ML19214A167

(External_Sender) Hatch Secondary Containment LAR

ML19214A167
Person / Time
Site:	Hatch
Issue date:	06/14/2019
From:	Joyce R - No Known Affiliation, Southern Nuclear Operating Co
To:	John Lamb Plant Licensing Branch II
References
Download: ML19214A167 (4)

Text

NRR-DRMAPEm Resource From: Joyce, Ryan M. <RMJOYCE@southernco.com>

Sent: Friday, June 14, 2019 2:34 PM To: Karipineni, Nageswara; Lamb, John Cc: Enfinger, Timothy Lee

Subject:

[External_Sender] RE: RE: RE: Hatch Secondary Containment LAR Please see the responses below.

Thanks.

From: Karipineni, Nageswara Sent: Thursday, June 13, 2019 4:13 PM To: Lamb, John ; Joyce, Ryan M.

Cc: Enfinger, Timothy Lee

Subject:

RE: RE: RE: Hatch Secondary Containment LAR EXTERNAL MAIL: Caution Opening Links or Files Thanks John. Other things that I would like to have a better understanding are:

SRs 3.6.4.1.3 and 3.6.4.1.4 were mentioned under Conditions 3.6.4.1.A and 3.6.4.1.b, respectively. Are these surveillance done under a single test procedure and a single test or they done under different procedures and at different times? SRs 3.6.4.1.3 and 3.6.4.1.4 are performed using the same test procedure. The surveillances are performed at the same time.

The drawdown test occurs first (SR 3.6.4.1.3), then the duration test (SR 3.6.4.1.4) begins once a vacuum of > 0.20 WG is reached. If the surveillance test was done under the best combination of SGT systems available for the secondary containment configuration the plant is in at the time of the test, would the Secondary Containment be declared inoperable as soon as it is determined that the surveillance is not met? Regardless of the combination of SGT subsystems used to perform SRs 3.6.4.1.3 and 3.6.4.1.4, (e.g. either using two Unit 1 SGT subsystems and one Unit 2 SGT subsystem OR using one Unit 1 SGT subsystem and two Unit 2 SGT subsystems), the secondary containment is immediately declared inoperable after the SR is not met in accordance with SR 3.0.1. The underlying cause for the SR not being met is then determined, so that the appropriate TS Conditions are entered. Reasons for not meeting SRs 3.6.4.1.3 and 3.6.4.1.4 could be that the secondary containment itself is degraded, in which case TS 3.6.4.1 Condition A is entered.

However, other reasons for not meeting SR 3.6.4.1.3 or SR 3.6.4.1.4 could be that a SGT subsystem used for the surveillance is inoperable. The test would be run with a different combination of SGT subsystems to determine if the cause of the failure was due to an inoperable SGT subsystem. If the SR passes with a different combination of SGT subsystems, then TS 3.6.4.3 Condition A or B is entered, as appropriate. Per LCO 3.0.6, the Secondary Containment is still inoperable; however, the Conditions and Required Actions associated with the Secondary Containment (TS 3.6.4.1 Condition A) are not required to be entered. Section 2.3 of the LAR provides an example from when SR 3.6.4.1.3 was run in January 2018 and was not met.

Under the required actions A.1 and B.1, explain the wording using one or more OPERABLE standby gas treatment (SGT) systems? If the secondary containment is slightly degraded, SR 3.6.4.1.3 and/or 3.6.4.1.4 may not be able to be met using a combination of two Unit 1 SGT subsystems and one Unit 2 SGT subsystem, due in large part from the shared ductwork of the two Unit 1 SGT subsystems. However, if the SRs can be met using the SGT systems that are Operable at the time (e.g. using the two Unit 2 SGT subsystems), then the secondary containment is capable of performing its safety function, and the assumptions in the Chapter 15 accident analysis can be met. This change would allow additional time 1

(beyond the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) for a slightly degraded secondary containment if the safety function can still be performed during the time the secondary containment degraded condition is being restored.

Is it because, sometimes there may still be two OPERABLE standby gas treatment (SGT) available and sometimes there may not be? Yes. If less than the required number of SGT subsystems are Operable per LCO 3.6.4.3, the associated Conditions and Required Actions of TS 3.6.4.3 are entered. SRs 3.6.4.1.3 and 3.6.4.1.4 are required to be Met using one less than the required number of SGT subsystems required per LCO 3.6.4.3, to ensure SRs 3.6.4.1.3 and 3.6.4.1.4 could still be met if theres a single failure on an Operable SGT subsystem. It could be possible that, with one required SGT subsystem inoperable, a combination of operable/inoperable SGT subsystems could draw and maintain proper vacuum (e.g, all 4 SGT subsystems). SNC believes this would not be acceptable.

Also, why are the completion times different for Conditions A and B? As described in Section 3.3 and the proposed TS Bases, additional time is needed to perform Required Action B.1 since the required vacuum must be met for one hour.

SNC believes that 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided a reasonable time to perform this Required Action (i.e., align and run various combinations of SGT subsystems for at least one hour each until one combination is determined acceptable). The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> CT is consistent with TS 3.6.4.2 Required Action A.1.

For new Conditions C and D, other than surveillances 3.6.4.1.1 and 3.6.4.1.2, what else does the plant do to determine the Secondary Containment Integrity? As stated on page E-7 and E-8 of the LAR:

Additionally, the equipment hatch and door seals are periodically inspected and maintained in accordance with the requirements of Sections X and XI of 10 CFR 50, Appendix B as described in the HNP quality assurance program and associated plant procedures. Seal integrity of the equipment hatches is verified in accordance with the requirements of SR 3.6.4.1.1 at a frequency in accordance with the SFCP. The current performance frequency for this verification is every 31 days. Door seals are inspected in accordance with the plant preventative maintenance schedule at an interval based on the history of seal degradation. Leak tightness of equipment hatch and door seals are verified during performance of secondary containment drawdown and duration tests (SRs 3.6.4.1.3 and 3.6.4.1.4).

During the time periods between testing and inspections, operators are alerted to a degradation of secondary containment leak tightness by reactor building-to-outside air differential pressure low and refueling floor-to-outside air differential pressure low annunciation provided in the main control room.

Also, have the license amendment request handy during the call.

Thanks, Nageswara Rao Karipineni From: Lamb, John Sent: Thursday, June 13, 2019 1:02 PM To: Joyce, Ryan M. <RMJOYCE@southernco.com>

Cc: Enfinger, Timothy Lee <TLENFING@SOUTHERNCO.COM>; Karipineni, Nageswara <Nageswara.Karipineni@nrc.gov>

Subject:

RE: RE: RE: Hatch Secondary Containment LAR Importance: High

Ryan, My understanding is that the tech reviewer wishes an explanation of Conditions and Required Actions for TS 3.6.4.1.A and TS 3.6.4.1.B and how it relates to the Configuration Types A, B1, B2, and C.

The tech reviewer will try to draft up more specific clarifications and will email them to you tomorrow.

Thanks.

John 2

From: Joyce, Ryan M. <RMJOYCE@southernco.com>

Sent: Thursday, June 13, 2019 12:27 PM To: Lamb, John <John.Lamb@nrc.gov>

Subject:

[External_Sender] RE: RE: Hatch Secondary Containment LAR Can you provide a high level summary of what theyre looking for us to clarify, to ensure were prepared to discuss?

Thanks.

From: Lamb, John <John.Lamb@nrc.gov>

Sent: Thursday, June 13, 2019 10:51 AM To: Joyce, Ryan M. <RMJOYCE@southernco.com>

Subject:

RE: RE: Hatch Secondary Containment LAR EXTERNAL MAIL: Caution Opening Links or Files Let me check with the tech reviewer and get back to you.

From: Joyce, Ryan M. <RMJOYCE@southernco.com>

Sent: Thursday, June 13, 2019 11:49 AM To: Lamb, John <John.Lamb@nrc.gov>; Enfinger, Timothy Lee <TLENFING@SOUTHERNCO.COM>

Cc: 'gregg.ellis@excelservices.com' <gregg.ellis@excelservices.com>

Subject:

[External_Sender] RE: Hatch Secondary Containment LAR Monday will work, except from 3 - 4 EDT.

Tuesday will work, except from 12 - 3 EDT.

Will either of those days work for the NRC?

From: Lamb, John <John.Lamb@nrc.gov>

Sent: Thursday, June 13, 2019 5:13 AM To: Joyce, Ryan M. <RMJOYCE@southernco.com>; Enfinger, Timothy Lee <TLENFING@SOUTHERNCO.COM>

Subject:

Hatch Secondary Containment LAR EXTERNAL MAIL: Caution Opening Links or Files Ryan & Tim, I have a tech reviewer that wants some clarification on the proposed tech spec changes for the Hatch Secondary Containment LAR. What is SNCs availability next week for a phone call?

Thanks.

John 3

Hearing Identifier: NRR_DRMA Email Number: 154 Mail Envelope Properties (SN2PR04MB21912822397F76D6D54D3E0DD0EE0)

Subject:

[External_Sender] RE: RE: RE: Hatch Secondary Containment LAR Sent Date: 6/14/2019 2:33:52 PM Received Date: 6/14/2019 2:34:03 PM From: Joyce, Ryan M.

Created By: RMJOYCE@southernco.com Recipients:

"Enfinger, Timothy Lee" <TLENFING@SOUTHERNCO.COM>

Tracking Status: None "Karipineni, Nageswara" <Nageswara.Karipineni@nrc.gov>

Tracking Status: None "Lamb, John" <John.Lamb@nrc.gov>

Tracking Status: None Post Office: SN2PR04MB2191.namprd04.prod.outlook.com Files Size Date & Time MESSAGE 8841 6/14/2019 2:34:03 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

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