ML082680184

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.

ML082680184
Person / Time
Site:	Watts Bar
Issue date:	09/04/2008
From:	Brandon M Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TVA-WBN-TS-08-03
Download: ML082680184 (12)

Text

September 4, 2008 TVA-WBN-TS-08-03 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Gentlemen:

In the Matter of the ) Docket No. 50-390 Tennessee Valley Authority )

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 Pursuant to 10 CFR 50.90, Tennessee Valley Authority (TVA) is submitting a request for a TS change (TS 08-03) to License NPF-90 for WBN Unit 1.

The proposed amendment will delete the TS requirements related to hydrogen recombiners and hydrogen monitors. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors, that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors. The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as part of the consolidated line item improvement process (CLIIP). provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitment. Enclosure 2 provides the existing TS pages marked-up to show the proposed change. Implementation of TSTF-447 also involves various changes to the TS Bases. The TS Bases changes will be submitted with a future update in accordance with WBN TS 5.6, Technical Specifications (TS) Bases Control Program."

TVA requests that the implementation of the revised TS be within 60 days of NRC approval.

U.S. Nuclear Regulatory Commission Page 2 September 4, 2008 In accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and enclosures to the Tennessee State Department of Public Health.

The commitment contained in this submittal is detailed in Section 6.1.1 of Enclosure 1.

If you have any questions about this change, please contact me at 423-365-1824.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 4th day of September, 2008.

Sincerely, Original signed by M. K. Brandon Manager, Site Licensing and Industry Affairs

Enclosures:

1. Description and Assessment of the Proposed Change

2. Proposed Technical Specification Changes Enclosures cc (Enclosures):

NRC Resident Inspector U.S. Nuclear Regulatory Commission Watts Bar Nuclear Plant Region II 1260 Nuclear Plant Road Sam Nunn Atlanta Federal Center Spring City, Tennessee 37381 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 ATTN: Patrick D. Milano, Project Manager Mr. Lawrence E. Nanny, Director U.S. Nuclear Regulatory Commission Division of Radiological Health Division of Operating Reactor Licensing 3rd Floor Office of Nuclear Reactor Regulation L & C Annex MS O-8 H4 401 Church Street Washington, DC 20555-0001 Nashville, Tennessee 37243

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY (TVA)

WATTS BAR NUCLEAR PLANT (WBN)

UNIT 1 TS-08-03 Description and Assessment

1.0 INTRODUCTION

The proposed License amendment deletes Technical Specification (TS) 3.6.7, Hydrogen Recombiners, and references to the hydrogen monitors in TS 3.3.3, Post Accident Monitoring (PAM) Instrumentation. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors, that became effective on October 16, 2003. The deletion of the requirements for the hydrogen recombiner and references to the hydrogen monitors resulted in numbering and formatting changes to other TS, which were otherwise unaffected by this proposed amendment.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors. The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as part of the consolidated line item improvement process (CLIIP) (Reference 1).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

TS 3.3.3, Condition D Two Hydrogen Monitor Deleted Channels Inoperable TS 3.3.3, 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 Other TS changes included in this request are limited to renumbering and formatting changes that resulted directly from the deletion of the above requirements related to hydrogen recombiners and hydrogen monitors.

As described in NRC-approved Revision 1 of TSTF-447, the changes to TS requirements results in changes to various TS Bases sections. The TS Bases changes will be submitted with a future update in accordance with WBN TS 5.6, Technical Specifications (TS) Bases Control Program."

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3.0 BACKGROUND

The background for this request is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this request are adequately addressed by the NRC Notice of Availability published on September 25, 2003, (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 TECHNICAL ANALYSIS

TVA has reviewed the safety evaluation (SE) published on September 25, 2003, (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staffs SE, as well as the supporting information provided to support TSTF-447.

In addition, TVA reviewed the staffs SE associated with Amendment No. 40 to the WBN Operating License (Reference 2). Amendment 40 approved the irradiation of up to 2304 Tritium-Producing Burnable Absorber Rods (TPBARs) in the reactor core. The TPBARs are an additional source of hydrogen that is unique to the WBN facility. The potential post-LOCA hydrogen contribution from this source was evaluated in the Amendment 40 SE. The contribution was shown to be small and the NRC staff concluded that the TPBARs are not a significant contributor to the post-LOCA hydrogen inventory. The SE for Amendment 40 did credit the use of the hydrogen recombiner system for maintaining the maximum containment hydrogen concentration at less than the lower flammability limit. However, the WBN Hydrogen Management System (i.e., hydrogen ignitors), which will remain in the WBN TS, will continue to provide an effective means for mitigating unacceptable post-LOCA hydrogen concentrations consistent with WBN's current licensing basis and the current regulatory requirements for Combustible Gas Control as specified in 10 CFR 50.44. Additionally, as noted in Amendment 40, the hydrogen concentration remains below 4% for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (section 2.6, p 20) which is consistent with the TSTF conclusion that the design basis LOCA does not contribute to the conditional probability of a large release of hydrogen within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the onset of core damage.

Based on these reviews, TVA has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to WBN Unit 1 and justify this amendment for the incorporation of the changes to the WBN TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

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6.1 Verification and Commitment As discussed in the model SE published in the Federal Register on September 25, 2003, (68 FR 55416) for this TS improvement, TVA is making the following verifications and regulatory commitment:

1. TVA has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at WBN and is making a regulatory commitment to maintain that capability. The hydrogen monitoring function will be included in the WBN Technical Requirements Manual. This regulatory commitment will be implemented in conjunction with the implementation of the proposed TS revision.

2. WBN does not have an inerted containment.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION TVA has reviewed the proposed no significant hazards consideration determination published on September 25, 2003, (68 FR 55416) as part of the CLIIP. TVA has concluded that the proposed determination presented in the notice is applicable to WBN, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 ENVIRONMENTAL EVALUATION TVA has reviewed the environmental evaluation included in the model SE published on September 25, 2003, (68 FR 55416) as part of the CLIIP. TVA has concluded that the NRC staffs findings presented in that evaluation are applicable to WBN, and the evaluation is hereby incorporated by reference for this requested TS change.

9.0 PRECEDENT This request is being made in accordance with the CLIIP. TVA is not proposing variations or deviations from the TS changes described in TSTF-447 or the NRC staffs model SE published on September 25, 2003 (68 FR 55416).

10.0 REFERENCES

1) Federal Register Notice: Notice of Availability of 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, published September 25, 2003 (68 FR 55416).

2) NRC letter to J. A. Scalice (TVA), Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment to Irradiate Up to 2304 Tritium-Producing Burnable Absorber Rods in the Reactor Core (TAC No. MB1884), dated September 23, 2002.

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ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT (WBN)

UNIT 1 TS-08-03 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

I. AFFECTED PAGE LIST Unit 1 3.3-42 3.3.43 3.3-44 3.3-45 3.6-20 3.6-21 II. MARKED PAGES See attached.

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PAM Instrumentation 3.3.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. --------------NOTE------------- C.1 Restore one channel to 7 days Not applicable to hydrogen OPERABLE status.

monitor channels.

One or more Functions with two required channels inoperable.

OR 14 16 Functions 3, 4, 15, and 17 with one required channel inoperable.

D. Two hydrogen monitor D.1 Restore one hydrogen monitor 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> channels inoperable. channel to OPERABLE status.

E. Required Action and E.1 Enter the Condition referenced Immediately associated Completion in Table 3.3.3-1 for the D Time of Condition C or D D channel.

not met.

F. As required by Required F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action E.1 and referenced E E in Table 3.3.3-1. AND D F.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> E

G. As required by Required G.1 Initiate action in accordance Immediately Action E.1 and referenced with Specification 5.9.8.

F in Table 3.3.3-1. F D

Watts Bar-Unit 1 3.3-42

PAM Instrumentation 3.3.3 SURVEILLANCE REQUIREMENTS 2

---

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

SR 3.3.3.1 and SR 3.3.3.3 apply to each PAM instrumentation Function in Table 3.3.3-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

SR 3.3.3.2 Perform COT on hydrogen monitor channels. 31 days SR 3.3.3.3 ---------------------------NOTES-------------------------------

1. Neutron detectors are excluded from CHANNEL 2 CALIBRATION. 16

2. Not applicable to Functions 11 and 17.

Perform CHANNEL CALIBRATION. 18 months SR 3.3.3.4 --------------------------NOTES-------------------------------

1. Verification of relay setpoints not required.

3 16

2. Only applicable to Functions 11 and 17.

Perform TADOT. 18 months Watts Bar-Unit 1 3.3-43

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 2)

Post Accident Monitoring Instrumentation APPLICABLE MODES CONDITION OR OTHER REFERENCED FROM SPECIFIED REQUIRED REQUIRED FUNCTION CONDITIONS CHANNELS/TRAINS ACTION E.1 D

1. Intermediate Range Neutron 1(a), 2(b), 3 2 F E Flux(g)

2. Source Range Neutron Flux 2 (c)

,3 2 F E

3. Reactor Coolant System (RCS) Hot 1,2,3 1 per loop F E Leg Temperature (T-Hot)

E

4. RCS Cold Leg Temperature (T- 1,2,3 1 per loop F Cold)

5. RCS Pressure (Wide Range) 1,2,3 3 F E

6. Reactor Vessel Water Level (f) (g) 1,2,3 2 G F

7. Containment Sump Water Level 1,2,3 2 F E (Wide Range)

8. Containment Lower Comp. 1,2,3 2 F E Atm. Temperature

9. Containment Pressure (Wide 1,2,3 2 F E (g)

Range)

10. Containment Pressure (Narrow 1,2,3 4 F E Range)

11. Containment Isolation Valve 1,2,3 2 per penetration F E (g) (d)(i)

Position flow path

12. Containment Radiation (High 1,2,3 2 upper containment G F Range) 2 lower containment

13. Containment Hydrogen 1,2,3 2 F Concentration (g)

E 13 14. RCS Pressurizer Level 1,2,3 3 F 14 15. Steam Generator (SG) Water Level 1,2,3 1/SG F E (g)

(Wide Range)

16. Steam Generator Water Level 1,2,3 3/SG F E 15 (Narrow Range)

(j) 16 17. AFW Valve Status 1,2,3 1 per valve F E (e)

18. Core Exit Temperature- 1,2,3 2 F E 17 Quadrant 1 (f)

(continued)

Watts Bar-Unit 1 3.3-44

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 2 of 2)

Post Accident Monitoring Instrumentation APPLICABLE MODES CONDITION OR OTHER REFERENCED FROM SPECIFIED REQUIRED REQUIRED FUNCTION CONDITIONS CHANNELS/TRAINS ACTION E.1 D

19. Core Exit Temperature- 1,2,3 2 (e) F E

Quadrant 2(f)

20. Core Exit Temperature- 1,2,3 2 (e) F E Quadrant 3(f)

21. Core Exit Temperature- 1,2,3 2 (e) F E Quadrant 4(f)

22. Auxiliary Feedwater Flow 1,2,3 2/SG F E

23. Reactor Coolant System 1,2,3 2 F E (h)

Subcooling Margin Monitor

24. Refueling Water Storage Tank 1,2,3 2 F E Water Level

25. Steam Generator Pressure 1,2,3 2/SG F E

26. Auxiliary Building Passive Sump 1,2,3 2 F E Level (j)

(a) Below the P-10 (Power Range Neutron Flux) interlocks.

(b) Above the P-6 (Intermediate Range Neutron Flux) interlocks.

(c) Below the P-6 (Intermediate Range Neutron Flux) interlocks.

(d) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, pressure relief valve, or check valve with flow through the valve secured.

(e) A channel consists of two core exit thermocouples (CETs).

(f) The ICCM provides these functions on a plasma display.

(g) Regulatory Guide 1.97, non-Type A, Category 1 Variables.

(h) This function is displayed on the ICCM plasma display and digital panel meters.

(i) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel.

(j) Watts Bar specific (not required by Regulatory Guide 1.97) non-Type A Category 1 variable.

Watts Bar-Unit 1 3.3-45

(Hydrogen Recombiners - DELETED) 3.6.7 3.6 CONTAINMENT SYSTEMS 3.6.7 Hydrogen Recombiners This Specification Deleted LCO 3.6.7 Two hydrogen recombiners shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One hydrogen recombiner A.1 Restore hydrogen recombiner 30 days inoperable. to OPERABLE status.

B. Two hydrogen recombiners B.1 Verify by administrative means 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. that the hydrogen control function is maintained. AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND B.2 Restore one hydrogen 7 days recombiner to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

Watts Bar-Unit 1 3.6-20 Amendment 55

(Hydrogen Recombiners - DELETED) 3.6.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.1 Perform a system functional test for each hydrogen 18 months recombiner.

SR 3.6.7.2 Visually examine each hydrogen recombiner enclosure and 18 months verify there is no evidence of abnormal conditions.

SR 3.6.7.3 Perform a resistance to ground test for each heater phase. 18 months THIS PAGE INTENTIONALLY LEFT BLANK Watts Bar-Unit 1 3.6-21