ML13106A146

Application to Modify Administrative Controls Section of WBN Unit 1 Technical Specifications (TS-WBN-13-01)

ML13106A146
Person / Time
Site:	Watts Bar
Issue date:	04/12/2013
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TS-WBN-13-01
Download: ML13106A146 (16)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 April 12, 2013 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant Unit 1 Facility Operating License No. NPF-90 NRC Docket No. 50-390

Subject:

Application to Modify Administrative Controls Section of WBN Unit I Technical Specifications (TS-WBN-13-01)

Reference:

1. Letter from NRC to TVA, "Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment Regarding Request to Adopt Technical Specifications Task Force (TSTF) Standards TS Change Traveler, TSTF-447, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors (TAC No. MD9603)", dated December 23, 2008.

In accordance with the provisions of 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Tennessee Valley Authority (TVA) is submitting a request for an amendment to Facility Operating License No. NPF-90 for Watts Bar Nuclear Plant (WBN) Unit 1.

This license amendment request (LAR) seeks to amend WBN Unit 1 Technical Specification (TS) 5.9.2. "Annual Radiological Environmental Operating Report," to delete the reference to collocated dosimeters in relation to the NRC TLD program. This change is consistent with NRC-approved Technical Specification Task Force (TSTF) change TSTF-348.

In addition, this LAR requests to correct a cross-reference error in TS 5.9.8, "Post Accident Monitoring System (PAMS) Report, "that was introduced with WBN Unit 1 Amendment 72, issued December 23, 2008 (Reference 1). provides a description of the proposed changes, technical evaluation of the proposed changes, regulatory evaluation, and a discussion of environmental considerations.

Attachments 1 and 2 to Enclosure 1 provide the existing TS pages marked-up to show the proposed changes. Attachments 3 and 4 to Enclosure 1 provide the existing TS pages retyped to show the proposed changes.

D02 0 Printed on recycled paper

U.S. Nuclear Regulatory Commission Page 2 April 12, 2013 TVA requests routine processing of this requested TS change by the NRC and that the implementation of the revised TS be within 30 days of NRC approval.

TVA has determined that there are no significant hazards considerations associated with the proposed change and that the change qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9).

The WBN Plant Operations Review Committee and the WBN Nuclear Safety Review Board have reviewed this proposed change and determined that operation of WBN, in accordance with the proposed change, will not endanger the health and safety of the public.

Additionally, in accordance with 10 CFR 50.91 (b)(1), TVA is sending a copy of this letter and the enclosure to the Tennessee Department of Environment and Conservation.

There is one regulatory commitment contained in this letter as described in Enclosure 2.

Please address any questions regarding this request to Ed Schrull at 423-751-3850.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 12th day of April 2013.

Respec Ily, J. S ea V* e P esident, Nuclear Licensing

Enclosures:

1. Evaluation of Proposed Changes

2. Regulatory Commitment cc (Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Watts Bar Nuclear Plant, Unit 1 NRC Senior Resident Inspector - Watts Bar Nuclear Plant, Unit 2 Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation

ENCLOSURE I TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT UNIT I EVALUATION OF PROPOSED CHANGES

Subject:

Application to Modify WBN Unit I Technical Specifications (TS-WBN-13-01)

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS

1. Proposed TS Changes (Mark-Ups) for WBN Unit 1

2. Proposed TS Changes (Final Typed) for WBN Unit 1 Page 1 of 7

1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Appendix A of Facility Operating License NPF-90 for Watts Bar Nuclear Plant (WBN) Unit 1. The Technical Specifications (TSs) to be amended include TS 5.9.2, "Annual Radiological Environmental Operating Report,"

and TS 5.9.8, "Post Accident Monitoring System (PAMS) Report."

The proposed change to TS 5.9.2 removes the requirement to provide data to the NRC associated with the thermoluminescent dosimeters (TLDs) that TVA has collocated with NRC TLDs. The NRC TLD Program was cancelled at the end of 1997. Therefore, there is no longer a need to report these results or to reference this program.

The proposed change to TS 5.9.8 corrects a cross-reference error introduced with the implementation of WBN Unit 1 License Amendment 72, issued December 23, 2008.

2.0 DETAILED DESCRIPTION TS 5.9.2, Annual Radiological Environmental Operating Report TS 5.9.2 states, "The report shall identify the TLD results that represent collocated dosimeters in relation to the NRC TLD program and the exposure period associated with each result." The NRC TLD Program was cancelled at the end of 1997, as reported in Press Release No. 98-08. Therefore, there is no longer a need to report these results or to reference this program.

This proposed change is consistent with NRC-approved Technical Specification Task Force (TSTF) Traveler TSTF-348.

TS 5.9.8. PAMS Report The following TS changes were approved in WBN Unit 1 License Amendment 72:

TS 3.3.3, Condition D Two Hydrogen Monitor Deleted Channels Inoperable SR 3.3.3.2 Perform COT on Hydrogen Deleted Monitor Channels TS Table 3.3.3-1 Item 13, Containment Deleted Hydrogen Concentration TS 3.6.7 Hydrogen Recombiners Deleted Deletion of TS 3.3.3, Condition D above resulted in Conditions E, F, and G being changed to Conditions D, E, and F, respectively. However, the proposed change failed to identify the impact on TS 5.9.8. TS 5.9.8 currently states:

'When a Report is required by Condition B or G of LCO 3.3.3, Post Accident Monitoring (PAM) Instrumentation, a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the Page 2 of 7

inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status."

TS 5.9.8 will be revised to read:

'When a Report is required by Condition B or F of LCO 3.3.3, Post Accident Monitoring (PAM) Instrumentation, a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status."

This change is necessary to ensure that TS 5.9.8 is consistent with the Required Actions specified in LCO 3.3.3, Condition F.

3.0 TECHNICAL EVALUATION

TS 5.9.2, Annual Radioloqical Environmental Operatingq Report The NRC monitoring program began in the 1970s as a joint effort between NRC and the States to independently compare the results of environmental measurements with those performed by NRC licensees. In Press Release No. 98-08, dated January 13, 1998, the NRC announced that it had ended its contract with 34 States to perform radiation monitoring around certain facilities as of the end of 1997. In Revision 1 of the STS, the last paragraph of Specification 5.6.2, "Annual Radiological Environmental Operating Report," contained the following reporting requirement statement.

[The report shall identify the TLD results that represent collocated dosimeters in relation to the NRC TLD program and the exposure period associated with each result.]

This statement was bracketed to indicate that it did not apply to facilities that did not participate in this program, i.e., plants that did not have collocated dosimeters. The NRC TLD program referred to by this statement, however, was the same program that the NRC canceled at the end of 1997. In 1999, the industry proposed TSTF-348 to delete this reporting requirement because without a program there would be no program results to report.

The NRC staff approved TSTF-348, Revision 0, on November 1, 1999. This TSTF revised Standard Technical Specifications (STS) 5.6.2, "Annual Radiological Environmental Operating Report," to delete reference to collocated dosimeters to reflect cancellation of the NRC environmental monitoring program with States.

This proposed change is consistent with NRC-approved TSTF-348, and is considered an administrative change because there is no longer a TLD program with results to report.

TS 5.9.8, PAMS Report On September 4, 2008 TVA submitted a license amendment request to revise the WBN Unit 1 TSs. The requested changes proposed to delete the TS requirements associated with hydrogen recombiners and hydrogen monitors.

Page 3 of 7

The license amendment request proposed the deletion of TS 3.6.7, "Hydrogen Recombiners," and the deletion of the requirements for the hydrogen monitors. The deletion of the requirements for hydrogen monitors was reflected in TS 3.3.3, with the deletion of Condition D, Surveillance Requirement (SR) 3.3.3.2, and TS Table 3.3.3-1, Item 13. The deletion of TS 3.3.3, Condition D resulted in Conditions E, F, and G being changed to Conditions D, E, and F, respectively. The change in Conditions E, F, and G designations was further reflected in the references to the Conditions within TS Table 3.3.3-1.

The proposed changes were consistent with NRC-approved TSTF-447, Revision 1, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors,"

with the exception that the changes to TS 5.9.8 were inadvertently omitted.

This license amendment will correct the above omission within TS 5.9.8 by reflecting the change in Condition G to Condition F.

The editorial change is administrative in nature, as it does not alter any TS requirements or operational restrictions and, therefore, does not affect plant safety.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements and Criteria TVA is proposing to remove the reporting requirement for collocated TLDs from WBN Unit 1 TS 5.9.2 (STS Specification 5.6.2) in accordance with the guidance of TSTF-348.

Deleting this reporting requirement is considered an administrative change because there is no longer an NRC TLD program with results to report.

The proposed changes to the cross-reference errors contained in TS 5.9.8 are administrative and do not affect any regulatory requirements or criteria.

4.2 Precedent TVA evaluated precedent license amendment requests in which the NRC had approved modification of TS 5.9.2 (STS Specification 5.6.2). TVA identified the following precedents that were applicable, in part, to the changes WVA is proposing in this LAR:

" Susquehanna Steam Electric Station, Units 1 and 2 - Issuance of Amendments Re: Adoption of Generic Changes to Improved Technical Specifications (TAC Nos.

MB3269 and MB3270), dated February 25, 2003.

• Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2 -Amendment Re: Revision to the Administrative Controls Section of the Technical Specifications (TAC Nos.

MB5416 and MB5417), dated July 16, 2003.

4.3 Significant Hazard Consideration The proposed amendment revises the WBN Unit 1 Technical Specification (TS)

Administrative Controls Section to incorporate a change previously approved for the Improved Standard Technical Specifications (ISTS). This change is reflected in NUREG-1431, Revision 4. This change removes a reporting requirement from Page 4 of 7

Specification 5.9.2, recognizing the cancellation of the Nuclear Regulatory Commission (NRC) environmental monitoring program with the States. In addition, a cross-referencing error between TS 3.3.3 and Specification 5.9.8 is resolved.

The Tennessee Valley Authority (TVA) has concluded that the changes to WBN Unit 1 Specifications 5.9.2 and 5.9.8 do not involve a significant hazards consideration. TVA's conclusion is based on its evaluation in accordance with 10 CFR 50.91(a)(1) of the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probabilityor consequence of an accidentpreviously evaluated?

Response: No.

The proposed changes do not require physical changes to plant systems, structures, or components. The proposed changes are administrative in nature and therefore, do not change the fundamental requirements of the Technical Specifications. Removal of the discussion of the NRC environmental monitoring program with the State reflects the cancellation of that program with the State. It does not alter any other environmental monitoring requirements. Therefore, the changes do not affect accident or transient initiation or consequences.

As described above, the proposed changes are administrative in nature and do not impact the operation of any equipment needed for the mitigation of an accident or any known accident initiators. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accidentpreviously evaluated?

Response: No.

The proposed changes are administrative in nature and therefore, do not change the fundamental requirements of the Technical Specifications. The proposed changes would not require any new or different accidents to be postulated, since no changes are being made to the plant that would introduce any new accident causal mechanisms. This license amendment request does not impact any plant systems that are potential accident initiators; nor does it have any significantly adverse impact on any accident mitigating systems.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significantreduction in a margin of safety?

Response: No.

Since the proposed changes are administrative in nature, they do not change the fundamental requirements of the Technical Specifications. The proposed Page 5 of 7

changes do not alter the permanent plant design, including instrument set points, nor does it change the assumptions contained in the safety analyses. Removal of the discussion of the NRC environmental monitoring program with the State reflects the cancellation of that program with the State. It does not alter any other environmental monitoring requirements. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's 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.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Technical Specification Task Force Standard Technical Specification Change Traveler TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors," Revision 1.

2. NRC Notice of Availability, "Model Application Concerning Technical Specification Improvement to Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process," dated September 12, 2003.

3. TVA Letter, Watts Bar Nuclear Plant (WBN) - Unit 1 - Technical Specifications (TS)

Change 08-03, "Request for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process," dated September 4, 2008.

4. NRC Letter, 'Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment Regarding Request to Adopt Technical Specifications Task Force (TSTF) Standards TS Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors" (TAC No. MD9603), dated December 23, 2008.

5. NRC Press Release No. 98-08, "NRC to End Environmental Monitoring Program with States," dated January 13, 1998.

Page 6 of 7

6. Technical Specification Task Force Improved Standard Technical Specification Change Traveler TSTF-348, "Cancellation of NRC Environmental Monitoring Program with States," Revision 0.

7. NRC Letter, NRC Approval of NEI Technical Specification Task Force travelers (TSTF)- 017, Rev. 2; -036, Rev. 4; -037, Rev. 2; -051, Rev. 2; -348; -350; and -351, dated November 1, 1999.

8. NRC Letter, "Susquehanna Steam Electric Station, Units 1 and 2 - Issuance of Amendments Re: Adoption of Generic Changes to Improved Technical Specifications (TAC Nos. MB3269 and MB3270)," dated February 25, 2003.

Page 7 of 7

ATTACHMENT I Proposed TS Changes (Mark-Ups) for WBN Unit I

Reporting Requirements 5.9 5.0 ADMINISTRATIVE CONTROLS 5.9 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.9.1 DELETED 5.9.2 Annual Radiological Environmental Operating Report

---

NOTE A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. The repo.t 6hall identify the TLDreOu that r*elpesent collo-ated dosimoters in relation to-the NRC TL"DIpFrgram and the exposure d a"ssociaited ,h "i*t* e*ah result. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

(continued)

Watts Bar- Unit 1 5.0-27 Amendment 57

Reporting Requirements 5.9 5.9 Reporting Requirements (continued) 5.9.7 EDG Failures Report If an individual emergency diesel generator (EDG) experiences four or more valid failures in the last 25 demands, these failures and any nonvalid failures experienced by that EDG in that time period shall be reported within 30 days. Reports on EDG failures shall include the information recommended in Regulatory Guide 1.9, Revision 3, Regulatory Position C.4, or existing Regulatory Guide 1.108 reporting requirement.

5.9.8 PAMS Report When a Report is required by Condition B or G F of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.9.9 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.7.2.12, Steam Generator (SG) Program. The report shall include:

a. The scope of inspections performed on each SG,

b. Active degradation mechanisms found,

c. Nondestructive examination techniques utilized for each degradation mechanism,

d. Location, orientation (if linear), and measured sizes (if available) of service induced indications,

e. Number of tubes plugged during the inspection outage for each active degradation mechanism,

f. Total number and percentage of tubes plugged to date,

g. The results of condition monitoring, including the results of tube pulls and in-situ testing, and

h. The effective plugging percentage for all plugging in each SG.

Watts Bar - Unit 1 5.0-32 Amendment 27, 38, 65

ATTACHMENT 2 Proposed TS Changes (Final Typed) for WBN Unit I

Reporting Requirements 5.9 5.0 ADMINISTRATIVE CONTROLS 5.9 Reporting Requirements The following reports shall be submitted in accordance with 10 CFR 50.4.

5.9.1 DELETED 5.9.2 Annual Radiological Environmental Operating Report

---

NOTE -------------------------

A single submittal may be made for a multiple unit station. The submittal should combine sections common to all units at the station.

The Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.

The Annual Radiological Environmental Operating Report shall include the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in the table and figures in the ODCM, as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results I are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted in a supplementary report as soon as possible.

(continued)

Watts Bar - Unit 1 5.0-27 Amendment 57

Reporting Requirements 5.9 5.9 Reporting Requirements (continued) 5.9.7 EDG Failures Report If an individual emergency diesel generator (EDG) experiences four or more valid failures in the last 25 demands, these failures and any nonvalid failures experienced by that EDG in that time period shall be reported within 30 days. Reports on EDG failures shall include the information recommended in Regulatory Guide 1.9, Revision 3, Regulatory Position C.4, or existing Regulatory Guide 1.108 reporting requirement.

5.9.8 PAMS Report When a Report is required by Condition B or F of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.9.9 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.7.2.12, Steam Generator (SG) Program. The report shall include:

a. The scope of inspections performed on each SG,

b. Active degradation mechanisms found,

c. Nondestructive examination techniques utilized for each degradation mechanism,

d. Location, orientation (if linear), and measured sizes (if available) of service induced indications,

e. Number of tubes plugged during the inspection outage for each active degradation mechanism,

f. Total number and percentage of tubes plugged to date,

g. The results of condition monitoring, including the results of tube pulls and in-situ testing, and

h. The effective plugging percentage for all plugging in each SG.

Wafts Bar - Unit 1 5.0-32 Amendment 27, 38, 65

ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT UNIT 1 REGULATORY COMMITMENT Update Watts Bar Nuclear Plant Unit 2 Technical Specifications Tennessee Valley Authority will provide a revision to the Watts Bar Nuclear Plant (WBN) Unit 2 Technical Specifications (TS) no later than June 4, 2013, to reflect the proposed changes to WBN Unit 1 TS 5.9.2 and TS 5.9.8, as submitted to the NRC on April 12, 2013.