ML083260241

Issuance of Amendment Regarding Technical Specifications for Reactor Coolant System (RCS) Leakage Detection Systems

ML083260241
Person / Time
Site:	Sequoyah
Issue date:	12/04/2008
From:	Moroney B Plant Licensing Branch II
To:	Campbell W Tennessee Valley Authority
Orf, Tracy J.; NRR/DORL 415-2788
References
TAC ME0103, TAC ME0104
Download: ML083260241 (24)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 December 4, 2008 Mr. William R. Campbell, Jr.

Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 SUB..IECT: SEOUOYAH NUCLEAR PLANT, UNITS 1 AND 2 -- ISSUANCE OF AMENDMENT REGARDING TECHNICAL SPECIFICATIONS FOR REACTOR COOLANT SYSTEM LEAKAGE DETECTION SYSTEMS (TAC NOS. ME0103 AND ME0104)

Dear Mr. Campbell:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment Nos. 322 and 314 to Facility Operating License Nos. DPR-77 and DPR-79 for Sequoyah Nuclear Plant (SON), Units 1 and 2, respectively. The amendments are in response to your application dated November 12, 2008.

The amendments change the SON, Units 1 and 2 Technical Specification (TS) 3.3.3.1, "Radiation Monitoring," and TS 3.4.6.1, "Leakage Detection Instrumentation," by removing the requirement for one operable containment atmosphere gaseous radioactivity monitor. The changes include corresponding changes to surveillance requirements.

A copy of the safety evaluation is also enclosed. Notice of issuance will be included in the NRC's biweekly Federal Register notice.

Sincerely, A !aG, I u /'-VV~ j/a.v / f"\

Brendan T. Moroney, Proje anager Plant Licensing Branch II Division of Operating Re t r Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosures:

1. Amendment 1\10. 322 to License No. DPR-77

2. Amendment No. 314 to License No. DPR-79

3. Safety Evaluation cc w/enclosures: Distribution via Listserve

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-327 SEQUOYAH NUCLEAR PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 322 License No. DPR-77

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

A. The application for amendrnent by Tennessee Valley Authority (the licensee) dated November 12, 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 set forth in Title 10 of the Code of Federal Regulations (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 assura.nce (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. DPR-77 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 322 ,are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance, to be implemented no later than 60 days after issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/ 7/

(

Thomas H. Boyce, Cttlef Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. DPR-77 and the Technical Specifications Date of Issuance: December 4, 2008

ATTACHMENT TO AMENDMENT NO. 322 FACILITY OPERATING LICENSE NO. DPR-77 DOCKET NO. 50-327 Replace Page 3 of Operating License DPR-77 with the attached Page 3.

Replace the following pages of the Appendix A, Technical Specifications, with the attached pages. The revised pages are identified by amendment number and contain vertical lines indicating the area of change.

Remove Page Insert Page 3/4.3-40 3/4.3-40 3/4.3-42 3/4.3-42 3/4.4-13 3/4.4-13

-3 (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required, any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis, instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the Sequoyah and Watts Bar Unit 1 Nuclear Plants.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is sUbject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The Tennessee Valley Authority is authorized to operate the facility at reactor core power levels not in excess of 3455 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 322, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Initial Test Program The Tennessee Valley Authority shall conduct the post-fuel-Ioading initial test program (set forth in Section 14 of Tennessee Valley Authority's Final Safety Analysis Report, as amended), without making any major modifications of this program unless modifications have been identified and have received prior NRC approval. Major modifications are defined as:

a. Elimination of any test identified in Section 14 of TVA's Final Safety Analysis Report as amended as being essential;

b. Modification of test objectives, methods or acceptance criteria for any test identified in Section 14 of TVA's Final Safety Analysis Report as amended as being essential;

c. Performance of any test at power level different from there described; and Facility Operating License No. DPR-77 Amendment No. 322

TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION MINIMUM CHANI\JELS APPLICABLE ALARMITRIP MEASUREMENT INSTRUMENT OPERABLE MODES SETPOINT RANGE ACTION

1. AREA 1VI01\J ITOR

a. Fuel Storage Pool ~ 151 mR/hr -1 4 26 10 -10 mR/hr Area

2. PROCESS MONITORS

-3 7

~8.5x10 Il 10 - 10 cpm

a. Containment Purge 1,2,3,4 & 6 28 Ci/cc Air

b. Containment

i. Deleted ii. Particulate Activity 7

RCS Leakage 1,2,3 & 4 N/A 10- 10 cpm 27 Detection

c. Control Room 7 2 ALL MODES ~ 400 cpm** 10 - 10 cpm 29 Isolation and during movement of irradiated fuel assemblies

• With fuel in the storage pool or building 5

• • Equivalent to 1.0 x 10- IlCilcc.

SEQUOYAH - UI\JIT 1 3/43-40 Amendment Nos. 12,60,112,168,256,310,322

TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL MODES FOR WHICH CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE INSTRUMENT CHECK CALIBRATION TEST REQUIRED

1. AREA MONITOR

a. Fuel Storage Pool S R Q Area

2. PROCESS MONITORS

a. Containment Purge Air S R Q 1,2,3,4 & 6 Exhaust

b. Containment

i. Deleted ii. Particulate Activity RCS Leakage S R Q 1,2,3, & 4 Detection

c. Control Room S R Q ALL MODES Isolation

• With fuel in the storage pool or building.

SEQUOYAH - UNIT 1 3/43-42 Amendment Nos. 12,112,168,220,322

REACTOR COOLANT SYSTEM 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE LEAKAGE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.4.6.1 The following Reactor Coolant System leakage detection instrumentation shall be OPERABLE:

a. One lower containment atmosphere particulate radioactivity monitoring channel, and

b. One containment pocket sump level monitor.

APPLICABILITY: MODES 1,2,3 and 4.

ACTION:

a. With both containment pocket sump monitors inoperable, operation may continue for up to 30 days provided SR 4.4.6.2.1 is performed once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s*; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With the particulate lower containment atmosphere radioactivity monitor inoperable, operation may continue for up to 30 days provided grab samples of the lower containment atmosphere are analyzed once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or SR 4.4.6.2.1 is performed once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s*; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

c. With both containment pocket sump monitors and the lower containment atmosphere radioactivity monitor inoperable, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.4.6.1 The leakage detection instrumentation shall be demonstrated OPERABLE by:

a. Performance of the lower containment atmosphere particulate monitor CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST at the frequencies specified in Table 4.3-3, and

b. Performance of containment pocket sump level monitor CHANNEL CALIBRATION at least once per 18 months.

• Surveillance performance not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

SEQUOYAH - Ut\IIT 1 3/44-13 Amendment Nos. 12,259,301, 322

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-328 SEQUOYAH NUCLEAR PLANT. UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 314 License No. DPR-79

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

A. The application for amendment by Tennessee Valley Authority (the licensee) dated November 12, 2008, compiies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. DPR-79 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 314 ,are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance, to be implemented no later than 60 days after issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

~

Thomas H. BOYC~

Plant Licensing Branch 11-2 Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. DPR-79 and the Technical Specifications Date of Issuance: December 4, 2008

ATTACHMENT TO AMENDMENT NO. 314 FACILITY OPERATING LICENSE NO. DPR-79 DOCKET NO. 50-328 Replace Page 3 of Operating License DPR-79 with the attached Page 3.

Replace the following pages of the Appendix A, Technical Specifications, with the attached pages. The revised pages are identified by amendment number and contain vertical lines indicating the area of change.

Remove Page Insert Page 3/4.3-41 3/4.3-41 3/4.3-43 3/4.3-43 3/4.4-17 3/4.4-17

-3 (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the Sequoyah and Watts Bar Unit 1 Nuclear Plants.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The Tennessee Valley Authority is authorized to operate the facility at reactor core power levels not in excess of 3455 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 314, are hereby incorporated into this license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Initial Test Program The Tennessee Valley Authority shall conduct the post-fuel-loading initial test program (set forth in Section 14 of Tennessee Valley Authority's Final Safety Analysis Report, as amended), without making any major modifications of this program unless modifications have been identified and have received prior NRC approval. Major modifications are defined as:

a. Elimination of any test identified in Section 14 of TVA's Final Safety Analysis Report as amended as being essential;

b. Modification of test objectives, methods or acceptance criteria for any test identified in Section 14 of TVA's Final Safety Analysis Report as amended as being essential;

c. Performance of any test at power level different from there described; and Facility Operating License No. DPR-79 Amendment No. 314

TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION MINIMUM CHANNELS APPLICABLE ALARM/TRIP MEASUREMENT INSTRUMENT OPERABLE MODES SETPOINT RANGE ACTION

1. AREA MONITOR

a. Fuel Storage Pool ~151 mR/hr 10 10 4 mR/hr 26 Area

2. PROCESS MONITORS 7

a. Containment Purge 1,2,3,4 & 6 ~8.5 X 10-3 10-10 cpm 28 Air ~Ci/cc

b. Containment

i. Deleted ii. Particulate Activity 7

RCS Leakage 1,2,3 & 4 N/A 10- 10 cpm 27 Detection 7

c. Control Room 2 ALL MODES ~ 400 cpm** 10-10 cpm 29 Isolation and during movement of irradiated fuel assemblies With fuel in the storage pool or building Equivalent to 1.0 x 10-5

~lCi/cc.

SEQUOYAH - UNIT 2 3/43-41 Amendment Nos. 52, 102, 158,247,299,314

TABLE 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS CHANNEL MODES FOR WHICH CHANNEL CHANNEL FUNCTIONAL SURVEILLANCE IS INSTRUMENT CHECK CALIBRATION TEST REQUIRED

1. AREA MONITOR

a. Fuel Storage Pool S R Q

• Area

2. PROCESS MONITORS

a. Containment Purge Air S R Q 1,2,3,4 & 6 Exhaust

b. Containment

i. Deleted ii. Particulate Activity RCS Leakage S R Q 1,2,3 & 4 Detection

c. Control Room S R Q ALL MODES Isolation

• With fuel in the storage pool or building.

SEQUOYAH - UNIT 2 3/43-43 Amendment Nos. 102, 158,210, 314

REACTOR COOLANT SYSTEM 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE LEAKAGE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.4.6.1 The following Reactor Coolant System leakage detection instrumentation shall be OPERABLE:

a. One lower containment atmosphere particulate radioactivity monitoring channel, and

b. One containment pocket sump level monitor.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a. With both containment pocket sump monitors inoperable, operation may continue for up to 30 days provided SR 4.4.6.2.1 is performed once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s*; otherwise, be in at least HOT STAr---IDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. With the particulate lower containment atmosphere radioactivity monitor inoperable, operation may continue for up to 30 days provided grab samples of the lower containment atmosphere are analyzed once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or SR 4.4.6.2.1 is performed once per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s*; otherwise, be in at least HOT STAr---IDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

c. With both containment pocket sump monitors and the lower containment atmosphere radioactivity monitor inoperable, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMEI'.JTS 4.4.6.1 The leakage detection instrumentation shall be demonstrated OPERABLE by:

a. Performance of the lower containment atmosphere particulate monitor CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST at the frequencies specified in Table 4.3-3, and

b. Performance of containment pocket sump level monitor CHANNEL CALIBRATION at least once per 18 months.

• Surveillance performance not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

SEQUOYAH - UNIT 2 3/44-17 Amendment Nos. 250, 290, 314

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 322 TO FACILITY OPERATING LICENSE NO. DPR-77 AND AMENDMENT NO. 314 TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION

By letter dated November 12, 2008 (Agencywide Document and Access Management System Accession No. ML083180805), the Tennessee Valley Authority (TVA or the licensee), submitted a request to change the Sequoyah Nuclear Plant (SQN), Units 1 and 2, Technical Specifications (TSs). The proposed changes would revise TS 3.3.3.1, "Radiation Monitoring," and TS 3.4.6.1, "Leakage Detection Instrumentation," by removing the requirement for one operable containment atmosphere gaseous radioactivity monitor. The changes include corresponding changes to surveillance requirements.

The radiation monitoring function of the reactor coolant leakage detection system is accomplished through particulate and noble gas monitors. The containment air from the lower and upper compartments is normally sampled and monitored by separate monitor assemblies.

One assembly normally monitors the lower compartment and one assembly normally monitors the upper compartment. Each assembly consists of a particulate and noble gas monitors.

These separate monitor systems are interconnected by stainless steel tubing to allow monitoring of the lower compartment by either monitor, in case one monitor assembly malfunctions. The particulate and noble gas monitors are each indicated, recorded, and annunciated in the main control room (MCR). Visual and audible alarms are initiated on high radiation and instrument malfunction.

The integrated computer system (ICS) utilizes the count rate input signal from these radiation monitors to calculate an ICS alarm setpoint to further comply with General Design Criterion (GDC) 30, "Quality of reactor coolant pressure boundary," of Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 and the U.S. Nuclear Regulatory Commission (NRC or Commission) Regulatory Guide (RG) 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," Revision O. The ICS alarm setpoint is calculated with a predetermined percent increase of count rate above a .continuous updated hourly background count rate that reflects current plant conditions. When the lower compartment 1-minute current average background count rate exceeds the predetermined percent increase of the hourly averaged background count rate, an ICS computer alarm in the MCR will initiate.

-2 Because of improvements in fuel integrity and lower reactor coolant activities, the gaseous radiation monitor cannot reliably provide indication of a reactor coolant leak within the guidelines of RG 1.45. Therefore, the licensee proposes to remove the requirement for the gaseous monitor from the TSs.

As discussed in the licensee's application, dated November 12, 2008, TVA requested that the proposed amendments be processed by the NRC staff on an exigent basis in accordance with the provisions in1 a CFR 50.91 (a)(6). The NRC staff evaluation regarding the exigent circumstances is discussed below in Section 4.0 of this safety evaluation (SE).

2.0 REGULATORY EVALUATION

GDC 30, addresses in part, the means for providing, detecting, and to the extent practical, identifying the location of the source of reactor coolant leakage. RG 1.45, Revision a describes acceptable methods of implementing GDC 30 with regard to the selection of leakage detection systems for the reactor coolant pressure boundary (RCPB). Position C.3 of RG 1.45, Revision 0, states that at least three different detection methods should be employed. Two of these methods should be sump level and flow monitoring and airborne particulate radioactivity monitoring. The third method may involve either monitoring of condensate flow rate from air coolers or monitoring of gaseous radioactivity.

RG 1.45, Revision a recommended that the sensitivity and response time of each leakage detection system employed for unidentified leakage should be adequate to detect a leakage rate, or its equivalent, of 1 gallon per minute (gpm) in less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

In May 2008, the NRC staff issued Revision 1 to RG 1.45. Section B, "Discussion," of RG 1.45, Revision 1, describes that the effectiveness of airborne gaseous radioactivity monitors depends primarily on the activity of the reactor coolant and also, in part, on the containment volume and the background activity level. Because of improvements in fuel integrity, many operating plants have reported experiencing very long gaseous radioactivity monitor response times to reactor coolant system (RCS) leakage, considering realistic coolant activities. Accordingly, Position C.2.3 of RG 1.45, Revision 1, states that plant TSs should identify at least two independent and diverse methods and recommends considering the following leakage detection methods for incorporation in the TSs: monitoring containment sump level or flow; monitoring airborne particulate radioactivity; and monitoring condensate flow rate from air coolers. That position also recommended considering several other methods for supplemental detection of leakage, including containment gaseous radioactivity monitoring.

In Section 5.2.7, "RCPB Leakage Detection Systems," of the SON, Units 1 and 2, Updated Final Safety Analysis Report (UFSAR), the licensee describes the degree of conformance with the intent of GDC 30. The SON RCPB leakage detection system is based on a diverse set of leakage detection methods. As discussed in Section 5.2.7 of the UFSAR, these detection methods can include containment particulate radiation monitors, containment radioactive gas monitors, humidity monitors, reactor vessel flange leak-off detectors, condenser vacuum pump radiation monitors, component cooling system radiation monitors, steam generator blowdown radiation monitors, charging pump operation and excessive makeup volume detection, main

-3 steam line radiation monitors, and the reactor building floor and equipment drain sump level monitors.

GDC 4 of Appendix A to 10 CFR Part 50 states that "...dynamic effects associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping." The NRC allows the application of leak-before-break (LBB) technology on the primary piping systems under the broad-scope revision to GDC 4 (52 FR 41288-41295; October 27, 1987). Specific guidance on LBB evaluation is discussed in NRC's Standard Review Plan (SRP) Section 3.6.3, "Leak-Before-Break Evaluation Procedures." Section 3.6.3 of the SRP specifies that leak detection systems be reliable, redundant, diverse and sensitive, and that substantial margin exists to detect the leakage from the through-wall flaw used in the deterministic fracture mechanics evaluation.

The SON, Units 1 and 2, UFSAR Section 3.6.1, "Systems in Which Design Basis Piping Breaks Occur," identifies that the NRC staff accepted LBB analyses for several piping segments at SON, Units 1 and 2, including the main RCS piping and certain branch piping. In accepting these LBB analyses, the NRC staff considered the performance of the available leak detection systems.

3.0 TECHNICAL EVALUATION

3.1 Specific Changes Requested The proposed amendments would change the required RCS leakage detection instrumentation by removing reference to the containment atmosphere gaseous radioactivity monitor from TSs.

These amendments modify TS 3.3.3.1, "Radiation Monitoring," and TS 3.4.6.1, "Leakage Detection Instrumentation," at SON, Units 1 and 2, to remove the operability requirement for one containment atmosphere gaseous radioactivity monitor, leaving the requirement for one containment atmosphere particulate radioactivity monitor and one containment pocket sump level monitor to be operable in Modes 1, 2, 3 and 4. Corresponding changes to Surveillance Requirement 4.3.3.1 and 4.4.6.1 are also proposed at each unit. Additionally, the proposed changes include modifications to existing TS 3.4.6.1 Action requirements.

These proposed changes will maintain a requirement for at least two diverse leakage monitoring systems and, thus, are consistent with the guidance of Position C.2.3 of RG 1.45, Revision 1.

The proposed changes are also consistent with NUREG-1431, "Standard Technical Specifications - Westinghouse Plants," Revision 3.1. Therefore, the NRC staff finds the proposed changes to TS LCO 3.4.6.1 acceptable.

3.2 Leak-Before-Break The basic concept of LBB is that certain piping material has sufficient fracture toughness (Le., ductility) to resist rapid flaw propagation. A postulated flaw in such piping would not lead to pipe rupture and potential damage to adjacent safety related systems, structures and components before the plant could be placed in a safe, shutdown condition. Before pipe

-4 rupture, the postulated flaw would lead to limited but detectable leakage which would be identified by the leak detection systems in time for the operator to take action.

The NRC staff reviews the application of LBB methodology to primary system piping to ensure that certain safety margins are satisfied to assure the structural integrity of the pipe. SRP Section 3.6.3 specifies a margin of the square-root of 2 be applied to the loads to assure that leakage-size flaws are stable at the normal load plus safe-shutdown earthquake load. A margin of 10 is to be applied to leakage so that detection of leakage from the postulated flaw size is ensured when the pipe is subjected to normal operational loads. In addition, the critical flaw size should be twice as large as the leakage flaw size (Le., a margin of 2 on leakage flaw size). SRP Section 3.6.3 also specifies that leakage detection systems for LBB applications be sufficiently redundant, diverse, and sensitive. It further specifies that leak detection systems for LBB applications be equivalent to RG 1.45, Revision 0 for piping inside the containment. RG 1.45, Revision 0 specifies a time frame of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or less to detect a 1 gpm leak. This time frame ensures that plant operators have timely information about unidentified leakage.

The NRC staff notes that TVA is not changing the assumptions and technical basis of its LBB analyses of the RCS piping in the proposed amendments other than the proposed changes to leakage detection systems. TVA stated that even if the diversity of the leak detection system is reduced by lack of sufficient primary system activity to credit operation of the gaseous radiation monitors discussed in Section 5.2.7 of the UFSAR, sufficient diversity and sensitivity exist in the remaining portions of the leak detection systems to meet the design basis leak detection requirement (1 gpm in approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />). As previously noted, these detection methods can include containment particulate radiation monitors, containment radioactive gas monitors, humidity monitors, reactor vessel flange leak-off detectors, condenser vacuum pump radiation monitors, component cooling system mdiation monitors, steam generator blowdown radiation monitors, charging pump now rate and excessive makeup volume detection, main steam line radiation monitors, and the reactor building floor and equipment drain sump level monitors.

The NRC staff finds that, with the aforementioned multiple monitors, the ability to detect a leakage rate of 1 gpm in approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is ensured and maintained, even if gaseous radiation monitors are not considered. The NRC staff finds further that the 1 gpm per hour capability of the $ON detection systems satisfies the recommended factor of 10 in SRP 3.6.3, and NUREG-1 061, Volume 3, "Report of the NRC Piping Review Committee, Evaluation of Potential Pipe Breaks." Therefore, the NRC staff finds the proposed changes to TS LCO 3.4.6.1 acceptable in terms of LBB consideration.

3.3 Summary The NRC staff has reviewed the licensee's submittal and supporting documentation. Based on its review, the NRC staff concludes that the required RCS leakage detection systems will continue to provide diverse methods of leak detection that satisfy the intent of GDC 30 and RG 1.45, Revision 0 as described by the SON, Units 1 and 2, UFSAR. Further, the required leakage detection capability is adequate to support the application of the LBB methodology at SON, Units 1 ano 2. Therefore, the proposed changes for the deletion of the containment atmosphere gaseous radiation monitor are acceptable. On this basis, the !\IRC staff concludes that the proposed amendments are ac~eptable.

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Background===

The Commission's regulations in 10 CFR 50.91 contain provisions for issuance of amendments when the usual 30-day public comment period cannot be met. One of these provisions is an exigency. An exigency is a case where the licensee and the NRC staff must act quickly and there is insufficient time to process the license amendment request within the normal time frame.

Pursuant to the provisions in 10 CFR 50.91 (a)(6), the licensee requested the proposed amendments on an exigent basis.

Under the provisions in 10 CFR 50.91 (a)(6), the Commission notifies the public in one of two ways: (1) by issuing a Federal Register notice providing an opportunity for hearing and allowing at least 2 weeks from the date of the notice for prior public comments; or (2) by using local media to provide reasonable notice to the public in the area surrounding the licensee's facility.

In this case, the Commission used the second approach and published a public notice in the local newspaper, the Chattanooga Times Free Press (Chattanooga, Tennessee), on November 26, 2008.

As discussed in the licensee's application dated November 12, 2008, TVA requested that the proposed amendments be processed by the NRC staff on an exigent basis based on the recent identification of this issue and the significant impact it has on shutting down SON, Units 1and 2.

Identification of the Issue While the containment gaseous radiation monitor continues to provide leakage detection and trending capability, improvements in nuclear fuel reliability over time have resulted in baseline RCS coolant radioactivity being reduced to a level far below that used for original design specification for these monitors, resulting in a reduction of effectiveness of the containment gaseous radiation monitors in detecting very small leaks and changes in leak rate. Although there has been ongoing dialogue between the NRC and industry to address this issue, a final resolution has not been identified. TVA stated that it had previously recognized the detection sensitivity limitations, took actions to clarify the TS Bases and UFSAR, and continued to monitor the industry initiative. It did not interpret RG 1.45 to require monitor operability under all plant conditions until the discussion with the NRC staff on November 6, 2008. At that time, TVA declared that the gaseous radiation monitor channel was inoperable since it was unable to detect a 1 gpm RCS leak within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> under current plant conditions, and entered Action B of LCO 3.4.6.1 for SON Unit 1, which has a 30-day action statement. On November 7, SON Unit 2 entered Mode 4 and also entered Action B of LCO 3.4.6.1. The licensee determined that a license amendment request was needed. TVA submitted the amendment request to the NRC on November 12, 2008.

Impact on Shutting down SON Units 1 and 2 Generic resolution of the issue based on the ongoing industry initiative will not be completed in the near term. The issue could be resolved at SON if the proposed license amendments were issued before the end of the 30-day TS action period. Otherwise, both units would be required to shut down. In the licensee's application, dated November 12, 2008, TVA requested that the

- 6 proposed amendments be processed by the NRC staff on an exigent basis in accordance with provisions in 10 CFR 50.91 (a)(6) to avoid an unnecessary plant shutdown.

NRC Staff Conclusion Based on the above circumstances, the NRC staff finds that the licensee made a timely application for the proposed amendments following identification of the issue. In addition, the NRC staff finds that the licensee could not avoid the exigency without shutting down SON, Units 1 and 2. Based on these findings, the NRC staff has determined that a valid need exists for issuance of the license amendments using the exigent provisions of 10 CFR 50.91 (a)(6).

5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION The Commission has made a final determination that the amendment request involves no significant hazards consideration. Under the Commission's regulations in 10 CFR 50.92, this means that operation of the facility in accordance with the proposed amendments do 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 accident previously evaluated; or (3) involve a significant reduction in a margin of safety. As required by 10 CFR 50.91 (a), the licensee has provided in its letter of November 12, 2008, its analysis of the issue of no significant hazards consideration which is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change has beenevaluated and determined to not increase the probability or consequences of an accident previously evaluated. The proposed change does not make any hardware changes and does not alter the configuration of any plant system, structure or component (SSC). The containment atmosphere gaseous radioactivity monitor is not credited for use in the initiation of any protective functions. The proposed change only removes the containment atmosphere gaseous radioactivity monitor for meeting the operability requirements for Technical Specification (TS) 3.4.6.1 and TS 3.3.3.1. Therefore, the probability of occurrence of an accident is not increased. The TS will continue to require diverse means of leakage detection equipment, thus ensuring that leakage due to cracks would continue to be identified prior to breakage and the plant shutdown accordingly. Therefore, the consequences of an accident are not increased.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change does not involve the use or installation of new equipment and the currently installed equipment will not be operated in a new or different

-7 manner. No new or different system interactions are created and no new processes are introduced. The proposed changes will not introduce any new failure mechanisms, malfunctions, or accident initiators not already considered in the design and licensing bases. The proposed change does not affect any SSC associated with an accident initiator. Based on this evaluation, 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 change involve a significant reduction in a margin of safety?

Response: No The proposed change does not make any alteration to any RCS leakage detection components. The proposed change removes the gaseous channel of the containment atmosphere radioactivity monitor from TS 3.4.6.1 and TS 3.3.3.1.

The proposed amendment continues to require diverse means of leakage detection equipment with capability to promptly detect RCS leakage. Additional diverse means of leakage detection capability are available, although not provided in the TSs. Based on this evaluation, the proposed change does not involve a significant reduction in a margin of safety.

The NRC staff has reviewed the licensee's analysis and based on this review, determined that the three standards of 10 CFR 50.92 are satisfied. Therefore, the NRC staff has determined that the amendments involve no significant hazards consideration.

6.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Tennessee state official was notified of the proposed issuance of the amendments. The State official had no comments.

7.0 ENVIRONMENTAL CONSIDERATION

The amendments change 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 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 made a final determination that no significant hazards consideration is involved for the proposed amendments as discussed above in SE Section 5.0. 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.

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8.0 CONCLUSION

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

Principal contributors: Steven Jones John Tsao Tracy Ort Date: December 4, 2008

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