Text

License Application Request 238, Application for Technical Specification (TS) Improvement to Extend the Completion Time for Conditions B and C of TS 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process
	ML040500723
Person / Time
Site:	Point Beach
Issue date:	02/10/2004
From:	Vanmiddlesworth G; Nuclear Management Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC 2004-0009
	Download: ML040500723 (18)
	v • d • e

NMC]

Committed to NuclearExcellence Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC February 10, 2004 NRC 2004-0009 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 License Amendment Request 238 Application for Technical Specification Improvement to Extend the Completion Time for Conditions B and C of Technical Specification 3.5.1, "Accumulators", Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, Nuclear Management Company, LLC (NMC), is submitting a request for an amendment to the Technical Specifications (TS) for Point Beach Nuclear Plant, Units 1 and 2.

The proposed amendment would extend the completion time from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Condition C of TS 3.5.1, "Accumulators", and from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Condition B of TS 3.5.1. The change is consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-370, "Risk Informed Evaluation of an Extension to Accumulator Completion Times for Westinghouse Plants". The availability of this technical specification improvement was noticed in the Federal Registeron March 12, 2003 as part of the consolidated line item improvement process (CLIIP).

Enclosure I provides a description of the proposed change and confirmation of applicability. Enclosure II provides the existing TS pages marked up to show the proposed change. Enclosure III provides the existing TS Bases pages marked up to reflect the proposed change. Enclosure IV provides revised (clean) TS pages. There are no new regulatory commitments associated with this proposed change.

NMC requests approval of the proposed license amendment by December 2004, with the amendment being implemented within 45 days.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Wisconsin Official.

6590 Nuclear Road

Two Rivers, Wisconsin 54241 Telephone: 920.755.2321

i Document Control Desk Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on February 10, 2004.

Gary . Van Middlesworth Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC

Enclosures:

I - Description and Confirmation of Applicability 11 - Proposed Technical Specification Changes III - Proposed Technical Specification Bases Changes IV - Revised Technical Specification Pages cc: Project Manager, Point Beach Nuclear Plant, NRR, USNRC Regional Administrator, Region ll, USNRC NRC Resident Inspector - Point Beach Nuclear Plant PSCW

ENCLOSURE I DESCRIPTION AND CONFIRMATION OF APPLICABILITY APPLICATION FOR TECHNICAL SPECIFICATION IMPROVEMENT TO EXTEND THE COMPLETION TIME FOR CONDITIONS B AND C OF TECHNICAL SPECIFICATION 3.5.1, "ACCUMULATORS", USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

1.0 INTRODUCTION

The proposed amendment would extend the completion time from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Condition C of Technical Specification (TS) 3.5.1, "Accumulators", and from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Condition B of TS 3.5.1.

2.0 DESCRIPTION

The proposed changes, including the variations described in Section 3.2 below, are consistent with NRC approved Industry/Technical Specification Task Force (TSTF)

Standard Technical Specification Change Traveler, TSTF-370, 'Risk Informed Evaluation of an Extension to Accumulator Completion Times for Westinghouse Plants". The availability of the model safety evaluation for this technical specification improvement was noticed in the Federal Register on March 12, 2003, as part of the consolidated line item improvement process (CLIIP).

3.0 ASSESSMENT 3.1 Applicability of Published Safety Evaluation NMC has reviewed the safety evaluation published on July 15, 2002 (67 FR 46542), as part of the CLIIP. This verification included a review of the NRC staff's evaluation as well as the supporting information provided to support TSTF-370 (i.e., WCAP-1 5049-A, "Risk-Informed Evaluation of an Extension to Accumulator Completion Times", dated May 18,1999). NMC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Point Beach Nuclear Plant, Units 1 and 2, and justify this amendment for the incorporation of the changes to the Point Beach TS.

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3.2 Optional Changes and Variations NMC is not proposing any deviations from the TS changes described in TSTF-370 or the NRC staffs model safety evaluation published on July 15, 2002.

One plant-specific variation is being proposed to eliminate a difference between the existing Point Beach TS and the Standard TS (NUREG-1431, Revision 2) on which TSTF-370 is based. This variation will align Point Beach TS 3.5.1 with the Standard TS.

Condition B of Point Beach TS 3.5.1 is a condition that is not separately listed in the Standard TS (nor in TSTF-370). This condition contains additional allowances that were carried over from the former Point Beach Custom TS during the conversion to Improved TS. These additional allowances are being proposed for deletion in their entirety. Point Beach Condition B currently states:

CONDITION REQUIRED ACTION COMPLETION TIME B. Power not removed B..1 Remove power from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from one or both accumulator isolation accumulator isolation valve(s).

valve(s) for maintenance or testing.

Condition B of NUREG-1431, Standard TS 3.5.1 states, "One accumulator inoperable for reasons other than Condition A." Only a single reason is specified in Condition A of Standard TS, 'boron concentration not within limit'. The condition of 'power not removed from one accumulator isolation valve for maintenance or testing' is, in fact, a condition other than 'boron

concentration not within limit'. Therefore, the portion of the existingPoint Beach Condition B concerning one accumulator (i.e., power not removed from one or both accumulator isolation valve(s) for maintenance or testing) is bounded by Condition B of Standard TS (one accumulator inoperable for reasons other than Condition A). As such, a separate condition is redundant and this portion of the existing Point Beach Condition B may be deleted. The additional allowance in the Point Beach TS for both accumulator isolation valves' being powered simultaneously is inconsistent with NUREG-1431 and is aiso'proposed for deletion. The proposed Completion Time is consistent with that specified in TSTF-370.

Conditions C, D and E of Point Beach TS 3.5.1 will be redesignated as Conditions B, C and D respectively, as a result of the deletion of the current Condition B. Grammatical and reference changes are also proposed for these conditions to reflect deletion of the current Condition B. As a result of these Page 2 of 3

plant-specific variations, the proposed changes to Point Beach TS LCO 3.5.1 will make this specification consistent with TSTF-370.

The proposed Bases associated with these conditions have been revised to reflect these changes, consistent with TSTF-370. A formatting error in the Background section of the Bases was also corrected (an inadvertently omitted title at the top-left of page B 3.5.1-2 is being reinserted).

4.0 REGULATORY ANALYSIS

4.1 No Significant Hazards Determination NMC has reviewed the proposed no significant hazards consideration determination published in the Federal Register on July 15, 2002 (67 FR 46542) as part of the CLIIP. NMC has concluded that the proposed determination presented in the Federal Register notice is applicable to Point Beach Nuclear Plant (including the variations described in Section 3.2 above) and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

4.2Verification and Commitments There are no new regulatory commitments associated with this proposed change.

5.0 ENVIRONMENTAL EVALUATION NMC has reviewed the environmental evaluation included in the model safety evaluation published on July 15, 2002 (67 FR 46542) as part of the CLIIP. NMC has concluded that the NRC staffs findings presented in that evaluation are applicable to Point Beach and the evaluation is hereby incorporated by reference for this application.

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ENCLOSURE II PROPOSED TECHNICAL SPECIFICATION CHANGES (additions are double-underlined; deletions are strikethrough)

APPLICATION FOR TECHNICAL SPECIFICATION IMPROVEMENT TO EXTEND THE COMPLETION TIME FOR CONDITIONS B AND C OF TECHNICAL SPECIFICATION 3.5.1, "ACCUMULATORS", USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (1 page follows)

Accumulators 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Accumulators LCO 3.5.1 Two Safety Injection Accumulators shall be OPERABLE.

APPLICABILITY: MODES 1 and 2, MODE 3 with RCS pressure > 1000 psig.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One accumulator A.1 Restore boron 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable due to boron concentration to within concentration not within limits.

limits.

B. Power noet Femovcd B.i Remove power fromn 4 he-u-vs from one or both accumulator isolation accumulator isolation va vex6s.

vampe(s)4fe maintenancc or testing.

GBE. One accumulator GA.1 Restore accumulator to 4-24 hours I inoperable for reasons OPERABLE status.

other than Conditions A e-. I Q9,. Required Action and DIG.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months I

associated Completion Time of Condition A-BT AND or GB not met.

&g.2 Reduce RCS pressure 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to < 1000 psig.

En. Two accumulators E12.1 Enter LCO 3.0.3. Immediately inoperable foereaso-ns other than Condition B.

Point Beach 3.5.1-1 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

ENCLOSURE III PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (additions are double-underlined; deletions are strikethrough)

APPLICATION FOR TECHNICAL SPECIFICATION IMPROVEMENT TO EXTEND THE COMPLETION TIME FOR CONDITIONS B AND C OF TECHNICAL SPECIFICATION 3.5.1, "ACCUMULATORS", USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (4 pages follow)

Accumulators B 3.5.1 BASES BACKGROUND assumption that the entire contents of one accumulator will be lost via (continued) the RCS pipe break during the blowdown phase of the LOCA.

APPLICABLE The accumulators are assumed OPERABLE in both the large and small SAFETY ANALYSES break LOCA analyses (Ref. 1). These are the Design Basis Accidents (DBAs) that establish the acceptance limits for the accumulators.

Reference to the analyses for these DBAs is used to assess changes in the accumulators as they relate to the acceptance limits.

In performing design basis accident calculations, conservative assumptions are made concerning the availability of ECCS flow, offsite power, and initial plant conditions.

The limiting large break LOCA is a double ended guillotine break at the discharge of the reactor coolant pump. The limiting large break LOCA analysis (Ref. 3) assumes availability of offsite power. In addition, the contents of one accumulator are assumed to be lost through the break.

The main effects of maintaining offsite power are in the modeling of the containment pressure response, and operation of the reactor coolant pumps. By maintaining offsite power, both containment spray systems and all four containment fan cooler units are assumed to operate, and the worst case single failure becomes the loss of the largest ECCS Pump (a residual heat removal (RHR) pump). By maintaining full containment cooling capability, containment pressure is minimized which increases RCS blowdown rate, while the loss of a RHR pump decreases the amount of injection flow available to reflood the core.

These assumptions result in an increase in core reflood time leading to higher peak clad temperatures. Operation of the reactor coolant pumps during the blowdown phase increases the rate of RCS blowdown while lowering mass flow through the core, also leading to higher peak clad temperatures. During the reflood phase, the reactor coolant pumps are assumed to cease operation, obtaining a locked rotor flow resistance to delay core reflood, which contributes to a higher peak clad temperature.

While this may in fact be the most limiting case relative to peak clad temperature, it is clear that the availability of the emergency diesel generators, buses and safeguards equipment, are key to mitigating the consequences of a large break LOCA in the event of a loss-of-offsite power. No operator action is assumed during the blowdown stage of a large break LOCA.

The limiting small break LOCA analysis (Ref. 3) assume loss of offsite power with the limiting single failure conservatively taken to be loss of one train of ECCS due to loss of an emergency diesel generator.

Accordingly, the worst case small break LOCA analyses assumes a time delay before pumped flow reaches the core. For the larger range of small breaks, the rate of blowdown is such that the increase in fuel Point Beach B 3.5.1-2 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

Accumulators B 3.5.1 BASES APPLICABILITY In MODE 3, with RCS pressure < 1000 psig, and in MODES 4, 5, and 6, (continued) the accumulator motor operated isolation valves are closed to isolate the accumulators from the RCS. This allows RCS cooldown and depressurization without discharging the accumulators into the RCS or requiring depressurization of the accumulators.

ACTIONS A.1 If the boron concentration of one accumulator is not within limits, it must be returned to within the limits within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Condition, ability to maintain subcriticality or minimum boron precipitation time may be reduced. The boron in the accumulators contributes to the assumption that the combined ECCS water in the partially recovered core during the early reflooding phase of a large break LOCA is sufficient to keep that portion of the core subcritical. One accumulator below the minimum boron concentration limit, however, will have no effect on available ECCS water and an insignificant effect on core subcriticality during reflood. Thus, 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is allowed to return the boron concentration to within limits.

84 If one or both accunmLlator ar e inoperable solely beeausc powcr has bcen restored to the associated isolation valve, then power must be removed from the isolation valve(s) restoring the accumulators to an OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In this condition the accumulators are capable of injecting in the event of a LOCA thus performing their design function. The four hours allowed to remove power from the isolation valves is reasonable based on operating expcrien'c and due to the capability of the accumulators to perform their design function. In addition, during maintenance and testing, if an accumulator is isolated then the more limiting 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of Condition C applies.

GB.1 If one accumulator is inoperable for a reason other than boron concentration, or power not removed from the associated isolation valve, the accumulator must be returned to OPERABLE status within 4-24 hours. In this Condition, the required contents of one accumulator cannot be assumed to reach the core during a LOCA. Due to the severity of the consequences should a LOCA occur in these conditions, the 4-24 hour Completion Time to open the valve, remove power to the I valve, or restore the proper water volume or nitrogen cover pressure ensures that prompt action will be taken to return the inoperable accumulator to OPERABLE status. The Completion Time minimizes Point Beach B 3.5.1-5 Unit 1 - Amendment No. 201 Unit 2 - Amendment No. 206

Accumulators B 3.5.1 BASES ACTIONS (continued) the potential for exposure of the plant to a LOCA under these conditions. The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed to restore an inoperable accumulator to OPERABLE status is iustified in WCAP-1 5049-A, Rev. 1 (Ref. 4).

OC.1 and PC.2 If the accumulator cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and RCS pressure reduced to

1000 psig within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

E01 If both accumulators are inoperable, the water volume and boron concentrations assumed in the various accident analyses may not be delivered to the RCS therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.5.1.1 REQUIREMENTS Each accumulator valve should be verified to be fully open every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This verification ensures that the accumulators are available for injection and ensures timely discovery if a valve should be less than fully open. If an isolation valve is not fully open, the rate of injection to the RCS would be reduced. Although a motor operated valve position should not change with power removed, a closed valve could result in not meeting accident analyses assumptions. This Frequency is considered reasonable in view of other administrative controls that ensure a mispositioned isolation valve is unlikely.

SR 3.5.1.2 and SR 3.5.1.3 Every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , borated water volume and nitrogen cover pressure are verified for each accumulator. This Frequency is sufficient to ensure adequate injection during a LOCA. Because of the static design of the accumulator, a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency usually allows the operator to identify changes before limits are reached. Operating experience has shown this Frequency to be appropriate for early detection and correction of off normal trends.

Point Beach B 3.5.1-6 Unit 1 -Amendment No. 201 Unit 2 - Amendment No. 206

BASES SURVEILLANCE SR 3.5.1.4 REQUIREMENTS (continued) The boron concentration should be verified to be within required limits for each accumulator every 31 days since the static design of the accumulators limits the ways in which the concentration can be changed. The 31 day Frequency is adequate to identify changes that could occur from mechanisms such as stratification or inleakage.

Sampling the affected accumulator within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after a 5% volume increase will identify whether inleakage has caused a reduction in boron concentration to below the required limit. It is not necessary to verify boron concentration if the added water inventory is from the refueling water storage tank (RWST), and the water contained in the RWST is within the accumulator boron concentration requirements. This is consistent with the recommendation of NUREG-1366 (Ref. 4-. I SR 3.5.1.5 Verification every 31 days that power is removed from each accumulator isolation valve operator when the RCS pressure is

> 1000 psig ensures that an active failure could not result in the undetected closure of an accumulator motor operated isolation valve. If this were to occur, no accumulators would be available for injection in the event of a LOCA. Since power is removed under administrative control, the 31 day Frequency will provide adequate assurance that power is removed.

This SR allows power to be supplied to the motor operated isolation valves when RCS pressure is

1000 psig, thus allowing operational flexibility by avoiding unnecessary delays to manipulate the breakers during plant startups or shutdowns.

REFERENCES 1. FSAR, Section 6.2.

2. 10 CFR 50.46.

3. FSAR, Chapter 14.

4. WCAP-1 5049-A, Rev. . Aprij1999..

4-5. NUREG-1366, February 1990.

Point Beach B 3.5.1-7 Unit I -Amendment No. 201 Unit 2 -Amendment No. 206

ENCLOSURE IV REVISED TECHNICAL SPECIFICATION PAGES APPLICATION FOR TECHNICAL SPECIFICATION IMPROVEMENT TO EXTEND THE COMPLETION TIME FOR CONDITIONS B AND C OF TECHNICAL SPECIFICATION 3.5.1, "ACCUMULATORS", USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (5 pages follow)

Accumulators 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Accumulators LCO 3.5.1 Two Safety Injection Accumulators shall be OPERABLE.

APPLICABILITY: MODES I and 2, MODE 3 with RCS pressure > 1000 psig.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One accumulator A.1 Restore boron 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable due to boron concentration to within concentration not within limits.

limits.

B. One accumulator B.1 Restore accumulator to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months inoperable for reasons OPERABLE status.

other than Condition A.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or B AND not met.

C.2 Reduce RCS pressure 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to < 1000 psig.

D. Two accumulators D.1 Enter LCO 3.0.3. Immediately inoperable.

Point Beach 3.5.1-1 Unit 1 - Amendment No.

Unit 2 - Amendment No.