ML14008A350

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Oyster Creek Nuclear Generating Station-Issuance of Amendment to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Per Month, Using the Consolidated Line Item Impr
ML14008A350
Person / Time
Site: Oyster Creek
Issue date: 05/27/2014
From: Lamb J G
Plant Licensing Branch 1
To: Pacilio M J
Exelon Nuclear
Lamb J G
References
TAC MF3242
Download: ML14008A350 (13)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 May 27, 2014

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION -ISSUANCE OF AMENDMENT TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522, "REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH," USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TAC NO. MF3242)

Dear Mr. Pacilio:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 282 to Renewed Facility Operating License No. DPR-16 and the technical specification (TS) for Oyster Creek Nuclear Generating Station, in response to your application dated December 12, 2013. The amendment modifies a TS requirement to operate a ventilation system with charcoal filters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month in accordance with TS Task Force (TSTF) Traveler TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month," to 15 continuous minutes using the Consolidated Line Item Improvement Process. A copy of the related Safety Evaluation is also enclosed.

Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket No. 50-219

Enclosures:

1. Amendment No. 282 to DPR-16 2. Safety Evaluation cc w/encls: Distribution via Listserv G. Lamb, Senior Project Manager nt Licensing Branch 1-2 ision of Operating Reactor Licensing Office of Nuclear Reactor Regulation UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 EXELON GENERATION COMPANY. LLC DOCKET NO. 50-219 OYSTER CREEK NUCLEAR GENERATING STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 282 Renewed License No. DPR-16 1. The Nuclear Regulatory Commission (the Commission) has found that: A. The application for amendment by Exelon Generation Company, LLC (the licensee), dated December 12, 2013, 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 the Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment IS in accordance with 1 0 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Renewed Facility Operating License No. DPR-16 is hereby amended to read as follows: (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 282, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.
3. This license amendment is as of the date of issuance, and shall be implemented within 60 days of issuance.

Attachment:

Changes to the License and Technical Specifications Date of Issuance:

May 27, 2014 FOR THE NUCLEAR REGULATORY COMMISSION Meena K. Khanna, Chief Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation ATTACHMENT TO LICENSE AMENDMENT NO. 282 RENEWED FACILITY OPERATING LICENSE NO. DPR-16 DOCKET NO. 50-219 Replace the following page of the Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change. Remove Page 3 Page 3 Replace the following page of the Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change. Remove 4.5-5 4.5-5 (3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, or special nuclear materials as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (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 materials without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate such byproduct, source, or special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter 1 and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below: (1) Maximum Power Level AmerGen Energy Company, LLC is authorized to operate the facility at steady-state power levels not in excess of 1930 megawatts (thermal) ( 100 percent rated power) in accordance with the conditions specified herein. (2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 282, are hereby incorporated in the license. AmerGen Energy Company, LLC shall operate the facility in accordance with the Technical Specifications.

(3) Fire Protection

  • Implemented AmerGen Energy Company, LLC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility and as approved in the Safety Evaluation Report dated March 3, 1978, and supplements thereto, subject to the following provision:

AMENDMENT NO. 282 (2) Results of laboratory carbon sample analysis show radioactive methyl iodide removal efficiency when tested in accordance with ASTM D 3803-1989 (30°C, 95% relative humidity, at least 45.72 feet per minute charcoal bed face velocity).

b. At the frequency specified in the Surveillance Frequency Control Program by demonstrating:

(1) That the pressure drop across a HEPA filter is equal to or less than the maximum allowable pressure drop indicated in Figure 4.5.1. (2) The inlet heater is capable of at least 10.9 KW input. (3) Operation with a total flow within 10% of design flow. c. At the frequency specified in the Surveillance Frequency Control Program by operating each circuit for a minimum of 15 continuous minutes. d. Anytime the HEPA filter bank or the charcoal absorbers have been partially or completely replaced, the test per 4.5.H.1.a(as applicable) will be performed prior to returning the system to OPERABLE STATUS. e. Automatic initiation of each circuit at the frequency specified in the Surveillance Frequency Control Progam. I. lnerting Surveillance When an inert atmosphere is required in the primary containment, the oxygen concentration in the primary containment shall be checked at the frequency specified in the Surveillance Frequency Control Program. J. Drywell Coating Surveillance Carbon steel test panels coated with Firebar D shall be placed inside the drywell near the reactor core midplane level. They shall be removed for visual observation and weight loss measurements during the first, second, fourth and eighth refueling outages. K. Instrument Line Flow Check Valves Surveillance The capability of a representative sample of instrument line flow check valves to isolate shall be tested at the frequency specified in the Surveillance Frequency Control Program. In addition, each time an instrument line is returned to service after any condition which could have produced a pressure flow disturbance in that line, the open position of the flow check valve in that line shall be verified.

Such conditions include: OYSTER CREEK 4.5-5 Amendment No.: 132,186,216,219,276, CarreGteEI ay letter af 3/18/{)2 2 8 2 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 282 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-16 EXELON GENERATION COMPANY. LLC OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219

1.0 INTRODUCTION

By letter dated December 12. 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 13351A412), Exelon Generation Company, LLC (Exelon or the licensee) requested changes to the technical specifications (TSs) for Oyster Creek Nuclear Generating Station (Oyster Creek). Specifically, the licensee requested to adopt the U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF) change to NUREG-1433, "Standard Technical Specifications General Electric Plants BWR/4" (STS), Traveler TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month" (ADAMS Accession No. ML 100890316), dated March 30, 2010. On June 23, 2009, the NRC approved TSTF-425, "Relocate Surveillance Frequencies to Licensee Control-RITSTF [risk-informed technical specification task force] Initiative 5b" (ADAMS Accession No. ML090900716).

This traveler relocated periodic surveillance frequencies to a licensee-control program, including the 31-day frequency of the subject Surveillance Requirements (SRs). Subsequently, the NRC approved Amendment No. 276, dated September 27, 2010 (ADAMS Accession No. ML 101930172), for Oyster Creek to adopt TSTF-425 to relocate most periodic frequencies of TS surveillances to a licensee-controlled program in TS 6.24 called the "Surveillance Frequency Control Program," or SFCP. As noted in the TSTF-522 model safety evaluation, some plants have adopted TSTF-425, which relocated certain TS SR frequencies to a licensee-controlled program. As stated above, the Oyster Creek TS have been previously revised to include the SFCP. Thus. the proposed changes are consistent with the licensee's current licensing basis, and the NRC's model safety evaluation, and therefore, do not constitute a deviation or variation from TSTF-522.

The proposed change would revise the SR, which currently requires operating the ventilation system for at least 10 continuous hours with the heaters operating at a frequency controlled in accordance with the SFCP. The SR would be changed to require at least 15 continuous minutes of ventilation system operation at a frequency controlled in accordance with the SFCP. The licensee stated that the license amendment request is consistent with NRC-approved Traveler TSTF-522.

The availability of this TS improvement was announced in the Federal Register on September 20,2012 (77 FR 58421), as part of the consolidated line item improvement process. The licensee identified the following variations or deviations from the TS changes described in TSTF-522 or the applicable parts of the NRC's model safety evaluation dated September 13, 2012 (ADAMS Accession No. ML 12158A464):

  • Oyster Creek TS 4.5.H, "Standby Gas Treatment System," does not require "continuous" operation for the duration of the SR test. However, the continuous operation requirement is stated in the TSTF-522 TS wording. Therefore, the continuous operation requirement is being added to the Oyster Creek TS to conform to the TSTF-522.
  • Oyster Creek TS 4.17, "Control Room Heating, Ventilating, and Air-Conditioning System," does not have an equivalent SR to STS Section 3.7.4, "Main Control Room Environmental Control (MCREC) System," to operate each ventilation subsystem for a specified period (i.e., 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />). Therefore, Oyster Creek is not pursuing the corresponding change forTS 4.17. This does not affect the applicability of TSTF-522 to the Oyster Creek TS 4.5.H. Changes were proposed forTS 4.5.H, "Standby Gas Treatment System." Specifically, TS 4.5.H.c, which currently requires operating the system for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> operating at a frequency controlled in accordance with the SFCP, would be changed to require at least 15 continuous minutes of ventilation system operation at a frequency controlled in accordance with the SFCP.

2.0 REGULATORY EVALUATION

One of the reasons air filtration and adsorption systems are required at nuclear power plants is to lower the concentration of airborne radioactive material that may be released from the site to the environment due to a design basis event. Lowering the concentration of airborne radioactive materials can mitigate doses to plant operators and members of the public in the event of a design basis event. A typical system consists of ventilation ductwork, fans, dampers, valves, instrumentation, prefilters or demisters, high efficiency particulate air (HEPA) filters, heaters, and activated charcoal adsorbers.

These systems are tested by operating the systems and monitoring the response of the overall system as well as individual components.

Laboratory tests of charcoal adsorbers are also performed to ensure the charcoal adsorbs an acceptable amount of radioactive gasses. Current testing requirements for the air filtration and adsorption systems state that the systems should be operated for at least 10 continuous hours with heaters operating at a frequency controlled by the SFCP. These requirements are based on NRC staff guidance for testing air filtration and adsorption systems that has been superseded.

New NRC staff guidance states at least 15 continuous minutes of ventilation system operation with heaters operating every 31 days is acceptable for those plants that test ventilation system adsorption at a relative humidity of less than 95 percent. Plants that test ventilation system adsorption at a relative humidity of 95 percent do not require heaters for the ventilation system to perform its specified safety function and the bracketed phrase "with heaters operating" is not included in the SR. The licensee has proposed revising the SR, which currently requires operating the ventilation system for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> operating at a frequency controlled in accordance with the SFCP. The SR would be changed to require at least 15 continuous minutes of ventilation system operation at a frequency controlled in accordance with the SFCP. The regulatory requirements for design and testing of these systems are contained in Title 10 of the Code of Federal Regulations (1 0 CFR) Section 50.67 and Part 100, as well as Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," General Design Criteria (GDC) 19, 41, 42, 43, and 61. Oyster Creek is not licensed to the 10 CFR 50, Appendix A, GDC. Oyster Creek's Updated Final Safety Analysis Report (UFSAR), Section 3.1, "Conformance with NRC General Design Criteria," provides an assessment against the GDC in effect on July 7, 1971. Regulatory Guide (RG) 1.52, Revision 2, "Design, Testing, and Maintenance Criteria for Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorbtion Units of Light-Water-Cooled Nuclear Power Plants," (ADAMS Accession No. ML003740139) was published in March 1978 to provide guidance and criteria acceptable to the NRC staff for licensees to implement the regulations in 10 CFR related to air filtration and adsorption systems. Regulatory Position 4.d of Revision 2 of RG 1.52 states that "[e]ach ESF [engineered safety feature] atmosphere cleanup train should be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month, with the heaters on (if so equipped), in order to reduce the buildup of moisture on the adsorbers and HEPA filters." The purpose of this position is to minimize the moisture content in the system and thereby enhance efficiency in the event the system is called upon to perform its design basis function.

The SR for General Electric Plants STS 3.6.4.3.1 and STS 3. 7.4.1, currently require operating the heaters in the respective ventilation and filtering systems for at least 10 continuous hours every 31 days. The STS Bases explain that operation of heaters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> would eliminate moisture on the charcoal adsorbers and HEPA filters. Subsequently, the NRC staff was informed that 10 continuous hours of system operation would dry out the charcoal adsorber for a brief period of time but, following heater de-energization, the level of moisture accumulation in adsorbers would rapidly return to the pre-test level. The NRC staff found this information persuasive and subsequently issued NRC Generic Letter (GL) 99-02: "Laboratory Testing of Nuclear-Grade Activated Charcoal" (Errata sheet under ADAMS Accession No. ML031110094).

GL 99-02 requested licensees to confirm their charcoal testing protocols accurately reflect the adsorber gaseous activity capture capability.

GL 99-02 also requested the licensees to account for the effects of moisture accumulation in adsorbers.

Therefore, the NRC staff updated RG 1.52 to include the new information (ADAMS Accession No. ML01171 0176). RG 1.52, Revision 3, Regulatory Position 6.1 states, "[e]ach ESF atmosphere cleanup train should be operated continuously for at least 15 minutes each month, with the heaters on (if so equipped), to justify the operability of the system and all its components." One of the reasons for the previous 1 0-hour requirement for ventilation system operation with heaters operating was to minimize the effects of moisture on the adsorber's ability to capture gaseous activity.

Consistent with RG 1.52, Revision 3, Oyster Creek TS 4.5.H, Standby Gas Treatment System, currently requires testing charcoal adsorbers in a manner to account for the effects of moisture on the adsorber's ability to capture gaseous activity by achieving greater than or equal to 95 percent radioactive methyl iodide removal efficiency when tested in accordance with ASTM D 3803-1989 (30°C, 95 percent relative humidity, at least 45.72 feet per minute charcoal bed face velocity).

Therefore, the licensee's proposed TS change from a minimum of 10 continuous hours to a minimum of 15 continuous minutes is consistent with the charcoal adsorber testing described in RG 1.52, Revision 3. The NRC's regulatory requirements related to the content of the TS are contained in 10 CFR 50.36. The regulations at 10 CFR 50.36 require that the TS include items in the following categories:

(1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCO); (3) SR; (4) design features; and (5) administrative controls.

TS SR are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCO will be met. The NRC's guidance for the format and content of licensee TS can be found in NUREG-1433, "Standard Technical Specifications General Electric Plants BWR/4." 3.0 TECHNICAL EVALUATION The NRC staff evaluated the licensee's proposed change against the applicable regulatory guidance in RG 1.52, Revision 3, guidance in the STS as modified by TSTF-522, and the regulatory requirements of 10 CFR 50.36. The NRC staff evaluated the licensee's proposed change against the applicable regulatory guidance in RG 1.52, Revision 3. The proposed change would require at least 15 minutes of system operation.

The NRC staff found that the proposed change is consistent with guidance in RG 1.52, Revision 3. The NRC staff evaluated the licensee's proposed change against the applicable regulatory guidance in the STS, as modified by TSTF-522.

The proposed change adopted the TS format and content, to the extent practicable, contained in the changes made to NUREG-1433, "Standard Technical Specifications General Electric Plants BWR/4" by TSTF-522.

The NRC staff found that the proposed change is consistent with guidance in the STS, as modified by TSTF-522.

The NRC staff compared the proposed change to the existing SR, as well as the regulatory requirements of 1 0 CFR 50.36. The existing SR provides assurance that the necessary quality of ventilation systems and components will be maintained and that the LCO will be met. The proposed change reduces the amount of required system operational time from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to 15 minutes. The 1 0-hour operational requirement for heaters was based on using the SR for General Electric Plants to eliminate moisture in the adsorbers and thus ensure the adsorbers would capture gaseous activity.

As discussed in Section 2.0, the effects of moisture on the adsorber's ability to capture gaseous activity are currently accounted for in the licensee's containment standby gas treatment ventilation system by performing testing at a relative humidity of 95 percent. Since the SR is no longer relied upon to ensure the effects of moisture on the adsorber's ability to capture gaseous activity are accounted for, the 1 0-hour heater operational requirement is unnecessary.

The NRC staff found that reducing the required minimum system operation time to 15 minutes, consistent with RG 1.52, Revision 3, in conjunction with the licensee's current TS standby gas treatment system charcoal filter test requirements, is sufficient to justify operability of the system and all its components.

The NRC staff found that the proposed SR meets the regulatory requirements of 10 CFR 50.36, because it provides assurance that the necessary quality of the standby gas treatment system ventilation system and components will be maintained and that the LCO will be met. Therefore, the NRC staff finds the proposed change acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New Jersey State official was notified of the proposed issuance of the amendment.

The Mr. Ron Zack of New Jersey State official had a comment. Mr. Zak questioned that since Oyster Creek is not a standard TS plant, how is the proposed SR controlled in accordance with the SFCP? On June 23, 2009, the NRC approved TSTF-425, "Relocate Surveillance Frequencies to Licensee Control-RITSTF Initiative 5b." This traveler relocated periodic surveillance frequencies to a licensee-control program, including the 31-day frequency of the subject SRs. Subsequently, the NRC approved Amendment No. 276, dated September 27, 2010, for Oyster Creek to adopt TSTF-425 to relocate most periodic frequencies of TS surveillances to a licensee-controlled program in TS 6.24 called the "Surveillance Frequency Control Program." 5.0 ENVIRONMENTAL CONSIDERATION The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs. 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.

The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding on February 4, 2014 (79 FR 6643). 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.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributor:

G. Waig and J. Lamb Date of issuance:

May 27, 2014 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION-ISSUANCE OF AMENDMENT TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-522, "REVISE VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS TO OPERATE FOR 10 HOURS PER MONTH," USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TAC NO. MF3242)

Dear Mr. Pacilio:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 282 to Renewed Facility Operating License No. DPR-16 and the technical specification (TS) for Oyster Creek Nuclear Generating Station, in response to your application dated December 12, 2013. The amendment modifies a TS requirement to operate a ventilation system with charcoal filters for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month in accordance with TS Task Force (TSTF) Traveler TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month," using the Consolidated Line Item Improvement Process. A copy of the related Safety Evaluation is also enclosed.

Notice of Issuance will be included in the Commission's biweekly Federal Register notice. Docket No. 50-219

Enclosures:

1. Amendment No. 282 to DPR-16 2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

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