ML16330A672

Issuance of Amendment Nos. 228 and 230, Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation (CAC MF7275 and MF7276)

ML16330A672
Person / Time
Site:	Diablo Canyon
Issue date:	01/05/2017
From:	Balwant Singal Plant Licensing Branch IV
To:	Halpin E Pacific Gas & Electric Co
Singal B
References
CAC MF7275, CAC MF7276
Download: ML16330A672 (25)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 5, 2017 Mr. Edward D. Halpin Senior Vice President, Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424

SUBJECT:

DIABLO CANYON POWER PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: REVISE TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATIONS TASK FORCE CHANGE TRAVELER TSTF-523, "GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION" (CAC NOS. MF7275 AND MF7276)

Dear Mr. Halpin:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 228 to Facility Operating License No. DPR-80 and Amendment No. 230 to Facility Operating License No. DPR-82 for the Diablo Canyon Power Plant, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated January 21, 2016, as supplemented by letter dated December 27, 2016.

The amendments revise TS 3.4.6, "RCS [Reactor Coolant System] Loops - MODE 4," TS 3.4.7, "RCS Loops - MODE 5, Loops Filled," TS 3.4.8, "RCS Loops - MODE 5, Loops Not Filled,"

TS 3.5.2, "ECCS [Emergency Core Cooling System] - Operating," TS 3.6.6, "Containment Spray and Cooling Systems," TS 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level," and TS 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level." The amendments modify TS requirements to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in Technical Specification Task Force (TSTF) Standard Technical Specifications Change Traveler TSTF-523, Revision 2.

E. Halpin A copy of the related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely, b~+- ~t\N'&Sl Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosures:

1. Amendment No. 228 to DPR-80

2. Amendment No. 230 to DPR-82

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PACIFIC GAS AND ELECTRIC COMPANY DOCKET NO. 50-275 DIABLO CANYON NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 228 License No. DPR-80

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Pacific Gas and Electric Company (the licensee), dated January 21, 2016, as supplemented by letter dated December 27, 2016, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

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 Facility Operating License No. DPR-80 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. 228, are hereby incorporated in the license. Pacific Gas & Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. DPR-80 and Technical Specifications Date of Issuance: January 5, 2017

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 PACIFIC GAS AND ELECTRIC COMPANY DOCKET NO. 50-323 DIABLO CANYON NUCLEAR POWER PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 230 License No. DPR-82

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Pacific Gas and Electric Company (the licensee), dated January 21, 2016, as supplemented by letter dated December 27, 2016, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2

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 Facility Operating License No. DPR-82 is hereby amended to read as follows:

(2) Technical Specifications (SSER 32. Section 8)* and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 230, are hereby incorporated in the license. Pacific Gas & Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of its date of issuance and shall be implemented within 180 days.

FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. DPR-82 and Technical Specifications Dateoflssuance:January S, 2017

ATTACHMENT TO LICENSE AMENDMENT NO. 228 TO FACILITY OPERATING LICENSE NO. DPR-80 AND AMENDMENT NO. 230 TO FACILITY OPERATING LICENSE NO. DPR-82 DIABLO CANYON POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323 Replace the following pages of the Facility Operating License Nos. DPR-80 and DPR-82, and 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.

Facility Operating License Nos. DPR-80 REMOVE INSERT 3 3 Facility Operating License Nos. DPR-82 REMOVE INSERT 3 3 Technical Specifications REMOVE INSERT 3.4-11 3.4-11 3.4-13 3.4-13 3.4-15 3.4-15 3.5-4 3.5-4 3.5-5 3.5-5 3.6-15 3.6-15 3.6-15a 3.9-5 3.9-5 3.9-7 3.9-7

(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 calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40, 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 License shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I 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 Pacific Gas and Electric Company is authorized to operate the facility at reactor core power levels not in excess of 3411 megawatts thermal (100% rated power) 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. 228 are hereby incorporated in the license.

Pacific Gas & Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Initial Test Program The Pacific Gas and Electric Company shall conduct the post-fuel-loading initial test program (set forth in Section 14 of Pacific Gas and Electric Company's Final Safety Analysis Report, as amended), without making any major modifications of this program unless modifications have been identified and have received prior NRC approval. Major modifications are defined as:

a. Elimination of any test identified in Section 14 of PG&E's Final Safety Analysis Report as amended as being essential; Amendment No. 228

(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 calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40, 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 License shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I 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 Pacific Gas and Electric Company is authorized to operate the facility at reactor core power levels not in excess of 3411 megawatts thermal (100% rated power) in accordance with the conditions specified herein.

(2) Technical Specifications (SSER 32. Section 8)* and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 230, are hereby incorporated in the license.

Pacific Gas & Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

(3) Initial Test Program (SSER 31. Section 4.4.1)

Any changes to the Initial Test Program described in Section 14 of the FSAR made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.

• The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. 230

RCS Loops - MODE 4 3.4.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Two required loops B.1 Suspend operations that Immediately inoperable. would cause introduction of coolant into the RCS OR with boron concentration less than required to meet SOM of LCO 3.1.1.

AND No RCS or RHR loop in B.2 Initiate action to restore Immediately operation. one loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RHR or RCS loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.6.2 Verify SG secondary side water levels are ~ 15% for In accordance with required RCS loops. the Surveillance Frequency Control Program SR 3.4.6.3 Verify correct breaker alignment and indicated power In accordance with are available to the required pump that is not in the Surveillance operation. Frequency Control Program SR 3.4.6.4 -------------------------------NOTE------------------------------ In accordance with Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the Surveillance entering MODE 4. Frequency Control Program Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water.

DIABLO CANYON - UNITS 1 & 2 3.4-11 Unit 1 - Amendment No. 4-J.a ~ ~ 200, 228 Unit 2 - Amendment No. 4-J.a ~ +w 2-04-, 230

RCS Loops - MODE 5, Loops Filled 3.4.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop inoperable. A.1 Initiate action to restore Immediately a second RHR loop to AND OPERABLE status.

OR Required SGs secondary A.2 Initiate action to restore Immediately side water levels not within required SG secondary limits. side water levels to within limits.

B. Required RHR loops B.1 Suspend operations that Immediately inoperable. would cause introduction of coolant into the RCS OR with boron concentration less than required to meet SDM of LCO 3.1.1.

AND No RHR loop in operation. B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify one RHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.7.2 Verify SG secondary side water level is;::: 15% in In accordance with required SGs. the Surveillance Frequency Control Program SR 3.4.7.3 Verify correct breaker alignment and indicated power In accordance with are available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program SR 3.4.7.4 Verify required RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program DIABLO CANYON - UNITS 1 & 2 3.4-13 Unit 1 - Amendment No. ~ +ag 200, 228 Unit 2 - Amendment No. ~ +§9 ~. 230

RCS Loops - MODE 5, Loops Not Filled 3.4.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. In accordance with the Surveillance Frequency Control Program SR 3.4.8.2 Verify correct breaker alignment and indicated power In accordance with are available to the required RHR pump that is not in the Surveillance operation. Frequency Control Program SR 3.4.8.3 Verify RHR loop locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program DIABLO CANYON - UNITS 1 & 2 3.4-15 Unit 1 - Amendment No. 39, 2-00, 228 Unit 2 - Amendment No. 35, 2-G-l, 230

ECCS - Operating 3.5.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 Verify the following valves are in the listed position In accordance with with power to the valve operator removed. the Surveillance Frequency Control Number Position Function Program 8703 Closed RHR to RCS Hot Legs 8802A Closed Safety Injection to RCS Hot Legs 88028 Closed Safety Injection to RCS Hot Legs 8809A Open RHR to RCS Cold Legs 88098 Open RHR to RCS Cold Legs 8835 Open Safety Injection to RCS Cold Legs 8974A Open Safety Injection Pump Recirc.

to RWST 89748 Open Safety Injection Pump Recirc.

to RWST 8976 Open RWST to Safety Injection Pumps 8980 Open RWST to RHR Pumps 8982A Closed Containment Sump to RHR Pumps 89828 Closed Containment Sump to RHR Pumps 8992 Open Spray Additive Tank to Eductor 8701 Closed RHR Suction

. 8702 Closed RHR Suction SR 3.5.2.2 ------------------------------N 0 TE---------------------------------

Not required to be met for system vent flow paths opened under administrative control.

Verify each ECCS manual, power operated, and In accordance with automatic valve in the flow path, that is not locked, the Surveillance sealed, or otherwise secured in position, is in the Frequency Control correct position. Program (continued)

DIA8LO CANYON - UNITS 1 & 2 3.5-4 Unit 1 - Amendment No. ~. 2-00, 228 Unit 2 - Amendment No. ~. G-:1-, 230

ECCS - Operating 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.2.3 Verify ECCS locations susceptible to gas In accordance with accumulation are sufficiently filled with water. the Surveillance Frequency Control Program SR 3.5.2.4 Verify each ECCS pump's developed head at the test In accordance with flow point is greater than or equal to the required the lnservice developed head. Testing Program.

SR 3.5.2.5 Verify each ECCS automatic valve in the flow path In accordance with that is not locked, sealed, or otherwise secured in the Surveillance position, actuates to the correct position on an actual Frequency Control or simulated actuation signal. Program SR 3.5.2.6 Verify each ECCS pump starts automatically on an In accordance with actual or simulated actuation signal. the Surveillance Frequency Control Program SR 3.5.2.7 Verify, for each ECCS throttle valve listed below, In accordance with each mechanical position stop is in the correct the Surveillance position. Frequency Control Program Charging Injection Safety Injection Throttle Valves Throttle Valves 8810A 8822A 88108 88228 8810C 8822C 88100 88220 SR 3.5.2.8 Verify, by visual inspection, each ECCS train In accordance with containment recirculation sump suction inlet is not the Surveillance restricted by debris and the suction inlet trash racks Frequency Control and screens show no evidence of structural distress Program or abnormal corrosion.

DIABLO CANYON - UNITS 1 & 2 3.5-5 Unit 1 - Amendment No. ~. ~. 228 Unit 2 - Amendment No. ~. ~. 230

Containment Spray and Cooling Systems 3.6.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 ---------------------------N0 TE------------------------------

Not required to be met for system vent flow paths opened under administrative control.

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Verify each containment spray manual, power In accordance with the operated, and automatic valve in the flow path Surveillance Frequency that is not locked, sealed, or otherwise secured in Control Program position is in the correct position.

SR 3.6.6.2 Operate each CFCU for.:::. 15 minutes. In accordance with the Surveillance Frequency Control Program SR 3.6.6.3 Verify component cooling water flow rate to each In accordance with the required CFCU is.:::. 1650 gpm. Surveillance Frequency Control Program SR 3.6.6.4 Verify containment spray locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program SR 3.6.6.5 Verify each containment spray pump's developed In accordance with the head at the flow test point is greater than or lnservice Testing equal to the required developed head. Program SR 3.6.6.6 Verify each automatic containment spray valve in In accordance with the the flow path that is not locked, sealed, or Surveillance Frequency otherwise secured in position, actuates to the Control Program correct position on an actual or simulated actuation signal.

SR 3.6.6.7 Verify each containment spray pump starts In accordance with the automatically on an actual or simulated actuation Surveillance Frequency signal. Control Program SR 3.6.6.8 Verify each CFCU starts automatically on an In accordance with the actual or simulated actuation signal. Surveillance Frequency Control Program (continued)

DIABLO CANYON - UNITS 1 & 2 3.6-15 Unit 1 - Amendment No. -1.J5, 200, 228 Unit 2 - Amendment No. ~. ~. 230

Containment Spray and Cooling Systems

3.6.6 SUR\J_f.:_l!J_f'l.t::J.gE REQUIREMENTS (continued)

SURVEILLANCE FF\EOUENCY SR 3.6.6.9 Verify each spray nozzle is unobstructed.

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***- -**** -------*

SR 3.6.6.10 Verify each CFCU stmts on low spE:!ed In accorclam:e with U1e Surveillance Frequency Control Program DIABLO CANYON UNITS 1 & 2 3 6-15a Unit 1 1\mendment No. 228 Unit 2 /\mc:ndment No 230

RHR and Coolant Circulation - High Water Level 3.9.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.5.1 With the reactor subcritical less than 57 hours6.597222e-4 days <br />0.0158 hours <br />9.424603e-5 weeks <br />2.16885e-5 months <br />, In accordance with the verify one RHR loop is in operation and circulating Surveillance reactor coolant at a flow rate of<:: 3000 gpm, Frequency Control OR Program With the reactor subcritical for 57 hours6.597222e-4 days <br />0.0158 hours <br />9.424603e-5 weeks <br />2.16885e-5 months <br /> or more, In accordance with the verify one RHR loop is in operation and circulating Surveillance reactor coolant at a flow rate of<:: 1300 gpm.

Frequency Control Program SR 3.9.5.2 Verify required RHR loop locations susceptible to In accordance with the gas accumulation are sufficiently filled with water. Surveillance Frequency Control Program DIABLO CANYON - UNITS 1 & 2 3.9-5 Unit 1 - Amendment No. 4-Ja, :2-00, 228 Unit 2 - Amendment No. 4-Ja, :2-G4, 230

RHR and Coolant C.irculation - Low Water Level 3.9.6 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 With the reactor subcritical less than 57 hours6.597222e-4 days <br />0.0158 hours <br />9.424603e-5 weeks <br />2.16885e-5 months <br />, In accordance with the verify one RHR loop is in operation and circulating Surveillance reactor coolant at a flow rate of:::: 3000 gpm, Frequency Control Program In accordance with the With the reactor subcritical for 57 hours6.597222e-4 days <br />0.0158 hours <br />9.424603e-5 weeks <br />2.16885e-5 months <br /> or more, Surveillance verify one RHR loop is in operation and circulating Frequency Control reactor coolant at a flow rate of~ 1300 gpm.

Program SR 3.9.6.2 Verify correct breaker alignment and indicated In accordance with the power available to the required RHR pump that is Surveillance not in operation. Frequency Control Program SR 3.9.6.3 Verify RHR loop locations susceptible to gas In accordance with the accumulation are sufficiently filled with water. Surveillance Frequency Control Program DIABLO CANYON - UNITS 1 & 2 3.9-7 Unit 1 - Amendment No . .:f.d.a, 2-00, 228 Unit 2 - Amendment No . .:f.d.a, ;w.:+., 230

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 228 TO FACILITY OPERATING LICENSE NO. DPR-80 AND AMENDMENT NO. 230 TO FACILITY OPERATING LICENSE NO. DPR-82 PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323

1.0 INTRODUCTION

By letter dated January 21, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16021A067), as supplemented by letter dated December 27, 2016 (ADAMS Accession No. ML16363A030), Pacific Gas and Electric Company (the licensee) requested changes to the Technical Specifications (TSs) for Diablo Canyon Power Plant, Units 1 and 2 (DCPP). Specifically, the licensee requested to adopt U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" (ADAMS Accession No. ML13053A075), dated February 21, 2013. The availability of this TS improvement was announced in the Federal Register on January 15, 2014 (79 FR 2700) as part of the Consolidated Line Item Improvement Process.

The proposed change would revise Surveillance Requirements (SRs) related to gas accumulation for the emergency core cooling system (ECCS). The proposed change would also add new SRs related to gas accumulation for the residual heat removal (RHR) and containment spray (CS) systems. TS Bases changes associated with these SRs would also be incorporated. The licensee stated that it has reviewed the information contained in the model safety evaluation dated December 23, 2013 (ADAMS Accession No. ML13255A169), and that the license amendment request is consistent with NRG-approved TSTF-523, Revision 2.

The supplemental letter dated December 27, 2016, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Federal Register on March 15, 2016 (81FR13844).

Enclosure 3

2.0 REGULATORY EVALUATION

2.1 Background Gas accumulation in reactor systems can result in water hammer, pump cavitation, and pumping of non-condensable gas into the reactor vessel. These effects may result in the subject system being unable to perform its specified safety function. The NRC issued Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," on January 11, 2008 (ADAMS Accession No. ML072910759), to address the issue of gas accumulation in ECCS, decay heat removal (OHR), and CS systems. The industry and NRC staff agreed that a change to the STS and plant-specific TS would be necessary to address some issues discussed in GL 2008-01.

TSTF-523 contains changes to the TS SRs and TS Bases to address the appropriate concerns in GL 2008-01. The licensee proposed amending the DCPP TS using a plant-specific adoption of the TSTF-523 changes.

2.2 Technical Specification Changes Changes were proposed for SRs 3.5.2.2, 3.5.2.3, 3.6.6.1, as well as the addition of new SRs 3.4.6.4, 3.4.7.4, 3.4.8.3, 3.6.6.4, 3.9.5.2, and 3.9.6.3 to TS 3.4.6, "RCS Loops - MODE 4,"

TS 3.4.7, "RCS Loops - MODE 5, Loops Filled," TS 3.4.8, "RCS Loops - MODE 5, Loops Not Filled," TS 3.5.2, "ECCS - Operating," TS 3.6.6, "Containment Spray and Cooling Systems,"

TS 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level," and TS 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level,"

respectively.

2.3 Regulatory Review The regulations in Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 or similar plant-specific principal design criteria provide design requirements. Appendix B to 10 CFR Part 50, the TSs, and the licensee's quality assurance programs provide operating requirements. The regulatory requirements of 10 CFR Part 50, Appendix A, that are applicable to gas management in the subject systems include: General Design Criteria (GDC) for Nuclear Power Plants, 1 Criterion 1, "Quality standards and records, Criterion 34, "Residual heat removal," Criterion 35, "Emergency core cooling,: Criterion, 36, "Inspection of emergency core cooling system," Criterion 37, "Testing of emergency core cooling system, Criterion 38, "Containment heat removal," Criterion 39, "inspection of containment heat removal system," and Criterion 40, "Testing of containment heat removal system." GDC 1 requires that the subject systems be designed, fabricated, erected, and tested to quality standards. GDC 34 requires an RHR system designed to maintain specified acceptable fuel design limits and to meet design conditions that are not exceeded if a single failure occurs and specified electrical power systems fail. GDCs 35, 36, and 37 require an ECCS design that meets performance, inspection, and testing requirements. Additionally, the regulations in 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," provide specified 1 DCPP was designed to comply with the Atomic Energy Commission (AEC) GDCs published in July 1967. As discussed in Appendix 3.1 Aof the Final Safety Analysis Report Update (FSARU), Revision 22 (ADAMS Accession No. ML15138A105), DCPP conforms to the intent of these GDCs. Appendix 3.1 A of the FSARU explains how the plant design conforms to the intent of the 10 CFR 50, Appendix A GDCs and provides a reference to the associated 1967 GDCs.

ECCS performance criteria. GDCs 38, 39, and 40 require a containment heat removal system design that meets performance, inspection, and testing requirements.

Quality assurance criteria provided in 10 CFR Part 50, Appendix B, that apply to gas management in the subject systems include: Criteria Ill, V, XI, XVI, and XVII. Criteria Ill and V require measures to ensure that applicable regulatory requirements and the design basis, as defined in 10 CFR 50.2, "Definitions," and as specified in the license application, are correctly translated into controlled specifications, drawings, procedures, and instructions. Criterion XI requires a test program to ensure that the subject systems will perform satisfactorily in service and requires that test results shall be documented and evaluated to ensure that test requirements have been satisfied. Criterion XVI requires measures to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances, are promptly identified and corrected, and that significant conditions adverse to quality are documented and reported to management.

Criterion XVII requires maintenance of records of activities affecting quality.

The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36(c). The regulations at 10 CFR 50.36, "Technical specifications," require that the TSs include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) design features; and (5) administrative controls. SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met. Typically, TS Section 5 requires that licensees establish, implement, and maintain written procedures covering the applicable procedures recommended in Appendix A to Regulatory Guide (RG) 1.33, Revision 2, "Quality Assurance Program Requirements (Operation)," February 1978 (ADAMS Accession No. ML003739995). Appendix A to RG 1.33, Revision 2, identifies instructions for filling and venting the ECCS and OHR system, as well as for draining and refilling heat exchangers. The STS and most licensee's TSs include SRs to verify that at least some of the subject systems piping is filled with water.

The NRC's guidance for the format and content of licensee TSs can be found in NUREG-1431, Revision 4.0, "Standard Technical Specifications - Westinghouse Plants" (ADAMS Accession No. ML12100A222).

Regulatory guidance for the NRC staff's review of containment heat removal systems, ECCS, and RHR systems is provided in the following revisions and sections of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR Edition" (SRP), during the review.

• Revision 5 of SRP Section 6.2.2, "Containment Heat Removal Systems,"

March 2007 (ADAMS Accession No. ML070160661), provides the procedures concerning the review of containment heat removal under post-accident conditions to help ensure compliance with GDCs 38, 39, and 40.

• Revision 5 of SRP Section 6.3, "Emergency Core Cooling System," March 2007 (ADAMS Accession No. ML070550068), provides the procedures concerning the review of ECCS to help ensure compliance with GDCs 35, 36, and 37.

• Revision 5 of SRP Section 5.4.7, "Residual Heat Removal (RHR) System,"

May 2010 (ADAMS Accession No. ML100680577), provides the procedures concerning the review of RHR system as it is used to cool the reactor coolant system during and following shutdown to help ensure compliance with GDC 34.

3.0 TECHNICAL EVALUATION

The proposed change adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1431 by TSTF-523.

The NRC staff compared the proposed changes to the existing SRs, as well as the regulatory requirements of 10 CFR 50.36(c).

The licensee proposed the following TS changes:

1. Add SR 3.4.6.4, which states "Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water," with a note that states "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering MODE 4," and a frequency of "In accordance with the Surveillance Frequency Control Program."

2. Add SR 3.4.7.4, which states "Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water," with a frequency of "In accordance with the Surveillance Frequency Control Program."

3. Add SR 3.4.8.3, which states "Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water," with a frequency of "In accordance with the Surveillance Frequency Control Program."

4. Add a note to SR 3.5.2.2, which states "Not required to be met for system vent flow paths opened under administrative control."

5. Revise the language for SR 3.5.2.3 from "Verify ECCS piping is full of water" to "Verify ECCS locations susceptible to gas accumulation are sufficiently filled with water."

6. Add a note to SR 3.6.6.1, which states "Not required to be met for system vent flow paths opened under administrative control."

7. Add SR 3.6.6.4, which states "Verify containment spray locations susceptible to gas accumulation are sufficiently filled with water" with a frequency of "In accordance with the Surveillance Frequency Control Program."

8. Revise numbering scheme for SRs 3.6.6.4 through 3.6.6.9 to 3.6.6.5 through 3.6.6.10 due to addition of SR 3.6.6.4.

9. Add SR 3.9.5.2, which states "Verify required RHR loop locations susceptible to gas accumulation are sufficiently filled with water," with a frequency of "In accordance with the Surveillance Frequency Control Program."

10. Add SR 3.9.6.3, which states "Verify RHR loop locations susceptible to gas accumulation are sufficiently filled with water," with a frequency of "In accordance with the Surveillance Frequency Control Program."

The new language for the SRs was developed using licensee responses to GL 2008-01 and the NRC discussion contained in Task Interface Agreement (TIA) 2008-03, "Emergency Core Cooling System (ECCS) Voiding Relative To Compliance With Surveillance Requirements (SR) 3.5.1.1, 3.5.2.3, and 3.5.3.1" (ADAMS Accession No. ML082560209). Many of the GL 2008-01 responses stated that licensees identified system locations susceptible to gas accumulation. In the TIA, the NRC stated that the intent of the TS SRs, which state "full of water," may be met if the licensee can establish, through an Operability Determination, that there is a reasonable expectation that the system in question will perform its specified safety function. Therefore the phrase, "sufficiently filled with water" was recommended for the proposed TS changes. In the TS, "sufficiently filled with water" is understood to mean "sufficiently filled with water to support Operability." The regulation at 10 CFR 50.36(c)(3) states that one of the purposes of the SR is to verify that the LCO is met. Therefore, the new SR language, "Verify the [system name] locations susceptible to gas accumulation are sufficiently filled with water," is acceptable since this language will allow the licensee to make a conclusion as to whether or not a system is operable.

The language for the notes that state that the SR does not have to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after entering Mode 4 is acceptable because the note provides a limited time to perform the surveillance after entering the Applicability of the LCO; however, under the DCPP TS usage rules (TS Section 1.4), the requirement to manage gas accumulation is not affected. The licensee must have confidence that the SR can be met or the LCO must be declared not met.

The language for the notes that allow the SRs to not be met for system vent flow paths opened under administrative control is necessary to allow the licensee to credit administratively controlled manual action to close the system vent flow path in order to maintain system Operability during system venting and performance of the proposed gas accumulation SR.

Therefore, these notes are acceptable.

The NRC staff concluded that the proposed SRs meet the regulatory requirements of 10 CFR 50.36 because they provide assurance that the necessary quality of systems and components will be maintained and that the LCO will be met. Therefore, the NRC staff concludes that the proposed amendment is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the California State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the 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 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 and there has been no public comment on such finding published in the Federal Register on March 15, 2016 (81 FR 13844). 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 Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Matthew Hamm, NRR/DSS/STSB Date: January 5, 2017

ML16330A672 *Memo dated 11 /22/16 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4-1/LA NRR/DSS/STSB/BC NRR/DSS/SRXB/BC NAME BSingal JBurkhardt AKlein* EOesterle**

DATE 12/12/16 12/09/16 11/22/16 12/12/16 OFFICE OGC (NLO w/comments) NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME BMizuno RPascarelli BSingal DATE 12/20/16 1/04/17 1/05/17