ML16138A651

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Audit of Supporting Design, Licensing & Other Documents Related to License Amendment Requests to Support the Adoption of Technical Specification Task Force Traveler 312
ML16138A651
Person / Time
Site: Vogtle, Farley  Southern Nuclear icon.png
Issue date: 06/02/2016
From: Denning R, Undine Shoop
NRC/NRR/DSS
To: Markley M
Plant Licensing Branch II
Blumberg M
References
TAC MF4560, TAC MF4561, TAC MF5317, TAC MF5318
Download: ML16138A651 (6)


Text

June 2, 2016 MEMORANDUM TO: Michael Markley, Chief Plant Licensing Branch II-1 Division of Reactor Licensing Office of Nuclear Reactor Regulation FROM: Undine Shoop, Chief /RA/

Radiation Protection and Consequence Branch Division of Risk Assessment Office of Nuclear Reactor Regulation Robert Dennig, Chief /RA/

Balance of Plant Branch Division of Safety Systems Office of Nuclear Reactor Regulation

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT UNITS 1 AND 2 AND VOGTLE ELECTRIC GENERATING PLANT UNITS 1 AND 2 - AUDIT OF SUPPORTING DESIGN, LICENSING AND OTHER DOCUMENTS RELATED TO LICENSE AMENDMENT REQUESTS TO SUPPORT THE ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER 312 ( TAC NOS. MF5317, ME5318, MF4560 AND 4561)

By letter dated November 24, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14335A623), the Southern Nuclear Operating Company, Inc. (SNC, the licensee) submitted a license amendment request (LAR) to revise the Joseph M. Farley Nuclear Plant, Units 1 and 2, Technical Specifications (TS) to adopt various previously approved Technical Specifications Task Force (TSTF) Travelers and two changes not associated with Travelers. In addition, by letter dated July 18, 2014 (ADAMS Accession No. ML14203A124), SNC submitted a LAR to revise the Vogtle Electric Generating Plant Units 1 and 2 TS to adopt various previously approved TSTF Travelers.

The U.S. Nuclear Regulatory Commission, staff determined that additional information is needed related to the requested implementation of TSTF-312-A. The Radiation Protection and Consequence Branch with the support of Balance of Plant Branch staff performed a regulatory CONTACTS: Mark Blumberg, NRR/DRA/ARCB John Parillo, NRR/DRA/ARCB 301-415-1083 301-415-1344

M. Markley 2 audit of the calculations and supporting documents used to justify the LARs in accordance with LIC-111, Regulatory Audits. A summary of the audit performed on May 3, 2016 is attached.

Docket Nos. 50-348, 50-364, 50-424, 50-425

Enclosure:

As stated

ML16138A651

  • via email OFFICE DRA/ARCB DRA/ARCB DSS/SBPB DRA/ARCB DSS/SBPB NAME WBlumberg JParillo SJones
  • UShoop RDennig DATE 05 / 20 / 16 05 / 20 / 16 05 / 17 / 16 06 / 02 / 16 05 / 26 / 16 JOSEPH M. FARLEY NUCLEAR PLANT UNITS 1 AND 2 AND VOGTLE ELECTRIC GENERATING PLANT UNITS 1 AND 2 - SUPPORTING DESIGN, LICENSING AND OTHER DOCUMENTS RELATED TO LICENSE AMENDMENT REQUESTS TO SUPPORT THE ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE TRAVELER 312 (TAC No. MF5317, ME5318, MF4560 AND 4561)

AUDIT

SUMMARY

BACKGROUND By letter dated November 24, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14335A623), the Southern Nuclear Operating Company, Inc.

(SNC, the licensee) submitted a request to revise the Joseph M. Farley Nuclear Plant, Units 1 and 2 (Farley), Technical Specifications (TS) to adopt various previously approved Technical Specifications Task Force (TSTF) Travelers and two changes not associated with Travelers.

The U.S. Nuclear Regulatory Commission (NRC) issued a request for additional information (RAI) on December 30, 2015 and a response from SNC was provided on March 3, 2016 (ADAMS Accession No. ML14335A623).

In addition, by letter dated July 18, 2014 (ADAMS Accession No. ML14203A124), SNC submitted a request to revise the Vogtle Electric Generating Plant Units 1 and 2 (Vogtle) TS to adopt various previously approved TSTF Travelers. The NRC issued RAIs on January 13, 2015 and a response from SNC was provided on February 27, 2015 (ADAMS Accession No. ML15058A91).

In a call with SNC on April 6, 2016, the staff discussed the Farley RAI response and it was decided that an audit of the design, licensing and other document related to the TSTF-312 license amendment request would be held. It was also decided that the audit should include information supporting both the Farley and Vogtle applications to adopt TSTF-312. To supplement the information previously provided by SNC, SNC made available to the NRC staff supporting documents, detailed engineering drawings, analyses and design basis calculations used to justify the requested TSTF-312 changes.

ENCLOSURE

2 AUDIT

SUMMARY

The NRC staff performed this audit at the EXCEL Services Corporation office in Rockville, Maryland on May 3, 2016. The audit team consisted of the NRC staff members and applicants staff identified in the Table below. The regulatory audit was performed in accordance with Office or Nuclear Reactor Regulation procedure, LIC-111, Regulatory Audits.

The audit began with a presentation by SNC staff providing their position regarding implementation of TSTF-312 for Farley and Vogtle. Then SNC provided the supporting documents for the NRC staffs review. As the NRC staff reviewed the supporting documents, SNC provided clarifying information regarding the inputs and assumptions used by SNC. Based upon this review the NRC staff developed an RAI question and SNC developed a draft response to the RAI.

AUDIT PARTICIPANTS The audit was conducted by a team of NRC staff members who are knowledgeable in various aspects of the radiological dose consequences and heating and ventilation system design (HVAC). The following table provides a comprehensive list of the audit participants from the NRC, SNC and Bechtel.

Name Affiliation Mark Blumberg (Farley Reviewer)- Dose) NRC John Parillo (Vogtle Reviewer)- Dose NRC Undine Shoop NRC Bob Martin NRC Mike Markley NRC Steven Jones (HVAC) NRC Jamie Coleman SNC Keith Drudy SNC Ken McElroy SNC William Evans SNC Deep Ghosh (by phone) SNC Ken Jha Bechtel DOCUMENTS REVIEWED BY THE NRC STAFF Farley Drawing D-176005 Farley Drawing D-176006 Farley DOEJ-SM-C060059901-001, Descriptions of Operation for Adjacent HVAC Systems to the Common Control Room Containment Personnel Air Lock Open during Refueling Farley DOEJ-FXCR10185172, Evaluation of Non-Conservatism in Fuel Handling Accident Dose Calc Farley Calculation SM-96-1064-001, Fuel Handling Accident Doses

3 CLOSING BRIEFING At the audit exit, the NRC staff and SNC discussed SNCs proposed RAI responses to the following draft RAl:

Following a fuel handling accident (FHA) there exists a potential for activity to migrate from open containment penetrations into adjacent buildings and eventually into the control room. Please provide additional information describing how this potential contribution to control room dose is accounted for in, or bounded by, the FHA dose consequence analysis of record.

SNCs strategy and content for their response for Farley is provided below:

  • Describe via qualitative evaluations, why any build-up of radioactivity around the MCR [Main Control Room] as released from open containment penetrations would be small and take time to accumulate - based on size of and locations of penetrations, driving mechanisms for activity transport, etc. Submit drawings and such as appropriate.
  • The SNC Analysis of Record assumes the PAL [Personnel Air Lock] open and 450 CFM [cubic feet per minute] (plus 10 CFM) of unfiltered in-leakage through the MCR HVAC (pressurization mode). SNC had also submitted a documentation of engineering judgment (DOEJ) that added 10 SCFM of unfiltered, not dispersed, but diluted, in-leakage coming from containment into the MCR. This DOEJ will be modified with a 50% dilution factor (containment and aux building volume) and results will be submitted to the NRC. SNC will also provide key inputs and assumptions in the response (DOEJ inputs, assumptions, and justifications for changes if they differ from the current licensing basis). SNC will also include justification for 50% dilution and 10 CFM unfiltered in-leakage.

SNCs strategy and content for their response for Vogtle is provided below:

  • Describe, via qualitative evaluations, why the potential for activity to build-up around and infiltrate the MCR is a very low based upon the design features of the plant. Include a discussion on the MCR airlocks and aux building airlocks, locations and size of penetrations, and the paths activity would have to traverse to build up around the MCR. Our conclusion will be there are [no] realistic scenarios for the proposed change to significantly increase dose to the MCR.
  • Demonstrate by qualitative arguments that the activity in the vicinity of the MCR when conservatively diluted within the containment volume and a portion of the auxiliary building would be less than that already modeled to transport to the MCR via the dispersion modeled in the analysis of record (AOR) - This will consider existing conservatisms in the FHA analysis such as no credit for containment dilution and direct path dispersion modeled - the key is this will be a comparative evaluation to make the case that the current analysis is bounding. Finally, point to existing margin to the MCR dose.

The staff concluded the audit by informing SNC, per L-101, that all results from the audit are preliminary in nature and are subject to NRC management review.