ML070030072

Supplement to Proposed Technical Specification Change (LBDCR 04-MP3-011) Auxiliary Feedwater System Allowed Outage Time

ML070030072
Person / Time
Site:	Millstone
Issue date:	01/02/2007
From:	Gerald Bichof Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
05-699C
Download: ML070030072 (19)

Text

Dominion Nuclear Connecticut, Inc.

5000 Dominion Roulevard, Glen Allen, Virginia 2.1060

\Xch Address: www.dom.com January 2, 2007 U. S. Nuclear Regulatory Commission Serial No. 05-6996 Attention: Document Control Desk NLOSIPRW RO One White Flint North Docket No. 50-423 11555 Rockville Pike License No. NPF-49 Rockville, MD 20852-2738 DOMINION NUCLEAR CONNECTICUT. INC.

MILLSTONE POWER STATION UNIT 3 SUPPLEMENT TO PROPOSED TECHNICAL SPECIFICATION CHANGE JLBDCR 04-MP3-011)

AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME This letter provides supplemental information for request LBDCR 04-MP3-011, submitted by Dominion Nuclear Connecticut, Inc. (DNC) in a letter dated February 7, 2006, for Millstone Power Station Unit 3. The submittal was originally supplemented in a letter dated August 14, 2006. Attachment 1 of this letter provides clarifications requested by the NRC in a conference call with DNC on November 9, 2006. Attachments 2 and 3 provide the replacement marked up page and retyped pages. The revised marked up bases page is provided in Attachment 4 for information only.

The additional information provided in this letter does not affect the conclusions of the safety summary and significant hazards consideration discussion in DNC1s submittal of February 7, 2006.

In accordance with 10 CFR 50.91(b), a copy of this letter is being provided to the State of Connecticut.

If you should have any questions regarding this submittal, please contact Mr. Paul R. Willoughby at (804) 273-3572.

Very truly yours, Gerald T. Bischof w

Vice President - Nuclear Engineering Commitments made in this letter: None

Serial No. 05-699C Docket No. 50-423 Supplement to Proposed Technical Specification Change Request Auxiliary Feedwater System Allowed Outage Time Page 2 of 3 Attachments: (4)

1. Supplement to Proposed Technical Specification Change

2. Replacement Marked Up Page

3. Replacement Retyped Pages

4. Revised Marked Up Bases Page (Information Only) cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 Mr. V. Nerses Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8 C2 Rockville, MD 20852-2738 Mr. S. M. Schneider NRC Senior Resident Inspector Millstone Power Station Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No. 05-699C Docket No. 50-423 Supplement to Proposed Technical Specification Change Request Auxiliary Feedwater System Allowed Outage Time Page 3 of 3 COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President -

Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this cq= day of My Commission Expires:

/,d Notary Public f

(SEAL)

Serial No. 05-699C Docket No. 50-423 ATTACHMENT 1 AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME SUPPLEMENT TO PROPOSED TECHNICAL SPECIFICATION CHANGE DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

Serial No. 05-699C Docket No. 50-423 Attachment 1, Page 1 of 2 SUPPLEMENT TO PROPOSED TECHNICAL SPECIFICATION CHANGE AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME This letter provides supplemental information for request LBDCR 04-MP3-011, submitted by Dominion Nuclear Connecticut, Inc. (DNC) in a letter dated February 7, 2006, for Millstone Power Station Unit 3. The submittal was originally supplemented in a letter dated August 14, 2006. This attachment provides clarifications requested by the NRC in a conference call with DNC on November 9, 2006.

Question 1 The proposed change to Millstone Power Station Unit 3 (MPS 3) TS 3.7.1.2 ACTIONS includes an asterisked footnote that discusses separate condition entry for selected specified ACTIONS. Please explain the necessity and basis for the footnote.

Response 1 Based on the perspective provided by the NRC during the conference call between DNC and the NRC on November 9, 2006, the referenced footnote and its basis were reviewed. It was concluded that the footnote was not required. Also as a result of the discussions during the conference call, the description of the inoperable equipment for ACTION a. is being clarified. The emphasis in the description of the inoperable equipment is changed from the proposed "two inoperable steam supplies to turbine-driven auxiliary feedwater pump" to the proposed "inoperable turbi ne-driven auxiliary feedwater pump due to one of the two required steam supplies being inoperable." At MPS 3, only two of the three available steam supplies are required to establish an OPERABLE steam supply system. With one of the two required steam supplies inoperable, normally the third steam supply will be used to satisfy the requirement for two OPERABLE steam supplies. If the third steam supply is also inoperable (i.e., only one steam supply to the turbine-driven auxiliary feedwater pump is OPERABLE), then ACTION a. is entered. provides the revised marked up pages including a revision to Insert C provided in the original proposal (DNC Serial No.05-699, dated February 7, 2006) that removes the footnote and the asterisks and clarifies the ACTION a. inoperable equipment description. Replacement retyped pages are provided in Attachment 3 of this letter.

Additionally, the changes to the Technical Specification Bases that were previously provided for information only will be further modified to address the above changes.

Revised marked up pages of the Technical Specification Bases are provided in of this letter for information only.

Serial No. 05-699C Docket No. 50-423 Attachment 1, Page 2 of 2 Question 2 Please explain the purpose of the word "required" in proposed MPS 3 TS 3.7.1.2 Required Action c.

Response 2 Upon review, the word "required" was determined to be unnecessary. Although present in the current Technical Specification, it has no explicit value and will be removed. provides the revised marked up pages including a revision to Insert C provided in the original proposal (DNC Serial No.05-699, dated February 7, 2006) that removes the word "required" in proposed Required Action c. Replacement retyped pages are provided in Attachment 3 of this letter.

Serial No. 05-699C Docket No. 50-423 ATTACHMENT 2 AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME REPLACEMENT MARKED UP PAGE DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2 At least three independent steam generator auxiliary feedwat& pumps and associated flow paths shall be OPERABLE with:

a. Two motor-driven auxiliary feedwaterpumps, each capable of being powered from separate emergency busses, and

b. One steam turbinedriven auxiliary feedwater pump capable of being powered from an OPERABLE steam supply system.

APPLICABI[LITTY: MODES I , 2, and 3.

SURVEILLANCE REQUIReMENTS 4.7.1.2.1 Each auxiliary feedwater pump shall be demonstrated OPERABLE; At least once per 31 days by:

MILLSTONE UNTT 3 3/4 7-4 AMENDMENT NO.57,

Serial No. 05-699C Docket No. 50-423 Attachment 2 Insert Pages Page 1 of 3 Revised Insert C Millstone Power Station Unit 3 Technical Specifications Page 314 7-4 Inoperable Equipment Required ACTION

a. Turbine-driven auxiliary a. Restore affected equipment to OPERABLE status feedwater pump due to within 7 days. If these ACTIONS are not met, one of the two required be in at least HOT STANDBY within the next 6 steam supplies being hours and in HOT SHUTDOWN within the inoperable. following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. Restore affected equipment to OPERABLE status within 7 days. If these ACTIONS are not met,

---

NOTE------------- be in at least HOT SHUTDOWN within the Only applicable if MODE following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2 has not been entered following REFUELING.

One turbine-driven auxiliary feedwater pump in MODE 3 following REFUELING.

c. One auxiliary feedwater c. Restore the auxiliary feedwater pump to pump in MODE 1,2, or 3 OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If these for reasons other than a. ACTIONS are not met, be in at least HOT or b. above. STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

d. Two auxiliary feedwater d. Be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pumps in MODE 1,2, or in HOT SHUTDOWN within the following 12

3. hours.

Serial No. 05-699C Docket No. 50-423 Attachment 2 Insert Pages Page 2 of 3 Inoperable Equipment Required ACTION

e. Three auxiliary feedwater e.

pumps in MODE 1,2, or .......................... NOTE------- - -------- -------------

3. LC0 3.0.3 and all other LC0 required ACTIONS requiring MODE changes are suspended until one A M pump is restored to OPERABLE status.

Immediately initiate ACTION to restore one auxiliary feedwater pump to OPERABLE status.

Serial No. 05-699C Docket No. 50-423 Attachment 2 Insert Pages Page 3 of 3 Insert D (Unchanged from February 7, 2006 submittal)

Millstone Power Station Unit 3 Technical Specifications Page 314 7-4 Auxiliary feedwater pumps may be considered OPERABLE during alignment and operation for steam generator level control, if they are capable of being manually realigned to the auxiliary feedwater mode of operation.

Verifying each auxiliary feedwater manual, power operated, and automatic valve in each water flow path and in each required supply flow path to the steam turbine driven auxiliary feedwater pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Serial No. 05-699C Docket No. 50-423 ATTACHMENT 3 AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME REPLACEMENT RETYPED PAGES DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPEMTION 3.7.1.2 At Ieast three independent steam generator auxiliary feedwater pumps and associated flow paths shall be OPERABLE with:

a. Two motor-driven auxiliary feedwater pumps, each capable of being powered from separate emergency busses, and

b. One steam turbine-driven auxiliary feedwater pump capable of being powered from an OPERABLE steam supply system.

APPLICABILITY MODES 1,2, and 3.

ACTION:

Inoperable Equipment tequired ACTION

a. Turbine-driven auxiliary I. Restore affected equipment to OPERABLE status feedwater pump due to one of the within 7 days. If these ACTIONS are not met, be in two required steam supplies being at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and inoperable. in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. ,. Restore affected equipment to OPERABLE status within 7 days. If these ACTIONS are not met, be in

- - - - - NOTE----- at least HOT SHUTDOWN within the following 12 Only applicable if MODE 2 has hours.

not been entered following REFUELING One turbine-driven auxiliary feedwater pump in MODE 3 following REFUELING

c. One auxiliary feedwater pump in  :. Restore the auxiliary feedwater pump to MODE 1,2, or 3 for reasons other OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If these than a. or b. above. ACTIONS are not met, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

d. Two auxiliary feedwater pumps in 1. Be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 1,2, or 3. HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

MILLSTONE - UNIT 3 3/4 7-4 Amendment No. 57,188,

PLANT SYSTEMS AUXILIARY FEEDWATER SYSTEM LIMITING CONDITION FOR OPERATION ACTION: (Continued) llnoperabie Equipment

- - Xequired ACTION 1 e. Three auxiliary feedwater L C 0 3.0.3 and all other LC0 required ACTIONS requiring MODE changes are suspended until one AFW pump is restored to OPERABLE status.

Immediately initiate ACTION to restore one auxiliary feedwater pump to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.7.1.2.1 Each auxiliary feedwater pump shall be demonstrated OPERABLE:

a. At Ieast once per 3 1 days by:

Auxiliary feedwater pumps may be considered OPERABLE during aIignment and operation for steam generator level control, if they are capable of being manually realigned to the auxiliary feedwater mode of operation.

Verifying each auxiliary feedwater manual, power operated, and automatic valve in each water flow path and in each required steam supply flow path to the steam turbine driven auxiliary feedwater pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

b. At least once per 92 days on a STAGGERED TEST BASIS, tested pursuant to Specification 4.0.5, by:

1) Verifying that on recirculation flow each motor-driven pump develops a total head of greater than or equal to 3385 feet;.

2) Verifying that on recirculation flow the steam turbine-driven pump deveIops a total head of greater than or equal to 3780 feet when the secondary steam supply pressure is greater than 800 psig. The provisions of Specification 4.0.4 are not applicable for entry into MODE 3.

MILLSTONE - UNIT 3 314 7-5 Amendment No. 96, W ,427,W, a,

Serial No. 05-699C Docket No. 50-423 ATTACHMENT 4 AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME REVISED MARKED UP BASES PAGE JINFORMATIONONLY)

DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3

June 3,2002 AUXILImFEEDWAvR SYSTEM (Continued)

In addition, given the worst case failure, the AFW is designed to supply sufficient makeup water to replace SG inventory loss as the RCS is cooled to less than 350°F at which point the Residual Heat Removal System may be placed into operation.

Su~eillanceRequirement 4.7.1.2.1 verifies that each AFW pump's total head at a recirculation flow test point is greater than or equal to the required total head. This surveilIance ensures that the AFW purnp performance has not degraded during the operating cycle. Because it is undesirable to introduce cold AFW into the steam generators while they are operating, this testing is performed with recirculation ff ow. This test confirms one point on the pump curve and is indicative of o v e d l performance. This test confirms component OPERABILITY is used to trend pdormance and to detect incipient failures by indicating abnormal performance. The total head specified in Surveillance Requirement 4.7.1.2.1 does not include a margin for test measurement uncertainty. This consideration shall be addressed at the implementing procedure level.

Motor driven auxiliary feedwater pumps and associated flow paths are OPERABLE in the following alignment during normal operation below 10% RATED THERMAL POWER.

Motor operated isolation vaIves (3FWA*MOV35A/B/C/D) are open in MODE 1,2 and 3,

- Control valves (3FWA*HV31A/B/C/D) may be throttled or closed during alignment, operation and restoration of the associated motor driven AFW pump for steam generator inventory control.

The motor operated isolation valves must remain fully open due to single failure criteria (the valves and associated pump are powered from the opposite electrical trains),

The Turbine Driven Auxiliary Feedwater (TDAFW) pump and akociated flow paths are OPERABLE with a11 control and isolation valves fully open in MODE 1,2 and 3. Due to High TDAFW purnp cannot be used for steam generator inventory below 10% RATED THERMAL POWER.

ZED WATER STORAGETANK The OPERABILITY of the demineralized water storage tank (DWST)with a 334,000 gallon minimum measured water volume ensures that sufficient water is available to maintain the reactor coolant system at HOT STANDBY conditions for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with steam discharge to the atmosphere, concurrent with a total loss-of-offsite power, and with an additional 6-hourcooldown period to reduce reactor coolant temperature to 350°F. The 334,000 gallon required water volume contains an allowance for tank inventory not usable because of tank discharge line location, other tank physical characteristics, and surveillance measurement uncertainty considerations. The inventory requirement is conservatively bssed on 120°F water temperature which maximizes inventory required to remove RCS decay heat. In the event of a feedline break, this inventory requirement includes an allowance for 30 minutes of spillage before operator action is credited to isolate flow to the line break.

MILLSTONE UNIT 3- B 314 7-2a Amendment No. 442,439, M, "Revised by NRC Letter A1 57 10"

Serial No. 05-699C Docket No. 50-423 Attachment 4 Insert Pages Page 1 of 3 Revised Insert F Millstone Power Station Unit 3 Technical Specifications Page B 314 7-2a At MPS 3, only two of the three available steam supplies are required to establish an OPERABLE steam supply system. With one of the two required steam supplies inoperable, normally the third steam supply will be used to satisfy the requirement for two OPERABLE steam supplies. If the third steam supply is also inoperable (i.e., only one steam supply to the turbine-driven auxiliary feedwater pump is OPERABLE), then ACTION a. is entered.

If the turbine-driven auxiliary feedwater pump is inoperable due to one required steam supply being inoperable in MODES 1, 2, and 3, or if a turbine-driven auxiliary feedwater pump is inoperable while in MODE 3 immediately following REFUELING, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day allowed outage time is reasonable, based on the following reasons:

a. For the inoperability of the turbine-driven auxiliary feedwater pump due to one required steam supply to the turbine-driven auxiliary feedwater pump being inoperable (i.e., only one steam supply to the turbine-driven auxiliary feedwater pump is operable), the 7 day allowed outage time is reasonable since the auxiliary feedwater system design affords adequate redundancy for the steam supply line for the turbine-driven pump.

b. For the inoperability of a turbine-driven auxiliary feedwater pump while in MODE 3 immediately subsequent to a refueling, the 7 day allowed outage time is reasonable due to the minimal decay heat levels in this situation.

c. For both the inoperability of the turbine-driven auxiliary feedwater pump due to one required steam supply to the turbine-driven auxiliary feedwater pump being inoperable (i.e., only one steam supply to the turbine-driven auxiliary feedwater pump is operable), and an inoperable turbine-driven auxiliary feedwater pump while in MODE 3 immediately following a refueling outage, the 7 day allowed outage time is reasonable due to the availability of redundant OPERABLE motor driven auxiliary feedwater pumps, and due to the low probability of an event requiring the use of the turbine-driven auxiliary feedwater pump.

Serial No. 05-699C Docket No. 50-423 Attachment 4 Insert Pages Page 2 of 3 The required ACTION dictates that if either the 7 day allowed outage time is reached the unit must be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The allowed time is reasonable, based on operating experience, to reach the required conditions from full power conditions in an orderly manner and without challenging plant systems.

A Note limits the applicability of the inoperable equipment condition b. to when the unit has not entered MODE 2 following a REFUELING. Required ACTION b. allows one auxiliary feedwater pump to be inoperable for 7 days vice the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time in required ACTION c. This longer allowed outage time is based on the reduced decay heat following REFUELING and prior to the reactor being critical.

With one of the auxiliary feedwater pumps inoperable in MODE 1, 2, or 3 for reasons other than ACTION a. or b., ACTION must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This includes the loss of three steam supply lines to the turbine-driven auxiliary feedwater pump. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time is reasonable, based on redundant capabilities afforded by the auxiliary feedwater system, time needed for repairs, and the low probability of a DBA occurring during this time period.

Two auxiliary feedwater pumps and flow paths remain to supply feedwater to the steam generators.

If all three AFW pumps are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with non safety related equipment.

In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW pump to OPERABLE status. Required ACTION e. is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW pump is restored to OPERABLE status. In this case, LC0 3.0.3 is not applicable because it could force the unit into a less safe condition.

SR 4.7.1.2.1 a. verifies the correct alignment for manual, power operated, and automatic valves in the auxiliary feedwater water and steam supply flow paths to provide assurance that the proper flow paths exist for auxiliary feedwater operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulations; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position. The 31 day frequency is

Serial No. 05-699C Docket No. 50-423 Attachment 4 Insert Pages Page 3 of 3 based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.

The SR is modified by a Note that states one or more auxiliary feedwater pumps may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually (i.e., remotely or locally, as appropriate) realigned to the auxiliary feedwater mode of operation, provided it is not otherwise inoperable. This exception to pump OPERABILITY allows the pump(s) and associated valves to be out of their normal standby alignment and temporarily incapable of automatic initiation without declaring the pump(s) inoperable. Since auxiliary feedwater may be used during STARTUP, SHUTDOWN, HOT STANDBY operations, and HOT SHUTDOWN operations for steam generator level control, and these manual operations are an accepted function of the auxiliary feedwater system, OPERABILITY (i.e., the intended safety function) continues to be maintained.