ML042040136
| ML042040136 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/09/2004 |
| From: | Tam P NRC/NRR/DLPM/LPD1 |
| To: | Crane C AmerGen Energy Co |
| Tam P, NRR/DLPM, 415-1451 | |
| References | |
| TAC MC2408 | |
| Download: ML042040136 (14) | |
Text
August 9, 2004 Mr. Christopher M. Crane President and Chief Nuclear Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION - ISSUANCE OF AMENDMENT RE: ELIMINATION OF REQUIREMENTS FOR HYDROGEN MONITORS (TAC NO. MC2408)
Dear Mr. Crane:
The Commission has issued the enclosed Amendment No. 246 to Facility Operating License No. DPR-16 for the Oyster Creek Nuclear Generating Station, in response to your application dated March 23, 2004.
The amendment eliminates the requirements in the Technical Specifications (TSs) related to hydrogen monitors. This is a TS improvement using the consolidated line item improvement process published in the Federal Register on September 25, 2003 (68 FR 55416).
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Peter S. Tam, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-219
Enclosures:
- 1. Amendment No. 246 to DPR-16
- 2. Safety Evaluation cc w/encls: See next page
August 9, 2004 Mr. Christopher M. Crane President and Chief Nuclear Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION - ISSUANCE OF AMENDMENT RE: ELIMINATION OF REQUIREMENTS FOR HYDROGEN MONITORS (TAC NO. MC2408)
Dear Mr. Crane:
The Commission has issued the enclosed Amendment No. 246 to Facility Operating License No. DPR-16 for the Oyster Creek Nuclear Generating Station, in response to your application dated March 23, 2004.
The amendment eliminates the requirements in the Technical Specifications (TSs) related to hydrogen monitors. This is a TS improvement using the consolidated line item improvement process published in the Federal Register on September 25, 2003 (68 FR 55416).
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Peter S. Tam, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-219
Enclosures:
- 1. Amendment No. 246 to DPR-16
- 2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC OGC CHolden PD1-1 R/F GHill (2) RLaufer TBoyce PTam SLittle ACRS PEselgroth, RI Accession Number: ML042040136 OFFICE CLIIP LPM PD1-1/PM PD1-1/LA OGC PDI-1/SC NAME WReckley PTam SLittle CMarco RLaufer DATE 7/7/04 7/22/04 7/22/04 8/5/04 8/06/04 OFFICIAL RECORD COPY
AMERGEN ENERGY COMPANY, LLC DOCKET NO. 50-219 OYSTER CREEK NUCLEAR GENERATING STATION AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.
246 License No. DPR-16
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by AmerGen Energy Company, LLC, et al., (the licensee), dated March 23, 2004, 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 10 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 Facility Operating License No. DPR-16 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 246, are hereby incorporated in the license. AmerGen Energy Company, LLC, shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of the date of issuance and shall be implemented within 60 days of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: August 9, 2004
ATTACHMENT TO LICENSE AMENDMENT NO. 246 FACILITY OPERATING LICENSE NO. DPR-16 DOCKET NO. 50-219 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages as indicated. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert 3.13-2 3.13-2 3.13-3 3.13-3 3.13-5 3.13-5 4.13-1 4.13-1 4.13-2 4.13-2
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 246 TO FACILITY OPERATING LICENSE NO. DPR-16 AMERGEN ENERGY COMPANY, LCC OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219
1.0 INTRODUCTION
By letter dated March 23, 2004, AmerGen Energy Company, LLC, (AmerGen, or the licensee) submitted an application for amendment to the Oyster Creek Nuclear Generating Station (OCNGS) Technical Specifications (TSs) (Accession No. ML040970230). The proposed changes would delete the TS requirements associated with hydrogen monitors.
The Nuclear Regulatory Commission (NRC) has revised 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-Cooled 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 to incorporate the amended standards. This proposed change is designated TSTF-447.
The NRC staff prepared a model safety evaluation (SE) for the elimination of requirements regarding containment hydrogen recombiners and the removal of requirements from 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 proposed amendments that remove the hydrogen recombiner and hydrogen and oxygen monitor requirements from TSs. Licensees of nuclear power reactors to which this model applies were informed (68 FR 55416; September 25, 2003) that they could request amendments conforming to the model, and, in such requests, should confirm the applicability of the model SE to their reactors and provide the requested plant-specific verifications and commitments.
2.0 BACKGROUND
Regulatory Issue Summary 2000-06, Consolidated Line Item Improvement Process for Adopting 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 TSs are responsible for reviewing the NRC staff's SE, 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 Commissions regulatory requirements related to the contents of TSs are set forth in 10 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 (LCOs), (3) surveillance requirements, (4) design features, and (5) administrative controls. However, the regulation does not specify the particular TSs to be included in a plants license.
Additionally, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether an LCO is required to be included in the TSs. These criteria are as follows:
- 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
- 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes 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 success path and which functions or actuates to mitigate a design basis accident 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 or probabilistic 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 the criteria stated above must be retained in the TSs. On the other hand, 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 for ensuring 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-basis loss-of-coolant accident (LOCA) 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.
3.0 EVALUATION The ways in which the requirements and recommendations for combustible gas control were incorporated 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 to adopt these changes, which would remove hydrogen recombiner and hydrogen and oxygen monitoring controls from TSs, supersede the combustible gas control specific requirements imposed by post-TMI confirmatory orders.
3.1 Hydrogen Recombiners The revised 10 CFR 50.44 no longer defines a design-basis LOCA hydrogen release, and eliminates requirements for hydrogen control systems to mitigate such a release. The installation of hydrogen recombiners and/or vent and purge systems required by 10 CFR 50.44(b)(3) was intended to address the limited quantity and rate of hydrogen generation that was postulated from a design-basis LOCA. The Commission has found that this hydrogen release is not risk-significant because the design-basis LOCA hydrogen release does not contribute to the conditional probability of a large release up to approximately 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. In addition, these systems were ineffective at mitigating hydrogen releases from risk-significant beyond-design-basis accidents (beyond-DBAs).
Therefore, the Commission eliminated the hydrogen release associated with a design-basis LOCA from 10 CFR 50.44 and the associated requirements that necessitated the need for the hydrogen recombiners and the backup hydrogen vent and purge systems. As a result, the NRC staff finds that requirements related to hydrogen recombiners no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in TSs and the existing TS requirements may, therefore, be eliminated for all plants. OCNGS does not have a specific TS requirement related to hydrogen recombiners; accordingly, the licensee did not propose a TS change related to this finding.
3.2 Hydrogen Monitoring Equipment Section 50.44(b)(1), the STS, and plant-specific TSs currently contain requirements for monitoring 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 Regulatory Guide (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 no longer 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 to diagnose 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 TSs and, therefore, may be relocated to other licensee-controlled documents.
The elimination of Post-Accident Sampling System requirements from some plant-specific TS (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.
However, because the monitors are required 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.
3.3 Oxygen Monitoring Equipment STS and many plant-specific TSs currently require oxygen monitoring to verify the status of the inert containment.1 Combustible gases produced by beyond-DBAs involving both fuel-1 The OCNGS TS include no requirement for oxygen monitors even though plant design includes an inerted containment. The licensee did not, therefore, include a TS change related to this finding. As recommended in the Notice of Availability, the licensee has
cladding oxidation and core-concrete interaction would be risk-significant for plants with Mark I and II containments if not for the inerted containment atmospheres. If an inerted containment were to become de-inerted during a beyond-DBA, then other severe accident management strategies, such as purging and venting, would need to be considered. The oxygen monitors are needed to implement these severe accident management strategies. Oxygen concentration also appears extensively in the emergency procedure guidelines/severe accident guidelines of plants with inerted containment atmospheres.
With the elimination of the design-basis LOCA hydrogen release, the oxygen monitors are no longer required to mitigate DBAs and, therefore, the oxygen monitors do not meet the definition of a safety-related component as defined in 10 CFR 50.2. RG 1.97 recommends that, for inerted containment plants, the oxygen monitors be Category 1 which is intended for key variables that most directly indicate the accomplishment of a safety function for DBA events. As part of the rulemaking to revise 10 CFR 50.44, the Commission found that Category 22, as defined in RG 1.97, is an appropriate categorization for the oxygen monitors, because the monitors are required to verify the status of the inert containment. Oxygen monitoring is not the primary means of indicating a significant abnormal degradation of the reactor coolant pressure boundary. Oxygen monitors have not been shown by a probabilistic risk assessment to be risk-significant. Therefore, the NRC staff finds that oxygen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in TSs and, therefore, may be relocated to other licensee-controlled documents.
However, for plant designs with an inerted containment, each licensee should verify that it has, and make a regulatory commitment to maintain, an oxygen monitoring system capable of verifying the status of the inert containment. In addition, separate requirements for primary containment oxygen concentration will be retained in TSs for plant designs with an inerted containment. The basis for retention of this requirement in TS is that it meets Criterion 2 of 10 CFR 50.36(c)(2)(ii) in that it is a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. This is based on the fact that calculations typically included in Chapter 6 of Updated Final Safety Analysis Reports (UFSARs) assume that the primary containment is inerted, that is, oxygen concentration < 4.0 volume percent, when a design basis LOCA occurs.
4.0 VERIFICATION AND COMMITMENTS As requested by the NRC staff in the notice of availability for this TS improvement, the licensee has addressed the following plant-specific verifications and commitments.
included a regulatory commitment related to the maintenance of oxygen monitors.
2 While discussing the designation of the oxygen monitors as Category 2, the NRC acknowledged in the final rule (68 FR 54123) that the monitors need not be qualified in accordance with 10 CFR 50.49. The amended rule implements performance-based requirements for hydrogen and oxygen monitors to be functional, reliable, and capable of continuously measuring the appropriate parameter in the beyond-DBA environment.
4.1 Each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing beyond design-accidents.
The licensee has verified that it has a hydrogen monitoring system capable of diagnosing beyond-DBAs. The licensee has committed to maintain the hydrogen monitors within its plant procedures. The licensee has implemented this commitment.
4.2 For plant designs with an inerted containment, each licensee should verify that it has, and make a regulatory commitment to maintain, an oxygen monitoring system capable of verifying the status of the inert containment. (for applicable plants)
The licensee has verified that it has an oxygen monitoring system capable of verifying the status of the inert containment. The licensee has committed to maintain the oxygen monitors within its plant procedures. The licensee has implemented this commitment.
The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are provided by the licensees administrative processes, including its commitment management program.
Should the licensee choose to incorporate a regulatory commitment into the emergency plan, UFSAR, or other document with established regulatory controls, the associated regulations would define the appropriate change-control and reporting requirements. The NRC staff has determined that the commitments do not warrant the creation of regulatory requirements 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 Regulatory Issue Summary 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.
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 State official had no comments.
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 surveillance requirements. 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 (69 FR 22879; April 27, 2004). 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) 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: W. Reckley Date: August 9, 2004
Oyster Creek Nuclear Generating Station cc:
Chief Operating Officer S. Collins AmerGen Energy Company, LLC Regional Administrator, Region I 4300 Winfield Road U.S. Nuclear Regulatory Commission Warrenville, IL 60555 475 Allendale Road King of Prussia, PA 19406-1415 Senior Vice President - Nuclear Services AmerGen Energy Company, LLC Mayor of Lacey Township 4300 Winfield Road 818 West Lacey Road Warrenville, IL 60555 Forked River, NJ 08731 Site Vice President - Oyster Creek Senior Resident Inspector Generating Station U.S. Nuclear Regulatory Commission AmerGen Energy Company, LLC P.O. Box 445 P.O. Box 388 Forked River, NJ 08731 Forked River, NJ 08731 Director - Licensing and Regulatory Affairs Vice President - Mid-Atlantic AmerGen Energy Company, LLC Operations 200 Exelon Way, KSA 3-E AmerGen Energy Company, LLC Kennett Square, PA 19348 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Manager Licensing - Oyster Creek Exelon Generation Company, LLC John E. Matthews, Esquire 200 Exelon Way, KSA 3-E Morgan, Lewis, & Bockius LLP Kennett Square, PA 19348 1111 Pennsylvania Avenue, NW Washington, DC 20004 Oyster Creek Generating Station Plant Manager Kent Tosch, Chief AmerGen Energy Company, LLC New Jersey Department of P.O. Box 388 Environmental Protection Forked River, NJ 08731 Bureau of Nuclear Engineering CN 415 Regulatory Assurance Manager Trenton, NJ 08625 Oyster Creek AmerGen Energy Company, LLC Vice President - Licensing and P.O. Box 388 Regulatory Affairs Forked River, NJ 08731 AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Operations Support AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555
Oyster Creek Nuclear Generating Station cc:
Vice President, General Counsel and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA 19101 Pete Eselgroth, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Correspondence Control Desk AmerGen Energy Company, LLC P.O. Box 160 Kennett Square, PA 19348