ML22240A094

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Changes Related to AP1000 Gts Subsection 3.7.4, Secondary Specific Activity
ML22240A094
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Issue date: 06/26/2015
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NRC/NRR/DSS/STSB
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Craig Harbuck NRR/DSS 301-415-3140
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GTST AP1000-O44-3.7.4, Rev. 1 Advanced Passive 1000 (AP1000)

Generic Technical Specification Traveler (GTST)

Title:

Changes Related to LCO 3.7.4, Secondary Specific Activity I. Technical Specifications Task Force (TSTF) Travelers, Approved Since Revision 2 of STS NUREG-1431, and Used to Develop this GTST TSTF Number and

Title:

TSTF-425-A, Rev 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b STS NUREGs Affected:

TSTF-425-A, Rev 3: NUREGs 1430, 1431, 1432, 1433, and 1434 NRC Approval Date:

TSTF-425-A, Rev. 3: 06-Jul-09 TSTF Classification:

TSTF-425-A, Rev 3: Technical Change Date report generated:

Friday, June 26, 2015 Page 1

GTST AP1000-O44-3.7.4, Rev. 1 II. Reference Combined License (RCOL) Standard Departures (Std. Dep.), RCOL COL Items, and RCOL Plant-Specific Technical Specifications (PTS) Changes Used to Develop this GTST RCOL Std. Dep. Number and

Title:

There are no Vogtle departures applicable to GTS 3.7.4.

RCOL COL Item Number and

Title:

There are no Vogtle COL items applicable to GTS 3.7.4.

RCOL PTS Change Number and

Title:

VEGP LAR DOC A003: References to various Chapters and Sections of the Final Safety Analysis Report (FSAR) are revised to include FSAR.

Date report generated:

Friday, June 26, 2015 Page 2

GTST AP1000-O44-3.7.4, Rev. 1 III. Comments on Relations Among TSTFs, RCOL Std. Dep., RCOL COL Items, and RCOL PTS Changes This section discusses the considered changes that are: (1) applicable to operating reactor designs, but not to the AP1000 design; (2) already incorporated in the GTS; or (3) superseded by another change.

TSTF-425-A deferred for future consideration.

Date report generated:

Friday, June 26, 2015 Page 3

GTST AP1000-O44-3.7.4, Rev. 1 IV. Additional Changes Proposed as Part of this GTST (modifications proposed by NRC staff and/or clear editorial changes or deviations identified by preparer of GTST)

APOG Recommended Changes to Improve the Bases Revise the first paragraph of the Background section of the Bases to state:

. . . OtherTherefore, fission product isotopes, as well as activated corrosion products in lesser amounts, may also be found in the secondary coolant. . . .

This non-technical change provides improved clarity, consistency, and operator usability.

Throughout the Bases, references to Sections and Chapters of the FSAR do not include the FSAR clarifier. Since these Section and Chapter references are to an external document, it is appropriate to include the FSAR modifier. (DOC A003)

Date report generated:

Friday, June 26, 2015 Page 4

GTST AP1000-O44-3.7.4, Rev. 1 V. Applicability Affected Generic Technical Specifications and Bases:

Section 3.7.4, Secondary Specific Activity Changes to the Generic Technical Specifications and Bases:

The first paragraph of the Background section of the Bases is revised to improve clarity, consistency, and operator usability. (APOG Comment)

The acronym FSAR is added to modify Section and Chapter in references to the FSAR throughout the Bases. (DOC A003) (APOG Comment)

Date report generated:

Friday, June 26, 2015 Page 5

GTST AP1000-O44-3.7.4, Rev. 1 VI. Traveler Information Description of TSTF changes:

Not Applicable Rationale for TSTF changes:

Not Applicable Description of changes in RCOL Std. Dep., RCOL COL Item(s), and RCOL PTS Changes:

Not Applicable Rationale for changes in RCOL Std. Dep., RCOL COL Item(s), and RCOL PTS Changes:

Not Applicable Description of additional changes proposed by NRC staff/preparer of GTST:

The first paragraph of the Background section of the Bases is revised to state (APOG Comment):

. . . OtherTherefore, fission product isotopes, as well as activated corrosion products in lesser amounts, may also be found in the secondary coolant. . . .

The acronym FSAR is added to modify Section and Chapter in references to the FSAR throughout the Bases. (DOC A003) (APOG Comment)

Rationale for additional changes proposed by NRC staff/preparer of GTST:

The non-technical change to the Background section of the Bases provides improved clarity, consistency, and operator usability.

Since Bases references to FSAR Sections and Chapters are to an external document, it is appropriate to include the FSAR modifier.

Date report generated:

Friday, June 26, 2015 Page 6

GTST AP1000-O44-3.7.4, Rev. 1 VII. GTST Safety Evaluation Technical Analysis:

The changes are editorial, clarifying, grammatical, or otherwise considered administrative.

These changes do not affect the technical content, but improve the readability, implementation, and understanding of the requirements, and are therefore acceptable.

Having found that this GTSTs proposed changes to the GTS and Bases are acceptable, the NRC staff concludes that AP1000 STS Subsection 3.7.4 is an acceptable model Specification for the AP1000 standard reactor design.

References to Previous NRC Safety Evaluation Reports (SERs):

None Date report generated:

Friday, June 26, 2015 Page 7

GTST AP1000-O44-3.7.4, Rev. 1 VIII. Review Information Evaluator Comments:

None Randy Belles Oak Ridge National Laboratory 865-574-0388 Review Information:

Availability for public review and comment on Revision 0 of this traveler approved by NRC staff on 5/19/2014.

APOG Comments (Ref. 7) and Resolutions:

1. (Internal # 3) Throughout the Bases, references to Sections and Chapters of the FSAR do not include the FSAR clarifier. Since these Section and Chapter references are to an external document, it is appropriate (DOC A003) to include the FSAR modifier. This is resolved by adding the FSAR modifier as appropriate.
2. (Internal #13) Many GTSTs evaluated TSTF-425 with the following note: Risk-informed TS changes will be considered at a later time for application to the AP1000 STS.

The NRC approval of TSTF-425, and model safety evaluation provided in the CLIIP for TSTF-425, are generically applicable to any designs Technical Specifications. As such, the replacement of certain Frequencies with a Surveillance Frequency Control Program should be included in the GTST for AP1000 STS NUREG.

However, implementation in the AP1000 STS should not reflect optional (i.e., bracketed) material showing retention of fixed Surveillance Frequencies where relocation to a Surveillance Frequency Control Program is acceptable. Since each represented AP1000 Utility is committed to maintaining standardization, there is no rationale for an AP1000 STS that includes bracketed options.

Consistent with TSTF-425 criteria, replace applicable Surveillance Frequencies with In accordance with the Surveillance Frequency control Program and add that Program as new AP1000 STS Specification 5.5.15.

NRC Staff disagreed with implementing TSTF-425 in the initial version of the STS.

Although the APOG thinks the analysis supporting this traveler is general enough to be applicable to AP1000, staff thinks an AP1000-specific proposal from APOG is needed to identify any GTS SRs that should be excluded. Also, with the adoption of a Surveillance Frequency Control Program (SFCP) in the AP1000 STS, bracketed Frequencies, which provide a choice between the GTS Frequency and the SFCP Frequency, are needed because the NRC will use the AP1000 STS as a reference, and to be consistent with NUREG-1431, Rev. 4. APOG was requested to consider proposing an AP1000 version of TSTF-425 for a subsequent revision of the STS.

Date report generated:

Friday, June 26, 2015 Page 8

GTST AP1000-O44-3.7.4, Rev. 1

3. (Internal # 410) In the Background section of the Bases, revise the first paragraph as follows:

. . . OtherTherefore, fission product isotopes, as well as activated corrosion products in lesser amounts, may also be found in the secondary coolant.

This non-technical change provides improved clarity, consistency, and operator usability.

This is resolved by making the recommended change.

NRC Final Approval Date: 6/26/2015 NRC

Contact:

T. R. Tjader United States Nuclear Regulatory Commission 301-415-1187 Theodore.Tjader@nrc.gov Date report generated:

Friday, June 26, 2015 Page 9

GTST AP1000-O44-3.7.4, Rev. 1 IX. Evaluator Comments for Consideration in Finalizing Technical Specifications and Bases None Date report generated:

Friday, June 26, 2015 Page 10

GTST AP1000-O44-3.7.4, Rev. 1 X. References Used in GTST

1. AP1000 DCD, Revision 19, Section 16, Technical Specifications, June 2011 (ML11171A500).
2. Southern Nuclear Operating Company, Vogtle Electric Generating Plant, Units 3 and 4, Technical Specifications Upgrade License Amendment Request, February 24, 2011 (ML12065A057).
3. NRC Safety Evaluation (SE) for Amendment No. 13 to Combined License (COL) No. NPF-91 for Vogtle Electric Generating Plant (VEGP) Unit 3, and Amendment No. 13 to COL No.

NPF-92 for VEGP Unit 4, September 9, 2013, ADAMS Package Accession No. ML13238A337, which contains:

ML13238A355 Cover Letter - Issuance of License Amendment No. 13 for Vogtle Units 3 and 4 (LAR 12-002).

ML13238A359 Enclosure 1 - Amendment No. 13 to COL No. NPF-91 ML13239A256 Enclosure 2 - Amendment No. 13 to COL No. NPF-92 ML13239A284 Enclosure 3 - Revised plant-specific TS pages (Attachment to Amendment No. 13)

ML13239A287 Enclosure 4 - Safety Evaluation (SE), and Attachment 1 - Acronyms ML13239A288 SE Attachment 2 - Table A - Administrative Changes ML13239A319 SE Attachment 3 - Table M - More Restrictive Changes ML13239A333 SE Attachment 4 - Table R - Relocated Specifications ML13239A331 SE Attachment 5 - Table D - Detail Removed Changes ML13239A316 SE Attachment 6 - Table L - Less Restrictive Changes The following documents were subsequently issued to correct an administrative error in Enclosure 3:

ML13277A616 Letter - Correction To The Attachment (Replacement Pages) - Vogtle Electric Generating Plant Units 3 and 4-Issuance of Amendment Re:

Technical Specifications Upgrade (LAR 12-002) (TAC No. RP9402)

ML13277A637 Enclosure 3 - Revised plant-specific TS pages (Attachment to Amendment No. 13) (corrected)

4. TSTF-GG-05-01, Writer's Guide for Plant-Specific Improved Technical Specifications, June 2005.
5. RAI Letter No. 01 Related to License Amendment Request (LAR)12-002 for the Vogtle Electric Generating Plant Units 3 and 4 Combined Licenses, September 7, 2012 (ML12251A355).
6. Southern Nuclear Operating Company, Vogtle Electric Generating Plant, Units 3 and 4, Response to Request for Additional Information Letter No. 01 Related to License Amendment Request LAR-12-002, ND-12-2015, October 04, 2012 (ML12286A363 and ML12286A360)

Date report generated:

Friday, June 26, 2015 Page 11

GTST AP1000-O44-3.7.4, Rev. 1

7. APOG-2014-008, APOG (AP1000 Utilities) Comments on AP1000 Standardized Technical Specifications (STS) Generic Technical Specification Travelers (GTSTs), Docket ID NRC-2014-0147, September 22, 2014 (ML14265A493).

Date report generated:

Friday, June 26, 2015 Page 12

GTST AP1000-O44-3.7.4, Rev. 1 XI. MARKUP of the Applicable GTS Subsection for Preparation of the STS NUREG The entire section of the Specifications and the Bases associated with this GTST is presented next.

Changes to the Specifications and Bases are denoted as follows: Deleted portions are marked in strikethrough red font, and inserted portions in bold blue font.

Date report generated:

Friday, June 26, 2015 Page 13

GTST AP1000-O44-3.7.4, Rev. 1 Secondary Specific Activity 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Secondary Specific Activity LCO 3.7.4 The specific activity of the secondary coolant shall be < 0.1 Ci/gm DOSE EQUIVALENT I-131.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Specific activity not A.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> within limit.

AND A.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify the specific activity of the secondary coolant 31 days 0.1 Ci/gm DOSE EQUIVALENT I-131.

AP1000 STS 3.7.4-1 Amendment 0Rev. 0 Revision 19 Date report generated:

Friday, June 26, 2015 Page 14

GTST AP1000-O44-3.7.4, Rev. 1 Secondary Specific Activity B 3.7.4 B 3.7 PLANT SYSTEMS B 3.7.4 Secondary Specific Activity BASES BACKGROUND Activity in the secondary coolant results from steam generator tube LEAKAGE from the Reactor Coolant System (RCS). Therefore, Other fission product isotopes, as well as activated corrosion products in lesser amounts, may also be found in the secondary coolant. While fission products present in the primary coolant, as well as activated corrosion products, enter the secondary coolant system due to the primary to secondary LEAKAGE, only the iodines are of a significant concern relative to airborne release of activity in the event of an accident or abnormal occurrence (radioactive noble gases that enter the secondary side are not retained in the coolant but are released to the environment via the condenser air removal system throughout normal operation).

The limit on secondary coolant radioactive iodines minimizes releases to the environment due to anticipated operational occurrences or postulated accidents.

APPLICABLE The accident analysis of the main steam line break (SLB) as discussed in SAFETY FSAR Chapter 15 (Ref. 1) assumes the initial secondary coolant specific ANALYSES activity to have a radioactive isotope concentration of 0.1 Ci/gm DOSE EQUIVALENT I-131. This assumption is used in the analysis for determining the radiological consequences of the postulated accident.

The accident analysis, based on this and other assumptions, shows that the radiological consequences of a postulated SLB are within the acceptance criteria in SRP Section 15.0.1, and within the exposure guideline values of 10 CFR Part 50.34.

Secondary specific activity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO As indicated in the Applicable Safety Analyses, the specific activity limit of the secondary coolant is required to be 0.1 Ci/gm DOSE EQUIVALENT I-131 to maintain the validity of the analyses reported in FSAR Chapter 15 (Ref. 1).

Monitoring the specific activity of the secondary coolant ensures that when secondary specific activity limits are exceeded, appropriate actions are taken in a timely manner to place the unit in an operational MODE that would minimize the radiological consequences of a DBA.

AP1000 STS B 3.7.4-1 Amendment 0Rev. 0 Revision 19 Date report generated:

Friday, June 26, 2015 Page 15

GTST AP1000-O44-3.7.4, Rev. 1 Secondary Specific Activity B 3.7.4 BASES APPLICABILITY In MODES 1, 2, 3, and 4 the limits on secondary specific activity apply due to the potential for secondary steam releases to the atmosphere.

In MODES 5 and 6, the steam generators are not being used for heat removal. Both the RCS and steam generators are depressurized, and primary to secondary LEAKAGE is minimal. Therefore, monitoring of secondary specific activity is not required.

ACTIONS A.1 and A.2 DOSE EQUIVALENT I-131 exceeding the allowable value in the secondary coolant, is an indication of a problem in the RCS and contributes to increased post-accident doses. If the secondary specific activity cannot be restored to within limits within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that the secondary specific activity is within the limits of the accident analysis. A gamma isotopic analysis of the secondary coolant, which determines DOSE EQUIVALENT I-131, confirms the validity of the safety analysis assumptions as to the source terms in post-accident releases. It also serves to identify and trend any unusual isotopic concentrations that might indicate changes in reactor coolant activity or leakage. The 31 day Frequency is based on the detection of increasing trends of the level of DOSE EQUIVALENT I-131, and allows for appropriate action to be taken to maintain levels below the LCO limit.

REFERENCES 1. FSAR Chapter 15, Accident Analyses.

AP1000 STS B 3.7.4-2 Amendment 0Rev. 0 Revision 19 Date report generated:

Friday, June 26, 2015 Page 16

GTST AP1000-O44-3.7.4, Rev. 1 XII. Applicable STS Subsection After Incorporation of this GTSTs Modifications The entire subsection of the Specifications and the Bases associated with this GTST, following incorporation of the modifications, is presented next.

Date report generated:

Friday, June 26, 2015 Page 17

GTST AP1000-O44-3.7.4, Rev. 1 Secondary Specific Activity 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Secondary Specific Activity LCO 3.7.4 The specific activity of the secondary coolant shall be < 0.1 Ci/gm DOSE EQUIVALENT I-131.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Specific activity not A.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> within limit.

AND A.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.4.1 Verify the specific activity of the secondary coolant 31 days 0.1 Ci/gm DOSE EQUIVALENT I-131.

AP1000 STS 3.7.4-1 Rev. 0 Date report generated:

Friday, June 26, 2015 Page 18

GTST AP1000-O44-3.7.4, Rev. 1 Secondary Specific Activity B 3.7.4 B 3.7 PLANT SYSTEMS B 3.7.4 Secondary Specific Activity BASES BACKGROUND Activity in the secondary coolant results from steam generator tube LEAKAGE from the Reactor Coolant System (RCS). Therefore, fission product isotopes, as well as activated corrosion products in lesser amounts, may be found in the secondary coolant. While fission products present in the primary coolant, as well as activated corrosion products, enter the secondary coolant system due to the primary to secondary LEAKAGE, only the iodines are of a significant concern relative to airborne release of activity in the event of an accident or abnormal occurrence (radioactive noble gases that enter the secondary side are not retained in the coolant but are released to the environment via the condenser air removal system throughout normal operation).

The limit on secondary coolant radioactive iodines minimizes releases to the environment due to anticipated operational occurrences or postulated accidents.

APPLICABLE The accident analysis of the main steam line break (SLB) as discussed in SAFETY FSAR Chapter 15 (Ref. 1) assumes the initial secondary coolant specific ANALYSES activity to have a radioactive isotope concentration of 0.1 Ci/gm DOSE EQUIVALENT I-131. This assumption is used in the analysis for determining the radiological consequences of the postulated accident.

The accident analysis, based on this and other assumptions, shows that the radiological consequences of a postulated SLB are within the acceptance criteria in SRP Section 15.0.1, and within the exposure guideline values of 10 CFR Part 50.34.

Secondary specific activity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO As indicated in the Applicable Safety Analyses, the specific activity limit of the secondary coolant is required to be 0.1 Ci/gm DOSE EQUIVALENT I-131 to maintain the validity of the analyses reported in FSAR Chapter 15 (Ref. 1).

Monitoring the specific activity of the secondary coolant ensures that when secondary specific activity limits are exceeded, appropriate actions are taken in a timely manner to place the unit in an operational MODE that would minimize the radiological consequences of a DBA.

AP1000 STS B 3.7.4-1 Rev. 0 Date report generated:

Friday, June 26, 2015 Page 19

GTST AP1000-O44-3.7.4, Rev. 1 Secondary Specific Activity B 3.7.4 BASES APPLICABILITY In MODES 1, 2, 3, and 4 the limits on secondary specific activity apply due to the potential for secondary steam releases to the atmosphere.

In MODES 5 and 6, the steam generators are not being used for heat removal. Both the RCS and steam generators are depressurized, and primary to secondary LEAKAGE is minimal. Therefore, monitoring of secondary specific activity is not required.

ACTIONS A.1 and A.2 DOSE EQUIVALENT I-131 exceeding the allowable value in the secondary coolant is an indication of a problem in the RCS and contributes to increased post-accident doses. If the secondary specific activity cannot be restored to within limits within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.4.1 REQUIREMENTS This SR verifies that the secondary specific activity is within the limits of the accident analysis. A gamma isotopic analysis of the secondary coolant, which determines DOSE EQUIVALENT I-131, confirms the validity of the safety analysis assumptions as to the source terms in post-accident releases. It also serves to identify and trend any unusual isotopic concentrations that might indicate changes in reactor coolant activity or leakage. The 31 day Frequency is based on the detection of increasing trends of the level of DOSE EQUIVALENT I-131, and allows for appropriate action to be taken to maintain levels below the LCO limit.

REFERENCES 1. FSAR Chapter 15, Accident Analyses.

AP1000 STS B 3.7.4-2 Rev. 0 Date report generated:

Friday, June 26, 2015 Page 20

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