Text

Issuance of Amendments the Revision to Technical Specifications to Adopt TSTF-566, Revise Actions for Inoperable (Residual Heat Removal) RHR Shutdown Cooling Subsystems, Using Consolidated Line Item Improvement Process
	ML19267A023
Person / Time
Site:	Hatch
Issue date:	11/13/2019
From:	John Lamb; Plant Licensing Branch II
To:	Gayheart C; Southern Nuclear Operating Co
	Lamb J
References
	EPID L-2019-LLA-0156
	Download: ML19267A023 (26)
	v • d • e

UNITED STATES November 13, 2019 Ms. Cheryl A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING THE REVISION TO TECHNICAL SPECIFICATIONS TO ADOPT TSTF-566, "REVISE ACTIONS FOR INOPERABLE RESIDUAL HEAT REMOVAL SHUTDOWN COOLING SUBSYSTEMS," USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (EPID L-2019-LLA-0156)

Dear Ms. Gayheart:

The Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 300 to Renewed Facility Operating License No. DPR-57 and Amendment No. 245 to Renewed Facility Operating License No. NPF-5 for the Edwin I. Hatch Nuclear Plant, Unit Nos 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated July 23, 2019.

The amendments revise TS actions for inoperable residual heat removal (RHR) shutdown cooling subsystems in the RHR shutdown cooling system limiting conditions for operation (LCOs). The proposed changes are based on Technical Specifications Task Force (TSTF)

Traveler TSTF-566, Revision 0, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems," dated January 19, 2018, using the Consolidated Line Item Improvement Process.

C. A. Gayheart A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

. Lamb, Senior Project Manager Licensing Branch 11-1 Di

ion of Operating Reactor Licensing 0 ice of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosures:

1. Amendment No. 300 to DPR-57

2. Amendment No. 245 to NPF-5

3. Safety Evaluation cc: Listserv

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-321 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 300 Renewed License No. DPR-57

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit No. 1 (the facility) Renewed Facility Operating License No. DPR-57 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated July 23, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 set forth in 10 CFR Chapter I; 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 Enclosure 1

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 hereby amended by page 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-57 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. 300, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. DPR-57 and Technical Specifications Date of Issuance: November 1 3, 2 O1 9

ATTACHMENT TO LICENSE AMENDMENT NO. 300 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-57 DOCKET NO. 50-321 Replace the following pages of the License and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License 4 4 TSs TSs 3.4-13 3.4.13 3.4-14 3.4-14 3.4-16 3.4-16 3.4-17 3.4-17

for sample analysis or instrumentation calibration, or associated with radioactive apparatus or components (6) Southern Nuclear, 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 the operation of the facility.

(C) This renewed license shall be deemed to contain, and is subject to, the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions 2 specified or incorporated below:

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at steady state reactor core power levels not in excess of 2804 megawatts thermal.

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B); as revised through Amendment No. 300 are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance Requirement (SR) contained in the Technical Specifications and listed below, is not required to be performed immediately upon implementation of Amendment No. 195. The SR listed below shall be successfully demonstrated before the time and condition specified:

SR 3.8.1.18 shall be successfully demonstrated at its next regularly scheduled performance.

(3) Fire Protection Southern Nuclear shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Updated Final Safety Analysis Report for the facility, as contained in the updated Fire Hazards Analysis and Fire Protection Program for the Edwin I. Hatch Nuclear Plant, Units 1 and 2, which was originally submitted by letter dated July 22, 1986. Southern Nuclear may make changes to the fire protection program without prior Commission approval only if the changes Renewed License No. DPR-57 Amendment No. 300

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4. 7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NOTES-----------------------------------------

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3 with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

NO TE------------------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months cooling subsystems method of decay heat inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter

8. Required Action and 8.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

HATCH UNIT 1 3.4-13 Amendment No. 300

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling C.1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or AND one recirculation pump to operation.

No recirculation pump in operation. AND C.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery circulation by an of no reactor coolant alternate method. circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.3 Monitor reactor coolant Once per hour temperature and pressure.

HATCH UNIT 1 3.4-14 Amendment No. 300

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NO TES----------------------------------------

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: M0DE4.

ACTIONS

NO TE---------------------------------------------------------

Sepa rate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months cooling subsystems method of decay heat inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately Associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

HATCH UNIT 1 3.4-16 Amendment No. 300

RHR Shutdown Cooling System - Cold Shutdown

, 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery subsystem in operation. circulation by an of no reactor coolant alternate method. circulation No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR shutdown cooling subsystem or In accordance with recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.8.2 --~--------------------------NOTE-----------------------------

An operating RHR shutdown cooling subsystem will meet this requirement for the RHR shutdown cooling subsystem running unless the RHR shutdown cooling subsystem is in a low flow system operation.

Verify required RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program HATCH UNIT 1 3.4-17 Amendment No. 300

SOUTHERN NUCLEAR OPERATING COMPANY. INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON. GEORGIA DOCKET NO. 50-366 EDWIN I. HATCH NUCLEAR PLANT. UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 245 Renewed License No. NPF-5

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit No. 2 (the facility) Renewed Facility Operating License No. NPF-5 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated July 23, 2019, complies' with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as 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 set forth in 10 CFR Chapter I; 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 Enclosure 2

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 hereby amended by page 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. NPF-5 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix 8), as revised through Amendment No. 245 are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 30 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-5 and Technical Specifications Date of Issuance: November 1 3, 2 O1 9

ATTACHMENT TO LICENSE AMENDMENT NO. 245 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. NPF-5 DOCKET NO. 50-366 Replace the following pages of the License and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License 4 4 TSs TSs 3.4-13 3.4.13 3.4-14 3.4-14 3.4-16 3.4-16 3.4-17 3.4-17

(6) Southern Nuclear, 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 the operation of the facility.

(C) This renewed license shall be deemed to contain, and is subject to, the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions 2 specified or incorporated below:

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at steady sate reactor core power levels not in excess of 2,804 megawatts thermal, in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B); as revised through Amendment No. 245 are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the renewed license or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the license supported by a favorable evaluation by the Commission.

(a) Fire Protection Southern Nuclear shall implement and maintain in effect all provisions of the fire protection program, which is referenced in the Updated Final Safety Analysis Report for the facility, as contained 2

The original licensee authorized to possess, use, and operate the facility with Georgia Power Company (GPC). Consequently, certain historical references to GPC remain in certain license conditions.

Renewed License No. NPF-5 Amendment No. 245

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4. 7 Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown LCO 3.4.7 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NO TES------------------------------------------

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE 3 with reactor steam dome pressure less than the RHR low pressure permissive pressure.

ACTIONS

NO TE--------------------------------------------------------

Separate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months cooling subsystems method of decay heat inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and B.1 Initiate action to restore Immediately associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

HATCH UNIT 2 3.4-13 Amendment No. 245

RHR Shutdown Cooling System - Hot Shutdown 3.4.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling C.1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or one recirculation pump to operation.

No recirculation pump in operation. AND C.2 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery circulation by an of no reactor coolant alternate method. circulation AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.3 Monitor reactor coolant Once per hour temperature and pressure.

HATCH UNIT 2 3.4-14 Amendment No. 245

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown LCO 3.4.8 Two RHR shutdown cooling subsystems shall be OPERABLE and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem shall be in operation.

NO TES--------------------------------------------

1. Both RHR shutdown cooling subsystems and recirculation pumps may be removed from operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period.

2. One RHR shutdown cooling subsystem may be inoperable for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for performance of Surveillances.

APPLICABILITY: MODE4.

ACTIONS

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

Se pa rate Condition entry is allowed for each RHR shutdown cooling subsystem.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or two RHR shutdown A.1 Verify an alternate 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months cooling subsystems method of decay heat inoperable. removal is available for AND each inoperable RHR shutdown cooling Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months subsystem. thereafter B. Required Action and 8.1 Initiate action to restore Immediately Associated Completion RHR shutdown cooling Time of Condition A not subsystem(s) to met. OPERABLE status.

(continued)

HATCH UNIT 2 3.4-16 Amendment No. 245

RHR Shutdown Cooling System - Cold Shutdown 3.4.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. No RHR shutdown cooling C.1 Verify reactor coolant 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from discovery subsystem in operation. circulation by an of no reactor coolant alternate method. circulation No recirculation pump in operation. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter C.2 Monitor reactor coolant Once per hour temperature.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR shutdown cooling subsystem or In accordance with recirculation pump is operating. the Surveillance Frequency Control Program SR 3.4.8.2 --------------------------~--NOTE-------------~~------------

An operating RHR shutdown cooling subsystem will meet this requirement for the RHR shutdown cooling subsystem running unless the RHR shutdown cooling subsystem is in a low flow system operation.

Verify required RHR shutdown cooling subsystem In accordance with locations susceptible to gas accumulation are the Surveillance sufficiently filled with water. Frequency Control Program HATCH UNIT 2 3.4-17 Amendment No. 245

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 300 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-57 AND AMENDMENT NO. 245 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-5 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-321 AND 50-366

1.0 INTRODUCTION

By application dated July 23, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19204A240)), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for Edwin I. Hatch Nuclear Power Plant (Hatch), Units 1 and 2. The amendment would revise technical specification (TS) actions for inoperable residual heat removal (RHR) shutdown cooling subsystems in the RHR shutdown cooling system limiting conditions for operation (LCOs).

The proposed changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-566, Revision 0, "Revise Actions for Inoperable RHR Shutdown Cooling Subsystems,"

dated January 19, 2018 (ADAMS Accession No. ML180198187). The U.S. Nuclear Regulatory Commission (NRC or the Commission) issued a final safety evaluation (SE) approving TSTF-566, Revision 0, on February 21, 2019 (ADAMS Accession No. ML19028A287), using the Consolidated Line Item Improvement Process (CLIIP).

The licensee has proposed variations from the TS changes described in TSTF-566, Revision 0.

The variations are described in Section 2.2.3 of this SE and evaluated in Section 3.3.

2.0 REGULATORY EVALUATION

2.1 Description of Residual Heat Removal Shutdown Cooling System Irradiated fuel in the shutdown reactor core generates heat during the decay of fission products and increases the temperature of the reactor coolant. This decay heat must be removed to reduce the temperature of the reactor coolant to less than or equal to 200 degrees Fahrenheit Enclosure 3

(°F). This decay heat is removed by the RHR shutdown cooling system in preparation for performing refueling or maintenance operations, or for keeping the reactor in the hot shutdown condition or cold shutdown condition.

The two redundant, manually controlled shutdown cooling subsystems of the RHR system provide decay heat removal. Each of the two shutdown cooling subsystems of the RHR system can provide the required decay heat removal.

The TS 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown," is applicable in Mode 3 with reactor steam dome pressure lower than the RHR cut-in permissive pressure. The TS 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," is applicable in Mode 4. They both require two operable RHR shutdown cooling subsystems and, with no recirculation pump in operation, at least one RHR shutdown cooling subsystem in operation.

2.2 Proposed Changes to the Technical Specifications The licensee proposed to revise TS actions for inoperable RHR shutdown cooling subsystems in the RHR shutdown cooling system LCOs, consistent with TSTF-566, Revision 0.

The proposed changes would revise TS 3.4. 7, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown," and 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," for Hatch, Units 1 and 2. The proposed changes are described below.

2.2.1 Proposed Changes to "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown" Required actions for one or two RHR shutdown cooling subsystems inoperable (Condition A) of Hatch, Units 1 and 2 TS 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown," require the operators to initiate action to restore RHR shutdown cooling subsystem(s) to operable status (Required Action A.1) immediately, verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem (Required Action A.2) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and be in Mode 4 (Required Action A.3) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The licensee proposed to move Required Action A.1 to new Condition B (as Required Action B.1) and delete Required Action A.3. The LAR also proposed to add a recurring completion time (CT) to current Required Action A.2 of "once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter." The proposed changes also re-number current Required Action A.2 as A.1 since Required Actions A.1 and A.3 are removed from Condition A.

The licensee also proposed a new Condition B for when the required action and associated CT of Condition A are not met. New Condition B's Required Action B.1 is moved from current Required Action A.1 and requires operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately.

Current Condition Band its required actions were renamed "C," "C.1," "C.2," and "C.3,"

respectively, since new Condition B was added.

2.2.2 Proposed Changes to "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown" Required actions for one or two RHR shutdown cooling subsystems inoperable (Condition A) of TS 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown," require the operators to verify an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem (Required Action A.1) within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

The licensee proposed a new Condition B for when the required action and associated CT of Condition A are not met which has a required action (new Required Action B.1) for operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately.

Current Condition Band its required actions were renamed "C," "C.1," and "C.2," respectively, since new Condition B was added.

2.2.3 Variations from TSTF-566 The Hatch, Units 1 and 2, TSs utilize different numbering than the Standard Technical Specifications (STS) on which TSTF-566 was based. Specifically, TS 3.4.8, "RHR Shutdown Cooling System - Hot Shutdown" is TS 3.4. 7 in the Hatch TS, and TS 3.4.9, "RHR Shutdown Cooling System -Cold Shutdown" is TS 3.4.8 in the Hatch TS. These differences are editorial and do not affect the applicability of TSTF-566 to the proposed LAR.

The licensee is proposing the following variations from the TS changes described in TSTF-566 or the applicable parts of the NRC staff's SE of TSTF-566. The Hatch TSs have minor differences in some wording from the STS, such as the word "the" sometimes is not included in the Hatch TSs in certain locations and use of the phrase "less than" instead of the symbol "<".

These variations do not affect the applicability of TSTF-566 or the NRC staff's SE to the proposed LAR.

2.3 Applicable Regulatory Requirements and Guidance Title 1O of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires each applicant for a license authorizing operation of a utilization facility to include in the application the proposed TSs.

The regulation at 10 CFR 50.36(b) requires:

Each license authorizing operation of a ... utilization facility ... will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The Commission may include such additional technical specifications as the Commission finds appropriate.

The regulation at 10 CFR 50.40(a) states, in part, that the TS shall provide reasonable assurance that the health and safety of the public will not be endangered.

The regulation at 10 CFR 50.36(a)(1) states:

A summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications.

The NRC staff's guidance for the review of TSs is in Chapter 16.0, "Technical Specifications," of NUREG-0800, Revision 3, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR [Light-Water Reactor] Edition" (SRP), March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the LWR nuclear designs. Accordingly, the NRC staff's review includes consideration of whether the proposed changes are consistent with the applicable reference STSs (i.e., the current STSs), as modified by NRC-approved travelers.

U.S. Nuclear Regulatory Commission, "Standard Technical Specifications, General Electric BWR/4 Plants," NUREG-1433, Volume 1, "Specifications," and Volume 2, "Bases," Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193, respectively).

3.0 TECHNICAL EVALUATION

3.1 Proposed Changes to "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown" The licensee proposed to modify TS 3.4.7, "Residual Heat Removal (RHR) Shutdown Cooling System - Hot Shutdown." The technical evaluation of each change follows.

3.1.1 Evaluation of Changes to Condition A The licensee proposed to add a recurring CT to current Required Action A.2 of "once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter." Current Required Action A.2 requires verification that an alternate method of decay heat removal is available for each inoperable RHR shutdown cooling subsystem within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The NRC staff finds this change is acceptable, since it requires continuous verification of alternate methods of decay heat removal every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and provides assurance of continued heat removal capability.

The licensee also proposed to delete current Required Action A.3, which requires the plant to be in Mode 4 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when one or two RHR shutdown cooling subsystems are inoperable.

Current Required Action A.3 requires operators to reduce the reactor coolant system temperature to the point where Mode 4 is entered, due to the potentially reduced reliability of the alternate methods of decay heat removal. However, if there is no operable RHR shutdown cooling subsystem and the plant is in a period of high decay heat load, it may not be possible to reduce the reactor coolant system temperature to the Mode 4 entry condition (typically less than 200 °F) within the CT. In addition, in a typical boiling-water reactor (BWR) design, the RHR shutdown cooling system has a heat rejection capability many times greater than alternate methods available. Therefore, for periods in which there is high decay heat load, the BWR design does not include any system which can satisfy Required Action A.3. The NRC staff finds the deletion of current Required Action A.3 is acceptable because, at below the RHR cut in permissive pressure, the remaining required action will continue to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.

Current Required Action A.2 is renumbered as A.1, since Required Actions A.1 and A.3 are removed from Condition A. The NRC staff finds this change is acceptable since it provides the correct number sequence.

3.1.2 Evaluation of New Condition B The licensee proposed a new Condition B for when the required action and associated CT of Condition A is not met. New Condition B's required action, B.1, is moved from current Required Action A.1 and requires operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately. The NRC staff finds that relocating the required action from A.1 to new Required Action B.1 is acceptable because other ways of removing decay heat are available, such as natural circulation, the spent fuel pool cooling system, the reactor water cleanup system and an inoperable, but functional, RHR shutdown cooling subsystem.

If an alternate method cannot be established (Condition A), new Condition B requires the licensee to immediately initiate action to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The CT "immediately" is defined in Section 1.3 of the Hatch's TSs as, "the Required Action should be pursued without delay and in a controlled manner."

New Required Action B.1 continues to apply until the inoperable RHR shutdown cooling subsystems are restored to operable status, an alternate decay heat removal method is established, or the specification is exited.

The NRC staff finds this change is acceptable because new Condition B, with its Required Action B.1, provides an appropriate terminal action for when an alternate method cannot be established within the CT. In addition, new Required Action B.1 will restore redundant decay heat removal paths and the immediate CT reflects the importance of maintaining the availability of two paths for heat removal.

3.1.3 Evaluation of Changes to Existing Condition B Current Condition B and its required actions were renamed "C," "C.1," "C.2," and "C.3,"

respectively, since new Condition B was added. The NRC staff finds this change is acceptable since it provides the correct number sequence.

3.2 Proposed Changes to "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown" The licensee proposed to modify TS 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System - Cold Shutdown." The technical evaluation of each change follows.

3.2.1 Evaluation of New Condition B The licensee proposed a new Condition B for when the required action and associated CT of Condition A is not met which has a required action (new Required Action B.1) for operators to initiate action to restore RHR shutdown cooling subsystems(s) to operable status immediately.

If an alternate method cannot be established (Condition A), new Condition B requires the licensee to immediately initiate action to restore the inoperable RHR shutdown cooling subsystem(s) to operable status. The CT "immediately" is defined in Section 1.3 of the TSs as,

"the Required Action should be pursued without delay and in a controlled manner." New Required Action B.1 continues to apply until the inoperable RHR shutdown cooling subsystems are restored to operable status, an alternate decay heat removal method is established, or the specification is exited.

The NRC staff finds this change is acceptable because new Condition B with its Required Action B.1 provide an appropriate terminal action for when an alternate method cannot be established within the CT. In addition, new Required Action B.1 will restore redundant decay heat removal paths and the immediate CT reflects the importance of maintaining the availability of two paths for heat removal.

3.2.2 Evaluation of Changes to Existing Condition B Current Condition Band its required actions were renamed "C," "C.1," and "C.2," respectively, since new Condition B was added. The NRC staff finds this change is acceptable since it provides the correct number sequence.

3.3 Variations from TSTF-566 The licensee described variations from TSTF-566 using CLIIP in Section 2.2 of the LAR. The licensee provided justification for the proposed variations and exceptions. The NRC staff reviewed the justifications and concludes the variations are acceptable because the variations do not affect the applicability of TSTF-566 using CLIIP or the conclusions reached in the NRC staff's SE to the proposed LAR.

The Hatch's TSs utilize different numbering than the STS on which TSTF-566 was based. The NRC staff agrees these differences are editorial and do not affect the applicability of TSTF-566 using CLIIP to the proposed LAR.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Georgia State official was notified on September 13, 2019, 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 the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. 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 on September 10, 2019 (84 FR 47551). Accordingly, the amendments 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) there is reasonable assurance that 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.

Principal Contributors: Pete Snyder, NRR/DSS John G. Lamb, NRR/DORL Date: November 13, 2019

C. A. Gayheart

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, ISSUANCE OF AMENDMENTS REGARDING THE REVISION TO TECHNICAL SPECIFICATIONS TO ADOPT TSTF-566, "REVISE ACTIONS FOR INOPERABLE RESIDUAL HEAT REMOVAL SHUTDOWN COOLING SUBSYSTEMS," USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (EPID L-2019-LLA-0156) DATED NOVEMBER 13, 2019 DISTRIBUTION PUBLIC LPL2-1 R/F RidsNrrPMHatch Resource RidsACRS MailCTR Resource RidsNrrLAKGoldstein Resource RidsRgn2MailCenter Resource RidsNrrDorlLpl2-1 Resource RidsNrrDssStsb Resource Amendment No. ML19267A023 *via email OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/DSS/STSB/BC (A)

NAME JLamb KGoldstein* VCusumano DATE 10/04/19 10/16/19 10/15/19 OFFICE OGC* NRR/LPL2-1 /BC NRR/LPL2-1/PM NAME DRoth MMarklev JLamb DATE 10/30/19 11/07/19 11/13/19 OFFICIAL RECORD COPY

v t e Letter Sequence Approval
EPID:L-2019-LLA-0156, TSTF-566 (Approved, Closed)
Initiation Request Acceptance... Administration Questions Answers Results Approval Other:
MONTHYEAR2019-11-13 [Table View]

ML19267A023

Text

SUBJECT:

Dear Ms. Gayheart:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

SUBJECT:

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