ML12121A034

Issuance of Amendment Extending Integrated Leak Rate Test

ML12121A034
Person / Time
Site:	Summer
Issue date:	05/01/2012
From:	Martin R Plant Licensing Branch II
To:	Gatlin T South Carolina Electric & Gas Co
Martin R
References
TAC ME7344
Download: ML12121A034 (12)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 1, 2012 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville, SC 29065

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 - ISSUANCE OF AMENDMENT EXTENDING INTEGRATED LEAK RATE TEST INTERVAL (TAC NO. ME7344)

Dear Mr. Gatlin:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 189 to Renewed Facility Operating License No. NPF-12 for the Virgil C. Summer Nuclear Station, Unit 1 (VCSNS), in response to your letter dated October 12, 2011, as supplemented April 5, 2012. This amendment allows a one-time extension of the 10-year interval (120 months) for the VCSNS containment integrated leakage rate test such that the existing test interval would be extended from 120 to 130 months.

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

Sincerely,

~~ts?~Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. Amendment No. 189 to NPF-12

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY DOCKET NO. 50-395 VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO.1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 189 Renewed License No. NPF-12

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

A. The application for amendment by South Carolina Electric & Gas Company (the licensee), dated October 12,2011, as supplemented April 5, 2012, 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 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 Renewed Facility Operating License No. NPF-12 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 189, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. South Carolina Electric & Gas Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This amendment is effective as of its date of issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION 1L~ -/ p~

Nancy L. Salgado, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-12 and the Technical Specifications Date of Issuance: May 1, 2()12

ATTACHMENT TO LICENSE AMENDMENT NO. 189 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-12 DOCKET NO. 50-395 Replace the following pages of the License and Appendix "An Technical Specifications with the enclosed pages as indicated. 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-12 License No. NPF-12 Page 3 Page 3 TS TS 6-12b 6-12b

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Renewed Facility Operating License No. NPF-12 Amendment No. 189

ADMINISTRATIVE CONTROLS

f. Radiological Environmental MODitoring Program A program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall provide (1) representative measures of radioactivity In the highest potential exposure pathways, and (2) verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways. The program shall (1) be contained In the ODCM. (2) conform to the guidance of Appendix I to 10 CFR Part 50. and (3) Include the following:

1) Monitoring. sampling, analysis, and reporting of radiation and radlonuclides In the environment in accordance with the methodology and parameters In the ODCM;

2) A Land Use Census to ensure that changes In the use of areas at and beyond the site boundary are Identified and that modifications to the monitoring program are made if required by the results of the census; and

3) Participation in an Inter-laboratory Comparison Program to ensure that independent checks on the precision and accuracy of measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program for environmental monitOring.

g. Containment Leakage Rate Testing Program A program shall be established to Implement leakage rate testing of the containment system 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 the guidelines contained in Regulatory Guide 1.183, "Performance-Based Containment Leak-Test Program," dated September 1995; NEI 94-01. "Industry Guideline for Performance-Based Option of 10 CFR 50, Appendix J," Revision 0; ANSIIANS-58.8-1994.

"Containment System Leakage Testing Requirements"; as modified by approved exceptions that the next Type A test performed after the October 15.2003 Type A test shall be performed no later than August 15. 2014.

The peak calculated containment Internal pressure for the design basis loss of coolant accident. p*. is 45.1 psig.

The maximum allowable containment leakage rate, La. at Pa. is 0.20 percent by weight of the containment air per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Leakage rate acceptance criteria are:

1) Containment overall leakage rate acceptance criterion is s 1.0 1...

During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are s 0.80 L. for the combined Type B and Type C tests, and S 0.75 L. for Type A tests; SUMMER - UNIT 1 6-12b Amendment No.104, 117.

~ 30, 135, 189

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 189 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-12 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 DOCKET NO. 50-395

1.0 INTRODUCTION

By letter dated October 12, 2011, as supplemented April 5, 2012, (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML11286A317 and ML12101A302, respectively), South Carolina Electric & Gas Company (SCE&G, the licensee), submitted a license amendment request (LAR) for changes to the Virgil C. Summer Nuclear Station (VCSNS),

Unit 1 Technical SpeCification (TS) 6.8.4(g) to allow for a one time extension of the 10-year (120 month) interval for the VCSNS containment leakage rate test (e.g., Integrated Leak Rate Test (ILRT) or Type A test). The proposed change would permit the existing ILRT interval to be extended from 120 to 130 months.

The letter of April 5, 2012, did not change the conclusions of the No Significant Hazards Determination that was published in the Federal Register on December 13, 2011 (76 FR 77571).

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (1 0 CFR), Part 50, Appendix J, Option B1, states, in part, the purpose of an ILRT:

One of the conditions required of all operating licenses and combined licenses for light-water-cooled power reactors as specified in § 50.54(0) is that primary reactor containments meet the leakage-rate test requirements in either Option A or B of this appendix. These test requirements ensure that (a) leakage through these containments or systems and components penetrating these containments does not exceed allowable leakage rates specified in the technical specifications; and (b) integrity of the containment structure is maintained during its service life. Option B of this appendix identifies the performance-based requirements and criteria for preoperational and subsequent periodic leakage-rate testing.

1 Option B of Appendix J is applicable to VCSNS. Unit 1.

-2 Type A tests to measure the containment system overall integrated leakage rate must be conducted under conditions representing design basis loss-of-coolant accident containment peak pressure. A Type A test must be conducted (1) after the containment system has been completed and is ready for operation and (2) at a periodic interval based on the historical performance of the overall containment system as a barrier to fission product releases to reduce the risk from reactor accidents. A general visual inspection of the accessible interior and exterior surfaces of the containment system for structural deterioration which may affect the containment leak-tight integrity must be conducted prior to each test, and at a periodic interval between tests based on the performance of the containment system. The leakage rate must not exceed the allowable leakage rate (La) with margin, as specified in the Technical Specifications.

The test results must be compared with previous results to examine the performance history of the overall containment system to limit leakage.

Thus, 10 CFR, Part 50, Appendix J, Option B, "Performance Based Requirements," requires that a Type A test be conducted at a periodic interval based on historical performance of the overall containment system.

A Type A test is an overall ILRT of the containment structure. NEI 94-01, "Industry Guideline for Performance-Based Option of 10 CFR 50, Appendix J," Revision 0, specifies an initial test interval of 48 months, but allows an extended interval of 10 years, based up to two consecutive successful tests. There is also a provision for extending the test interval an additional 15 months, but this "should be used only in cases where refueling schedules have been changed to accommodate other factors. n The most recent two Type A tests at VCSNS, Unit 1 have been successful, so the current interval requirement is 10 years.

The last VCSNS ILRT was completed on October 15, 2003. The next ILRT, per TS 6.8.4(g), is required to be performed no later than October 15, 2013. VCSNS refueling outage 20 is scheduled for October 2012. Therefore, the next Type A test would have to be performed 12 months less than 10 years after the most recent one, because the following refueling outage 21 would be 130 months after the most recent Type A test, and the extension allowed by NEI 94-01 does not apply. Thus, the licensee is requesting a TS change to add one more operating cycle to the test interval.

The proposed TS change does not involve any other changes to licensing commitments or acceptance criteria.

The regulation in 10 CFR 50.36(b) states, in part, that the TSs will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to 10 CFR 50.34. It also states in 10 CFR 50.36(c)(5) that TSs shall contain administrative controls "relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner."

As discussed below, TS 6.8.4(g) establishes a Containment Leak Rate Testing program to ensure containment integrity is maintained to assure safe operation.

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3.0 TECHNICAL EVALUATION

3.1 Technical Specifications The current TS 6.8.4(g) "Containment Leak Rate Testing Program," subsection a, reads as follows:

A program shall be established to implement leakage rate testing of the containment system 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 the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995; NEI94-01, "Industry Guideline for Performance-Based Option of 10 CFR 50, Appendix J," Revision 0; ANSIIANS-56.8-1994, "Containment System Leakage Testing Requirements"; as modified by approved exceptions:

The licensees proposed request would modify TS 6.8.4(g) by adding, after the word "exceptions:"

"that the next Type A test performed after the October 15, 2003 Type A test shall be performed no later than August 15, 2014."

3.2 Containment Leak-Tight Integrity Considerations The reactor containment leakage test program requires the licensee to perform an ILRT, also termed as a Type A test, and local leakage rate tests (LLRTs), termed as Type B and Type C tests. The Type A test measures the overall leakage rate of the primary reactor containment.

Type B tests are primarily intended to detect leakage paths and measure leakage rates for primary reactor containment penetrations. Type C tests are intended to measure containment isolation valve leakage.

The VCSNS TS 6.8.4(g), currently requires that the next Type A test shall be within 10 years after the last ILRT test, which was performed on October 15, 2003. The licensee has requested an extension of the next Type A test interval from 10 years (120 months) to 130 months.

NEI 94-01, Revision 0, allows an additional 15 months to be added on to the 10-year interval at the discretion of the licensee, but with the restriction that it "should be used only in cases where refueling schedules have been changed to accommodate other factors." The purpose of this restriction is to prevent a licensee from arbitrarily adding the 15 months on to every testing interval, which would effectively change the interval permanently to 135 months. The safety and risk significance of the 15-month extension has already been incorporated into the models used to determine the acceptability of the testing interval.

The proposed revision will allow rescheduling the next ILRT from no later than October 15,2013 to no later than August 15, 2014. This will allow the licensee to conduct the next ILRT during refueling outage 21 instead of refueling outage 20.

The leak-tight integrity of the penetrations and isolation valves are verified through Type Band Type C LLRTs and the overall leak-tight integrity and structural integrity of the primary containment is verified through a Type A test (ILRT) as required by 10 CFR 50, Appendix J.

These tests are performed at the design basis-basis accident pressure. The testing frequency for

-4 Type B and Type C tests is not affected by the proposed amendment and will continue to be performed in accordance with NEI 94-01, Revision 0, as endorsed by RG 1.163. Additionally, the licensee stated that no modifications that require a Type A test are planned prior to refueling outage 21.

3.3 Containment Pressure Boundary Evaluation The licensee provided additional information describing results from past Type A tests for VCSNS in its letter dated April 5, 2012.

Historically, VCSNS ILRT test results confirm that the VCSNS containment structure leakage is acceptable, with margin, with respect to the TS acceptance criterion of 0.20 percent (%) of containment air weight per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (%wtJday) at the design basis loss of coolant accident pressure.

A total of 5 ILRT tests were performed between the years 1981 and 2003. The leakage rate for the test in 1981 is 0.055 %wtJday. There were two more Type A tests performed in the 1984 and 1988 refueling outages. The results of these tests show leakage rates of 0.091 %wtJday and 0.106%wtJday, well within the allowable leakage rate of 0.20 %wtJday. In addition the licensee stated that the 1988 containment overall leakage (Type A plus Type Band C penetration leakage results) resulted in 0.115 %wtJday.

The VCSNS April 1993 periodic Type A test using the Mass Point method calculated at the 95%

Upper Confidence Limit (UCL) resulted in a leakage rate of 0.1298 %wtJday. The minimum pathway leakage rate for Type Band C pathways not in service (considering water level corrections) was 0.0070 %wtJday. Therefore, the performance leakage rate was 0.1298 %wtJday plus 0.0070 %wtJday = 0.1368 %wtJday.

The VCSNS October 2003 periodic Type A test using the Total Time method calculated at the 95%

UCL resulted in a leakage rate of 0.0581 %wtJday. The minimum pathway leakage rate for Type Band C pathways not in service and water level corrections was 0.0173 %wtJday. The Volume Change Correction factor is -0.00051 %wtJday. Therefore, the performance leakage rate was

=

0.0581 %wtJday plus 0.0173 %wtJday minus 0.00051 %wtJday 0.0749 %wt /day.

Although the local leakage rate values from Type B and Type C testing, as discussed above, are not the subject of the LAR, the staff has reviewed those results in conjunction with the Type A test results to confirm that there is reasonable assurance that the containment structural and leak-tight integrity will continue to be maintained during the Type A test interval extension of up to 10 months. Based on staff's review of the information provided by the licensee, there are no apparent adverse trends that would suggest containment leakage potential would exceed the TS acceptance criterion during the requested 10 month interval extension.

4.0

SUMMARY

Based on the foregoing evaluation, the NRC staff finds that there are no significant increases in risk or reductions in safety resulting from the requested test extension, beyond those already considered in the establishment of the intervals allowed by RG 1.163 and NEI94-01, Revision O.

Further, the VCSNS containment has a good recent leakage rate history. Therefore, the staff

-5 concludes that the requested TS change, increasing the Type A test interval on a one-time basis to 130 months, is acceptable.

5.0 STATE CONSULTATION

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

6.0 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. 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 previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (76 FR 77571, December 13,2011). 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.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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 Contributor: Roberto L. Torres Shaun Anderson Date: May 1,2012

May 1, 2012 Mr. Thomas D. Gatlin Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville, SC 29065 SUB..IECT: VIRGIL C. SUMMER NUCLEAR STATION, UNIT 1 -ISSUANCE OF AMENDMENT EXTENDING INTEGRATED LEAK RATE TEST INTERVAL (TAC NO. ME7344)

Dear Mr. Gatlin:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 189 to Renewed Facility Operating License No. NPF-12 for the Virgil C. Summer Nuclear Station, Unit 1 (VCSNS), in response to your letter dated October 12, 2011, as supplemented April 5, 2012. This amendment allows a one-time extension of the 10-year interval (120 months) for the VCSNS containment integrated leakage rate test such that the existing test interval would be extended from 120 to 130 months.

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

Sincerely, IRA!

Robert E, Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosures:

1. Amendment No. 189 to NPF-12

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

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