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| number = ML062690432
| number = ML062690432
| issue date = 09/28/2006
| issue date = 09/28/2006
| title = Fort Calhoun Station - Staff'S Review of Steam Generator Tube Integrity Technical Specification Amendment (TAC No. MD2188)
| title = Staff'S Review of Steam Generator Tube Integrity Technical Specification Amendment
| author name = Kobetz T J
| author name = Kobetz T
| author affiliation = NRC/NRR/ADRO/DIRS/ITSB
| author affiliation = NRC/NRR/ADRO/DIRS/ITSB
| addressee name = Terao D
| addressee name = Terao D
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:September 28, 2006MEMORANDUM TO:David Terao, ChiefPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationFROM:Timothy J. Kobetz, Chief /RA/Technical Specifications BranchDivision of Inspections and Regional Support Office of Nuclear Reactor Regulation
{{#Wiki_filter:September 28, 2006 MEMORANDUM TO:                 David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:                           Timothy J. Kobetz, Chief /RA/
Technical Specifications Branch Division of Inspections and Regional Support Office of Nuclear Reactor Regulation


==SUBJECT:==
==SUBJECT:==
FORT CALHOUN STATION - STAFF'S REVIEW OF THESTEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT (TAC NO. MD2188)By letter dated May 30, 2006 (ML061510203) as supplemented by two letters dated August 30,2006 (ML062430402 and ML062480074), Omaha Public Power District (the licensee) submitted a license amendment request (LAR) regarding Fort Calhoun Station steam generator (SG) tube integrity technical specifications (TSs). The proposed amendment would revise the existing SG tube surveillance program to be consistent with the U.S. Nuclear Regulatory Commission'sapproved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-449, "Steam Generator Tube Integrity," Revision 4. TSTF-449 is part of the consolidated line item improvement process (CLIIP). The staff of the Technical Specifications Branch (ITSB) of the Division of Inspections andRegional Support (DIRS) has completed its review of the LAR. The staff's review is enclosed. Docket No.: 50-285
FORT CALHOUN STATION - STAFFS REVIEW OF THE STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT (TAC NO. MD2188)
By letter dated May 30, 2006 (ML061510203) as supplemented by two letters dated August 30, 2006 (ML062430402 and ML062480074), Omaha Public Power District (the licensee) submitted a license amendment request (LAR) regarding Fort Calhoun Station steam generator (SG) tube integrity technical specifications (TSs). The proposed amendment would revise the existing SG tube surveillance program to be consistent with the U.S. Nuclear Regulatory Commissions approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-449, Steam Generator Tube Integrity, Revision 4. TSTF-449 is part of the consolidated line item improvement process (CLIIP).
The staff of the Technical Specifications Branch (ITSB) of the Division of Inspections and Regional Support (DIRS) has completed its review of the LAR. The staffs review is enclosed.
Docket No.: 50-285


==Enclosure:==
==Enclosure:==
Staff Safety Evaluation CONTACTS: Trent l. Wertz, ITSB/DIRS          301-415-1568


ML062690432OFFICEITSB:DIRSBC:ITSB:DIRSBC:CSGB:DCINAMETLWertzTJKobetzALHiserDATE09/11/200609/25/200609/28/2006              SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. TOFACILITY OPERATING LICENSE NO. DPR-40OMAHA PUBLIC POWER DISTRICTFORT CALHOUN STATION UNIT 1DOCKET NO. 50- 28
Staff Safety Evaluation CONTACTS: Trent l. Wertz, ITSB/DIRS 301-415-1568


==51.0  INTRODUCTION==
ML062690432 OFFICE    ITSB:DIRS      BC:ITSB:DIRS          BC:CSGB:DCI NAME      TLWertz        TJKobetz              ALHiser DATE      09/11/2006     09/25/2006             09/28/2006 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.             TO FACILITY OPERATING LICENSE NO. DPR-40 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT 1 DOCKET NO. 50- 285
By letter dated May 30, 2006 (Agencywide Documents Access and Management System(ADAMS) Accession No. ML061510203), as supplemented by two letters dated August 30, 2006 (ADAMS Accession No. ML062430402 and ML062480074), Omaho Public Power District (OPPD, (the licensee) requested changes to the Technical Specifications (TSs) for the Fort Calhoun Station Unit No. 1 (Fort Calhoun). The supplements dated August 30, 2006, provided additional information that clarified the application, did not expand the scope of the applicationas originally noticed, and did not change the staff's original proposed no significant hazards consideration determination as published in the Federal Register on [DATE] ([  ] FR [  ]).]The proposed changes would revise the existing steam generator (SG) tube surveillanceprogram. The changes are modeled after TS Task Force (TSTF) traveler TSTF-449, Revision 4, "Steam Generator Tube Integrity," and the model safety evaluation prepared by the NuclearRegulatory Commission (NRC) and published in the Federal Register on March 2, 2005 (70 FR10298). In this regard, the scope of the application includes changes to the definition of leakage, changes to the primary-to-secondary leakage requirements, changes to the SG tube surveillance program (SG tube integrity), changes to the SG reporting requirements, and associated changes to the TS Bases.


==2.0 REGULATORY EVALUATION==
==1.0 INTRODUCTION==
The background, description, and applicability of the proposed changes associated with theSG tube integrity issue and the applicable regulatory requirements were included in the NRCstaff's model safety evaluation (SE) published in the Federal Register on March 2, 2005(70 FR 10298). The "Notice of Availability of Model Application Concerning TechnicalSpecification Improvement To Modify Requirements Regarding Steam Generator TubeIntegrity Using the Consolidated Line Item Improvement Process" was published in the FederalRegister on May 6, 2005 (70 FR 24126), and made the model SE available for licensees toreference.


==3.0  TECHNICAL EVALUATION==
By letter dated May 30, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML061510203), as supplemented by two letters dated August 30, 2006 (ADAMS Accession No. ML062430402 and ML062480074), Omaho Public Power District (OPPD, (the licensee) requested changes to the Technical Specifications (TSs) for the Fort Calhoun Station Unit No. 1 (Fort Calhoun). The supplements dated August 30, 2006, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on [DATE] ([ ] FR [ ]).]
The proposed changes would revise the existing steam generator (SG) tube surveillance program. The changes are modeled after TS Task Force (TSTF) traveler TSTF-449, Revision 4, Steam Generator Tube Integrity, and the model safety evaluation prepared by the Nuclear Regulatory Commission (NRC) and published in the Federal Register on March 2, 2005 (70 FR 10298). In this regard, the scope of the application includes changes to the definition of leakage, changes to the primary-to-secondary leakage requirements, changes to the SG tube surveillance program (SG tube integrity), changes to the SG reporting requirements, and associated changes to the TS Bases.


===3.1 Overview===
==2.0 REGULATORY EVALUATION==
In its May 30, 2006, application, and August 30, 2006, supplements, the licensee proposedchanges to the TSs that are modeled after Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-449, "Steam Generator Tube Integrity."  Therewere minor differences between TSTF-449 and the licensee's application. These included differences in the facility licensing basis (than that discussed in TSTF-449) and differences inTS numbering and format, since the licensee has a different TS format (than that assumed in TSTF-449). With respect to the differences in the facility licensing basis, the differences did not invalidatethe technical evaluation on TSTF-449; rather they resulted in the licensee having to slightlydeviate from some of the modifications discussed in TSTF-449. For example, in the Bases section for Steam Generator Tube Integrity, TSTF-449 indicated that the accident analysis for asteam generator tube rupture assumed the contaminated secondary fluid was only brieflyreleased to the atmosphere via safety valves and the majority is discharged to the main condenser. Since the licensee has a different licensing basis than the one described in the standard technical specifications (i.e., TSTF-449), they modified the TSTF-449 wording to accommodate their existing licensing Bases. Another example is that TSTF-449 has specific definitions for the modes of operation. For example, in TSTF-449, Mode 5 is referred to as cold shutdown and the average reactor coolant temperature during this mode must be less than 200-degrees Fahrenheit. For Fort Calhoun, the comparable mode is termed "cold shutdown condition", is referred to as "Operating Mode 4" and the cold-leg temperature must be less than 210-degrees Fahrenheit. These differences in Modes required the licensee to deviate from the changes discussed in TSTF-449 to remain consistent with the intent of TSTF-449. Since thesedifferences were minor in nature, they were consistent with the plant's licensing basis (e.g., in the level of detail incorporated into the TS Bases), and they were consistent with the intent ofTSTF-449, the NRC staff determined they were acceptable.With respect to the differences in the format of the technical specifications, this resulted in thelicensee having to relocate many of the TSTF-449 requirements into the appropriate sections of their technical specifications. In addition, there were some changes in the Bases Section of TSTF-449 that were not incorporated into the licensee's submittal since the licensee did nothave the corresponding paragraphs in their version of the Bases. For example, the licensee did not have several references to their steam generator tube surveillance program in their existingtechnical specifications so they did not need to delete these changes in order to adopt TSTF-449. Since these differences were administrative in nature and did not affect the technical adequacy of the submittal, the NRC staff determined they were acceptable.In addition to these minor changes, the licensee proposed to delete reference to a previouslyapproved sleeving (i.e., repair) method since this repair method would no longer be applicable to their replacement steam generators (which were being installed in 2006). Removal of the sleeving method as a repair method is acceptable since the licensee will be required to plugtubes that exceed the repair criteria and plugging is an acceptable method for removing tubesfrom service.The remainder of the application was generally consistent with TSTF-449. As a result, the staffdetermined that the model SE is applicable to this review and finds the proposed changes acceptable.Consistent with TSTF-449, the proposed TS changes include:  (1) a revised definition ofLEAKAGE, (2) a revised TS 2.1.1 "RCS (Reactor Coolant System) Operable Components," andTS 2.1.4, "RCS Operational Leakage Limits," (3) a new TS 2.23, "Steam Generator (SG) TubeIntegrity," (4) a revised TS 3.2, "Equipment and Sampling Tests," (5) a revised TS 3.17, "SteamGenerator Tubes Integrity," (6) a new TS 5.23, "Steam Generator (SG Program)," and (7) arevised Table of Content pages to reflect the proposed changes. 3.2  ConclusionThe proposed TS changes establish a programmatic, largely performance-based regulatoryframework for ensuring SG tube integrity is maintained. The NRC staff finds that it addresseskey shortcomings of the current framework by ensuring that SG programs are focused on accomplishing the overall objective of maintaining tube integrity. It incorporates performance  criteria for evaluating tube integrity that the NRC staff finds consistent with the structuralmargins and the degree of leak tightness assumed in the current plant licensing basis. The NRC staff finds that maintaining these performance criteria provides reasonable assurance thatthe SGs can be operated safely without increase in risk.The revised TSs will contain limited specific details concerning how the SG Program is toachieve the required objective of maintaining tube integrity; the intent being that the licenseewill have the flexibility to determine the specific strategy for meeting this objective. However, the NRC staff finds that the revised TSs include sufficient regulatory constraints on theestablishment and implementation of the SG Program such as to provide reasonable assurancethat tube integrity will be maintai ned.Failure to meet the performance criteria will be reportable pursuant to the requirements in10 CFR Parts 50.72 and 50.73. The NRC reactor oversight process provides a process bywhich the NRC staff can verify that the licensee has identified any SG Program deficiencies thatmay have contributed to such an occurrence and that appropriate corrective actions have been implemented.In conclusion, the NRC staff finds that the TS changes proposed by the licensee in its May 30,2006, application August 30, 2006 supplement conform to the requirements of 10 CFR 50.36and establish a TS framework that will provide reasonable assurance that SG tube integrity ismaintained without undue risk to public health and safety.The licensee included in its application the revised TS Bases to be implemented with the TSchange. The NRC staff finds that the TS Bases Control Program is the appropriate process forupdating the affected TS Bases pages and has, therefore, not included the affected Basespages with this amendment.


==4.0  STATE CONSULTATION==
The background, description, and applicability of the proposed changes associated with the SG tube integrity issue and the applicable regulatory requirements were included in the NRC staffs model safety evaluation (SE) published in the Federal Register on March 2, 2005 (70 FR 10298). The Notice of Availability of Model Application Concerning Technical Specification Improvement To Modify Requirements Regarding Steam Generator Tube Integrity Using the Consolidated Line Item Improvement Process was published in the Federal Register on May 6, 2005 (70 FR 24126), and made the model SE available for licensees to reference.
In accordance with the Commission's regulations, the [STATE] State official was notified of theproposed issuance of the amendments. The State official had no comments.


==5.0 ENVIRONMENTAL CONSIDERATION==
==3.0 TECHNICAL EVALUATION==
The amendments change a requirement with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20. The NRC staff hasdetermined that the amendments involve no significant increase in the amounts, and nosignificant change in the types, of any effluents that may be released offsite, and that there isno 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
([  ] FR [  ]). Accordingly, the amendment[s] meet the eligibility criteria for categorical exclusionset 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==
3.1 Overview In its May 30, 2006, application, and August 30, 2006, supplements, the licensee proposed changes to the TSs that are modeled after Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-449, Steam Generator Tube Integrity. There were minor differences between TSTF-449 and the licensee's application. These included differences in the facility licensing basis (than that discussed in TSTF-449) and differences in TS numbering and format, since the licensee has a different TS format (than that assumed in TSTF-449).
The Commission has concluded, based on the considerations discussed above that (1) there isreasonable assurance that the health and safety of the public will not be endangered byoperation in the proposed manner, (2) such activities will be conducted in compliance with theCommission'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.
With respect to the differences in the facility licensing basis, the differences did not invalidate the technical evaluation on TSTF-449; rather they resulted in the licensee having to slightly deviate from some of the modifications discussed in TSTF-449. For example, in the Bases section for Steam Generator Tube Integrity, TSTF-449 indicated that the accident analysis for a steam generator tube rupture assumed the contaminated secondary fluid was only briefly released to the atmosphere via safety valves and the majority is discharged to the main condenser. Since the licensee has a different licensing basis than the one described in the standard technical specifications (i.e., TSTF-449), they modified the TSTF-449 wording to accommodate their existing licensing Bases. Another example is that TSTF-449 has specific definitions for the modes of operation. For example, in TSTF-449, Mode 5 is referred to as cold shutdown and the average reactor coolant temperature during this mode must be less than 200-degrees Fahrenheit. For Fort Calhoun, the comparable mode is termed cold shutdown condition, is referred to as Operating Mode 4" and the cold-leg temperature must be less than 210-degrees Fahrenheit. These differences in Modes required the licensee to deviate from the changes discussed in TSTF-449 to remain consistent with the intent of TSTF-449. Since these differences were minor in nature, they were consistent with the plant's licensing basis (e.g., in the level of detail incorporated into the TS Bases), and they were consistent with the intent of TSTF-449, the NRC staff determined they were acceptable.
With respect to the differences in the format of the technical specifications, this resulted in the licensee having to relocate many of the TSTF-449 requirements into the appropriate sections of their technical specifications. In addition, there were some changes in the Bases Section of TSTF-449 that were not incorporated into the licensees submittal since the licensee did not have the corresponding paragraphs in their version of the Bases. For example, the licensee did not have several references to their steam generator tube surveillance program in their existing technical specifications so they did not need to delete these changes in order to adopt TSTF-449. Since these differences were administrative in nature and did not affect the technical adequacy of the submittal, the NRC staff determined they were acceptable.
In addition to these minor changes, the licensee proposed to delete reference to a previously approved sleeving (i.e., repair) method since this repair method would no longer be applicable to their replacement steam generators (which were being installed in 2006). Removal of the sleeving method as a repair method is acceptable since the licensee will be required to plug tubes that exceed the repair criteria and plugging is an acceptable method for removing tubes from service.
The remainder of the application was generally consistent with TSTF-449. As a result, the staff determined that the model SE is applicable to this review and finds the proposed changes acceptable.
Consistent with TSTF-449, the proposed TS changes include: (1) a revised definition of LEAKAGE, (2) a revised TS 2.1.1 RCS (Reactor Coolant System) Operable Components, and TS 2.1.4, "RCS Operational Leakage Limits," (3) a new TS 2.23, "Steam Generator (SG) Tube Integrity," (4) a revised TS 3.2, "Equipment and Sampling Tests," (5) a revised TS 3.17, "Steam Generator Tubes Integrity," (6) a new TS 5.23, Steam Generator (SG Program), and (7) a revised Table of Content pages to reflect the proposed changes.
3.2 Conclusion The proposed TS changes establish a programmatic, largely performance-based regulatory framework for ensuring SG tube integrity is maintained. The NRC staff finds that it addresses key shortcomings of the current framework by ensuring that SG programs are focused on accomplishing the overall objective of maintaining tube integrity. It incorporates performance criteria for evaluating tube integrity that the NRC staff finds consistent with the structural margins and the degree of leak tightness assumed in the current plant licensing basis. The NRC staff finds that maintaining these performance criteria provides reasonable assurance that the SGs can be operated safely without increase in risk.
The revised TSs will contain limited specific details concerning how the SG Program is to achieve the required objective of maintaining tube integrity; the intent being that the licensee will have the flexibility to determine the specific strategy for meeting this objective. However, the NRC staff finds that the revised TSs include sufficient regulatory constraints on the establishment and implementation of the SG Program such as to provide reasonable assurance that tube integrity will be maintained.
Failure to meet the performance criteria will be reportable pursuant to the requirements in 10 CFR Parts 50.72 and 50.73. The NRC reactor oversight process provides a process by which the NRC staff can verify that the licensee has identified any SG Program deficiencies that may have contributed to such an occurrence and that appropriate corrective actions have been implemented.
In conclusion, the NRC staff finds that the TS changes proposed by the licensee in its May 30, 2006, application August 30, 2006 supplement conform to the requirements of 10 CFR 50.36 and establish a TS framework that will provide reasonable assurance that SG tube integrity is maintained without undue risk to public health and safety.
The licensee included in its application the revised TS Bases to be implemented with the TS change. The NRC staff finds that the TS Bases Control Program is the appropriate process for updating the affected TS Bases pages and has, therefore, not included the affected Bases pages with this amendment.


==7.0 REFERENCES==
==4.0 STATE CONSULTATION==
A complete list of references used to complete this review can be found in the NRC's model SEpublished in the Federal Register on March 2, 2005 (70 FR 10298).Principal Contributor: Trent L. WertzDate: September 11, 2006}}
 
In accordance with the Commission's regulations, the [STATE] State official was notified of the proposed issuance of the amendments. The State official had no comments.
 
==5.0 ENVIRONMENTAL CONSIDERATION==
 
The amendments change 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 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
([ ] FR [ ]). Accordingly, the amendment[s] 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) 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.
 
==7.0 REFERENCES==
 
A complete list of references used to complete this review can be found in the NRCs model SE published in the Federal Register on March 2, 2005 (70 FR 10298).
Principal Contributor: Trent L. Wertz Date: September 11, 2006
                                            }}

Latest revision as of 01:28, 14 March 2020

Staff'S Review of Steam Generator Tube Integrity Technical Specification Amendment
ML062690432
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 09/28/2006
From: Kobetz T
NRC/NRR/ADRO/DIRS/ITSB
To: Terao D
NRC/NRR/ADRO/DORL/LPLIV
Wertz, Trent, NRR/DIRS, 301-415-1568
References
TAC MD2188
Download: ML062690432 (6)


Text

September 28, 2006 MEMORANDUM TO: David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Timothy J. Kobetz, Chief /RA/

Technical Specifications Branch Division of Inspections and Regional Support Office of Nuclear Reactor Regulation

SUBJECT:

FORT CALHOUN STATION - STAFFS REVIEW OF THE STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATION AMENDMENT (TAC NO. MD2188)

By letter dated May 30, 2006 (ML061510203) as supplemented by two letters dated August 30, 2006 (ML062430402 and ML062480074), Omaha Public Power District (the licensee) submitted a license amendment request (LAR) regarding Fort Calhoun Station steam generator (SG) tube integrity technical specifications (TSs). The proposed amendment would revise the existing SG tube surveillance program to be consistent with the U.S. Nuclear Regulatory Commissions approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-449, Steam Generator Tube Integrity, Revision 4. TSTF-449 is part of the consolidated line item improvement process (CLIIP).

The staff of the Technical Specifications Branch (ITSB) of the Division of Inspections and Regional Support (DIRS) has completed its review of the LAR. The staffs review is enclosed.

Docket No.: 50-285

Enclosure:

Staff Safety Evaluation CONTACTS: Trent l. Wertz, ITSB/DIRS 301-415-1568

ML062690432 OFFICE ITSB:DIRS BC:ITSB:DIRS BC:CSGB:DCI NAME TLWertz TJKobetz ALHiser DATE 09/11/2006 09/25/2006 09/28/2006 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. TO FACILITY OPERATING LICENSE NO. DPR-40 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT 1 DOCKET NO. 50- 285

1.0 INTRODUCTION

By letter dated May 30, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML061510203), as supplemented by two letters dated August 30, 2006 (ADAMS Accession No. ML062430402 and ML062480074), Omaho Public Power District (OPPD, (the licensee) requested changes to the Technical Specifications (TSs) for the Fort Calhoun Station Unit No. 1 (Fort Calhoun). The supplements dated August 30, 2006, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on [DATE] ([ ] FR [ ]).]

The proposed changes would revise the existing steam generator (SG) tube surveillance program. The changes are modeled after TS Task Force (TSTF) traveler TSTF-449, Revision 4, Steam Generator Tube Integrity, and the model safety evaluation prepared by the Nuclear Regulatory Commission (NRC) and published in the Federal Register on March 2, 2005 (70 FR 10298). In this regard, the scope of the application includes changes to the definition of leakage, changes to the primary-to-secondary leakage requirements, changes to the SG tube surveillance program (SG tube integrity), changes to the SG reporting requirements, and associated changes to the TS Bases.

2.0 REGULATORY EVALUATION

The background, description, and applicability of the proposed changes associated with the SG tube integrity issue and the applicable regulatory requirements were included in the NRC staffs model safety evaluation (SE) published in the Federal Register on March 2, 2005 (70 FR 10298). The Notice of Availability of Model Application Concerning Technical Specification Improvement To Modify Requirements Regarding Steam Generator Tube Integrity Using the Consolidated Line Item Improvement Process was published in the Federal Register on May 6, 2005 (70 FR 24126), and made the model SE available for licensees to reference.

3.0 TECHNICAL EVALUATION

3.1 Overview In its May 30, 2006, application, and August 30, 2006, supplements, the licensee proposed changes to the TSs that are modeled after Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-449, Steam Generator Tube Integrity. There were minor differences between TSTF-449 and the licensee's application. These included differences in the facility licensing basis (than that discussed in TSTF-449) and differences in TS numbering and format, since the licensee has a different TS format (than that assumed in TSTF-449).

With respect to the differences in the facility licensing basis, the differences did not invalidate the technical evaluation on TSTF-449; rather they resulted in the licensee having to slightly deviate from some of the modifications discussed in TSTF-449. For example, in the Bases section for Steam Generator Tube Integrity, TSTF-449 indicated that the accident analysis for a steam generator tube rupture assumed the contaminated secondary fluid was only briefly released to the atmosphere via safety valves and the majority is discharged to the main condenser. Since the licensee has a different licensing basis than the one described in the standard technical specifications (i.e., TSTF-449), they modified the TSTF-449 wording to accommodate their existing licensing Bases. Another example is that TSTF-449 has specific definitions for the modes of operation. For example, in TSTF-449, Mode 5 is referred to as cold shutdown and the average reactor coolant temperature during this mode must be less than 200-degrees Fahrenheit. For Fort Calhoun, the comparable mode is termed cold shutdown condition, is referred to as Operating Mode 4" and the cold-leg temperature must be less than 210-degrees Fahrenheit. These differences in Modes required the licensee to deviate from the changes discussed in TSTF-449 to remain consistent with the intent of TSTF-449. Since these differences were minor in nature, they were consistent with the plant's licensing basis (e.g., in the level of detail incorporated into the TS Bases), and they were consistent with the intent of TSTF-449, the NRC staff determined they were acceptable.

With respect to the differences in the format of the technical specifications, this resulted in the licensee having to relocate many of the TSTF-449 requirements into the appropriate sections of their technical specifications. In addition, there were some changes in the Bases Section of TSTF-449 that were not incorporated into the licensees submittal since the licensee did not have the corresponding paragraphs in their version of the Bases. For example, the licensee did not have several references to their steam generator tube surveillance program in their existing technical specifications so they did not need to delete these changes in order to adopt TSTF-449. Since these differences were administrative in nature and did not affect the technical adequacy of the submittal, the NRC staff determined they were acceptable.

In addition to these minor changes, the licensee proposed to delete reference to a previously approved sleeving (i.e., repair) method since this repair method would no longer be applicable to their replacement steam generators (which were being installed in 2006). Removal of the sleeving method as a repair method is acceptable since the licensee will be required to plug tubes that exceed the repair criteria and plugging is an acceptable method for removing tubes from service.

The remainder of the application was generally consistent with TSTF-449. As a result, the staff determined that the model SE is applicable to this review and finds the proposed changes acceptable.

Consistent with TSTF-449, the proposed TS changes include: (1) a revised definition of LEAKAGE, (2) a revised TS 2.1.1 RCS (Reactor Coolant System) Operable Components, and TS 2.1.4, "RCS Operational Leakage Limits," (3) a new TS 2.23, "Steam Generator (SG) Tube Integrity," (4) a revised TS 3.2, "Equipment and Sampling Tests," (5) a revised TS 3.17, "Steam Generator Tubes Integrity," (6) a new TS 5.23, Steam Generator (SG Program), and (7) a revised Table of Content pages to reflect the proposed changes.

3.2 Conclusion The proposed TS changes establish a programmatic, largely performance-based regulatory framework for ensuring SG tube integrity is maintained. The NRC staff finds that it addresses key shortcomings of the current framework by ensuring that SG programs are focused on accomplishing the overall objective of maintaining tube integrity. It incorporates performance criteria for evaluating tube integrity that the NRC staff finds consistent with the structural margins and the degree of leak tightness assumed in the current plant licensing basis. The NRC staff finds that maintaining these performance criteria provides reasonable assurance that the SGs can be operated safely without increase in risk.

The revised TSs will contain limited specific details concerning how the SG Program is to achieve the required objective of maintaining tube integrity; the intent being that the licensee will have the flexibility to determine the specific strategy for meeting this objective. However, the NRC staff finds that the revised TSs include sufficient regulatory constraints on the establishment and implementation of the SG Program such as to provide reasonable assurance that tube integrity will be maintained.

Failure to meet the performance criteria will be reportable pursuant to the requirements in 10 CFR Parts 50.72 and 50.73. The NRC reactor oversight process provides a process by which the NRC staff can verify that the licensee has identified any SG Program deficiencies that may have contributed to such an occurrence and that appropriate corrective actions have been implemented.

In conclusion, the NRC staff finds that the TS changes proposed by the licensee in its May 30, 2006, application August 30, 2006 supplement conform to the requirements of 10 CFR 50.36 and establish a TS framework that will provide reasonable assurance that SG tube integrity is maintained without undue risk to public health and safety.

The licensee included in its application the revised TS Bases to be implemented with the TS change. The NRC staff finds that the TS Bases Control Program is the appropriate process for updating the affected TS Bases pages and has, therefore, not included the affected Bases pages with this amendment.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the [STATE] State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change 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 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

([ ] FR [ ]). Accordingly, the amendment[s] 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) 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.

7.0 REFERENCES

A complete list of references used to complete this review can be found in the NRCs model SE published in the Federal Register on March 2, 2005 (70 FR 10298).

Principal Contributor: Trent L. Wertz Date: September 11, 2006