NL-11-1812, Edwin I. Hatch, Units 1 and 2, Updated Final Safety Analysis Report, Fire Hazards Analysis Changes, Technical Specification Bases Changes, Technical Requirements Manual Changes, 10 CFR 50.59 Report, and Revised NRC Commitments Report

Edwin I. Hatch, Units 1 and 2, Updated Final Safety Analysis Report, Fire Hazards Analysis Changes, Technical Specification Bases Changes, Technical Requirements Manual Changes, 10 CFR 50.59 Report, and Revised NRC Commitments Report

ML11320A042
Person / Time
Site:	Hatch
Issue date:	10/24/2011
From:	Ajluni M J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-11-1812
Download: ML11320A042 (12)

Text

Mark J. Ajiluni, P.E. Southern Nuclear Nuclear Licensing Director Operating Company, Inc.40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7673 Fax 205.992.7885 SOUTHERN N.October 24, 2011 COMPANY Docket Nos.: 50-321 NL-1 1-1812 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Updated Final Safety Analysis Report, Fire Hazards Analysis Changes, Technical Specification Bases Changes, Technical Requirements Manual Changes, 10 CFR 50.59 Report, and Revised NRC Commitments Report Ladies and Gentlemen:

In accordance with the provisions of Sections 50.4(b) and 50.71(e) of Title 10 of the Code of Federal Regulations (10 CFR), Southern Nuclear Operating Company (SNC) hereby submits Revision 29 to the Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2 Updated Final Safety Analysis Report (UFSAR), Revision 29 of the HNP Units 1 and 2 Fire Hazards Analysis (FHA), Revision 84 of the HNP Unit 1 Technical Requirements Manual (TRM), and Revision 87 of the HNP Unit 2 TRM. This submittal represents changes made through September 9, 2011.The HNP Unit 1 and Unit 2 Technical Specifications, section 5.5.11, "Technical Specifications (TS) Bases Control Program," provides for changes to the Bases without prior NRC approval.

In addition, TS section 5.5.11 requires that Bases changes made without prior NRC approval be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

Pursuant to TS 5.5.11, SNC hereby submits a complete copy of Revision 67 of the HNP Unit 1 TS Bases and Revision 76 of the HNP Unit 2 TS Bases, on CD-ROM, which reflects all changes to TS Bases for the same time period as Revision 29 of the UFSAR.Enclosure 1 provides a table of contents with associated file names for the CD-ROM provided as Enclosure 2, which meets the requirements of Regulatory Issue Summary (RIS) 2001-05, "Guidance on Submitting Documents to the NRC by Electronic Information Exchange or on CD-ROM." This CD-ROM contains all the current pages of the HNP UFSAR, the UFSAR revised reference drawings, all the current pages of the HNP FHA, all the current pages of the HNP TS Bases, and all the current pages of the HNP TRM in portable document format (PDF) with non-proprietary browser included.ACY53 U. S. Nuclear Regulatory Commission NL-11-1812 Page 2 Enclosure 3 provides the 10 CFR 50.59 Report in accordance with the requirements of 10 CFR 50.59(d)(2), which contains a brief description of any changes, tests, or experiments, including a summary of the safety evaluation of each. This report is based on the same time period as Revision 29 of the UFSAR.Enclosure 4 contains the Revised NRC Commitments Report, as required to be submitted in accordance with the NEI 99-04, "Guideline for Managing NRC Commitment Changes," Revision 0. This report is based on the same time period as Revision 29 of the UFSAR.Mr. M. J. Ajluni states he is the Nuclear Licensing Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.This letter contains no NRC commitments..If you have any questions, please contact Jack Stringfellow at (205) 992-7037.Respectfully submitted, M. J. Ajluni Nuclear Licensing Director Sworn to and subscribed before me this 20 day of o ' A,, , 2011.Notary Public My commission expires: / 1//MJA/EGA/lac

Enclosures:

1. CD-ROM Table of Contents 2. CD-ROM NRC Submittal:

Contains Files 001-013 3. 10 CFR 50.59 Report 4. Revised NRC Commitments Report U. S. Nuclear Regulatory Commission NL-1 1-1812 Page 3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President

& CEO Mr. D. G. Bost, Chief Nuclear Officer Mr. D. R. Madison, Vice President

-Hatch Ms. P. M. Marino, Vice President

-Engineering RType: CHA02.004 (w/o Enclosures)(w/o Enclosures)(w/o Enclosures)(w/o Enclosures)

U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. D. H. Gleaves, NRR Senior Project Manager -Hatch Mr. E. D. Morris, Senior Resident Inspector

-Hatch State of Geor-gia Mr. Allen Barnes, Environmental Director Protection Division Edwin I. Hatch Nuclear Plant Updated Final Safety Analysis Report, Fire Hazards Analysis Changes, Technical Specification Bases Changes, Technical Requirements Manual Changes, 10 CFR 50.59 Report, and Revised NRC Commitments Report Enclosure 1 CD-ROM Table of Contents HNP-FSAR REVISION 29 FILE SPECIFICATIONS FILENAME SEQ CONTENT EXTENSION 001 HATCH FSAR_Ul pdf UNIT 1 Active Page List Table of Contents Chapters 1 thru 14 Appendices A thru K, Supplement Ka, M, N & R 002 HATCH FSARU2_APL, TOC, CH1 THRU CH5 .pdf UNIT 2 Active Page List Table of Contents Chapters 1 thru 5 003 HATCH FSARU2_CH6 THRU CH7 pdf UNIT 2 Chapters 6 thru 7 004 FSAR U2 CH8 THRU CH 18, APP A .pdf UNIT 2 Chapters 8 thru 18 Appendix A 005 HATCH FSARREF DWGS PART 1 pdf A21603- H16174 006 HATCH FSARREF DWGS PART 2 .pdf H16176- H21114 007 HATCH FSARREF DWGS PART 3 pdf H22250 -H26036 008 HATCH FSARREF DWGS PART 4 pdf H26037 -S15290 009 HATCH FSARREF DWGS PART 5 .pdf S15304- SX28760 010 HATCH BASES .pdf 011 HATCH TRM UNIT 1 pdf 012 HATCH TRM UNIT 2 pdf 013 HNPFHA.pdf Edwin I. Hatch Nuclear Plant Updated Final Safety Analysis Report, Fire Hazards Analysis Changes, Technical Specification Bases Changes, Technical Requirements Manual Changes, 10 CFR 50.59 Report, and Revised NRC Commitments Report Enclosure 2 CD-ROM NRC Submittal:

Contains Files 001-013 Edwin I. Hatch Nuclear Plant Updated Final Safety Analysis Report, Fire Hazards Analysis Changes, Technical Specification Bases Changes, Technical Requirements Manual Changes, 10 CFR 50.59 Report, and Revised NRC Commitments Report Enclosure 3 10 CFR 50.59 Report

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..... ...Licensing Document Change Requests 10 CFR 50.59 REPORT LDCR LD Type 5059 Full Eval? Title 2008041 FS Yes DCP to lower the HWC injection level to 10% reactor power and add a trip signal from the Mode Switch Activity:

DCP 2081302101 Description of Change: The DCP will lower the HWC injection level to 10% reactor power and add a trip signal from the Mode Switch on panel 2H11-P603.

The Mode Switch contact will be placed in series with the contact from the HWC Control Room Shutdown Switch on panel 2H11-P650.

5059 Summary: This DCP will make the following changes to the non-safety related Unit 2 Hydrogen Water Chemistry (HWC) system.1)HWC will be placed into service at -5% power. Between 5% and 30% power, the hydrogen flow-rate will be a constant value (3 SCFM).2) The "Low Reactor Power" HWC system trip will be deleted.3) By utilizing a contact on the Reactor mode switch, HWC will automatically shutdown when the mode switch is taken out of the "RUN" position (following a Reactor scram).Section C (of NMP-AD-010-F01) discusses the justification of removing an automatic trip of the HWC system and replacing it with a manual operator action. The manual action would be either placing the Reactor Mode switch to "SHUTDOWN" or placing the Control Room HWC Remote Shutdown Selector switch (located on Main Control Room Panel 2H1-1-P650) 2P73S405 to "OFF". The Reactor mode switch would be placed to "SHUTDOWN" as part of the Reactor Scram procedure, so no new manual actions would be added.Placing the HWC Remote Shutdown Selector switch located on the P650 panel in the Control Room to "OFF" would only be required while performing the "In Sequence Control Rod Insertion" Reactor Shutdown.

This would not add unduly to the actions required by the operator during a normal reactor shutdown.

In addition, Section C (of NMP-AD-010-F01) discussed the possible increase to the frequency of occurrence of an accident previously evaluated in the Update FSAR as a result of initiating hydrogen injection prior to the inerting of the drywell. No increase in the frequency of occurrence of an accident was determined based on the HWC system being procedurally shutdown if the hydrogen concentration IS > 2.5% in the drywell. There were no additional consequences, impacts, or malfunctions created as a result of adding the proposed changes to the HWC system.Page 1 of 2 Hatch Nuclea'r Plant SCUTHERN M COMPANY Energy xo ,5erve )our World'.............

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Licensing Document Change Requests 10 CFR 50.59 REPORT LDCR LD Type 5059 Full Eval? Title 2010008 5059 Yes 10 CFR 50.59 Review of TRACG04P for DIVOM Application Activity:

2011200600 Description of Change: Periodically.

fuel vendors or other code vendors will make changes to their codes and methods to implement improved features, improved methodologies, or error corrections.

According to 10 CFR 50.59, changes to a method of evaluation used in establishing the design bases or in the safety analyses (described in the plant's FSAR) must be evaluated to ensure that no NRC approval is required before application.

The TRACG computer code is used to model the thermal-hydraulics of boiling water reactors (BWRs). The current version of TRACG04P has been revised from its initial version 4.2.57.11 to its first error correction, version 4.2.60.3 to correct several identified errors described below.1. An internal limit of the code causes the simulation to fail if the model contains a large number of components.

2. An operation that should return a pseudo-random number returns a constant number.3. Perturbations in the solution when restarting from a dump file due to the dump file.4. Improper initialization of a source term that is used at the junction of 1 D and 3D components.

5. The PIRT model may incorrectly assume film dryout in some statistical analyses of events.6. Inability to process METHOD C input cards that results in a program crash.5059 Summary: The TRACG computer code is used to model the thermal-hydraulics of boiling water reactors (BWRs). The current version of TRACG04P has been revised from its initial version 4.2.57.11 to its first error correction, version 4.2.60.3 to correct several identified errors described in Reference 5.It is concluded that TRACG04P version 4.2.60.3 is not a departure from a method of evaluation described in the Updated FSAR because the DIVOM results are more conservative or essentially the same as those produced by the previously approved TRACG02A.Page 2 of 2 Edwin I. Hatch Nuclear Plant Updated Final Safety Analysis Report, Fire Hazards Analysis Changes, Technical Specification Bases Changes, Technical Requirements Manual Changes, 10 CFR 50.59 Report, and Revised NRC Commitments Report Enclosure 4 Revised NRC Commitments Report Edwin I. Hatch Nuclear Plant Updated Final Safety Analysis Report, Fire Hazards Analysis Changes, Technical Specification Bases Changes, Technical Requirements Manual Changes, 10 CFR 50.59 Report, and Revised NRC Commitments Report Enclosure 4 Revised NRC Commitments Report Commitment Number: SNC27678 Source Document:

HL-6123, Edwin I. Hatch Nuclear Plant Transmittal of Additional Information for License Renewal Draft Safety Evaluation Report Open Items Old Commitment:

"...2) require that inside insulation and jackets added to the program are inspected within 2 refueling cycles of issuance of the new operating license and at least once every 10 years thereafter..." New Commitment:

"...2) require that inside insulation and jackets added to the program are inspected prior to the period of extended operation and at least once every 10 years thereafter..." Basis for Change: This commitment comes from the Monitoring and Trending portion of the Revised Appendix B to the license renewal application, Section B.2.4, Page B-70. This revised Appendix B was Enclosure 3 to HL-6123. Earlier in Section B.2.4, is a statement that,"Program enhancements will be implemented by midnight August 6, 2014 for Unit 1, and midnight June 13, 2018 for Unit 2." These two statements appear to be contradictory.

The normal practice for implementing program enhancements for license renewal was that they be implemented prior to the period of extended operation.

Review of written communication between SNC and the NRC concerning review of the Hatch license renewal application, found no discussion of this commitment to explain why it would be different.

The NRC's SER repeated back both statements from HL-6123, that the enhancements to this program would be implemented before the period of extended operation and that inside insulation would be inspected within 2 cycles of issuance of the renewed license. The program description in FSAR Section 18.3.4 includes the statement that enhancements will be implemented prior to the period of extended operation but not the requirement to perform the inspection of inside insulation within 2 cycles of issuance of the renewed license. The wording in Section 18 of the FSAR was submitted to the NRC in Enclosure 4 to HL-6123. Also, in ML070640041, a March 6, 2007 memorandum to file from Tommy Le, the NRC documented the commitment lists for Hatch and the other four plants granted a renewed operating license before the NRC began requiring licensees to docket their future action commitment list for license renewal. Item 4 on the list of Hatch commitments was the only one that addressed the Equipment and Piping Insulation Monitoring Program.While it included a requirement to include in-scope portions of inside equipment and piping insulation in periodic inspections, it stated the implementation schedule was, "Prior to the end of the initial operating license term." Therefore, it is reasonable to assume the NRC did not consider the statement concerning when the inspections of inside insulation Enclosure 4 to NL-11-1812 Revised NRC Commitments Report Page 2 of 2 would begin to be a commitment they relied upon, or they would have required revision of the FSAR program description to include that statement and would have included the eprlier date in the Tommy Le memorandum of March 6, 2007.