert. These time frames are based on industry operating experience and are considered reasonable.
2.1.2 Pressure Suppression Following a LOCA The drywell is immediately pressurized when a postulated line break occurs within the primary containment. As drywell pressure increases, drywell atmosphere (primarily nitrogen gas) and steam are blown down through the vents into the suppression pool via the downcomers. The steam condenses in the suppression pool which suppresses the peak pressure in the drywell.
Non-condensable gases discharged into the suppression pool collect in the free air volume of the suppression chamber, increasing the suppression chamber pressure. As steam is condensed in the suppression pool and on the structures in the drywell, the pressure decreases until the suppression chamber pressure exceeds the drywell pressure and the suppression chamber-drywell vacuum breakers open and vent non-condensable gases back into the drywell.
2.1.3 TS 3.3.1, Oxygen Concentration The primary containment oxygen concentration is maintained to ensure that a LOCA, a postulated event that produces hydrogen, does not result in a combustible mixture inside primary containment. The TS requires that the primary containment oxygen concentration be maintained below 4 volume percent. Below this concentration, the primary containment is inerted and no combustion can occur.
2.2 Description of Proposed TSTF-568 TS Changes and Variations 2.2.1 Proposed Changes to TS 3.3.1, Oxygen Concentration and Variations from TSTF-568 The NMP-1 TSs use different numbering than the STS on which TSTF-568 was based.
Specifically, STS 3.6.3.2, Primary Containment Oxygen Concentration, corresponds to NMP-1 TS 3.3.1, Oxygen Concentration. This difference does not affect the applicability of TSTF-568 to the NMP-1 TSs.
Since several of the revisions to the STS identified in TSTF-568 were either already incorporated into the NMP-1 TS or not applicable to NMP-1, the licensee did not propose to adopt all TSTF-568 changes. The licensee proposes only to modify the language for TS 3.3.1.b consistent with the equivalent Action A.1 in the STS 3.6.3.2.
In the NRC-approved TSTF-568, the Applicability of TS 3.6.3.2, Primary Containment Oxygen Concentration, is revised to require the oxygen concentration limits to be met when in Modes 1 and 2. As noted above, the power operating condition for NMP-1 is the equivalent of the combination of Mode 1, Power Operation, and Mode 2, Startup, in the STS. Since the NMP-1 TS 3.3.1 already requires the oxygen concentration to be within limits when in the power operating condition, this TSTF-568 change is not needed for NMP-1.
The approved Traveler TSTF-568 included the following changes to STS Required Actions A.1 and B.1 and their associated CTs:
CONDITION REQUIRED ACTION COMPLETION TIME A. Primary containment oxygen concentration not within limit.
A.1 ----------- NOTE -------------
LCO 3.0.4.c is applicable.
Restore oxygen concentration to within limit.
72 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.Reduce THERMAL POWER TO
[15]% RTP.
12 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> The overall purpose of the TSTF-568 changes is to simplify the applicability statement by adding a new note and revising the CT. This change provides operational flexibility and more closely follows established TS conventions in that the plant is required to be in Mode 3 if oxygen concentration cannot be restored to within limits.
As noted in the LAR, the NMP-1 TS do not include limiting condition for operation (LCO) 3.0.4; therefore, the addition of the note to NMP-1 TS 3.3.1 to allow startup with the oxygen concentration limit not met is not needed. To make TS 3.3.1.b consistent with the requirements of STS 3.6.3.2, Required Action A.1 and its associated CT, the licensee proposed revising TS 3.3.1.b as follows:
- b.
If the containment oxygen concentration is greater than or equal to the four percent by volume limit while in the power operating condition then restore oxygen concentration to within limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and for transitory conditions during startup, shutdown and maintenance activities, restore the oxygen concentration to within the limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
NMP-1 TS 3.3.1.c requires that if the oxygen concentration is not restored to within the 4 percent concentration limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, then the plant must exit the power operating condition within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and transition to the NMP-1 plant-specific reactor operating condition Shutdown Condition - Hot 212°F which correlates to the STS Mode 3. Since the existing NMP-1 TS already requires the plant to enter a condition equivalent to Mode 3 with the same CT identified in TSTF-568, the associated changes to STS 3.6.3.2, Condition B and Required Action B.1 are not requested as part of the licensees LAR.
The licensee also provided the associated NMP-1 TS Bases mark-ups for TS 3.3.1 for information only, showing the corresponding STS Bases changes identified in TSTF-568 in a table as part of the proposed license amendment.
2.2.2 TSTF-568 TS Changes for Drywell-to-Suppression Chamber Differential Pressure NMP-1 does not have a TS controlling the drywell-to-suppression chamber differential pressure.
The licensee stated that the changes in TSTF-568 applicable to TS 3.6.2.5, Drywell-to-Suppression Chamber Differential Pressure, are not applicable to NMP-1. Accordingly, these changes are not requested as part of the licensees LAR.
2.3 Applicable Regulatory Requirements and Guidance Section 50.90 of 10 CFR, Application for amendment of license, construction permit, or early site permit, requires that whenever a licensee desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
Under 10 CFR 50.92(a), determinations on whether to grant an applied-for license amendment are to be guided by the considerations that govern the issuance of initial licenses or construction permits to the extent applicable and appropriate. Both the common standards for licenses and construction permits in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public.
The regulation, 10 CFR 50.36, Technical specifications, establishes the regulatory requirements related to the content of TSs. Section 50.36(a)(1) requires an application for an operating license to include proposed TSs. A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, must also be included in the application, but shall not become part of the TSs.
The regulation in 10 CFR 50.36(b) requires:
Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.
The categories of items required to be in the TSs are listed in 10 CFR 50.36(c).
The regulation in 10 CFR 50.36(c)(2) defines LCOs as the lowest functional capability or performance levels of equipment required for safe operation of the facility. When LCOs are not met, the licensee must shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. In addition, 10 CFR 50.36(c)(2)(ii)(B) requires that a TS LCO of a nuclear reactor be established for a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The regulation, 10 CFR 50.44(b)(2)(i), states that All boiling water reactors with Mark I or Mark II type containments must have an inerted atmosphere. Section 50.44(a)(1) defines [i]nerted atmosphere as a containment atmosphere with less than 4 percent of oxygen by volume.
Chapter 6.2.1.1.C, Revision 7, Pressure-Suppression Type BWR Containments of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2007 (ML063600403) states:
The acceptability of LOCA pool dynamic loads for plants with Mark I containments is based on conformance with NRC acceptance criteria found in NUREG-0661.
The NRC staffs guidance for the review of TSs is in Chapter 16.0, Revision 3, Technical Specifications, of the SRP, March 2010 (ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the applicable reference STSs (i.e., the current STSs), as modified by NRC-approved travelers. The STS applicable to a plant of NMP-1s design is NUREG-1433, Revision 4.0, Standard Technical Specifications, General Electric Plants BWR/4, Volume 1, Specifications, and Volume 2, Bases, April 2012 (ML12104A192 and ML12104A193, respectively).
3.0 TECHNICAL EVALUATION
The proposed amendment is based on the NRC-approved TSTF-568, Revision 2. The NRC staff also considered the regulations and guidance discussed in Section 2.3 of this SE in its review. The licensee stated in the LAR:
CEG has reviewed the Safety Evaluation for TSTF-568 provided to the TSTF in a letter dated December 17, 2019. This review also included a review of the NRC's evaluation, as well as the information provided in TSTF-568. CEG has concluded that the justifications presented in TSTF-568 and the safety evaluation prepared by the NRC with respect to Primary Containment Oxygen Concentration are applicable NMP1 and justify the requested amendments for the incorporation of the changes to the NMP1 TS.
However, since several of the revisions to the STS identified in TSTF-568 were either already incorporated into the NMP-1 TS or not applicable to NMP-1, the licensee did not request all of the changes identified in TSTF-568. Accordingly, the NRC staffs review also includes the verification that the proposed changes in combination with the existing NMP-1 TSs are consistent with the intent and technical basis of TSTF-568.
3.1 TSTF-568 Changes to TS 3.6.2.5, Drywell-to-Suppression Chamber Differential Pressure NMP-1 does not have a TS controlling the drywell-to-suppression chamber differential pressure.
Accordingly, the changes in TSTF-568 applicable to TS 3.6.2.5 are not requested for NMP-1.
The NRC staff notes that the other changes to the TS identified in TSTF-568 related to oxygen concentration are independent of, and not contingent on, the drywell-to-suppression chamber changes in TSTF-568. Accordingly, the staff has determined the changes identified in TSTF-568 for TS 3.6.2.5 are not applicable to NMP-1. Therefore, the staff finds the regulation at 10 CFR 50.36(c)(2) will continue to be met since there is no effect on the lowest functional capability of equipment required for safe operation of the facility as it relates to protecting containment integrity.
3.2 Proposed Changes to NMP-1 TS 3.3.1 3.2.1 TSTF-568 Changes in the Applicability As stated in the NRC staffs final SE for the NRC-approved Traveler TSTF-568, the NRC staff found the changes in the applicability statement for Oxygen Concentration LCO to be acceptable because the changes are more restrictive as the applicability extends to Modes 1 and 2 without exception. Also, the applicability for this LCO is more restrictive since an unlikely LOCA event leading to a degraded core that could produce hydrogen has the highest probability of occurrence during Modes 1 and 2 conditions. Since the licensees TS 3.3.1 already has an applicability equivalent to the STS Modes 1 and 2, the staff agrees that the TSTF-568 changes for the applicability are not needed. Therefore, not adopting this change is acceptable.
3.2.2 TSTF-568 Changes on Applicability of LCO 3.0.4.c The approved Traveler TSTF-568, Revision 2, added the following note to Required Action A.1:
LCO 3.0.4.c is applicable. As stated in section 2.2.2 of this SE, the NMP-1 TSs do not have an equivalent TS to STS LCO 3.0.4; therefore, the addition of the note to NMP-1 TS 3.3.1 is not requested. STS LCO 3.0.4 prohibits entering the Applicability of a TS with the LCO not met unless one of the three LCO 3.0.4 exceptions apply, including the exception in STS LCO 3.0.4.c, which states, "When an allowance is stated in the individual value, parameter, or other Specification." STS LCO 3.0.4.c would allow entering the mode of applicability when the oxygen limit is not met. The staff agrees that the associated note to Required Action A.1 identified in TSTF-568 is not applicable to NMP-1 as there is no equivalent requirement in the NMP-1 TSs to STS LCO 3.0.4. Therefore, not adopting this change is acceptable.
3.2.3 Proposed Changes to NMP-1 TS 3.3.1.b (Equivalent to STS 3.6.3.2, Condition A)
As shown in section 2.2.1 of this SE, the NRC-approved TSTF-568, Revision 2 changed the CT in the STS from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72-hour CT is based on the following sequence of operations: allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to de-inert the containment to permit safe personnel access, allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform the required maintenance or repair work, and allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to inert the containment. This is consistent with the existing basis for the 72-hour time in the NMP-1 TS 3.3.1.b as indicated in the existing NMP-1 Bases for TS 3.3.1. In its approval of TSTF-568, the NRC staff determined that the presence of a higher oxygen concentration for the 72-hour CT is appropriate considering the low safety significance of the change for potential accidents and the additional restrictions and conservatisms in the revised applicability. Therefore, the staff agrees that no change is needed to the TS 3.3.1.b 72-hour restoration time.
STS 3.6.3.2, Condition A applies to any situation in which the oxygen concentration is not within limits. Regardless of the reason for the limit not being met (e.g., delayed inerting for startup, or to conduct a maintenance activity, etc.), Required Action A.1 requires the containment oxygen concentration to be restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. As noted in 3.2.2 above, the licensees equivalent specification to STS Condition A and Required Action A.1 is TS 3.3.1.b. which states:
If the containment oxygen concentration is greater than or equal to the four percent by volume limit while in the power operating condition and for transitory conditions during startup, shutdown and maintenance activities, restore the oxygen concentration to within the limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. [Emphasis added]
The licensee proposes to delete the text shown in bold above. The licensee stated that the reason for removing the text was to be more consistent with the TSTF-568 wording. The staff compared the requirements of TS 3.3.1.b to STS 3.6.3.2, Condition A and Required Action A.1 and finds that there is no difference in the actions required by the licensee or the operating conditions that would require the actions since the TS applicability is limited to the power operating condition both before and after the change. In addition, the language proposed for deletion by the licensee does not add any operating restriction or clarification to the requirement to restore the oxygen concentration to within its limits within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The staff finds the proposed change to TS 3.3.1.b is consistent with the 72-hour completion time technical basis as approved in TSTF-568, Revision 2, and is therefore, acceptable.
3.2.4 TSTF-568 Changes in Required Action B.1 and Its Associated CT As discussed in section 2.2.2 of this SE, the NRC-approved TSTF-568, Revision 2, revised the applicability statement of TS LCO 3.6.3.2 to Modes 1 and 2. If the oxygen concentration is not restored within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, then Condition B and Required Action B.1 require the mode of applicability to be exited. Accordingly, TSTF-568 modifies Required Action B.1 such that if the oxygen concentration cannot be restored within the required limit and within the CT of Required Action A.1, the reactor is required to be brought to Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In this mode, the reactor would be in a hot shutdown condition (control rods fully inserted) with all reactor vessel head bolts fully tensioned.
As stated in the NRC staffs final SE for Traveler TSTF-568, Revision 2, the NRC staff found the change to STS Required Action B.1 acceptable because it provides a more appropriate terminal action since it requires the plant to be placed in a mode in which the LCO does not apply and the oxygen concentration limit is no longer required. The previous terminal action allowed an indefinite period of operation at [15] percent RTP.
The equivalent NMP-1 TS to STS 3.6.3.2, Condition B and Required Action B.1 is NMP-1 TS 3.3.1.c. This TS requires NMP-1 to exit the power operating condition if the plant is unable to restore the oxygen concentration within its limit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This means that the plant must be transitioned to reactor operating condition Shutdown Condition - Hot 212°F which correlates to the STS Mode 3. Since the NMP-1 TS 3.3.1 already requires the plant to enter a condition equivalent to Mode 3 with the same CT as identified in TSTF-568, the staff agrees that changes are not necessary to TS 3.3.1.c.
3.
2.5 NRC Staff Conclusion
for Proposed Changes to TS 3.3.1 The NRC staff concludes the proposed changes to TS 3.3.1 are acceptable because it provides additional clarity regarding the applicability and actions of TS 3.3.1, "Oxygen Concentration.". In addition, the proposed changes in combination with the existing NMP-1 TS requirements for oxygen concentration are consistent with the intent and technical basis of TSTF-568. Therefore, the NRC staff concludes the proposed change is acceptable because it continues to protect containment integrity and meets 10 CFR 50.36(c)(2) by providing the lowest functional capability of equipment required for safe operation of the plant.
3.3 Additional Variations from TSTF-568 The licensee identified differences between the TSs for NMP-1 and NUREG-1433, upon which TSTF-568 is based. These differences included the TS numbering and nomenclature. The NRC staff determined that these differences do not affect the applicability of TSTF-568 for NMP-1.
Therefore, the changes proposed in the LAR are acceptable and continue to meet 10 CFR 50.36(c)(2).
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the New York State official was notified of the proposed issuance of the amendment on May 2, 2023. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (87 FR 65833, November 1, 2022). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: R. Elliott, NRR Date: June 23, 2023
ML23131A424 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NAME RGuzman KEntz VCusumano DATE 05/12/2023 5/12/2023 05/01/2023 OFFICE NRR/DSS/SCPB/BC OGC (NLO)
NRR/DORL/LPL1/BC NAME DScully for BWittick MSpencer HGonzález DATE 06/19/2023 06/15/2023 06/22/2023 OFFICE NRR/DORL/LPL1/PM NAME RGuzman DATE 06/23/2023