ML18290A594

Audit Summary for ESF Safeguard Actuation TS Applicability Changes, LAR 18-011

ML18290A594
Person / Time
Site:	Vogtle
Issue date:	10/19/2018
From:	Peter Hearn NRC/NRO/DLSE/LB4
To:	Jennifer Dixon-Herrity NRC/NRO/DLSE/LB4
hearn p/415-1189
References
LAR-18-011
Download: ML18290A594 (6)

Text

October 19, 2018 MEMORANDUM TO: Jennifer Dixon-Herrity, Chief Licensing Branch 4 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors FROM: Peter Hearn, Senior Project Manager /RA/

Licensing Branch 4 Division of Licensing, Siting, and Environmental Analysis Division of New Reactor Licensing Office of New Reactors

SUBJECT:

AUDIT

SUMMARY

FOR VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4, REQUEST FOR LICENSE AMENDMENT REGARDING ENGINEERED SAFETY FEATURE SAFEGUARDS ACTUATION TECHNICAL SPECIFICATIONS APPLICABILITY CHANGES (LAR-18-011)

The U.S. Nuclear Regulatory Commission staff conducted an audit of documents related to the Vogtle Electric Generating Plant (VEGP) Units 3 and 4, combined licenses (COL), specifically Changes to COL Appendix A, Technical Specifications of VEGP Units 3 and 4, License Amendment Request (LAR)18-011, Engineered Safety Feature Safeguards Actuation Technical Specifications Applicabitiy Changes, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18138A396). The audit was conducted using the VEGP Electronic Reading Room.

The plan for this audit is available in ADAMS under Accession No. ML18221A227. A summary of the audit is enclosed.

Docket Nos.: 52-025 and 52-026

Enclosure:

As stated CONTACT: Peter Hearn, NRO/DNRL/LB4 301-415-1189

SUBJECT:

AUDIT

SUMMARY

FOR VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4, REQUEST FOR LICENSE AMENDMENT: ENGINEERED SAFETY FEATURE SAFEGUARDS ACTUATION TECHNICAL SPECIFICATIONS APPLICABILITY CHANGES (LAR-18-011) DATED OCTOBER 19, 2018 DISTRIBUTION:

Public RKaras, NRO NRO_DNRL_LB4 CPatel, NRO RidsOgcMailCenter DPalmrose, NRO RidsAcrsAcnwMailCenter JDixon-Herrity, NRO ADAMS ACCESSION: ML18290A594 *via email NRO-008 OFFICE DLSE/LB4:PM DLSE/LB4:LA DLSE/LB4:PM DLSE/LB4:BC NAME PHearn RButler CPatel JDixon-Herrity DATE 10/18/18 10/18/18 10/18/18 10/19/18 OFFICIAL RECORD COPY

UNITED STATES NUCLEAR REGULATORY COMMISSION AUDIT

SUMMARY

FOR THE REGULATORY AUDIT OF SOUTHERN NUCLEAR OPERATING COMPANY VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4 REQUEST FOR LICENSE AMENDMENT AND EXEMPTION:

CHANGES TO CONTAINMENT COOLING AND SPENT FUEL POOL MAKEUP STRATEGIES (LAR-18-011)

LICENSEE: Southern Nuclear Operating Company LICENSEE CONTACT: Wes Sparkman DURATION: September 4, 2018 to September 25, 2018 LOCATIONS: VEGP-designated electronic reading room A. BACKGROUND Southern Nuclear Operating Company submitted by a letter dated May 18, 2018, to the U.S. Nuclear Regulatory Commission (NRC) including a request for license amendment (LAR)18-011 Engineered Safety Feature Safeguards Actuation Technical Specifications Applicability Changes.

The requested amendment proposes changes to combined license (COL) Appendix A, Technical Specifications (TS) Limiting Condition for Operation (LCO) 3.3.8, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, related to Safeguard Actuation Functions.

Various ESFAS Functions require Applicability and corresponding Actions changes to more accurately reflect their operation and related safety analysis assumptions. In order to justify these changes, the licensee has revised the containment cooling thermal analysis and the spent fuel pool heatup and boiloff analysis.

To facilitate the staffs evaluation of information supporting LAR 18-011, and to complete its safety review of the proposed license changes, the staff performed an audit to evaluate supporting reports and calculations as stated in the staffs regulatory audit plan, dated August 23, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18221A326).

B. REGULATORY AUDIT BASIS This regulatory audit is based on the following regulations:

• Title 10 of the Code of Federal Regulations (10 CFR) Part 52, Appendix D,Section VIII.B.5.a allows an applicant or licensee who references this appendix to depart from Tier 2 information, without prior NRC approval, unless the proposed departure involves a change to or departure from Tier 1 information, Tier 2* information, or the Technical Specifications, or requires a license amendment under paragraphs B.5.b or B.5.c of the section.

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• 10 CFR Part 52, Appendix D, Section VIII.C.6 states that after issuance of a license, Changes to the plant-specific TS will be treated as license amendments under 10 CFR 50.90. 10 CFR 50.90 addresses the applications for amendments of licenses, construction permits, and early site permits. As discussed above, a change to COL Appendix A was requested, and thus a license amendment is required.

• 10 CFR 50 Appendix A, GDC 20, Protection System Functions, requires that the protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences, and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.

The staff followed NRO Office Instruction NRO-REG-108 (Revision 0), Regulatory Audits, (ADAMS Accession No. ML081910260) in performing the audit of the reports and calculations cited below.

C. AUDIT MEMBERS The following are the NRC audit team members:

Donald Palmrose, NRO, Audit Lead Peter Hearn, NRO, Senior Project Manager D. DOCUMENTS AUDITED The documents audited are listed below:

• APP-SSAR-GEF-119, Revision 0, Sensitivity Analysis to Demonstrate Offsite Doses for SGTR [steam generator tube rupture] During Cooldown (Below P-11) with PORV [power operated relief valve]/Block Valves Open Are Not Limiting, Approved January 8, 2018.

• The Westinghouse Electric Company (Westinghouse) Nuclear Safety Advisory Letter, Steam Line Break During Mode 3 for Westinghouse NSSS [Nuclear Steam Supply System] Plants, NSAL-02-14, Revision 2, August 4, 2005.

E. DESCRIPTION OF AUDIT ACTIVITIES AND

SUMMARY

OF OBSERVATIONS The staff examined APP-SSAR-GEF-119, Revision 0. During this examination staff noted:

• The base case run (i.e., a full-power SGTR calculation) is consistent with the SGTR analysis of VEGP Units 3 and 4 Final Safety Analysis Report (FSAR) Section 15.6.3, Steam Generator Tube Rupture, and associated tables and figures;

• The methodology is consistent with the method of analysis presented in VEGP Units 3 and 4 FSAR Section 15.6.3;

• The sensitivity cases consider different ruptured steam generator (SG) PORV positions following the SGTR and different operator response timing, namely:

o The ruptured SG PORV remains in the position set for the cooldown and the 2

ruptured SG steam flow paths are manually isolated 30 minutes after the SGTR; o The ruptured SG PORV remains in the position set for the cooldown and the ruptured SG flow paths are manually isolated 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the SGTR; o The ruptured SG PORV fails wide open and the ruptured SG steam flow paths are manually isolated 30 minutes after the SGTR; and o For all cases, the intact SG PORV remains in the position set for the cooldown.

• The sensitivity cases assumptions are reasonable, including the use of representative reactor coolant system (RCS) conditions and the operator response times; and

• The three sensitivity cases demonstrate that an SGTR initiated during a post-shutdown cooldown when automatic SG PORV block and steamline isolation functions are not available is not limiting based on a comparison of results to the base case.

The staffs examination of APP-SSAR-GEF-119 did not identify any issues or generate any Requests for Additional Information (RAIs).

The staff audited Westinghouses Nuclear Safety Advisory Letter NSAL-02-14, Revision 2. The purpose of NSAL-02-14 is to clearly communicate to all licensees of Westinghouse-designed pressurized-water reactors to review their cooldown procedures to determine if the requirement has been implemented for boration of the RCS to cold shutdown conditions when in Mode 3 below the protection system permissive (P-11). By doing so, licensees would ensure the hot zero power steamline break analysis remains bounding. During this review of NSAL-02-14 NRC staff noted:

• The protection system permissive (P-11) exists to allow for a cooldown/depressurization of the plant while preventing selected automatic safety injection signals.

• NSAL-02-14 recommends that the RCS is borated to cold shutdown margin concentration prior to the operator manually blocking the safeguards actuation signal;

• The discussion in NSAL-02-14 for borating to cold shutdown conditions provides reasonable assurance the core would not become critical following a steamline break when safety injection is blocked even for a lower limit of 200°F.

The staffs examination of NSAL-02-14 did not identify any issues or generate any RAIs, and the staff concluded that the information in NSAL-02-14 supports the analysis of record.

F. EXIT BRIEFING The staff conducted an audit closeout meeting on October 12, 2018. At the audit closeout briefing the staff reiterated the purpose of the audit and discussed their activities. The staff stated that it had not identified areas where additional information is needed.

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G. REFERENCES

• Southern Nuclear Operating Company, Vogtle Electric Generating Plant Units 3 and 4, Request for License Amendment: Engineered Safety Feature Safeguards Actuation Technical Specifications Applicability Changes (LAR-18-011), dated May 18, 2018 (ADAMS Accession Number ML18138A396).

• NRO-REG-108, Regulatory Audits, dated April 2, 2009 (ADAMS Accession Number ML081910260).

• Memo from Peter Hearn of NRC to Jennifer Dixon-Herrity of NRC, Audit Plan for Vogtle Electric Generating Plant Units 3 And 4, Request for License Amendment to Engineered Safety Feature Safeguards Actuation Technical Specifications Applicability Changes (LAR 18-011), dated August 23, 2018 (ADAMS Accession No. ML18221A326).

• Vogtle Units 3 and 4 Updated Final Safety Analysis Report, Revision 6, Chapter 15, Accident Analysis, dated March 12, 2017 (ADAMS Accession No. ML17172A279).

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