ML20206D683

Application for Amends to Licenses NPF-68 & NPF-81,changing Licensing Basis from Present Requirement to Establish Containment Hydrogen Monitoring within 30 Minutes of Initiation of Safety Injection to within 90 Minutes of LOCA

ML20206D683
Person / Time
Site:	Vogtle
Issue date:	04/28/1999
From:	Beasley J SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LCV-1294-A, NUDOCS 9905040200
Download: ML20206D683 (8)

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J. Barnie B:ast:y. Jr., P.E. ' Sruthern Nucinr

%ce Presider,t Oper: ting Cernpany,Inc.

Vogtie Project 40 inverness Center Parkway P.0 Box 1295 Birrnmgham, Alabama 35201 Tel 205 992.7110  ;

Iax 205 9920403 SOUTHERN COMPANY April 28, 1999 Energy to Serve hur World" l

LCV-1294-A l l

i Docket Nos. 50-424 50-425 l 1

U. S. Nuclear Regulatory Commission j ATTN: Document Control Desk Washington, D. C. 20555 i

Ladies and Gentlemen: 1 i

VOGTLE ELECTRIC GENERATING PLANT j EXTENSION OF TIME REQUIRED FOR ESTABLISHING POST-LOCA I CONTAINMENT HYDROGEN MONITORING l

t By letter dated February 17,1999, Southem Nuclear Operating Company requested an i extension of the time required to establish post-LOCA containment hydrogen monitoring I at Vogtle Electric Generating Plant (VEGP). The request changes the licensing basis for i VEGP from the present requirement to establish containment hydrogen monitoring within f j 30 minutes ofinitiation of a safety injection to within 90 minutes ofinitiation of a safety I); )

injection following a LOCA. This request is similar to a confirmatory order that was issued by the NRC to Arkansas Nuclear One on September 28,1998.

Based upon discussion with the NRC, it was determined that this change must be issued as a license amendment pursuant to 10 CFR 50.90. Therefore, provided as Enclosure 1 is j a 10 CFR 50.92 evaluation that concludes that this proposed change does not result in a I significant hazard consideration. Enclosure 2 provides a technical justification for the  !

proposed license amendment and Enclosure 3 contains proposed revisions to Facility Operating Licenses NPF-68 and 81.

This letter supersedes the request transmitted on February 17,1999. Southern Nuclear Operating Company requests approval of this proposed license amendment within 60 days of the date of this letter.  !

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9905040200 990428 PDR ADOCK 05000424 P PDR ,

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U. S. Nuclear Regulatory Commission Page 2 Mr. J. B. Beasley, Jr. states that he is a Vice President of Southern Nuclear Operating Company and is authorized to execute this oath on behalf of Southern Nuclear Operating Company and that, to the best of his knowledge and belief, the facts set in this letter and enclosures are true.

SOUTHERN NUCLEAR OPERATING COMPANY By:

wJ J. lie'asley( Jr. f Sworn to and subscribed before me this ay of . ,1999.

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. MYC0umwWEXPIRES N'otary Public 11*1 M

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JBB/BHW/gmb Enclosures xc: Southern ' Nuclear Operating Company Mr. J. T. Gasser Mr. M. Sheibani S~NC Document Management U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr R. R. Assa, Project Manager, NRR l Mr J. Zeiler, Senior Resident Inspector, Vogtle LCV-1294-A

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ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT EXTENSION OF TIME REQUIRED FOR ESTABLISHING POST-LOCA CONTAINMENT IIYDROGEN MONITORING Proposed License Amendment Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes ofinitiating safety injection following a loss of coolant accident.

Determination of No Sinnificant Hazards Consideration Pursuant to 10 CFR 50.92 Pursuant to 10 CFR 50.92 a determination may be made that a proposed license amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would 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. Each standard is discussed below: l l

(1) Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

Containment hydrogen concentration is not an input parameter to the FSAR Chapter l 15 accident analyses for a loss of reactor or secondary coolant accidents; nor is it used as an initial assumption for the containment response analysis. Control room operators use the containment hydrogen monitors to establish hydrogen control measures should it become necessary. However, the actions required to establish containment hydrogen monitoring are a distraction for the operators from more important tasks during the early phases of an accident. Hydrogen production occurs over a long period and a significant accumulation is not expected for several hours into the event. This function is more appropriately included as a part of the long-term core damage assessment process. The one-hour extension will have a positive impact on the ability of the operators to concentrate on their more immediate actions while having no negative impact on the long-term assessment efforts.

Therefore, the proposed license amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

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,, ,, ENCLOSURE 1 (CONTfNUED)

VOGTLE ELECTRIC GENERATING PLANT EXTENSION OF TIME REQUIRED FOR ESTABLISIIING POST-LOCA CONTAINMENT HYDROGEN MONITORING i (2) Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any  !

previously evaluated.

Operation of the containment hydrogen monitors is not an initiator of any design I basis accident. Control room operators use the containment hydrogen monitors following a LOCA to establish hydrogen control measures should it become necessary. Accurate indication of containment 1"+ ogen concentration is needed prior to initiating recombiner operation or contaimnent venting and for long-term core damage assessment. The proposed license amendment would not eliminate the i requirement to establish hydrogen monitoring, but would perm.it it to be delayed i until those actions required to diagnose the event and verify proper operation of essential safety equipment have been completed. The one-hour extension maintains the requirement to establish hydrogen monitoring well before calculated conditions inside the containment indicate any need to initiate hydrogen control measures.

Therefore, the proposed license amendment will not create a new or different kind of accident fron cay previously evaluated.

(3) Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The need to establish hydrogen control measures will not be present within the first 90 minutes following a LOCA since there will not be significant hydrogen accumulation. By extending the time allowed to establist containment hydrogen monitoring, the operators can remain focused on the actions necessary to assess and mitigate the accident before redirecting their attention to long-term recovery actions. The one-hour extension maintains the requirement to establish hydrogen monitoring well before calculated conditions inside the containment indicate any need to initiate hydrogen control measures. Therefore, the proposed license amendment will not involve a significant reduction in a margin of safety, but will instead result in an overall enhancement to safety, Based on the discussion presented above, Southern Nuclear Operating Company concludes that this proposed license amendment does not involve a significant hazards consideration.

r ENCLOSURE 2 TECIINICAL JUSTIFICATION FOR EXTENSION OF TIME REQUIRED FOR ESTABLISIIING POST-LOCA l CONTAINMENT 11YDROGEN MONITORING The guidance for establishing post-LOCA containment hydrogen monitoring at VEGP is contained in the Emergency Operating Procedure for a Loss of Reactor or Secondary l Coolant. Specifically, this action is included as a part of the step to initiate an evaluation of plant status. This step follows those immediate actions required to diagnose the event and verify proper operation of essential safety systems.

Manual operator action is required to establish containment hydrogen monitoring at VEGP. Considering the safety significance of the immediate actions reauired of the operating crews to assure that safety systems are functioning properly amd critical safety functions are being accomplished, it is appropriate to delay the operator actions necessary ,

to initiate hydrogen monitoring until the accident assessment and mitigation actions are l complete. These accident assessment and mitigation actions can typically be accomplished within 60 minutes from the start of the accident. As stated in the VEGP FSAR, indication of hydrogen concentration is available within 30 minutes ofinitiating flow through the monitors. This is accomplished by operating the monitors in standby during normal plant operation. Therefore, an accurate indication of the containment hydrogen concentration would be available to the operators within 90 minutes from ,

initiating safety injection following a LOCA.

For the reasons described above, which are consistent with those presented by Arkansas Nuclear One and found to be acceptable by the Commission, Southern Nuclear Operating Company believes the requested extension for the time allowed to establish containment hydrogen monitoring to within 90 minutes ofinitiating safety injection following a LOCA isjustified.

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ENCLOSURE 3 PROPOSED REVISIONS TO FACILITY OPERATING LICENSES NPF-68 AND 81 FOR EXTENSION OF TIME REQUIRED FOR ESTABLISIllNG POST-LOCA CONTAINMENT IIYDROGEN MONITORING i

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4 (2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. ,

and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southem Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Southem Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4) DELETED (5) DELETED (6) DELETED (7) DELETED (8) DELETED (9) DELETED (10) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No.102, are hereby incorporated into this license. Southem Nuclear shall operate the facility in accordance with the Additional Conditions.

D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70.

These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors I around the fuel storage area, and (b) an exemption from the requirements of Paragraph Ill.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not I required. The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 5.

An exemption was previously granted pursuant to 10 CFR 70.24. The exemption was granted with NRC materials license No. SNM-1967, issued August 21,1986, and relieved GPC from the ,

I requirement of having a criticality alarm system. GPC and Southem Nuclear are hereby exempted from the criticality alarm system provision of 10 CFR 70.24 so far as this section applies to the storage of fuel assemblies held under this license.

These exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The exemptions in items b and c above are granted pursuant to 10CCR 50.12. With Amendment No.

C. Thi 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 Southem Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3565 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. ,

and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southem Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance Requirements (SRs) contained in the Appendix A Technical Specifications and listed below are not required to be performed immediately upon implementation of Amendment No. 74. The SRs listed below shall be successfully demonstrated prior to the time and condition specified below for each:

a) DELETED b) DELETED c) SR 3.8.1.20 shall be successf Illy demonstrated at the first regularly scheduled performance afterimplementation of this license amendment.

(3) Southem Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4) Additional Conditions l The Additional Conditions contained in Appendix D, as revised through Amendment No. 80, are j hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance .

with the Additional Conditions.

D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70.

These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph lll.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not required. The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 8.

Amendment No.

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