ML22240A106
Text
GTST AP1000-A24-3.9.5, Rev. 1 Advanced Passive 1000 (AP1000)
Generic Technical Specification Traveler (GTST)
Title:
Removal of AP1000 GTS Subsection 3.9.5, Containment Penetration 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:
Not applicable NRC Approval Date:
Not applicable TSTF Classification:
Not applicable Date report generated:
Friday, May 22, 2015 Page 1
GTST AP1000-A24-3.9.5, 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:
None RCOL COL Item Number and
Title:
Not applicable RCOL PTS Change Number and
Title:
The Vogtle Electric Generating Plant Units 3 and 4 License Amendment Request (VEGP LAR) proposed the following changes to the initial version of the PTS (referred to as the current TS by the VEGP LAR).
These changes include Relocation Changes (R) and are addressed in enumerated discussions of change (DOCs). These changes are discussed in Sections VI and VII of this GTST.
DOC R1: Relocate GTS 3.9.5 Date report generated:
Friday, May 22, 2015 Page 2
GTST AP1000-A24-3.9.5, 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(1) applicable to operating reactor designs, but not to the AP1000 design; (2) already incorporated in the GTS; or (3) superseded by another change.
DOC R1 relocates Subsection 3.9.5 to a document that is required to be controlled in accordance with 10 CFR 52.98. Details of this change are discussed later in Section VI "Traveler Information.
Date report generated:
Friday, May 22, 2015 Page 3
GTST AP1000-A24-3.9.5, 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)
None Date report generated:
Friday, May 22, 2015 Page 4
GTST AP1000-A24-3.9.5, Rev. 1 V. Applicability Affected Generic Technical Specifications and Bases:
Section 3.9.5, Containment Penetrations Changes to the Generic Technical Specifications and Bases:
DOC R1 removes Subsection 3.9.5 TS and Bases from the AP1000 GTS Rev. 19 and relocates them to a document that is committed to be controlled in accordance with 10 CFR 52.98.
Date report generated:
Friday, May 22, 2015 Page 5
GTST AP1000-A24-3.9.5, Rev. 1 VI. Traveler Information Description of TSTF changes:
None Rationale for TSTF changes:
Not applicable Description of changes in RCOL Std. Dep., RCOL COL Item(s), and RCOL PTS Changes:
DOC R1 removes Subsection 3.9.5 TS and Bases from the AP1000 GTS Rev. 19 and relocates them to a document that is committed to be controlled in accordance with 10 CFR 52.98.
Rationale for changes in RCOL Std. Dep., RCOL COL Item(s), and RCOL PTS Changes:
According to DOC R1 SNC commits to relocate the Containment Penetrations during movement of irradiated fuel assemblies within containment Specification to a document that is controlled in accordance with 10 CFR 52.98.
The rational given in the DOC states that current TS 3.9.5 provides requirements for the containment penetrations during movement of irradiated fuel assemblies within containment.
The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained within the requirements. However, there are no safety analyses that assume containment closure during movement of irradiated fuel assemblies within containment, other than those discussed in current TS 3.6.8, "Containment Penetrations," which is applicable in Modes 5 and 6 and which is being maintained in the TS. Fuel handling accidents, analyzed in Final Safety Analysis Report (FSAR) Section 15.7.4, include dropping a single irradiated fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies. After the activity escapes from the water pool, it is assumed that it is released directly to the environment within a 2-hour period.
Closure of the containment purge lines can occur on detection of high radioactivity; however, no credit is taken for this in the analysis. The requirements of current TS 3.9.4, "Refueling Cavity Water Level," and current TS 3.9.7, "Decay Time," ensure that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are well within the dose acceptance limit.
While the containment design will mitigate the consequences of a fuel handling accident, it would have no effect on core damage frequency, since it does not prevent fuel failure, but only reduces the dose if it occurs. The dose rates associated with the spent fuel handling accidents are not enough to result in large early release, since a delay time to allow fission products to decay is required before fuel can be placed in and therefore moved within the spent fuel pool.
As such, while the VFS exhaust subsystem is modeled in the PRA, its importance in limiting the likelihood of a severe accident sequence that has shown to be significant to public health and safety is not significant (i.e., is less than 1.3% of the AP1000 Shutdown Large Release Frequency). Therefore, the requirements of current TS 3.9.5 are relocated to a document that is controlled in accordance with 10 CFR 52.98.
Date report generated:
Friday, May 22, 2015 Page 6
GTST AP1000-A24-3.9.5, Rev. 1 VEGP LAR for TSU DOC concludes that This change is acceptable because current TS 3.9.5 does not meet the 10 CFR 50.36(c)(2)(ii) criteria for inclusion into the TS, as discussed in the Applicable Regulatory Requirements.
However, as described in Reference (4), NRC staff raised concerns regarding the removal of Subsection 3.9.5 TS and Bases from the AP1000 GTS Rev. 19 and relocating them in another document. These concerns are documented in RAI 16-32 of Reference (4). NRC staff requested Southern Nuclear Operating Company (SNC) either (1) to withdraw the proposed relocation of the existing TS 3.9.5 from the LAR, or (2) to provide additional justification to support the relocation of this subsection.
In response to this RAI 16-32, SNC chose the latter option (2) as documented in Reference (5).
SNC provided further justification for the relocation of TS 3.9.5 to a Technical Requirements Manual (TRM) with changes controlled by 10 CFR 52.98. This TRM will be incorporated by reference into FSAR Chapter 16 as a site-specific portion of the FSAR.
The staffs rationale for approving the relocation of Subsection 3.9.5 is provided in Reference (7), VEGP Units 3 and 4 Safety Evaluation for Amendment 13.
Description of additional changes proposed by NRC staff/preparer of GTST:
None Rationale for additional changes proposed by NRC staff/preparer of GTST:
Not applicable Date report generated:
Friday, May 22, 2015 Page 7
GTST AP1000-A24-3.9.5, Rev. 1 VII. GTST Safety Evaluation Technical Analysis:
Technical discussion of the proposed relocation of Subsection 3.9.5 by DOC R1 is covered in Section VI.
References to Previous NRC Safety Evaluation Reports (SERs):
None Date report generated:
Friday, May 22, 2015 Page 8
GTST AP1000-A24-3.9.5, Rev. 1 VIII. Review Information Evaluator Comments:
None Joseph C. Braun Argonne National Laboratory 630-252-5574 joebraun@anl.gov E. Danial Doss Argonne National Laboratory 630-252-5967 doss@anl.gov Review Information:
Availability for public review and comment on Revision 0 of this traveler approved by NRC staff on 4/23/2014.
NRC Final Approval Date: 05/22/2015 NRC
Contact:
Derek Scully U.S. Nuclear Regulatory Commission 301-415-6972 Derek.Scully@nrc.gov Date report generated:
Friday, May 22, 2015 Page 9
GTST AP1000-A24-3.9.5, Rev. 1 IX. Evaluator Comments for Consideration in Finalizing Technical Specifications and Bases None Date report generated:
Friday, May 22, 2015 Page 10
GTST AP1000-A24-3.9.5, Rev. 1 X. References Used in GTST
- 1. AP1000 DCD, Revision 19, Section 16, Technical Specifications, June 2011 (ML11171A500).
- 2. Vogtle Electric Generating Plant (VEGP), Units 3 &4 COL Application, Part 4, Technical Specifications, Revision 3 (ML11180A102, 07/01/2011).
- 3. Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Final Safety Evaluation Report (ML110450302, 08/10/2011)
- 4. Southern Nuclear Operating Company, Vogtle Electric Generating Plant, Unit 3 and 4, Technical Specifications Upgrade License Amendment Request, February 24, 2011 (ML12065A057).
- 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 07, 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)
- 7. 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)
Date report generated:
Friday, May 22, 2015 Page 11