CNL-15-218, Application to Revise Technical Specification 6.8.4.h, Containment Leakage Rate Testing Program, (SQN-TS-14-03) (TAC Nos. MF5366 and MF5367), Supplement to Response to Request for Additional Information

Application to Revise Technical Specification 6.8.4.h, Containment Leakage Rate Testing Program, (SQN-TS-14-03) (TAC Nos. MF5366 and MF5367), Supplement to Response to Request for Additional Information

ML15299A140
Person / Time
Site:	Sequoyah
Issue date:	10/23/2015
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-15-218, L44 151023 001, TAC MF5366, TAC MF5367
Download: ML15299A140 (13)

Text

L44 151023 001 1101 Market Street, Chattanooga, Tennessee 37402 CNL-15-218 October 23, 2015 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRG Docket Nos. 50-327 and 50-328

Subject:

Application to Revise Technical Specification 6.8.4.h, "Containment Leakage Rate Testing Program," (SQN-TS-14-03) (TAC Nos. MF5366 and MF5367),

Supplement to Response to Request for Additional Information

References:

1. TVA Letter to NRC, CNL-14-176, "Application to Revise Technical Specification 6.8.4.h, "Containment Leakage Rate Testing Program,"

(SQN-TS-14-03)," dated December 2, 2014(ML14339A539)

2. Nuclear Energy Institute 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J,"

dated July 2012(ML12221A202)

3. Electronic mail from Andrew Hon (NRC) to Joseph W. Shea [rvA),

"Sequoyah Nuclear Station, Unit 1 & 2 - Request for Additional Information Related to LAR to Revise Containment Leakage Rate Testing Program,"

dated August 6, 2015(ML15287A451)

4. TVA Letter to NRG, CNL-15-171, "Application to Revise Technical Specification 6.8.4.h, 'Containment Leakage Rate Testing Program,'

(SQN-TS-14-03) (TAC Nos. MF5366 and MF5367), Response to Request for Additional Information," dated September 11, 2015 (ML15257A392)

5. TVA Letter to NRG, "Seq~oyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10),"

dated November 22, 2013(ML13329A717)

6. NRC Letter to TVA, "Sequoyah Nuclear Plant, Units 1 and 2 - Issuance of Amendments for the Conversion to the Improved Technical Specifications with Beyond Scope Issues (TAC Nos. MF3128 and MF3129)," dated September 30, 2015(ML152388499)

U.S. Nuclear Regulatory Commission CNL-15-218 Page 2 October 23, 2015 By letter dated December 2, 2014 (Reference 1), Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for Sequoyah Nuclear Plant (SQN), Units 1 and 2, revising the SQN, Units 1 and 2, Technical Specifications (TS) 6.8.4.h, "Containment Leakage Rate Testing Program." The purpose of the LAR was to adopt Nuclear Energy Institute (NEI) 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," (Reference 2) as the implementation document for the performance-based Option B of 10 CFR Part 50, Appendix J . The proposed changes permanently extend the Type A containment integrated leak rate test (CILRT) interval from 10 years to 15 years and the Type C local leakage rate test intervals from 60 months to 75 months.

By electronic mail dated August 6, 2015 (Reference 5), the NRC forwarded a Request for Additional Information (RAI). By letter dated September 10, 2015 (Reference 4), TVA provided a response to the NRC RAI. During telephone calls with TVA on September 30, 2015, and October 1, 2015, NRC requested that TVA supplement its RAI response to provide additional information. Enclosure 1 to this letter provides the requested information.

In addition, the Reference 1 letter stated that upon approval of the TS conversion requested in Reference 5, revised improved TS pages incorporating the changes proposed in this amendment request-would be provided to the NRC Licensing Project Manager. The TS conversion requested in Reference 5 was approved by the NRC in a Safety Evaluation dated September 30, 2015 (Reference 6). Enclosure 2 to this letter provides marked up improved TS pages showing the Reference 1 LAR proposed changes and retyped improved TS pages in~orporating the Reference 1 LAR proposed changes.

Consistent with the standards set forth in Title 1O of the Code of Federal Regulations (10 CFR),

Part 50.92(c), TVA has determined that the additional information, as provided in this letter, does not affect the no significant hazards consideration associated with the proposed application previously provided in Reference 1.

Additionally, in accordance with 10 CFR 50.91(b)(1) , TVA is sending a copy of this letter and the enclosure to the Tennessee Department of Environment and Conservation .

There are no new regulatory commitments contained in this submittal. Please address any questions regarding this request to Mr. Edward D. Schrull at (423) 751-3850.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 23rd day of October 2015.

~

hea Vi e President, Nuclear Licensing Enclosures cc: See Page 3

U.S. Nuclear Regulatory Commission CNL-15-218 Page 3 October 23, 2015

Enclosures:

1. Supplemental Information

2. Marked Up and Re-Typed Sequoyah Nuclear Plant, Units 1 and 2 Improved Technical Specifications Pages Enclosures cc (Enclosures):

NRC Regional Administrator - Region II NRC Resident Inspector - Sequoyah Nuclear Plant NRC Project Manager - Sequoyah Nuclear Plant Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT UNITS 1AND2 Supplemental Information During telephone calls with TVA on September 30, 2015, and October 1, 2015, NRC requested that TVA supplement its Request for Additional Information (RAI) response dated September 11, 2015, to provide additional information related to RAI 1, RAI 3, RAI 6, and RAI 7.

RA/ 1 Supplemental Information The Tennessee Valley Authority (TVA) response to RAI 1 stated, in part, that "Steel Containment Vessel The General Visual Examination of the [Steel Containment Vessel] SCV found signs of distress and rust at penetration X-155. There were previously reported indications of coating/paint flaking at various locations on the SCV inboard surface. The SCV outboard surface had scratches and scrapes with light to medium rust, but no recordable indications were found. "

However, the term "signs of distress" was not defined. TVA has reviewed the 2015 U1 R20 examination report referred to in the TVA response to RAI 1 dated September 11, 2015, and determined that the response should have stated (revised text shown with underline):

The General Visual Examination of the SCV found signs of paint chips and scratches in the top coat and medium rust at penetration X-155. There were previously reported indications of coating/paint flaking at various locations on the SCV inboard surface. The SCV outboard surface had scratches and scrapes with light to medium rust, but no recordable indications were found.

RA/ 3 Supplemental Information

a. The NRC Reviewer requested that TVA provide additional information related to the percentage of the moisture barrier that was-found to have a lack of adhesion in response to RAI 3.a. The results of examinations for the last two examinations for each unit are provided in the following tables.

Unit 1 Cycle 20 Location Length of Lack of Adhesion (Azimuth in dearees) (inches) 21 3 69 5 70 2 99 6 288 4.5 Total length exhibiting lack of adhesion 20.5 <- 1.7 feet)

Unit 1 Cycle 18 Location Length of Lack of Adhesion (Azimuth in decrees) (inches) 34 8 CNL-15-218 Enclosure *1, Page 1 of 5

39 6 85 9 165 4 Total length exhibiting lack of adhesion 27 (-2 feet)

Unit 2 Cvcle 19 Location Length of Lack of Adhesion (Azimuth in dearees) (inches) 3 to 7 48 15 to 18 36 38 to 40 24 54.5 to 56 18 88 3 91 3 110 3 156 to 158 18 166 12 185 3 200* 15 205 12 212 24 216 to 218* 24 221to222*

• 12 222.5 to 224* 18 224.5 to 226* 18 226.5 to 227.5 12 228 to 229* 12 273 to 267 84 279 6 296 10 298 7 317 4 313 to 309 48 323 to 322 12 328 4 329 9 331 7 333 5 335 7 336 3 343 to 338 60 Total length exhibiting lack of adhesion 581 (-48 feet)

CNL-15-218 Enclosure 1, Page 2 of 5

• lnd.icates location of possible repeat lack of adhesion from repairs made during Unit 2 Cycle 17 examination. Condition Report (CR) 1094801 has been initiated in the TVA Corrective Action Program to determine the appropriate corrective measures for lack of moisture barrier adhesion.

Unit 2 Cvcle 17 Location Length of Lack of Adhesion (Azimuth in degrees) (inches) 46 6 47 5 48 to 50 21 71 3 165 4 179 2.5 183 2.5 200 2.5 208 to 215 48 218 2 220 8 222 6 224 2 225 2 226 6 228 42 235 2 276 24 281 2 283 2 286 7 Total length exhibiting lack of adhesion 199.5 (-17 feet)

The total circumference of each SQN SCV is approximately 361 feet. The percentage of SCV exhibiting a lack of moisture barrier adhesion is provided in the following table.

Examination Total Length Exhibiting Lack Percentage of Total SCV of Adhesion (approximate) Circumference Exhibiting Lack of Adhesion Unit 1 Cvcle 20 1.7 feet 0.5 Unit 1 Cvcl.e 18 2 feet 0.6 Unit 2 Cvcle 19 48 feet 13.4 Unit 2 Cycle 17 17 feet 4.6 In January 2000, TVA processed a design change to provide for alternative methods of sealing the seal joint between the concrete and SCV. The alternative method allows the removal of the existing fiberglass filler, and filling the crevice completely with a polyurethane elastomeric sealant when repairs to the moisture barrier seal are requ ired during regular maintenance or during American Society of Mechanical Engineers (ASME)Section XI IWE inspections. The polyurethane elastomeric sealant currently used is Sikaflex 2C. As described above, CR 1094801 has been initiated in the TVA Corrective Action Program to determine the appropriate corrective measures for lack of moisture barrier adhesion.

CR 1094801 applies to both SQN, Unit 1 and Unit 2.

CNL-15-218 Enclosure 1, Page 3 of 5

b. The NRC Reviewer requested that TVA provide results of the inspections performed on the SCV to concrete interface in the Annulus in response to RAI 3.b.

TVA has reviewed the past two examination reports for both SON units and determined that no "notices-of-indications" have been issued that list any findings with respect to the SCV to concrete interface of the Annulus exposed accessible surface, as described in the TVA response to RAI 2 in TVA letter dated September 11, 2015.

RA/6 The TVA response to RAI 6.b stated, in part:

"The last performance of this examination [Ultrasonic Testing (UT) thickness examination] for Unit 2 was in 2014 during refueling outage U2R19. One grid was-found to be less than the T minimum thickness, and that grid was evaluated and found to be acceptable."

The NRC Reviewer requested that TVA supplement its response to discuss the root cause of the grid that was less than the T minimum thickness.

The 2014 UT thickness examination was the first UT examination conducted on the SCV cutouts for Steam Generator replacement; therefore , no baseline existed. Consequently, no root cause could be determined. However, no degradation was noted in the examination report.

RA/7 During discussion of TVA response to RAI 7, the NRC Reviewer noted that the values provided for the SON, Unit 2 Containment Integrated Leak Rate Test (CILRT) test results for April 1992 differed between the December 2, 2014, License Amendment Request (LAR) and the September 10, 2015, RAI response and a previous LAR, "Sequoyah Nuclear Plant (SQN) -

Units 1 and 2 - Technical Specification (TS) Change No. 02-07, 'One Time Frequency Extension for Type A Test (Containment Integrated Leak Rate Test [CILRT]) ,"' dated October 4, 2002.

The NRC requested that TVA provide a discussion of the apparent differences in the two submittals.

Review of the April 1992 CILRT test report identified the following items that result in the total as-found mass leak rate (MLR).

0.26968 %/day 0.00000 %/da 0.05773 %/day 0.00081 %/da Total as-found MLR 0.32822 %/da CNL-15-218 Enclosure 1, Page 4 of 5

The October 4, 2002, LAR reported the April 1992 CILRT as-found MLR leakage rate using the rules in effect at the time of the 2002 submittal which did not require addition of the Leakage Savings. Therefore, the LAR reported the April 1992 CILRT as-found MLR result as 0.05854 %/day (0.2342 La) as determined below.

0.05773 %/da 0.00081 %/da 0.05854 %/da The December 2, 2014, LAR reported the April 1992 CILRT as-found MLR leakage rate using the rules in effect for calculating CILRT test results at the time of the April 1992 test which required addition of the Leakage Savings into the as-found MLR. The December 2, 2014, LAR reported the results as 1.31 La which translates to 0.32822 %/day as calculated in the April 1992 CILRT test report (see above). The December 2, 2014, LAR reported the CILRT results in terms of La for consistency with submittals by other licensees requesting similar changes related to CILRT interval extension.

The September 11, 2015, response to RAI 7 stated the April 1992 CILRT as-found MLR leakage rate without leakage savings*as 0.05773 %/day. This value was the Calculated 95%

UCL during test as reported in the April 1992 CILRT test report (see above) and was used in the response because the NEI 94-01, Revision 3-A methodology for calculating the CILRT performance leak rate uses the UCL. However, it would have been more appropriate to include the leakage adjustment due to sump level increase (i.e., 0.00081 %/day) for the total as-found MLR leakage rate of 0.05854 %/day in the RAI response.

CNL-15-218 Enclosure 1, Page 5 of 5

ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT UNITS 1AND2 Marked Up and Re-Typed Sequoyah Nuclear Plant, Units 1 and 2 Improved Technical Specifications Pages

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Safety Function Determination Program (SFDP) (continued)

A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable; and:

a. A required system redundant to the system(s) supported by the inoperable support system is also inoperable; or

b. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable; or

c. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.

5.5.14 Containment Leakage Rate Testing Program a.

NEI 94-01 , "Industry Guideline for Performance-Based Option of 10 1. Bypass leakage paths to the auxiliary building leakage from isolation CFR 50, Appendix J," Revision 3-A, July 2012, and Section 4.1, valves that are sealed with fluid from a seal system may be excluded, "Limitations and Conditions for subject to the provisions of Appendix J, Section 111.C.3, when NEI TR 94-01 , Revision 2," of the NRC Safety Evaluation Report in determining the combined leakage rate provided the seal system and NEI 94-01 , Revision 2-A, dated valves are pressurized to at least 1.10 Pa ( 13.2 psig) and the seal October 2008 system capacity is adequate to maintain system pressure (or fluid head for the containment spray system and RHR spray system valves at penetrations 48A, 48B, 49A, and 49B) for at least 30 days.

SEQUOYAH - UNIT 1 5.5- 13 Amendment 334

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Safety Function Determination Program (SFDP) (continued)

A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable; and:

a. A required system redundant to the system(s) supported by the inoperable support system is also inoperable; or

b. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable; or

c. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.

5.5.14 Containment Leakage Rate Testing Program a.

NEI 94-01 , "Industry Guideline for Performance-Based Option of 10 CFR 50, Appendix J," Revision 3-

1. Bypass leakage paths to the auxiliary building leakage from isolation A, July 2012, and Section 4.1, valves that are sealed with fluid from a seal system may be excluded ,

"limitations and Conditions for NEI TR 94-01 , Revision 2," of the subject to the provisions of Appendix J, Section 111.C.3, when NRG Safety Evaluation Report in determining the combined leakage rate provided the seal system and NEI 94-01 , Revision 2-A, dated October 2008 valves are pressurized to at least 1.10 Pa ( 13.2 psig) and the seal system capacity is adequate to maintain system pressure (or fluid head for the containment spray system and RHR spray system valves at penetrations 48A, 488, 49A, and 498) for at least 30 days.

SEQUOYAH - UNIT 2 5.5-13 Amendment 327

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5 .13 Safety Function Determination Program (SFDP) (continued)

A loss of safety function exists when , assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed . For the purpose of this program, a loss of safety function may exist when a support system is inoperable; and:

a. A required system redundant to the system(s) supported by the inoperable support system is also inoperable; or

b. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable; or

c. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program , the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered . When a loss of safety function is caused by the inoperability of a single Technical Specification support system , the appropriate Conditions and Required Actions to enter are those of the support system .

5.5 .14 Containment Leakage Rate Testing Program

a. A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with NEI 94-01 , "Industry Guideline for Performance-Based Option of 10 CFR 50, Appendix J," Revision 3-A, July 2012, and Section 4.1, "Limitations and Conditions for NEI TR 94-01 , Revision 2," of the NRC Safety Evaluation Report in NEI 94-01, Revision 2-A, dated October 2008, as modified by the following exceptions:

1. Bypass leakage paths to the auxiliary building leakage from isolation valves that are sealed with fluid from a seal system may be excluded ,

subject to the provisions of Appendix J, Section 111.C.3, when determining the combined leakage rate provided the seal system and valves are pressurized to at least 1.10 Pa (13 .2 psig) and the seal system capacity is adequate to maintain system pressure (or fluid head for the containment spray system and RHR spray system valves at penetrations 48A, 488, 49A, and 49B) for at least 30 days.

SEQUOYAH - UNIT 1 5.5-13 Amendment 334,

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Safety Function Determination Program (SFDP) (continued)

A loss of safety function exists when , assuming no concurrent single failure , no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable; and:

a. A required system redundant to the system(s) supported by the inoperable support system is also inoperable; or

b. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable; or

c. A required system redundant to the support system(s) for the supported systems (a) and (b) above is also inoperable.

The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered . When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system .

5.5.14 Containment Leakage Rate Testing Program

a. A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50 , Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with NEI 94-01 , "Industry Guideline for Performance-Based Option of 10 CFR 50 , Appendix J," Revision 3-A, July 2012, and Section 4 .1, "Limitations and Conditions for NEI TR 94-01, Revision 2," of the NRC Safety Evaluation Report in NEI 94-01 , Revision 2-A, dated October 2008, as modified by the following exceptions:

1. Bypass leakage paths to the auxiliary building leakage from isolation valves that are sealed with fluid from a seal system may be excluded ,

subject to the provisions of Appendix J, Section 111.C.3, when determining the combined leakage rate provided the seal system and valves are pressurized to at least 1.10 Pa (13.2 psig) and the seal system capacity is adequate to maintain system pressure (or fluid head for the containment spray system and RHR spray system valves at penetrations 48A, 488, 49A, and 498) for at least 30 days.

SEQUOYAH - UNIT 2 5.5-13 ' Amendment 327,