Text

Application for Technical Specification Change TSTF-491, Removal of the Main Steam (TS 3.7.2) and Main Feedwater (TS 3.7.3) Valve Isolation Times from Technical Specifications, Using the Consolidated Line Item Improvement Process
	ML072760125
Person / Time
Site:	Catawba
Issue date:	09/27/2007
From:	Morris J; Duke Energy Carolinas, Duke Power Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TSTF-491
	Download: ML072760125 (55)
	v • d • e

Duke Energy JAMES R. MORRIS Vice President Catawba Nuclear Station 4800 Concord Rd. / CNO1 VP York, SC 29745-9635 803 831 4251 803 831 3221 fax September 27, 2007 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C. 20555-0001

Subject:

Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Duke) Catawba Nuclear Station, Units 1 and 2 Docket Nos.

50-413, 50-414 Application for Technical Specification Change TSTF -

491, Removal of the Main Steam (Technical Specification 3.7.2) and Main Feedwater (Technical Specification 3.7.3) Valve Isolation Times from Technical Specifications, Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR50.90 Duke Energy (Duke) is submitting a request for an amendment to the Facility Operating License and Technical Specifications (TS) for Catawba Nuclear Station Units 1 and 2.

The proposed amendment would modify TS 3.7.2 (Main Steam Isolation Valves) and TS 3.7.3 (Main Feedwater Isolation Valves, Main Feedwater Control Valves, Associated Bypass Valves and Tempering Valves) by removing the specific isolation time for the isolation valves from the associated Surveillance Requirements (SRs).

The specific isolation times are currently provided in the TS Bases. provides a description of the proposed change, the requested confirmation of applicability, and plant specific verifications. provides the existing TS pages marked up to show the proposed change. provides the existing TS Bases pages marked up to show the proposed change (for information only).

Duke is requesting NRC review and approval of this license amendment by March 31, 2008, with the amendment being implemented within 60 days.

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www. duke-energy. corn

U.S. Nuclear Regulatory Commission Page 2 September 27, 2007 In accordance with Duke administrative procedures and the Quality Assurance Program Topical Report, the proposed amendment has been previously reviewed and approved by the Plant Operations Review Committee and the Duke Nuclear Safety Review Board.

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

If you should have any questions regarding this submittal, please contact Allison Jones-Young at (803) 831-3051.

Sincerely, Morris ENCLOSURES:

1. Description and Assessment

2. Proposed Technical Specification Changes

3. Marked up Existing TS Bases Changes

U.S. Nuclear Regulatory Commission Page 4 September 27, 2007 James R. Morris affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

Jajs R. Morris, Vice President Subscribed and sworn to me:

9/z /07 Date Notary P ic My commission expires:

7 Date

U.S. Nuclear Regulatory Commission Page 3 September 27, 2007 xc (with attachment):

W.D. Travers U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St.,

SW, Suite 23T85 Atlanta, GA 30303 A.

T.

Sabisch Senior Resident Inspector U.S. Nuclear Regulatory Commission Catawba Nuclear Station J.F. Stang NRC Project Manager (CNS)

U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 8 H4A 11555 Rockville Pike Rockville, MD 20852-2738 H.J. Porter, Director.

Division of Radioactive Waste Management Department of Health and Environmental Control 2600 Bull St.

Columbia, SC 29201

U.S. Nuclear Regulatory Commission Page 5 September 27, 2007 bxc (with attachment)

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Vaughn L. Ashe L. Gill D. Hart (MG01RC)

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(ON03RC)

(CN01RC)

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Davenport Jones-Young Nicholson NCMPA-1 NCEMC PMPA SREC RGC File Catawba Master File 801.01 (CN04DM)

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ENCLOSURE 1

DESCRIPTION and ASSESSMENT

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TS) 3.7.2 (Main Steam Isolation Valves ) and TS 3.7.3 (Main Feedwater Isolation Valves, Main Feedwater Control Valves, Associated Bypass Valves and Tempering Valves) by removing the specific isolation time for the isolation valves from the associated Surveillance Requirements (SR).

Currently, the Main Steam Isolation Valve and Main Feedwater Isolation

Valves, Main Feedwater Control Valves, Associated Bypass Valves and Tempering Valves specific isolation times are provided in the TS Bases.

The TS Bases are subject to control by thel0 CFR50.59 process.

The 10 CFR 50.59 criteria provide adequate assurance that prior NRC review and approval will be requested for changes to the Bases requirements that have the potential to affect the safe operation of the plant.

The changes to TS are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) TSTF-491, Revision 2.

The availability of this TS improvement was published in the Federal Register on December 29, 2006 as part of the Consolidated Line Item Improvement process (CLIIP).

2.0 ASSESSMENT

2.1 Applicability of TSTF-491, and Published Safety Evaluation Duke has reviewed TSTF-491(Reference 1), and the NRC model safety evaluation (SE)

(Reference 2) as part of the CLIIP.

Duke has concluded that the information in TSTF-491, as well as the SE prepared by the NRC staff are applicable to Catawba Nuclear Station Units 1 and 2 and justify this amendment for the incorporation of the changes to the Catawba Nuclear Station TS.

2.2 Optional Changes and Variations Duke is not proposing any variations or deviations from the TS changes described in TSTF-491 or the NRC staff's model safety evaluation dated June 16, 2006.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination Duke has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal register as part of the CLIIP.

Duke has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to Catawba Nuclear Station and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments As discussed in the notice of availability published in the Federal register on December 29, 2006 for this TS improvement, plant specific verifications were performed as follows:

The proposed change revises TS 3.7.2 and TS 3.7.3 surveillance requirements to remove specific valve isolation times from the associated surveillances.

The specific valve isolation times are replaced with the requirements to verify the valve isolation is within limits.

The specific valve isolation time required to meet the surveillances is relocated outside of the TS into a document that is subject to control by the 10 CFR 50.59 process.

For the Main Steam Isolation Valves, Main Feedwater Isolation Valves, Main Feedwater Control Valves, Associated Bypass Valves and Tempering Valves the specific isolation time is already provided in the TS Bases.

The proposed change does not alter TS requirements for the Main Steam and Main Feedwater System isolation valves to be operable nor does it change the TS requirement for the valve to isolate within the required time.

As such, the proposed change is acceptable because it does not affect the assumptions of any accident analysis or TS compliance with the requirements of 10 CFR 50.36 (c)

(2) (ii)

The proposed change simply adjusts the level of detail contained in TS 3.7.2 and 3.7.3 to be more consistent with the requirements of other ESF equipment required operable in the TS.

Duke has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications (STS).

4.0 Environmental Evaluation The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.

The NRC staff has determined that the amendment adopting TSTF-491, Rev.

2, involves no significant increase in the amounts and no significant changes in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that TSTF-491, Rev.

2, involves no significant hazards considerations, and there has been no public comment on the finding in Federal Register Notice 71 FR 193, October 5,

2006.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c) (9).

Pursuant to 10 CFR 51.22 (b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 REFERENCES

1. TSTF-491, Revision 2, "Removal of Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications."

2.

NRC Model Safety Evaluation Report

ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

MSIVs 3.7.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

Required Action and D.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 C not AND met.

D.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1

NOTE Only required to be performed prior to entry into MODE 2.

Verify closure time of each MSIV is e

G on an In accordance with actual or simulated actuation signal.

the Inservice Testing Program

,,;n 1, '4-s Catawba Units 1 and 2 3.7.2-2 Amendment Nos. >401

MFIVs, MFCVs, Associated Bypass Valves and Tempering Valves 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

One or more MFIV or C.1 Close or isolate bypass 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months MFCV bypass valves valve.

inoperable.

AND C.2 Verify bypass valve is Once per closed or isolated.

7 days D.

Two valves in the same D. 1 Isolate affected flow path.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months flow path or the tempering valve inoperable.

E.

Required Action and E.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS

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( '43 SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the closure time of each MFIV, MFCV, their In accordance with associated bypass valve, and the tempering valve is the Inservice 12--seGGod*on an actual or simulated actuation signal.

Testing Program Catawba Units 1 and 2 3.7.3-2 Amendment Nos. ;1/615

ENCLOSURE 3 PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES PAGES (For Information Only)

MSIVs B 3.7.2 BASES ACTIONS (continued) reasonable, based on operating experience, to reach MODE 2 and to close the MSIVs in an orderly manner and without challenging unit systems.

C.1 and C.2 Condition C is modified by a Note indicating that separate Condition entry is allowed for each MSIV.

Since the MSIVs are required to be OPERABLE in MODES 2 and 3, the inoperable MSIVs may either be restored to OPERABLE status or closed.

When closed, the MSIVs are already in the position required by the assumptions in the safety analysis.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is consistent with that allowed in Condition A.

For inoperable MSIVs that cannot be restored to OPERABLE status within the specified Completion Time, but are closed, the inoperable MSIVs must be verified on a periodic basis to be closed. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of MSIV status indications available in the control room, and other administrative controls, to ensure that these valves are in the closed position.

D.1 and D.2 If the MSIVs cannot be restored to OPERABLE status or are not closed 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 at least in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 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 unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.2.1

.cs REQUIREMENTS i

This SR verifies tha lo-urc tim is

_ 8.0 seconds on an actual or simulated actuation signal. The MSIV closure time is assumed in the accident and containment analyses This is normally Catawba Units 1 and 2B-37-.2 RvsoN.W

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MFIVs, MFCVs, Associated Bypass Valves and Tempering Valves B 3.7.3 BASES ACTIONS (continued) judgment, in view of valve status indications available in the control room, and other administrative controls, to ensure that these valves are closed or isolated.

D.. 1 With the tempering valve inoperable or two inoperable valves in the same flow path, there may be no redundant system to operate automatically and perform the required safety function. The tempering valves have no other automatic isolation valves in series to provide isolation. Under these conditions, affected valves in each flow path must be restored to OPERABLE status, or the affected flow path isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This action returns the system to the condition where at least one valve in each flow path is performing the required safety function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, based on operating experience, to complete the actions required to close the MFIV or MFCV, or otherwise isolate the affected flow path.

E.1 and E.2 If the MFIV(s), MFCV(s), and the associated bypass valve(s) or the tempering valve(s) cannot be restored to OPERABLE status, or closed, or isolated 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 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 unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that the closure time of each MFIV, MFCV, and associated bypass valves, and the tempering valve is _< 12 seconds on an actual or simulated actuation signal. The MFIV and MFCV closure times are assumed in the accident and containment analyses.

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eis normally performed upon returning the unit to operation following a refueling outage. These valves should not be tested at power art, stroke exer-cise-inueases.the risk of a aLva.e_

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-B3.7.3-5 Revisior Catawba Units 1 a nNo.,,0

WOG-182, Rcv. 0 TSTF-491, Rev. 2 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler m.p

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n..........p c _i c tio n s..C _~ _n _~_T a l Removal of Main Steam and Main Feedwater Valve Isolation Times From Technical Specifications NUREGs Affected:

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!.1 1431 v'I 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement:

Improvement NRC Fee Status:

Not Exempt Benefit:

Avoids Future Amendments Industry

Contact:

Wes Sparkman, (205) 992-5061, wasparkm@southemco.com

1.0 DESCRIPTION

The proposed change revises the Improved Standard Technical Specification (ISTS) requirements in ISTS 3.7.2, "Main Steam Isolation Valves (MSIVs)" and NUREG-1430 ISTS 3.7.3, "[Main Feedwater Stop Valves (MFSVs), Main Feedwater Control Valves (MFCVs), and Associated Startup Feedwater Control Valves (SFCVs)],"

NUREG-1431, ISTS 3.7.3, "Main Feedwater isolation Valves (MFIVs), Main Feedwater Regulation Valves (MFRVs), and [associated bypass valves]," and NUREG-1432, ISTS 3.7.3, "Main Feedwater Isolation Valves (MFIVs) [and [MF1V] Bypass Valves]."

These valves arc herein referred to generically as the Main Steam and Main Feedwater isolation valves.

The proposed change removes the specific isolation time for the isolation valves from the associated ISTS Surveillance Requirements (SRs). The bracketed isolation time in the ISTS SRs is replaced with the requirement to verify the valve isolation time is within limits. The specific valve isolation time required to meet the ISTS surveillances would be located outside of the technical specifications in a document subject to control by the 10 CFR 50.59 process.

In accordance with the ISTS definition of Engineered Safety Feature (ESF) Response Time, the affected valve isolation times are part of the ESF Response Time. The ISTS does not specify the specific ESF Response Time acceptance criteria in the technical specifications or Bases. The ISTS only requires the ESF response time to be verified within the limit. The proposed change would make the requirements pertaining to ESF Response Times consistent within the ISTS.

Similar to the current allowance for the ESF and Reactor Trip System (RTS) Response Times to be located outside the technical specifications, the proposed change will allow the affected valve isolation times to be revised in accordance with 10 CFR 50.59 instead of a license amendment request.

18-May-06 Triaveler Rev. 3. Copyrighit (C) 2006. FXC-IU., Services Corporation. Use by EXCEL Scevices associates, ulility clients. and the U.S. Nuclear Reguhlaory Coimn ission is grilled. All oihlei use withoul written permission is prohibited.

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WOG-182, Rev. 0 TSTF-491, Rev. 2

2.0 PROPOSED CHANGE

ISTS SR 3.7.2.1 currently states "Verify the isolation time of each MSIV is < [4.6] seconds." The proposed change would revise SR 3.7.2.1 to state "Verify the isolation time of each MSIV is within limits."

ISTS SR 3.7.3.1 states "Verify the isolation time of each [NUREG-specifie Main Fcedwater isolation valve title] is < [7] seconds. The proposed change would revise SR 3.7.3.1 to state "Verify the isolation time of each

[NUREG-specific Main Feedwater isolation valve title] is within limits."

The proposed changes would make the affected surveillances more consistent with the ESF Response Time requirement in SR 3.3.2.10 which states "Verify ESFAS RESPONSE TIMES arc within limit."

In summary, the proposed change would remove the plant specific details of valve operability (i.e., the isolation time) but continues to require the affected valves be verified operable including being capable of isolating within the required time. Similar to the Engineered Safety Feature and Reactor Trip System Response Time acceptance criteria, the required valve isolation times would be located outside the technical specifications in a document subject to control by the 10 CFR 50.59 process.

The Bases are also revised to reflect this change and include a reference to the licensee-controlled document that contains the isolation time limits.

r 18-May-06 Traveler Rev. 3. Copyright (C) 2006, EXCF, L Srcvices C votloution. Use by EXCEL Services associates, utility clients. and the U.S. Nuclear Regulatory Commission is girtttctd. All olthcr usc wilhout v'iitet peirmission is prohibited.

WOG-182, Rev. 0 rSTF-491, Rev. 2

3.0 BACKGROUND

MSIVs TThe MSIVs isolate steam flow from the secondary side of the steam generators following a high energy line break (HELB). MSIV closure terminates flow from the unaffected (intact) steam generators. One MSIV is located in cach main steam line outside of, but close to, containment. The MSIVs are downstream from the main steam safety valves (MSSVs) and auxiliary feedwater (AFW) (B&W plants - Emergency Feedwater) pump turbine steam supply, to prevent MSSV and AFW isolation from the steam generators by M.SIV closure.

Closing the MSIVs isolates each steam generator from the others, and isolates the turbine, Steam Bypass System, and other auxiliary steam supplies from thesteam generators. The MSIVs close on a main steam isolation signal typically generated by either low steam generator pressure or high containment pressure. The MSIVs are typically designed to fail closed on loss of control or actuation power. The design basis of the MSIVs is typically established by the containment analysis for steam line break (SLB) inside containment, and the accident analyses associated with SLB events outside containment.

The Standard Review Plan, Chapter 10.3, "Main Steam Supply System," contains additional information describing the functional requirements of the Main Steam System and MSIVs.

Main Feedwater Isolation Valves The MFIVs isolate main feedwater (MFW) flow to the secondary side of the steam generators following a high energy line break (HELB). The safety related function of the MFRVs is to provide the second isolation of MFW flow-to the secondary side of the steam generators following an HELB. Closure of the MFIVs terminates flow to the steam generators, terminating the event for feedwater line breaks (FWLBs) occurring upstream of the MFIVs. The consequences of events occurring in the main steam lines or in the MFW lines downstream from the MFIVs will be mitigated by their closure. Closure of the MFIVs effectively terminates the additionof feedwater to an affected steam generator, limiting the mass and energy release for steam line breaks (SLBs) or FWLBs inside containment, and reducing the cooldown effects for SLBs. The MFW isolation signal is typically generated by a Safety Injection Signal or on high steam generator water'level. The design basis of the MFIVs is typically established by the analyses for the large SLB and/or the large FWLB.

The Standard Review Plan, Chapter 10.4.7, "Condensate and Feedwater System," contains-additional information describing the functional requirements of the Main Feedwater System.

Description of Change The proposed change involves the ESF Functions of Main Steam and Main Feedwater Isolation described above. The affected valve isolation times are important to the Main Steam and Main Feedwater Isolation Functions because they are part of the associated overall ESF Response Time assumed in the safety analyses.

However, the safety analysis does not address the individual components of the overall ESF Response Time.

This concept was described in the NRC Safety Evaluation Report (SER) for Beaver Valley Power Station (BVPS) Unit 2 Amendment # 137 issued 6/25/03 (Ref. 1). In this Amendment, BVPS revised the MSIV full closure time specified in the technical specification surveillance. The BVPS proposed change to the MSIV closure time did not result in a change to the overall ESF Response Time assumed in the safety analyses for Main Steam Isolation but was necessary because the valve closure portion of the ESF Response Time was specified in the technical specifications. In the associated SER for this amendment, the NRC concluded the change was acceptable, in part, because "The current safety analyses which credit steam line isolation will remain unaffected since the analyses only address the overall delay time which combines both the signal generation and the MSIV closure time, and does not individually address signal generation nor valve stroke time."

18-May-06 Traveler Rev. 3. Copyright (C) 2006. EXCEL Servimcs Corporaliorn. Use by EXCIL Services associates, utility clients, and ilic U.S. Nuclear Regulatory Commission is granted. All other use without written permutission is prohibitcd.

WOG-182, Rev. 0 TSTF-491, Re6. 2 The ISTS, similar to the BVPS technical specifications, allows the ESF Response Time for the Main Steam and Main Fcedwatcr Isolation Functions to be controlled outside of the Technical Specifications but requires tile associated valve isolation times (part of the ESF Response Time) to be retained within the technical specifications. It should be noted that the ESF response time, by the ISTS definition, includes the time it takes the ESF equipment to perform its safety finction. The ISTS definition of ESF Response time states in part:

riThe ESF RESPONSE TIME shall be that tirne interval from when the monitored parameter exceeds its actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.)."

The requirement for the valve isolation portion of the ESF Response Time for the Main Steam and Main Feedwater Isolation Functions to be in the technical specifications appears to be unique. The specific values for the ESF pump and valve operation times associated with other ESF Function Response Times are not included in the technical specifications. Allowing the ESF Response Times to be controlled outside of the technical specifications, under 10 CFR 50.59 control eliminates the need for license amendment requests for minor changes that do not meet the threshold for a license amendment under the provisions of 10 CFR 50.59.

However, the retention of the valve isolation times (which are part of the ESF Response Times) within the ISTS introduces an unnecessary inconsistency regarding the treatment of Response Time. This inconsistency results in license amendment requests (see Ref. 1) that may not have been required if the Response Time for the affected ESF Functions was controlled outside of the technical specifications.

The proposed change, by allowing the valve isolation portion of the Main Steam and Main Feedwater ESF Function Response Times to be controlled outside the technical specifications (in the same manner as all other ESF Response Times) would resolve the inconsistency described above and allow all of the ESF Function Response Times to be treated the same.

10 CFR 50.36(c)(2)(ii) requires that an LCO be established for each item meeting one of the criteria listed within the regulation. The ISTS contains LCOs for both the Main Steam Isolation Valves and the Feedwater System isolation valves. The proposed change does not eliminate the LCOs for these valves. The ISTS LCOs for these valves require the valves to be operable and contain surveillances to confirm the valves are maintained operable. However, 10 CFR 50.36(c)(2)(ii) does not specify the particular requirements or level of detail to be included in the required LCOs. The proposed change removes the detail (i.e., specific valve isolation time) from the surveillances. An example of the NRC's previous approval of the removal of detail from the technical specifications is the NRC SER associated with the BVPS License Amendment numbers 210 (Unit I) and 88 (Unit 2) issued by NRC letter dated 1/20/98 (Ref 2). The BVPS Amendments implemented Generic Letter (GL) 93-08, "Relocation of Technical Specification Tables of Instrument Response Time Limits" (Ref. 3), which allowed the relocation of specific Response Time values from the technical specifications. In the NRC SER associated with the BVPS Amendments, the NRC addressed the technical specification criteria of 10 CFR 50.36. The NRC stated that "The regulation, however, does not specify the particular requirements to be included in the plant TSs." The SER approved the relocation of the specific Response Time values from the technical specifications based on the remaining LCO and surveillance requirements being considered adequate to meet the intent of 10 CFR 50.36(c)(2)(ii). Similar to GL 93-08, an earlier GL, 91-08, "Removal of Component Lists From Technical Specifications," (Ref. 4) allowed the removal of the list of containment Isolation Valves and the associated Isolation time for each valve from the technical specifications. Regarding the removal of the valve isolation times from the technical specifications, GL 91-08 on page 4 of Enclosure I stated: "The removal of valve closure times that are included in some plant TS would not alter the TS requirements to verify that valve stroke times are within their limits.

Therefore, removal of these closure times is acceptable." This concept is retained in the ISTS Section 3.6 (Containment) which does not contain the containment isolation valve times and by ISTS SR 3.6.3.5 which states: "Verify the isolation time of each automatic power operated containment isolation valve is within limits." The Bases for SR 3.6.3.5 states that; "The isolation time test ensures the valve will isolate in a time period less than or equal to that assumed in the safety analyses."

The proposed change is consistent with the intent and implementation of the GLs discussed above and with the legal requirements of 10 CFR 50.36. The proposed change adjusts the level of detail in the technical 18-May-06 Traveler Rev. 3. Copyright (C) 2006(, LXCEt. Services Corporation. Use by EXCEL Scrvices associates. utility clients, and the U.S. Nuclear Regolatory Commission is granted. All other use without wrillen permission is prohibited.

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WOG-182, Rev. 0 TSTF-491, Rev. 2 specifications but retains the essential requirements that ensure the operability of the affected components consistent with the rest of the ISTS (e.g., in a manner similar to ISTS SR 3.6.3.5 discussed above). Thus, the proposed change improves the internal consistency of the ISTS. The removal of system and component operability details from the technical specifications is not a new concept for the ISTS. The majority of ISTS LCOs simply require the system or component to be operable and the surveillances to verify the component or variable is within limits. The detailed requirements for system or component operability are typically described and controlled outside of the technical specifications.

In addition to the ISTS 3.7.2 and 3.7.3 surveillances to verify operability, it should be noted that the Main Steam and Main Feedwater Isolation valves are subject to periodic testing in accordance with the Inservice Testing (IST) Program. Compliance with the IST Program is required 10 CFR 50.55a and by the ISTS in Section 5.5.8. Failure to meet the applicable ASME valve operability requirements would also result in the affected valves being declared inoperable. As such, the ISTS provides multiple requirements to assure the Main Steam and Main Feedwater isolation valves are maintained operable.

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WOG-182, Rev. 0 TSTF-491, Rev. 2

4.0 TECHNICAL ANALYSIS

The proposed change revises the Improved Standard Technical Specification (ISTS) requirements in ISTS 3.7.2, Main Steam Isolation Valves (MSIVs) and ISTS 3.7.3, Main Feedwater Isolation Valves (MFIVs). The proposed change removes the specific valve isolation time from the associated ISTS Surveillance Requirements (SRs). The bracketed isolation time in the ISTS SRs is replaced with the requirement to verify the valve isolation time is within limits. The specific valve isolation time required to meet the ISTS surveillances would be located outside of the technical specifications in a document subject to control by the 10 CFR 50.59 process.

The affected valve isolation times are important to the safety analyses because they are part of the associated overall ESF Response Time assumed in the safety analyses. However, the individual component actuation times that make up the total ESF Response Time are not modeled in the associated safety analysis. Only the overall or total Response Time is considered in the safety analysis. The NRC has already determined (per Generic Letter 93-08) that the ESF Response Times (which include, by technical specification definition, the associated equipment actuation times) do not need to be in the technical specifications. As such, the removal of the Main Steam and Main Feedwater valve isolation time from the technical specifications is acceptable because this level of detail is not necessary to be included in the technical specifications to provide adequate protection of public health and safety. Similar to how the ESF Response Times are treated, the ISTS continues to retain LCO requirements for the affected valves to be operable and associated SRs to verify the valve isolation times are within limit. Therefore, after the removal of the affected valve isolation times, the ISTS will continue to be in compliance with the technical specification requirements of 10 CFR 50.36(c)(2)(ii). In addition, the ISTS provides further assurance the affected Main Steam and Main Feedwater isolation valves are maintained operable, beyond the specific LCO and SR requirements associated with these valves. ISTS 3.3.2 contains operability requirements for the ESF instrumentation that include surveillances which require the verification of the ESF Response Time (which also includes the affected valve isolation times).

Additionally, the affected Main Steam and Main Feedwater valves are subject to periodic testing in accordance with the Inservice Testing (IST) Program. Compliance with the IST Program is required by the ISTS in Specification 5.5.8. Therefore, the retained ISTS requirements continue to provide adequate assurance the affected valves arc maintained operable and that the plant will be operated in a safe manner within the bounds of the applicable safety analysis.

The proposed change includes the relocation of the specific valve isolation times to a document outside of the technical specifications that is subject to control by 10 CFR 50.59. This portion of the proposed change will allow the affected valve isolation times to be treated in the same manner as other ESF equipment actuation times and the ESF Response Times. The placement of the valve isolation times in a document subject to control by 10 CFR 50.59 is acceptable because it will assure changes to the valve isolation times will be evaluated and prior NRC review and approval will be obtained when required by 10 CFR 50.59. Thus, the affected Main Steam and Main Feedwater valve isolation times will be subject to the same level of control as currently applicable to all the ESF Response Times.

In summary, the proposed change does not alter the ISTS requirement for the affected Main Steam and Main Feedwater isolation valves to be operable nor does it change the ISTS requirement for the valves to isolate within the required time. As such, the proposed change is acceptable because it does not affect the assumptions of any safety analyses or the ISTS compliance with the requirements of 10 CFR 50.36(c)(2)(ii).

The proposed change simply adjusts the level of detail contained in ISTS 3.7.2 and 3.7.3 to be more consistent with the requirements of other ESF equipment required operable in the ISTS. The relocation of the specific valve isolation times to a document subject to control by 10 CFR 50.59 results in the same level of control being applied to these isolation times as is currently applicable to the equally important Reactor Trip System and ESF Response Times as well as the specific operability requirements for other ESF equipment (e.g., Safety Injection pumps and valves) required to be operable by the ISTS. Therefore, the proposed change also improves the consistency of the ISTS with regard to the treatment of specific equipment operability requirements and ESF Response Times.

18-May-06 Traveler Rcv. 3. Copyright (C) 2006, EXCIF.. Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is gratilcd. All other use without written permission is prohibited.

WOG-182, Rev. 0 TSTF-491, Rcv. 2

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change revises Improved Standard Technical Specification (ISTS) 3.7.2, Main Steam Isolation Valves (MSIVs) and ISTS 3.7.3, titled in NUREG-1430 "[Main Feedwater Stop Valves (MFSVs), Main Feedwater Control Valves (MFCVs), and Associated Startup Feedwater Control Valves (SFCVs)]," in NUREG-1431 "Main Feedwater Isolation Valves (MFIVs), Main Feedwater Regulation Valves (MFRVs), and [associated bypass valves]," and in NUREG-1432 "Main Feedwater Isolation Valves (MFIVs) [and [MFIV] Bypass Valves]." The piroposed change removes the specific valve isolation time for the Main Steam and Main Feedwater isolation valves from the associated ISTS Surveillance Requirements (SRs). The specific isolation time in the ISTS SRs is replaced with the requirement to verify the valve isolation time is within limits.

The Main Steam and Main Feedwater Isolation valves are not an initiator of any accident previously evaluated. As a result, the probability of an accident is not affected. The Main Steam and Main Feedwater isolation valves are assumed to function to mitigate some accidents.. The proposed change only affects the level of detail included in the ISTS. The technical specification requirements continue to provide the same level of assurance as before that the specified equipment is capable of performing its intended safety function. The affected equipment will continued to be verified operable in the same manner as before. As such, the proposed change does not affect the ability of the isolaiton valves to perform their assumed mitigation function. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change revises ISTS 3.7.2 and ISTS 3.7.3, to remove the specific valve isolation time for the Main Steam and Main Feedwater isolation valves from the associated ISTS Surveillance Requirements (SRs). The specific isolation time in the ISTS SRs is replaced with the requirement to verify the valve isolation time is within limits.

The proposed change only affects the level of detail included in the ISTS. The technical specification requirements continue to provide the same level of assurance as before that the specified equipment is capable of performing its intended safety function. The affected equipment will continued to be verified operable in the same manner. As such, the proposed change does not involve a modification to the physical configuration of the plant (i.e., no new equipment will be installed) or change in the methods governing normal plant operation. The proposed change will not impose any new or different requirements or introduce a new accident initiator, accident precursor, or malfunction mechanism.

Additionally, there is no change in the types or increases in the amounts of any effluent that may be released off-site and there is no increase in individual or cumulative occupational exposure.

Therefore, the proposed change does not create the possibility of a new or different kind of accident 18-May-06 "rnLVclCI Ryv. 3. Copyright (C) 2006, tEXCELI. services Corporation. Use by EXCEL Services associates, uLility clients. and ihe U.S. Nuclear Regulatory Commission is g'ramcd. All othcr use without written permission is prohibited.

WOG-182, Rcv. 0 TSTF-491, Rev. 2 from any accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change revises ISTS 3.7.2 and ISTS 3.7.3, to remove the specific valve isolation time for the Main Steam and Main Feedwater isolation valves from the associated ISTS Surveillance Requirements (SRs). The specific isolation time in the ISTS SRs is replaced with the requirement to verify the valve isolation time is within limits.

The proposed change only affects the level of detail included in the ISTS. The technical specification requirements continue to provide the same level of assurance as before that the specified equipment is capable of performing its intended safety function. The affected equipment will continued to be verified operable in the same manner as before. As such, the proposed change does not affect the assumptions of any safety analysis or the availability or operability of any plant equipment. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, the TSTF concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria The proposed change affects the content of the Improved Standard Technical Specifications (ISTS). 10 CFR 50.36 is the regulation that provides requirements regarding the content of technical specifications.

Specifically, 10 CFR 50.36(c)(2)(ii) states that: "A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:...." The proposed change affects ISTS 3.7.2 for the Main Steam Isolation Valves (MSIVs) and ISTS 3.7.3 for the Main Fecdwater Isolation Valves (MFIVs). These valves have been determined to meet the criteria referred to by 10 CFR 50.36(c)(2)(ii) and consistent with the requirements of 10 CFR 50.36(c)(2)(ii), a limiting condition for operation or LCO has been established for these valves. The proposed change only affects the level of detail included in the ISTS LCO and the level of regulatory control applicable to the details removed from the ISTS. The proposed change makes the level of detail in ISTS 3.7.2 and ISTS 3.7.3 more consistent with other similar ISTS LCOs. The established LCOs remain intact and continue to require the affected valves to be operable in accordance with 10 CFR 50.36(c)(2)(ii). The proposed change does not alter the operability requirements for the affected valves and the valves will continued to be verified operable in the same manner as before. Therefore, the ISTS requirements continue to provide adequate assurance the affected valves are maintained operable and that the plant will be operated in a safe manner within the bounds of the applicable safety analysis.

The proposed change includes the relocation of the specific valve isolation times to a document outside of the technical specifications that is subject to control by 10 CFR 50.59. The placement of the valve isolation times in a document subject to control by 10 CFR 50.59 is acceptable because it will assure changes to the valve isolation times will be evaluated and prior NRC review and approval obtained when required by 10 CFR 50.59.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

18-May-06 Tlratvelcr Rev. 3. Co7pyright (C) 2006, EXCEL Servicce Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclcar Regulatory Coin1mission is gianted. All olher ttsc witliotit w rittcn permnission is prohibiled.

I 1

WOC-182, Rev. 0 TSTF-491, Rev. 2

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that th e proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

7.0 REFERENCES

1.

NRC SER for Beaver Valley Power Station (BVPS) Unit 2 Amendment # 137 issued 6/25/03 (TAC NO. MB5686).

2.

NRC SER for BVPS License Amendment numbers 210 (Unit 1) and 88 (Unit 2) issued 1/20/98 (TAC NOS. M99671 and M99672).

3.

Generic Letter 93-08, "Relocation of Technical Specification Tables of Instrument Response Time Limits," dated 12/29/93.

4.

Generic Letter 91-08, "Removal of Component Lists From Technical Specifications,'" dated 5/6/91.

Revision History OG Revision 0 Revision Status: Closed Revision Proposed by:

Beaver Valley Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 02-Aug-05 Owners Group Comments (No Comments)

Owners Group Resolution:

Approved Date: 02-Aug-05 TSTF Review Information TSTF Received Date:

18-Aug-05 Date Distributed for Review 18-Aug-05 OG Review Completed:. BWOG ',ý WOG IV]

CEOG 141 BWROG TSTF Comments:

(No Comments)

TSTF R*esolution:

Approved Date: 09-Sep-05 NRC Review Information NRC Received Date:

13-Sep-05 18-Ma0,-06 rraveler Rcv. 3. Copyright (C) 2006, EXCEL. Services Cotpoh'ation. Use by EXCEL Scrvices associatles. utility clients, and the U.S. Nuclear Regulatory Commission is granted. All otlher use without written permission is prohibited.

/WOC-182, Rcv. 0 TSTF-491, Rev. 2 OG Revision 0 Revision Status: Closed NRC Comments:

NRC requested that the Bases and the justification be revised to state that the subject valves are also tested in accordance with the Inservice Testing Program.

Final Resolution:

Superceded by Revision Final Resolution Date:

12-Oct-05 TSTF Revision I Revision Status: Active Revision Proposed by:

NRC Revision

Description:

Revised the Bases and the justification to state that the subject valves are also tested in accordance with the Inservice Testing Program.

TSTF Review Information TSTF Received Date:

12-Oct-05 Date Distributed for Review 12-Oct-05 OG Review Completed: V; BWOG [

WOG

vj CEOG 1%ý BWROG TSTF Comments

(No Comments)

TSTF Resolution:

Approved Date: 12-Oct-05 NRC Review Information NRC Received Date:

13-Oct-05 NRC Comments:

NRC requested Bases change.

Final Resolution:

NRC Requests Changes: TSTF Will Revise Final Resolution Date:

03-May-06 TSTF Revision 2 Revision Status: Active Revision Proposed by:

WOG Revision

Description:

The Bases of 3.7.2 and 3.7.3 are revised to provide a reference to the time limits. The Reference section of the Bases is revised to include a corresponding bracketed reference to the Technical Requirements Manual.

This change is made to be consistent with the NRC plant-specific approval of this change for Beaver Valley.

TSTF Review Information TSTF Received Date:

04-May-06 Date Distributed for Review 04-May-06 OG Review Completed: V BWOG :i WOG IV. CEOG [F]

BWROG TSTF Comments:

(No Comments)

TSTF Resolution:

Approved Date: 18-May-06 18-AMIay-06 Travelcr Rev. 3. Copyright (C) 2006, EXCEL Services CorlpoatLion. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written penrission is prohibited.

TSTF Revision 2 WOG-182, Rev. 0 TSTF-491, Rev. 2 WOG-182, Rev. 0 TSTF-491, Rev. 2 Revision Status: Active NRC Review Information NRC Received Date:

18-May-06 Affected Technical Specifications SR 3.7.2.1 MSIVs SR 3.7.2.1 Bases MSIVs SR 3.7.3.1

[MFSVs, MFCVs, and Associated SFCVs]

SR 3.7.3.1 Bases

[MFSVs, MFCVs, and Associated SFCVs]

SR 3.7.3.1 MFIVs and MFRVs and [Associated Bypass Valves]

SR 3.7.3.1 Bases MFIVs and MFRVs and [Associated Bypass Valves]

SR 3.7.3.1 MFIVs [and [MFIV] Bypass Valves]

SR 3.7.3.1 Bases MFIVs [and [MFIV] Bypass Valves]

NUREG(s)- 1430 1431 1432 Only NUREG(s)- 1430 1431 1432 Only NUREG(s)- 1430 Only NUREG(s)- 1430 Only NUREG(s)- 1431 Only NUREG(s)- 1431 Only NUREG(s)- 1432 Only NUREG(s)- 1432 Only 18-May-06 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

Jý e-I TSTF-491, Rev. 2 MSIVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1

NOTE Only required to be performed in MODES 1 and 2.

Verify isolation time of each MSIV is_--.6]-seeeGds In accordance within limits, with the Inservice Testing Program SR 3.7.2.2

NOTE Only required to be performed in MODES 1 and 2.

Verify each MSIV actuates to the isolation position

[18] months on an actual or simulated actuation signal.

BWOG STS 3.7.2-2 Rev. 3.0, 03/31/04

1~P-Kt

'ernce TSTF-491, Rev. 2

[MFSVs, MFCVs, and Associated SFCVs]

3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two valves in the same D.1 Isolate affected flow path.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months flow path inoperable for one or more flow paths.

E. Required Action and E.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

[ AND E.2 Be in MODE 4.

12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s]

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1

NOTE---------------

Only required to be performed in MODES 1 and 2.

Verify the isolation time of each [MFSV], [MFCV],

In accordance and [SFCV] is!-5[7] seGeeRs within limits, with the Inservice Testing Program SR 3.7.3.2

NOTE---------------

Only required to be performed in MODES 1 and 2.

Verify each [MFSV], [MFCV], and [SFCV] actuates

[18] months to the isolation position on an actual or simulated actuation signal.

BWOG STS 3.7.3-2 Rev. 3.0, 03/31/04

e e^ cc, TSTF-491, Rev. 2 MSIVs B 3.7.2 BASES ACTIONS (continued)

D.1 and D.2 If the MSIV cannot be restored to OPERABLE status or closed in 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 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 unit'conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies that MIS-the closure time of each MSIV is 9 [6]....

nds. Th '*,

,I. isolation tim., s

.o iswithin the limit given in Reference 5 and is within that assumed in the accident and containment analyses. This SR also verifies the valve closure time is in accordance with the Inservice Testing Program. This Survoillanco SR is normally performed upon returning the unit to operation following a refueling outage, because the MSIVs should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. As the MSIVs are not to be tested at power, they are exempt from the ASME Code,Section XI (Ref. 56) requirements during operation in MODES 1 and 2.

The Frequency for this SR is in accordance with the Inservice Testing Program.

This test is conducted in MODE 3, with the unit at operating temperature and pressure. This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This allows delaying testing until MODE 3 in order to establish conditions consistent with those under which the acceptance criterion was generated.

SR 3.7.2.2 This SR verifies that each MSIV can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage. The Frequency of MSIV testing is every [18] months. The [18] month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the

[18] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

BWOG STS B 3.7.2-5 Rev. 3.0, 03/31/04

TSTF-491, Rev. 2 MSIVs B 3.7.2 BASES REFERENCES

1.

FSAR, Section [10.3].

2.

FSAR, Section [6.2].

3.

FSAR, Section [15.4].

4.

10 CFR 100.11.

5.

[Technical Reauirements Manual.1

56. ASME, Boiler and Pressure Vessel Code, Section Xl.

BWOG STS B 3.7.2-6 Rev. 3.0, 03/31/04

c TSTF-491, Rev. 2

.[MFSVs, MFCVs, and Associated SFCVs]

B 3.7.3 BASES ACTIONS (continued)

E.1 and E.2 If the [MFSVs], [MFCVs], and [associated SFCVs] cannot be restored to OPERABLE status, or closed, or isolated within the associated Completion Time, the unit must be 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 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 unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR verifies that the closure time of each [MFSV], [MFCV], and

[associated SFCV] is _--7seeend4 The [MFr=SV,

[MFrCVj, an\\ d [asr.

iated SFCV] io,,latio-n time oir, within the limit given in Reference 2 and is within that assumed in the accident and containment analyses. This SR also verifies the valve closure time is in accordance with the Inservice Testing Program. This SWURVillanco SR is normally performed upon returning the unit to operation following a refueling outage. The [MFSV], [MFCV], and [associated SFCV] should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. This is consistent with the ASME Code,Section XI (Ref. 23) requirements during operation in MODES 1 and 2.

This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR.

The Frequency for this SR is in accordance with the Inservice Testing Program.

SR 3.7.3.2 This SR verifies that each [MFSV, MFCV, and associated SFCV] can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage.

The Frequency for this SR is every [18] months. The [18] month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

BWOG STS B 3.7.3-5 Rev. 3.0, 03/31/04

I TSTF-491, Rev. 2

[MFSVs, MFCVs, and Associated SFCVs]

B 3.7.3 BASES REFERENCES

1.

FSAR, Section [10.4.7].

2.

[Technical Requirements Manual.1 2ý3. ASME, Boiler and Pressure Vessel Code,Section XI.

BWOG STS B 3.7.3-7 Rev. 3.0, 03/31/04

K4tkvL4%cL TSTF-491, Rev. 2 MSIVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1

NOTE Only required to be performed in MODES 1 and 2.

Verify the isolation time of each MSIV is In accordance

, f4.,]-seeeGdewithin limits, with the Inservice Testing Program SR 3.7.2.2

NOTE Only required to be performed in MODES 1 and 2.

Verify each MSIV actuates to the isolation position

[18] months on an actual or simulated actuation signal.

WOG STS 3.7.2-2 Rev. 3.0, 03/31/04

CTSTF-491, Rev. 2 MFIVs and MFRVs and [Associated Bypass Valves]

3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two valves in the same D.1 Isolate affected flow path.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months flow path inoperable.

E. Required Action and E.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

[ AND E.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ]

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the isolation time of each MFIV, MFRV[, and In accordance associated bypass valve] is-*-[7]-se*neds within with the Inservice limits.

Testing Program SR 3.7.3.2 Verify each MFIV, MFRV[, and associated bypass

[18] months valves] actuates to the isolation position on an actual or simulated actuation signal.

WOG STS 3.7.3-2 Rev. 3.0, 03/31/04

TSTF-491, Rev. 2 MSIVs B 3.7.2 BASES ACTIONS (continued)

D.1 and D.2 If the MSIVs cannot be restored to OPERABLE status or are not closed 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 at least in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 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 unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies that the MSIV-closure time of each MSIV is r [4.6] Goc..ds. The MASIV iolation timo iO within the limit given in Reference 5 and is within that assumed in the accident and containment analyses. This SR also verifies the valve closure time is in accordance with the Inservice Testing Program. This S.wve-IIaRG8-SR is normally performed upon returning the unit to operation following a refueling outage. The MSIVs should not be tested at power, since even a part stroke exercise increases the risk of a valve closure when the unit is generating power. As the MSIVs are not tested at power, they are exempt from the ASME Code,Section XI (Ref.,6), requirements during operation in MODE 1 or 2.

The Frequency is in accordance with the Inservice Testing Program.

This test is conducted in MODE 3 with the unit at operating temperature and pressure. This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This allows a delay of testing until MODE 3, to establish conditions consistent with those under which the acceptance criterion was generated.

SR 3.7.2.2 This SR verifies that each MSIV can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage. The Frequency of MSIV testing is every [18] months. The [18] month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the

[18] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

WOG STS B 3.7.2-5 Rev. 3.0, 03/31/04

P4eA~cLl TSTF-491, Rev. 2 MSIVs B 3.7.2 BASES REFERENCES

1.

FSAR, Section [10.3].

2.

FSAR, Section [6.2].

3.

FSAR, Section [15.1.5].

4.

10 CFR 100.11.

5.

[Technical Requirements Manual.1

56. ASME, Boiler and Pressure Vessel Code, Section Xl.

WOG STS B 3.7.2-6 Rev. 3.0, 03/31/04

TSTF-491, Rev. 2

.Rdt

..wI MFIVs and MFRVs [and Associated Bypass Valves]

B 3.7.3 BASES ACTIONS (continued)

D._1 With two inoperable valves in the same flow path, there may be no redundant system to operate automatically and perform the required safety function. Although the containment can be isolated with the failure of two valves in parallel in the same flow path, the double failure can be an indication of a common mode failure in the valves of this flow path, and as such, is treated the same as a loss of the isolation capability of this flow path. Under these conditions, affected valves in each flow path must be restored to OPERABLE status, or the affected flow path isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This action returns the system to the condition where at least one valve in each flow path is performing the required safety function. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable, based on operating experience, to complete the actions required to close the MFIV or MFRV, or otherwise isolate the affected flow path.

E.1 and E.2 If the MFIV(s) and MFRV(s) and the associated bypass valve(s) cannot be restored to OPERABLE status, or closed, or isolated 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 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s[, and in MODE 4 within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s]. 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 3.7.3.1 REQUIREMENTS This SR verifies that the closure time of each MFIV, MFRV, and

[associated bypass valve] is 9 7 sccords. The MFIV and MFRV icoation time&-afe-within the limit given in Reference 2 and is within that assumed in the accident and containment analyses. This SR also verifies the valve closure time is in accordance with the Inservice Testing Program. This 2SurveillAnSR is normally performed upon returning the unit to operation following a refueling outage. These valves should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. This is consistent with the ASME Code,Section XI (Ref. 23), quarterly stroke requirements during operation in MODES 1 and 2.

The Frequency for this SR is in accordance with the Inservice Testing Program.

WOG STS B 3.7.3-5 Rev. 3.0, 03/31/04 WOG STS B 3.7.3-5 Rev. 3.0, 03/31/04

..R'tkV4"Cý I TSTF-491, Rev. 2 MFIVs and MFRVs [and Associated Bypass Valves]

B 3.7.3 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.3.2 This SR verifies that each MFIV, MFRV, and [associated bypass valves]

can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage.

The Frequency for this SR is every [18] months. The [18] month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

REFERENCES

1.

FSAR, Section [10.4.7].

2.

[Technical Requirements Manual.1 2*3. ASME, Boiler and Pressure Vessel Code,Section XI.

WOG STS B 3.7.3-6 Rev. 3.0, 03/31/04

TSTF-491, Rev. 2 MSIVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1

NOTE Only required to be performed in MODES 1 and 2.

Verify the isolation time of each MSIV is In accordance 5 [4.1-seee within limits.

with the Inservice Testing Program SR 3.7.2.2

NOTE---------------

Only required to be performed in MODES 1 and 2.

Verify each MSIV actuates to the isolation position

[18] months on an actual or simulated actuation signal.

CEOG STS 3.7.2-2 Rev. 3.0, 03/31/04

I.

TSTF-491, Rev. 2 MFIVs [and [MFIV] Bypass Valves]

3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the isolation time of each MFIV [and [MFIV]

In accordance bypass valve] is4-f71 sepends within limits, with the Inservice Testing Program SR 3.7.3.2 Verify each MFIV [and [MFIV] bypass valve]

[18] months actuates to the isolation position on an actual or simulated actuation signal.

CEOG STS 3.7.3-2 Rev. 3.0, 03/31/04

TSTF-491, Rev. 2 MSIVs eI B

3.7.2 BASES ACTIONS (continued)

D.1 and D.2 If the MSIVs cannot be restored to OPERABLE status, or closed, 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within

[12] hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies that the closure time of each MSIV is [4.]6eeR The MSIV isolation time is within the limit given in Reference 5 and is within that assumed in the accident and containment analyses. This SR also verifies the valve closure time is in accordance with the Inservice Testing Program. This SR is normally performed upon returning the unit to operation following a refueling outage. The MSIVs should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. As the MSIVs are not tested at power, they are exempt from the ASME Code, Section Xl (Ref. 56), requirements during operation in MODES 1 and 2.

The Frequency for this SR is in accordance with the Inservice Testing Program.

This test is conducted in MODE 3, with the unit at operating temperature and pressure. This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This allows a delay of testing until MODE 3, in order to establish conditions consistent with those under which the acceptance criterion was generated.

SR 3.7.2.2 This SR verifies that each MSIV can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage. The Frequency of MSIV testing is every [18] months. The [18] month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the

[18] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

CEOG STS B 3.7.2-5 Rev. 3.0, 03/31/04

I.

Rttke li~x&AC.'O I

TSTF-491, Rev. 2 MSIVs B 3.7.2 BASES REFERENCES 1.

2.

3.

4.

5.

5ý6.

FSAR, Section [10.3].

FSAR, Section [6.2].

FSAR, Section [15.1.5].

10 CFR 100.11.

[Technical Requirements Manual.1 ASME, Boiler and Pressure Vessel Code,Section XI, Inservice Inspection, Article IVVV-3400.

CEOG STS B 3.7.2-6 Rev. 3.0, 03/31/04

TSTF-491, Rev. 2 fuj*u c-j MFIVs [and [MFIV] Bypass Valves]

B 3.7.3 BASES ACTIONS (continued)

C.1 and [C.21 If the MFIVs and their bypass valves cannot be restored to OPERABLE status, closed, or isolated in 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 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months s[,

and in MODE 4 within [12] hours]. 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 3.7.3.1 REQUIREMENTS This SR verifies that the closure time ensures the Verification of each MFIV [and [MFIV] bypass valve] is 9 [71.o.onds. Tho MFIV isolation ti;mo is-is within the limit -given in Reference 2 and is within that assumed in the accident and containment analyses. This SR also verifies the valve closure time is in accordance with the Inservice Testing Program. This 9Urvoillanco-SR is normally performed upon returning the unit to operation following a refueling outage. The MFIVs should not be tested at power since even a part stroke exercise increases the risk of a valve closure with the unit generating power. As these valves are not tested at power, they are exempt from the ASME Code, Section Xl (Ref. 23) requirements during operation in MODES 1 and 2.

The Frequency is in accordance with the Inservice Testing Program.

SR 3.7.3.2 This SR verifies that each MFIV [and [MFIV] bypass valve] can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling outage.

The Frequency for this SR is every [18] months. The [18] month Frequency for testing is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the [18] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

REFERENCES

1. FSAR, Section [10.4.7].

2.

[Technical Requirements Manual.1 CEOG STS B 3.7.3-4 Rev. 3.0, 03/31/04

TSTF-491, Rev. 2 MFIVs [and [MFIV] Bypass Valves]

B 3.7.3

23. ASME, Boiler and Pressure Vessel Code, Section Xl, Inservice Inspection, Article IWV-3400.

CEOG STS B 3.7.3-5 Rev. 3.0, 03/31/04

C-C June 16, 2006 Technical Specification Task Force

.11921 Rockville Pike Suite 100 Rockville, MD 20852

Dear Members of the TSTF:

The Nuclear Regulatory Commission has completed the review of the Technical Specification Task Force (TSTF) Change Traveler, TSTF-491, Revision 0, "Removal of Main Steam and Main Feedwater Valve Isolation Times from the Technical Specifications". The staff has approved the proposed change. The staff's Safety Evaluation Report for TSTF-491 is enclosed. Also enclosed are the model License Amendment Request and the model No Significant Hazzards Consideration.

Please contact me at (301) 415-0184 or e-mail IJK lnrc.goy if you have any questions or need further information on these proposed changes.

Sincerely, IRA by C. Schulten for!

Timothy J. Kobetz, Chief Technical Specifications Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation

Enclosures:

As stated cc: M. Crowthers (BWROG)

W. Sparkman (PWROG/W)

P. Infanger (PWROG/B&W)

B. Woods (PWROG/CE)

D. Hoffman (EXCEL)

B. Mann (EXCEL)

ML061220244 OFFICE DIRS:ITSB BC:DCI:CPT BC:DIRS:ITSB NAME PHearn SSLee TJKobetz - CSchulten for DATE 06/01/2006 06/02/2006 06/16/2006

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION TECHNICAL SPECIFICATION TASK FORCE-491, Rev.0 "REMOVAL OF MAIN STEAM AND MAIN FEEDWATER VALVE ISOLATION TIMES FROM TECHNICAL SPECIFICATIONS"

1.0 INTRODUCTION

By letter dated September 13, 2005, the Technical Specifications Task Force submitted Technical Specification Task Force Change Traveler, TSTF-491, R.0, "Removal of Main Steam and Feedwater Valve Isolation Times from Technical Specifications". Specifically, the proposed revisions to the Standard Technical Specifications (STS) relocate the isolation times for the main steam isolation valves, main feedwater isolation valves, main feedwater regulation/control valves and associated valves to the Licensing Requirements Manual. The actual isolation times in the present STS are replaced with the phrase "within limits".

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to include TS as part of the license. The TS ensure the operational capability of structures, systems and components that are required to protect the health and safety of the public. The Commission's regulatory requirements related to the content of the TS are contained in 10 CFR Section 50.36. That regulation requires that the TS include items in the following specific categories: (1) safety limits, limiting safety systems settings, and limiting control settings (50.36(c)(1)); (2) Limiting Conditions for Operation (50.36(c)(2));

(3) Surveillance Requirements (50.36(c)(3)); (4) design features (50.34(c)(4)); and (5) administrative controls (50.36(c)(5)).

In general, there are two classes of changes to TS: (1) changes needed to reflect modifications to the design basis (TS are derived from the design basis), and (2) voluntary changes to take advantage of the evolution in policy and guidance as to the required content and preferred format of TS over time. This amendment deals with the second class of changes.

In determining the acceptability of revising STS 3.7.2 and 3.7.3, the staff used the accumulation of generically approved guidance in NUREG-1430, "Standard Technical Specifications, Revision 3 Babcock and Wilcox Plants," dated June, 2004; NUREG-1431, Revision 3, "Standard Technical Specifications, Westinghouse Plants," dated June, 2004; and NUREG-1432, "Standard Technical Specifications, Revision 3 Combustion Engineering Plants,"

dated June, 2004.

Licensees may revise the TS to adopt current improved STS format and content provided that plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative or provides clarification (i.e., no requirements are materially altered),

(2) the change is more restrictive than the licensee's current requirement, or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate

-I-Enclosure

assurance of safety when judged against current regulatory standards. The detailed application of this general framework, and additional specialized guidance, are discussed in Section 3.0 in the context of specific proposed changes.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the justification for the proposed TSTF as described in the September 13, 2005 submittal. The detailed evaluation below will support the conclusion that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

3.1 Main Steam Isolation Valves (MSIV)

One MSIV is located in each main steam line outside of the containment. Closing the MSIVs isolates each steam generator from the others and isolates the turbine, steam bypass system and other auxiliary steam supplies from the steam generator.

By isolating the steam flow from the secondary side of the steam generator the MSIVs prevent over cooling the reactor core following a high energy line break (HELB). By preventing core overcooling the MSIVs protect the reactor core from being damaged.

TSTF-491 is proposing to relocate the required closure times for the MSIVs to the Licensing Requirements Manual (LRM). Changes to the LRM are subject to the 10 CFR 50.59 process.

The 10 CFR 50.59 criteria provide adequate assurance that prior staff review and approval will be requested by the licensee for changes to the LRM requirements with the potential to affect the safe operation of the plant. Furthermore, the MSIVs are subject to periodic testing and acceptance criteria in accordance with the Inservice Testing (IST) Program. Compliance with the IST Program is required by Section 5.5.7 of the Standard Technical Specifications (STS) and 10 CFR 50.55. The IST Program includes specific reference value baseline operating times for valves that are not subject to arbitrary changes.

10 CFR 50.36 requires the inclusion of the periodic testing of the MSIVs in the Surveillance Requirements not the actual closure time of the valves. TSTF-491 change maintains the periodic testing requirements for MSIVs in accordance with 10 CFR 50.36.

Based on the requirements of 10 CFR 50.36, 10 CFR 50.59 and IST Program, the staff concludes that relocating the MSIV closure time to the LRM is acceptable.

3.2 Main Feedwater Isolation Valve (MFIV), Main Feedwater Requlation/Control Valve (MFRV) and Associated Bypass Valves (BV)

The MFIVs and BVs or the MFRVs and BVs isolate the nonsafety related portions from the safety related portions of the system. In the event of a secondary side pipe rupture inside containment, these valves limit the quantity of high energy fluid that enters the containment through the break and provide a pressure boundary for the controlled addition of auxiliary feedwater to the intact loops.

By isolating the feedwater flow from the affected steam generator the MFIVs, MFR*'s and BVs prevent overcooling the reactor core and over pressurizing of the containment from feedwater pump runout.

As with the MSIVs, TSTF-491 is also proposing to relocate the required closure times for the MFIVs, MFRVs and BVS to the Licensing Requirements Manual (LRM). Changes to the LRM are subject to the 10 CFR 50.59 process. The 10 CFR 50.59 criteria provide adequate assurance that prior staff review and approval will be requested by the licensee for changes to the LRM requirements with the potential to affect the safe operation of the plant. Furthermore, the MFIVs, MFRVs and BVs are subject to periodic testing and acceptance criteria in accordance with the Inservice Testing (IST) Program. Compliance with the IST Program is required by Section 5.5.7 of the Standard Technical Specifications (STS) and 10 CFR 50.55.

The IST Program includes specific reference value baseline operating times for valves that are not subject to arbitrary changes.

10 CFR 50.36 requires the inclusion of the periodic testing of the MFIVs, MFRVs and BVs in the Surveillance Requirements not the actual closure time of the valves. TSTF-491 maintains the periodic testing requirements for MFIVs, MFRVs and BVs in accordance with 10 CFR 50.36.

Based on the requirements of 10 CFR 50.36, 10 CFR 50.59 and the IST Program, the staff concludes that relocating the MFIVs, MFRVs and BVs closure times to the LRM is acceptable.

4.0 CONCLUSION

The changes proposed by TSTF-491 would make the affected surveillances more consistent with the ESF Response Time requirement in SR 3.3.2.10 which states "Verify ESFAS REPONSE TIMES are within limits". The NRC staff concludes that the proposed changes are consistent with the requirements as contained in 10 CFR 50.36. On this basis, the NRC staff concludes that the changes proposed by TSTF-491 are acceptable.

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and, (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

FOR INCLUSION ON THE TECHNICAL SPECIFICATIONS WEB PAGE THE FOLLOWING EXAMPLE OF AN APPLICATION WAS PREPARED BY THE NRC STAFF TO FACILITATE USE OF THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (CLIIP). THE MODEL PROVIDES THE EXPECTED LEVEL OF DETAIL AND CONTENT FOR AN APPLICATION TO ADOPT TSTF-491, REVISION 0, REMOVAL OF MAIN STEAM AND MAIN FEEDWATER VALVE ISOLATION TIMES FROM THE TECHNICAL SPECIFICATIONS ASSOCIATED TS BASES.

LICENSEES REMAIN RESPONSIBLE FOR ENSURING THAT THEIR ACTUAL APPLICATION FULFILLS THEIR ADMINISTRATIVE REQUIREMENTS AS WELL AS NUCLEAR REGULATORY COMMISSION REGULATIONS.

U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

SUBJECT:

PLANT NAME DOCKET NO. 50-APPLICATION FOR TECHNICAL SPECIFICATION CHANGE TSTF-491, REMOVAL OF MAIN STEAM AND MAIN FEEDWATER VALVE ISOLATION TIMES FROM TECHNICAL SPECIFICATIONS Gentlemen:

In accordance with the provisions of 10 CFR 50.90 [LICENSEE] is submitting a request for an amendment to the technical specifications (TS) for [PLANT NAME, UNIT NOS.].

The proposed amendment would modify TS by relocating the main steam and main feedwater valve isolation times to the License Requirement Manual and replacing the isolation times with the phrase "within limits". provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing TS pages marked up to show the proposed change. Enclosure 3 provides revised (clean) TS pages. provides the existing TS Bases pages marked up to show the proposed change (for information only).)

[LICENSEE] requests approval of the proposed license amendment by [DATE], with the amendment being implemented [BY DATE OR WITHIN X DAYS].

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

I declare under penalty of perjury under the laws of the United States of America that I am authorized by [LICENSEE] to make this request and that the foregoing is true and correct.

(Note that request may be notarized in lieu of using this oath or affirmation statement). Enclosure 2

i If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER]

Sincerely,

[Name, Title]

Enclosures:

1. Description and Assessment

2. Proposed Technical Specification Changes

3. Revised Technical Specification Pages

4. Proposed Technical Specification Bases Changes cc: NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact Enclosure 2

ENCLOSURE I Description and Assessment

1.0 DESCRIPTION

The proposed amendment would modify technical specifications by relocating the isolation times for the main steam isolation valves, main feedwater isolation valves, and associated valves to the Licensing Requirements Manual. The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF)

TSTF-491 Revision 0, "Removal of Main Steam and Feedwater Valve Isolation Times from Technical Specifications.".'

2.0 ASSESSMENT

2.1 Applicability of TSTF-491, and Published Safety Evaluation

[LICENSEE] has reviewed TSTF-491 (Reference 1), and the NRC model safety evaluation (SE). [LICENSEE] has concluded that the information in TSTF-374, as well as the SE prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS. [NOTE: Only those changes proposed in TSTF-491 are addressed in the model SE. The model SE addresses the entire fleet of Combustion Engineering, Babcock & Wilcox, Westinghouse Pressurized Water Reactors, General Electric, and Boiling Water Reactor plants. The plants adopting TSTF-491 must confirm the applicability of the changes to their plant.]

2.2 Optional Changes and Variations

[LICENSEE] is not proposing any variations or deviations from the TS changes described in the TSTF-491 or the NRC staff's model safety evaluation dated [DATE]. [NOTE: The TSTF does not prevent licensees from requesting an alternate approach or proposing changes without the requested Bases or Bases control program. However, deviations from the approach recommended in this TSTF may require additional review by the NRC staff and may increase the time and resources needed for the review. Significant variations from the approach, or inclusion of additional changes to the license, will result in staff rejection of the submittal.

Instead, licensees desiring significant variations and/or additional changes should submit a LAR that does not claim to adopt TSTF-491.]

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination

'[In conjunction with the proposed change, technical specifications (TS) requirements for a Bases Control Program, consistent with the TS Bases Control Program described in Section 5,5 of the applicable vendor's standard TS (STS), shall be incorporated into the licensee's TS, if not already in the TS.] Enclosure 2

[LICENSEE] has reviewed the proposed no significant hazards consideration determination (NSHCD). [LICENSEE] has concluded that the proposed NSHCD enclosed is applicable to

[PLANT] and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

3.2 Verification and Commitments

[LICENSEE] has proposed TS Bases consistent with TSTF-491, which provide guidance and details on how to implement the new requirements. Finally, [LICENSEE] has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications (STS).

4.0 ENVIRONMENTAL EVALUATION The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment adopting TSTF-491, Rev 0, involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 REFERENCES

1.

TSTF-374, Revision 0, "Removal of Main Steam and Feedwater Valve Isolation Times from Technical Specifications." Enclosure 2

Proposed No Significant Hazards Consideration Determination Description of Amendment Request: A change is proposed to the technical specifications (TS) of [plant name], consistent with Techncial Specifications Task Force (TSTF) change TSTF-491 to the standard technical specifications (STS) for PWR Plants (NUREG 1430, NUREG 1431 and NUREG 1433) to relocate the main steam and main feedwater valve isolation times to the License Requirement Manual and replace the isolation times with the phrase, "within limits."

Basis for proposed no-significant-hazards-consideration determination: As required by 10 CFR 50.91(a), an analysis of the issue of no-significant-hazards-consideration is presented below:

Criterion I -

The Proposed Change Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated The proposed change allows relocating main steam and main feedwater valve isolation times to the License Requirements Manual. The proposed change is described in Technical Specification Task Force (TSTF) Standard TS Change Traveler TSTF-491 related to relocating the main steam and main feedwater valves isolation times to the License Requirements Manual and replacing the isolation time with the phase, "within limits."

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed). The proposed changes relocate the main steam and main feedwater isolation valve times to the license requirements manual. The requirements to perform the testing of these isolation valves are retained in the TS. Future changes to the licensee-controlled document will be evaluated pursuant to the requirements of 10 CFR 50.59, Changes, test and experiments", to ensure that such changes do not result in more than minimal increase in the probability or consequences of an accident previously evaluated.

The proposed changes do not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, and configuration of the facility or the manner in which the plant is operated and maintained. The proposed changes do not adversely affect the ability of structures, systems and components (SSCs) to perform their intended safety function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed changes do not affect the source term, containment isolation, or radiological consequences of any accident previously evaluated. Further, the proposed changes do not increase the types and the amounts of radioactive effluent that may be released, nor significantly increase individual or cumulative occupation/public radiation exposures.

Therefore, the changes do not involve a significant increase in the probability or consequences of any accident previously evaluated. Enclosure 2

iv Criterion 2 -

The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The proposed changes relocate the main steam and main feedwater valve isolation times to the License Requirements Manual. In addition, the valve isolation times are replaced in the TS with the phase "within limits". The changes do not involve a physical altering of the plant (i.e., no new or different type of equipment will be installed) or a change in methods governing normal pant operation. The requirements in the TS continue to require testing of the main steam and main feedwater isolation valves to ensure the proper functioning of these isolation valves.

Therefore, the changes do not create the possibility of a new or different kind of accident from any previously evaluated.

Criterion 3 -

The Proposed Change Does Not Involve a Significant Reduction in the Margin of Safety The proposed changes relocate the main steam and main feedwater valve isolation times to the License Requirements Manual. In addition, the valve isolation times are replaced in the TS with the phase "within limits". Instituting the proposed changes will continue to ensure the testing of main steam and main feedwater isolation valves. Changes to the license controlled document (LRM) are performed in accordance with 10 CFR 50.59. This approach provides an effective level of regulatory control and ensures that main steam and feedwater isolation valve testing is conducted such that there is no significant reduction in the margin of safety.

The margin of safety provided by the isolation valves is unaffected by the proposed changes since there continue to be TS requirements to ensure the testing of main steam and main feedwater isolation valves. The proposed changes maintain sufficient controls to preserve the current margins of safety.

Based upon the reasoning above, the NRC staff concludes that the amendment request involves no significant hazards consideration. Enclosure 2

ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION PAGES

[Clean copies of Licensee specific Technical Specification (TS) pages, corresponding to the TS pages changed by TSTF-491, Rev 0, are to be included in Enclosure 3]

ENCLOSURE 4 PROPOSED CHANGES TO TECHNICAL SPECIFICATION BASES PAGES Enclosure 2

ML072760125

Contents

Text

Subject:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

5.0 REFERENCES

Contact:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

Description:

Description:

Description:

Dear Members of the TSTF:

Enclosures:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 CONCLUSION

SUBJECT:

Enclosures:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

5.0 REFERENCES

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ML072760125

Text

Subject:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

5.0 REFERENCES

Contact:

1.0 DESCRIPTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY ANALYSIS

6.0 ENVIRONMENTAL CONSIDERATION

7.0 REFERENCES

Description:

Description:

Description:

Dear Members of the TSTF:

Enclosures:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 CONCLUSION

SUBJECT:

Enclosures:

1.0 DESCRIPTION

2.0 ASSESSMENT

3.0 REGULATORY ANALYSIS

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