ML070610269

Issuance of Amendment No. 250 Adoption of TSTF-447 to Delete Requirements for Hydrogen Purge System - CLIIP

ML070610269
Person / Time
Site:	Fort Calhoun
Issue date:	06/06/2007
From:	Wang A B NRC/NRR/ADRO/DORL/LPLIV
To:	Ridenoure R T Omaha Public Power District
Wang A B, NRR/DORL/LPL4, 301-415-1445
Shared Package
ML070610267	List: ML070610269 ML070610273
References
TAC MD3854
Download: ML070610269 (14)

Text

June 6, 2007Mr. R. T. RidenoureVice President - Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

Post Office Box 550 Fort Calhoun, NE 68023-0550

SUBJECT:

FORT CALHOUN STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT RE: ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE (TSTF) CHANGE TRAVELER TSTF-447 TO DELETE REQUIREMENTS FOR HYDROGEN PURGE SYSTEM (TAC NO. MD3854)

Dear Mr. Ridenoure:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 250to Renewed Facility Operating License No. DPR-40 for the Fort Calhoun Station, Unit No. 1.

The amendment consists of changes to the Technical Specifications (TSs) in response to yourapplication dated December 20, 2006.The amendment deletes the TS requirements associated with the hydrogen purge system. The change is consistent with revisions of Section 50.44 of Title 10 of the Code of FederalRegulations, "Combustible gas control for nuclear power reactors," that became effective onOctober 16, 2003. This operating license improvement was made available by the NRC on September 25, 2003 (68 FR 55416) as part of the consolidated line item improvement process (CLIIP).A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will beincluded in the Commission's next biweekly Federal Register notice.Sincerely,/RA/Alan B. Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-285

Enclosures:

1. Amendment No. 250 to DPR-402. Safety Evaluationcc w/encls: See next page

Pkg ML070610267 (Amdt./License Pg ML070610269, TS Pgs ML070610273)OFFICENRR/LPL4/PMNRR/LPL4/LAADRO/ITSB/BCOGCNRR/LPL4/BCNAMEAWangJBurkhardtTKobetzJRund NLO w/ commentTHiltz:JND for TGH DATE6/6/076/6/072/27/073/22/076/6/07 April 2006Ft. Calhoun Station, Unit 1 cc:Winston & Strawn ATTN: James R. Curtiss, Esq.

1700 K Street, N.W.

Washington, DC 20006-3817ChairmanWashington County Board of Supervisors P.O. Box 466 Blair, NE 68008Mr. John Hanna, Resident InspectorU.S. Nuclear Regulatory Commission P.O. Box 310 Fort Calhoun, NE 68023Regional Administrator, Region IVU.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005Ms. Julia Schmitt, Manager Radiation Control Program Nebraska Health & Human Services R & L Public Health Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007Mr. David J. Bannister, ManagerFort Calhoun Station Omaha Public Power District Fort Calhoun Station FC-1-1 Plant P.O. Box 550 Fort Calhoun, NE 68023-0550Mr. Joe L. McManisManager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

P.O. Box 550 Fort Calhoun, NE 68023-0550Mr. Daniel K. McGheeBureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319 OMAHA PUBLIC POWER DISTRICTDOCKET NO. 50-285FORT CALHOUN STATION, UNIT NO. 1AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 250License No. DPR-401.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by the Omaha Public Power District (thelicensee), dated December 20, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment 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 license amendment will not be inimical to the commondefense 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 theCommission's regulations and all applicable requirements have been satisfied. 2.Accordingly, Renewed Facility Operating License No. DPR-40 is amended by changesto the Technical Specifications and paragraph 3.B. of Facility Operating License No. DPR-40, as indicated in the attachment to this license amendment.3.The license amendment is effective as of its date of issuance and shall be implementedwithin 120 days of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/RA Jack Donohew for Thomas G. Hiltz/Thomas G. Hiltz, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-40 and the Technical SpecificationsDate of Issuance: June 6, 2007 ATTACHMENT TO LICENSE AMENDMENT NO. 250RENEWED FACILITY OPERATING LICENSE NO. DPR-40DOCKET NO. 50-285Replace the following pages of the Renewed Facility Operating License No. DPR-40 and theAppendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.License PageREMOVEINSERT-3--3-TSsREMOVEINSERT2.6 - Page 22.6 - Page 23.2 - Page 123.2 - Page 12 (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 when associated with radioactive apparatus or components;(5)Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate,such byproduct and special nuclear materials as may be produced by operation of the facility.3.This renewed license shall be deemed to contain and is subject to the conditions specifiedin the following Commission regulations in 10 CFR Chapter 1: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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:A.Maximum Power LevelOmaha Public Power District is authorized to operate the Fort Calhoun Station, Unit 1,at steady state reactor core power levels not in excess of 1500 megawatts thermal (rate power).B.Technical SpecificationsThe Technical Specifications contained in Appendix A, as revised through AmendmentNo. 250 are hereby incorporated in the license. Omaha Public Power District shall loperate the facility in accordance with the Technical Specifications.C.Security and Safeguards Contingency PlansThe Omaha Public Power District shall fully implement and maintain in effect allprovisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Fort Calhoun Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan," submitted by letter dated May 19, 2006.Renewed Operating License No. DPR-40Amendment No. 250 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 250 TO RENEWED FACILITYOPERATING LICENSE NO. DPR-40OMAHA PUBLIC POWER DISTRICTFORT CALHOUN STATION, UNIT NO. 1DOCKET NO. 50-28

51.0INTRODUCTION

By application to the U.S. Nuclear Regulatory Commission (NRC, Commission) datedDecember 20, 2006 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML063550038), Omaha Public Power District (the licensee), requested a change to the Technical Specifications (TSs) for the Fort Calhoun Station, Unit No. 1. The proposed change would delete the TS requirements associated with the hydrogen purge system. The licensee proposed to (1) delete TS 2.6.(3), "Hydrogen Purge System," (2) delete item 17, "Hydrogen Purge System," in TS Table 3-5, "Minimum Frequencies For Equipment Tests," and (3) revise TS 2.6.(1).d, "Containment Integrity," on containment isolation valves.The NRC has revised Section 50.44 of Title 10 of the Code of Federal Regulations (10 CFR),"Combustible gas control for nuclear power reactors." The amended standards eliminated the requirements for hydrogen recombiners and relaxed the requirements for hydrogen and oxygen monitoring. In letters dated December 17, 2002, and May 12, 2003, the Nuclear Energy Institute (NEI) Technical Specification Task Force (TSTF) proposed to remove requirements for hydrogen recombiners and hydrogen and oxygen monitors from the standard technical specifications (STS) (NUREGs 1430-1434) on behalf of the industry. This proposed change is designated TSTF-447. Hydrogen purge systems are not part of the STS, however, the Commission eliminated the hydrogen release associated with a design-basis loss-of-coolant accident (LOCA) from Section 50.44 of 10 CFR and the associated requirements that necessitated the need for the back-up hydrogen vent and purge systems.The NRC staff prepared a model safety evaluation (SE) for the elimination of requirementsregarding containment hydrogen recombiners and the removal of requirements from the TSs for containment hydrogen and oxygen monitors and solicited public comment (67 FR 50374, published August 2, 2002) in accordance with the Consolidated Line Item Improvement Process (CLIIP). The use of the CLIIP in this matter is intended to help the NRC to efficiently process amendments that propose to remove the hydrogen recombiner and hydrogen and oxygen monitor requirements from the TSs. Licensees of nuclear power reactors to which the model SE applies were informed (68 FR 55416, published September 25, 2003) that they could request amendments conforming to the model, and, in such requests, should confirm the applicability of this SE to their reactors and provide the requested plant-specific verificationsand commitments.2.0REGULATORY REQUIREMENTSRegulatory Issue Summary (RIS) 2000-06, "Consolidated Line Item Improvement Process forAdopting Standard Technical Specification Changes for Power Reactors," was issued on March 20, 2000. The CLIIP is intended to improve the efficiency of NRC licensing processes.

This is accomplished by processing proposed changes to the STS in a manner that supports subsequent license amendment applications. The CLIIP includes an opportunity for the public to comment on proposed changes to the STS following a preliminary assessment by the NRC staff and finding that the change will likely be offered for adoption by licensees. The NRC staff evaluates any comments received for a proposed change to the STS and either reconsiders the change or proceeds with announcing the availability of the change for proposed adoption by licensees. Those licensees opting to apply for the subject change to the TSs are responsiblefor reviewing the staff's evaluation, referencing the applicable technical justifications, and providing any necessary plant-specific information. Each amendment application made in response to the notice of availability would be processed and noticed in accordance with applicable rules and NRC procedures.The Commission's regulatory requirements related to the content of the TSs are set forth in10 CFR 50.36. This regulation requires that the TS include items in five specific categories.

These categories include: 1) safety limits, limiting safety system settings and limiting control settings, 2) limiting conditions for operation (LCO), 3) surveillance requirements, 4) design features, and 5) administrative controls. However, the regulation does not specify the particular TS to be included in a plant's license.Additionally, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether anLCO is required to be included in the TS. These criteria are as follows:1.Installed instrumentation that is used to detect, and indicate in the controlroom, a significant abnormal degradation of the reactor coolant pressure boundary.2.A process variable, design feature, or operating restriction that is an initialcondition of a design-basis accident (DBA) or transient analysis that assumes either the failure of or presents a challenge to the integrity of a fission product barrier.3.A structure, system, or component that is part of the primary successpath and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.4.A structure, system, or component which operating experience orprobabilistic risk assessment has shown to be significant to public health and safety. Existing LCOs and related surveillances included as TS requirements which satisfy any of thecriteria stated above must be retained in the TS. Those TS requirements which do not satisfy these criteria may be relocated to other licensee-controlled documents.As part of the rulemaking that revised 10 CFR 50.44, the Commission retained requirements forensuring a mixed atmosphere, inerting Mark I and II containments, and providing hydrogen control systems capable of accommodating an amount of hydrogen generated from a metal-water reaction involving 75 percent of the fuel cladding surrounding the active fuel region in Mark III and ice condenser containments. The Commission eliminated the design-basisLOCA hydrogen release from 10 CFR 50.44 and consolidated the requirements for hydrogen and oxygen monitoring to 10 CFR 50.44 while relaxing safety classifications and licensee commitments to certain design and qualification criteria. The Commission also relocated without change the hydrogen control requirements in 10 CFR 50.34(f) to 10 CFR 50.44 and the high-point vent requirements from 10 CFR 50.44 to 10 CFR 50.46a.3.0EVALUATIONThe ways in which the requirements and recommendations for combustible gas control wereincorporated into the licensing bases of commercial nuclear power plants varied as a function of when plants were licensed. Plants that were operating at the time of the Three Mile Island (TMI), Unit 2, accident are likely to have been the subject of confirmatory orders that imposed the combustible gas control functions described in NUREG-0737, "Clarification of TMI Action Plan Requirements," as obligations. The issuance of plant-specific amendments adopting the changes of TSTF-447 to remove hydrogen recombiner and hydrogen and oxygen monitoring controls from the TSs supersede the combustible gas control-specific requirements imposed by post-TMI confirmatory orders.3.1Hydrogen Monitoring EquipmentSection 50.44(b)(1), the STS, and plant-specific TS currently contain requirements formonitoring hydrogen. Licensees have also made commitments to design and qualification criteria for hydrogen monitors in Item II.F.1, Attachment 6, of NUREG-0737 and RegulatoryGuide (RG) 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident." The hydrogen monitors are required to assess the degree of core damage during a beyond DBA and confirm that random or deliberate ignition has taken place. If an explosive mixture that could threaten containment integrity exists during a beyond DBA, then other severe accident management strategies, such as purging and/or venting, would need to be considered. The hydrogen monitors are needed to implement these severe accident management strategies.With the elimination of the design-basis LOCA hydrogen release, hydrogen monitors are nolonger required to mitigate DBAs and, therefore, the hydrogen monitors do not meet the definition of a safety-related component as defined in 10 CFR 50.2. RG 1.97 recommends classifying the hydrogen monitors as Category 1. RG 1.97 Category 1 is intended for key variables that most directly indicate the accomplishment of a safety function for DBA events and, therefore, are items usually addressed within the TSs. As part of the rulemaking to revise 10 CFR 50.44, the Commission found that the hydrogen monitors no longer meet the definition of Category 1 in RG 1.97. The Commission concluded that Category 3, as defined in RG 1.97, is an appropriate categorization for the hydrogen monitors because the monitors are required todiagnose the course of beyond DBAs. Hydrogen monitoring is not the primary means of indicating a significant abnormal degradation of the reactor coolant pressure boundary.

Section 4 of Attachment 2 to SECY-00-0198, "Status Report on Study of Risk-Informed Changes to the Technical Requirements of 10 CFR Part 50 (Option 3) and Recommendations on Risk-Informed Changes to 10 CFR 50.44 (Combustible Gas Control)," found that the hydrogen monitors were not risk-significant. Therefore, the NRC staff finds that hydrogen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in the TSs and, therefore, may be relocated to other licensee-controlled documents. However, because the monitors are needed to diagnose the course of beyond DBAs, each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing beyond DBAs.The elimination of Post-Accident Sampling System requirements from some plant-specific TSs(and associated CLIIP notices) indicated that during the early phases of an accident, safety-grade hydrogen monitors provide an adequate capability for monitoring containment hydrogen concentration. The NRC staff has subsequently concluded that Category 3 hydrogen monitors also provide an adequate capability for monitoring containment hydrogen concentration during the early phases of an accident.The licensee's hydrogen purge system is included in the TSs under Containment Systems(LCO 2.6(3)). Even though TSTF-447 did not include hydrogen purge systems (hydrogen purge systems are not included in the STS) the changes made to 10 CFR 50.44 regarding the LOCA hydrogen release would apply to hydrogen purge systems. The NRC staff finds the change regarding the hydrogen purge system is consistent with the intent of TSTF-447 and is consistent with the revised 10 CFR 50.44, meets 10 CFR 50.36, and therefore is acceptable.4.0VERIFICATIONS AND COMMITMENTSAs requested by the NRC staff in the notice of availability for this TS improvement, the licenseehas addressed the following plant-specific verifications and commitments.1.Each licensee should verify that it has, and make a regulatory commitment tomaintain, a hydrogen monitoring system capable of diagnosing beyond DBAs.

The licensee has verified that it has a hydrogen monitoring system capable of diagnosing beyond DBAs. The licensee has committed in its application to maintain the hydrogen monitors within its Updated Final Safety Analysis Report.

The licensee will implement this commitment as part of the implementation of the amendment.2.For plant designs with an inerted containment, each licensee should verify that ithas, and make a regulatory commitment to maintain, an oxygen monitoring system capable of verifying the status of the inert containment. This is not applicable as the licensee does not have an inerted containment.The NRC staff finds that reasonable controls for the implementation and for subsequentevaluation of proposed changes pertaining to the above regulatory commitments are provided by the licensee's administrative processes, including its commitment management program. The NRC staff has determined that the commitments do not warrant the creation of regulatoryrequirements which would require prior NRC approval of subsequent changes. The NRC staff has agreed that NEI 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes,"

provides reasonable guidance for the control of regulatory commitments made to the NRC staff (see RIS 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000). The commitments should be controlled in accordance with the industry guidance or comparable criteria employed by a specific licensee.

The NRC staff may choose to verify the implementation and maintenance of these commitments in a future inspection or audit.

5.0STATE CONSULTATION

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

6.0ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. TheCommission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (72 FR 4309; published on January 30, 2007). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) thereis 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.Principal Contributor: T. Wertz Date: June 6, 2007