ML081770464
| ML081770464 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/25/2008 |
| From: | Richard Jervey NRC/NRR/ADRO/DORL/LPLII-1 |
| To: | Tynan T Southern Nuclear Operating Co |
| Jervey, Richard 301-415-2728 | |
| Shared Package | |
| ML081770449 | List: |
| References | |
| TAC MD9003 | |
| Download: ML081770464 (12) | |
Text
June 25, 2008 Mr. Tom E. Tynan Vice President - Vogtle Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNIT 2, ISSUANCE OF EMERGENCY AMENDMENT REGARDING ONE-TIME EXTENSION TO ALLOWED OUTAGE TIME FOR TECHNICAL SPECIFCATION 3.6.6 (TAC NO. MD9003)
Dear Mr.Tynan:
The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 131 to Facility Operating License NPF-81 for the Vogtle Electric Generating Plant, Unit 2. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 24, 2008 as supplemented by letter dated June 25, 2008.
The amendment revises Limiting Condition for Operation (LCO) 3.6.6, Containment Spray and Cooling Systems, Action A Completion Time (CT) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to a one-time 7 day CT allow repair on the VEGP Unit 2 Containment Spray Pump B.
The pump was removed from service on June 23, 2008, at 0723 eastern standard time, to perform an inservice test (IST) and inservice inspection (ISI) leakage test. During the ISI, it was noted that the pump bearing was over heating and the pump seal was smoking. The disassembly and repair would require the pump to remain out of service and force the maintenance schedule to exceed the completion time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
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,
/RA/
R. A. Jervey, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-425
Enclosures:
- 1. Amendment No. 131 to NPF-81
- 2. Safety Evaluation cc w/encls: See next page
June 25, 2008 Mr. Tom E. Tynan Vice President - Vogtle Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNIT 2, ISSUANCE OF EMERGENCY AMENDMENT REGARDING ONE-TIME EXTENSION TO ALLOWED OUTAGE TIME FOR TECHNICAL SPECIFCATION 3.6.6 (TAC NO. MD9003)
Dear Mr.Tynan:
The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 131 to Facility Operating License NPF-81 for the Vogtle Electric Generating Plant, Unit 2. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 24, 2008 as supplemented by letter dated June 25, 2008..
The amendment revises Limiting Condition for Operation (LCO) 3.6.6, Containment Spray and Cooling Systems, Action A Completion Time (CT) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to a one-time 7 day CT allow repair on the VEGP Unit 2 Containment Spray Pump B.
The pump was removed from service on June 23, 2008, at 0723 eastern standard time, to perform an inservice test (IST) and inservice inspection (ISI) leakage test. During the ISI, it was noted that the pump bearing was over heating and the pump seal was smoking. The disassembly and repair would require the pump to remain out of service and force the maintenance schedule to exceed the completion time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
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,
/RA/
R. A. Jervey, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-425
Enclosures:
- 1. Amendment No. 131 to NPF-81
- 2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
Public LPL2-1 R/F RidsAcrsAcnwMailCenter GHill (4)
RidsNrrDorl RidsNrrDorlLpl2-1 Resource RidsNrrDirsItsb Resource RidsNrrPMRJervey Resource RidsRgn2MailCenter RidsNrrLAGLappertResource RidsNrrDorlDpr Resource RidsOgcRp Resource RidsNrrDssScvb Resource RidsNrrDraAadb Document Name: Package No.: ML081770449 Amendment No.: ML081770464 Tech Spec No.: ML081770492
- Memo, ** SE OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/DIRS/ITSB/BC NRR/DSS/SCVB/BC NRR/DRA/AADB/BC OGC NRR/LPL2-1/BC NAME RJervey GLappert RElliott RDennig **
RTaylor *
- JAdler, NLO MWong, JStang for DATE 6/25/08 6/25/08 6/25/08 6/25/08 6/25/08 6/25/08 6/25/08 OFFICIAL RECORD COPY
SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 131 License No. NPF-81
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to the Vogtle Electric Generating Plant, Unit 2 (the facility) Facility Operating License No. NPF-81 filed by the 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 June 24, 2008 as supplemented by letter dated June 25, 2008 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 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 Facility Operating License No. NPF-81 is hereby amended to read as follows:
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 131, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this 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.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA by JStang for/
Melanie C. Wong, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to License No. NPF-81 and the Technical Specifications Date of Issuance: June 25, 2008
ATTACHMENT TO LICENSE AMENDMENT NO. 131 FACILITY OPERATING LICENSE NO. NPF-81 DOCKET NO. 50-425 Replace the following pages of the Licenses 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 License No. NPF-81, page 4 License No. NPF-81, page 4 TSs TSs 3.6.6-1 3.6.6-1
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 131 TO FACILITY OPERATING LICENSE NPF-81 SOUTHERN NUCLEAR OPERATING COMPANY, INC.
VOGTLE ELECTRIC GENERATING PLANT, UNIT 2 DOCKET NO. 50-425
1.0 INTRODUCTION
By application dated June 24, 2008, as supplemented June 25, 2008, Southern Nuclear Operating Company (SNC), requested an emergency amendment to Vogtle Electric Generating Plant (VEGP, Vogtle) Unit 2 Technical Specifications (TS). The proposed change to the TS revises Limiting Condition for Operation (LCO) 3.6.6, Containment Spray and Cooling Systems, Action A Completion Time from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to a 7 day Completion Time (CT) on a one-time basis to allow repair on the VEGP Unit 2 Containment Spray Pump B..
On June 23, 2008 at 0723 eastern standard time (EST), the VEGP Unit 2 Containment Spray Pump B was removed from service to perform an inservice test (IST) and inservice inspection (ISI) leakage test. During the ISI, it was noted that the pump bearing was overheating and the pump seal was smoking. Disassembly and repair of the pump involves a number of major steps that could force the maintenance schedule to exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, thereby exceeding the TS CT. The VEGP Unit 2 CT will expire on June 26, 2008 at 0723 EST without the one-time extension to the CT. A one-time extension from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days has been requested to the VEGP Unit 2 CT for TS 3.6.6, Action A, to allow the Containment Spray Pump B to be inoperable to permit the repair, testing, and return to service of the pump in the event that full-flow testing or some other contingency (e.g., parts do not fit, etc.) is required. The proposed extended CT will expire upon returning the Containment Spray Pump B to OPERABLE status, or on June 30, 2008 at 0723 EST, whichever occurs first. The one-time emergency TS change will prevent an unnecessary shutdown of VEGP Unit 2.
2.0 REGULATORY EVALUATION
The Commission's regulatory requirements related to the content of the TSs are set forth in Title 10 to the Code of Federal Regulations (10 CFR), Part 50, Section 50.36. This regulation requires that the TSs 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, 3) surveillance requirements, 4) design features, and 5) administrative controls.
The containment spray and cooling systems are included in the VEGP Unit 2 TS LCO 3.6.6.
Condition A of this LCO requires that with one train of containment spray inoperable, that train must be restored to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
3.0 TECHNICAL EVALUATION
As stated above, the licensee requests an emergency amendment to the VEGP Unit 2 TS.
The proposed one-time change to the TS revises LCO 3.6.6, Containment Spray and Cooling Systems, Action A Completion Time from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to a one-time 7 day Completion Time to allow repair on the VEGP Unit 2 Containment Spray Pump B.
The licensees proposal does not modify the design or operation of the containment spray system. The proposal also does not affect the emergency core cooling system (ECCS), the containment cooling system, emergency power supplies or containment integrity.
The VEGP licensing basis considers two single failure cases: minimum and maximum safeguards. The minimum safeguards case is the postulated loss of one (of two trains) emergency diesel generators. This results in the loss of one safety injection train and one train of containment cooling (one train of fan coolers and one train of containment spray). The maximum safeguards case considers maximum safety injection with minimum containment safeguards components available. This maximizes the mass release and minimizes the containment heat removal. The limiting case for VEGP Unit 2 is the minimum safeguards case.
The current VEGP Unit 2 configuration, with only one containment spray pump available, most closely resembles the maximum safeguards case which is not the limiting case for VEGP.
The licensees proposed TS change extends the period of time that the single failure criterion would not be satisfied from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days.
There are several bases for staff approval of the licensees proposed extension of the period of time that the single failure criterion would not apply. First, even if the single failure criterion were not met and the OPERABLE containment spray train were lost, an acceptable level of safety would be maintained. An acceptable outcome would be maintaining containment integrity and acceptable radiological consequences. Second, the licensee has committed to assuring the availability of the OPERABLE containment spray train, both trains of the containment cooling system, and the ECCS.
These bases are discussed in the paragraphs below One basis for approval of this change is an acceptable outcome assuming the loss of the OPERABLE train of the containment spray system during a postulated loss-of-coolant accident (LOCA) or main steam line break accident. The TS were formulated to preserve the single failure criterion for systems that are relied upon in the safety analysis report. By and large, the single failure criterion is preserved by specifying Limiting Conditions for Operation (LCOs) that require all redundant components of safety related systems to be OPERABLE. When the required redundancy is not maintained, either due to equipment failure or maintenance outage, action is required, within a specified time, to change the operating mode of the plant to place it in a safe condition. The specified time to take action is a temporary relaxation of the single failure criterion, which, consistent with overall system reliability considerations, provides a limited time to fix equipment or otherwise make it OPERABLE. If equipment can be returned to OPERABLE status within the specified time, plant shutdown is not required.
It is possible that with no containment spray cooling, the containment design pressure may be exceeded (depending on power level, break type and location, etc.). Scale tests have been performed which demonstrate that containment failure occurs at pressures much greater than the design pressure (typically more than a factor of two)1. In addition, increased leakage was not observed in these tests until pressures close to the ultimate containment pressure were reached. Thus, the increase in containment pressure due to loss of both trains of the containment spray system should not result in increased leakage and containment integrity will be maintained. Calculations performed for other pressurized water reactors with large dry containments confirm that containment integrity will be maintained with loss of the containment spray system. A licensee for a pressurized water reactor (PWR) with a large dry containment requested an increase in containment spray system allowed outage time from 7 to 14 days.
To support this change, the licensee performed an analysis of a main steam line break with no containment spray available. The results showed that the magnitude and duration of the peak pressure and temperature inside containment which exceeded the current design basis limits were relatively minor with respect to the safety margins inherent in the design of the containment.2 Following the loss of both trains of containment spray for three minutes at another PWR with a large dry containment, the licensee for that plant performed analyses assuming loss of all containment spray for 20 minutes.3 The LOCA analyses, assuming no containment spray for 20 minutes showed no impact on the LOCA containment response. The main steam line break (MSLB), calculations found that there was no significant increase in the MSLB long term temperature profile when compared to the design basis thermal aging profile for environmentally qualified equipment.
These calculations help to support the conclusion that containment integrity would be maintained upon loss of all containment spray, which is beyond what the licensee is proposing.
The containment spray system also has the design basis function of reducing the radiological source term in the containment atmosphere in order to maintain offsite and control room dose levels below the limits of Title 10 of the Code of Federal Regulations (10 CFR) Part 100 and 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 19. However, the assumed design basis source term is based on the assumption that the core has melted. The licensees proposed TS change, together with the assumption that the OPERABLE containment spray train would not be available is outside of the VEGP Unit 2 licensing basis. Therefore, it is acceptable to consider a more realistic source term. The four additional days of this allowed outage time extension do not affect the operability of the ECCS. Also, the proposed change does not affect the low probability of core melt due to a LOCA or main steam line break.
Therefore, the source term of radioactive material would be expected to be significantly less than the 10 CFR Part 100 core melt assumptions, even without containment spray. Therefore, there is a reasonable assurance that the limits of 10 CFR Part 100 and GDC 19 will be met without containment spray.
1 M.F. Hessheimer and R. A. Dameron, Containment Integrity Research at Sandia National Laboratories, An Overview, Sandia national laboratories, NUREG/CR-6906, July 2006 2 Letter from James R. Becker, Vice-President-Diablo canyon Operations and Station Director, Response to NRC Request for Additional Information Regarding Emergency license Amendment request 04-03, Revision to Technical Specification 3.6.6, Containment Spray and Cooling Systems July 30, 2004 3 Letter from R. A. Jones, Vice President Oconee Nuclear Site, Duke Power, to US NRC, Licensee Event Report 269/2004-03, Revision 0, November 11, 2004
The licensee supplemented the June 24, 2008, letter with a June 25, 2008, letter containing the following commitments related to the proposed extension of the containment spray system CT.
Both trains of the emergency core cooling system (ECCS), both trains of the containment cooling system (CCS), the remaining train of the containment spray (CS) system, and attendant equipment will remain OPERABLE during the proposed 7 day Completion Time.
If any train of ECCS, CCS, or the remaining train of CS becomes inoperable or requires maintenance during the proposed 7 day Completion Time, TS LCO 3.0.3 will be entered.
The staff finds these commitments to be acceptable since they support the staffs basis for granting the increase in containment spray system TS CT.
The NRC has previously approved a similar extension of a CT from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days for another PWR with a large dry containment.4 4.0
SUMMARY
The NRC staff has concluded that the proposed one-time extension of the CTs for the VEGP Unit 2 Containment Spray Pump B is acceptable. This conclusion is based, in part, on the availability and reliability of the Containment Spray Pump A and the availability of all ECCS trains coupled with the low likelihood of the loss of the Containment Spray Pump A during the extended CT. In addition, the licensee has taken compensatory measures limiting activities that have the potential to result in a plant transient. Therefore, the NRC staff finds that there is no undue risk to public health and safety associated with granting the CT extensions for the Containment Spray Pump B.
5.0 STATEMENT OF EMERGENCY CIRCUMSTANCES Section 50.91 of 10 CFR Part 50 provides special exceptions for the issuance of amendments when the usual 30-day notice for public comment cannot be met. One type of special exception is an emergency. Specifically, 10 CFR 50.91(a)(5) provides that where the NRC finds that an emergency situation exists, in that failure to act in a timely way would result in the derate or shut down of a nuclear power plant, it may issue a license amendment involving no significant hazards consideration without prior notice and opportunity for a hearing or public comment. In this situation, the NRC will publish a notice of issuance under 10 CFR 2.106, providing for opportunity of a hearing and for public comment after issuance.
The licensee provided the following in the application for this amendment.
The proposed one-time change to the VEGP Unit 2 Completion Time of Technical Specifications 3.6.6, Action A, is needed to avoid the unnecessary shutdown of the plant to complete Unit 2 Containment Spray Pump B repair activities. The change 4 Letter from US NRC to Mr. Jeffrey S. Forbes, Site Vice President Arkansas Nuclear One, Entergy Operations, Inc., Arkansas Nuclear One, unit No. 2 - Issuance of Amendment re: License Amendment Request for a One-Time Extension of the Containment Spray System (CSS) Allowable Outage Time (AOT), September 28, 2006
averts known risks from complex and infrequent plant shutdown and startup evolutions that would unnecessarily challenge plant systems.
The need for containment spray pump repairs did not become apparent until after the scheduled testing was performed. The condition was unexpected because previous surveillance testing was successful and indicated the pump was reliable, the licensee could not have anticipated the need for a license amendment that would allow for a 30-day comment period. Additionally, the proposed amendment involves no significant hazards as specified in 10 CFR 50.92.
6.0 REGULATORY COMMITMENTS In the June 25, 2008, submittal the licensee made the following regulatory commitments; Both trains of the emergency core cooling system (ECCS), both trains of the containment cooling system (CCS), the remaining train of the containment spray (CS) system, and attendant equipment will remain OPERABLE during the proposed 7 day Completion Time.
If any train of ECCS, CCS, or the remaining train of CS becomes inoperable or requires maintenance during the proposed 7 day Completion Time, TS LCO 3.0.3 will be entered.
The above regulatory commitments have been entered in the licensees commitment management system which complies with Nuclear Energy Institute Document 99-04, Revision 0, Guidelines for Managing NRC Commitment Changes. The NRC staff has reviewed the regulatory commitments and how they will be controlled and finds that the licensees commitments provide adequate assurance that safe plant operation will not be affected by the extended CT.
7.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
DETERMINATION The Commissions regulations in 10 CFR 50.92(c) state that the Commission may make a final determination that a license amendment involves no significant hazards consideration if operation of the facility in accordance with the amendment would not:
(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or, (2) Create the possibility of a new or different kind of accident from any previously evaluated; or, (3) Involve a significant reduction in a margin of safety.
The following analysis was provided by the licensee in its June 24, 2008, letter:
- 1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change does not alter any plant equipment or operating practices in such a manner that the probability of an accident is increased. The proposed
changes will not alter assumptions relative to the mitigation of an accident or transient event. The proposed change has no impact on CDF or LERF because the containment spray system is not required to prevent core damage or large early release. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the proposed license amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Based on the operability of the remaining containment spray train and the two containment cooling trains, the proposed change ensures that the accident analysis assumptions continue to be met. The systems design and operation are not affected by the proposed changes. The safety analysis acceptance criteria are not altered by the proposed changes.
Therefore, the proposed change does not involve a significant decrease in the margin of safety.
The NRC staff reviewed the licensees analysis and, based on the review, has concluded that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff determined that the proposed amendment involves no significant hazards consideration.
8.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendment.
9.0 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 made a final no significant hazards finding with respect to the amendment. 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.
10.0 CONCLUSION
The NRC staff has concluded, based on the considerations discussed above, that (1) the amendment does not (a) involve a significant increase in the probability or consequences of an accident previously evaluated or, (b) create the possibility of a new or different kind of accident from any previously evaluated or, (c) involve a significant reduction in a margin of safety and therefore, the amendment involves no significant hazards consideration; (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (3) such activities will be conducted in compliance with the Commissions regulations, and (4) 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 Contributors: R. Lobel, NRR Date: June 25, 2008