ML13156A046

NRC Pre-Submittal Meeting, Improved Technical Specification Conversion

ML13156A046
Person / Time
Site:	Sequoyah
Issue date:	06/04/2013
From:	Conner M Tennessee Valley Authority
To:	Siva Lingam Plant Licensing Branch II
Lingam S NRR/DORL/LPLII-2
References
Download: ML13156A046 (46)

Text

NRC Pre-Submittal Meeting Sequoyah Nuclear Plant IMPROVED TECHNICAL SPECIFICATION Conversion June 4, 2013 1 TVA Nuclear Power Group

Agenda I. Introduction

- Purpose of Meeting

- NRC, TVA, and Excel Services II. Project Description

- Overview

- Scope

- Phases

• Initial Planning

• LAR Development

• Support of NRC Review and Approval

• Implementation

- Current TS LAR Status III. Discussion Topics

- CTS LAR Incorporation

- Licensee Identified Items which may require a Formal Technical Branch Review

- NRC Resources and 2013/2014 Schedule/LIC-601 Support IV. Summary of I - III V. Tech Spec Section 3.8, Electrical Systems (Separate discussion)

VI. Summary of V 2 TVA Nuclear Power Group

Introduction and Project Description Michelle Conner Improved Technical Specification Project Task Manager 3 TVA Nuclear Power Group

I. Introduction Purpose of Meeting Given the complexity of ITS Conversions, this meeting is intended to ensure common understanding of the ITS Conversion process and therefore allow for a more efficient use of both NRC and TVA resources.

Attendees:

• TVA

- Michelle Conner - ITS Project Task Manager

- Scott Bowman - Licensing Core Team

- John Crawford - Engineering Core Team

- Dennis Dimopoulos - Engineering Design Manager

- Michael McBrearty - SQN Site Licensing Manager

- Ed Schrull - Corporate Licensing Manager

• EXCEL Services

- Ray Schiele - ITS Project Manager, Consultant

- Roger Scott - Senior Licensing Manager, Consultant 4 TVA Nuclear Power Group

II. Project Description Overview

• Current TS are based on NUREG-0452 (SQN was originally licensed in 1980/1981)

• Significant Expenditure

• ITS Conversion is a priority and the site recognizes the Key Benefits which include:

- The flexibility to support required preventative maintenance during scheduled refueling outages (CTS Electrical Specifications prevent necessary preventative maintenance on the 6.9kV Shutdown Boards);

- Fleet Standardization, enhanced safety, operational, and regulatory performance

- Significantly improved TS Bases, including alignment of the TS Bases with SQNs Current Licensing Bases

- Moves periodic Surveillance Frequencies out of TS and into the Surveillance Frequency Control Program

- Adoption of the TS Rules of Usage Section 1.0 5 TVA Nuclear Power Group

II. Project Description (continued)

Scope

• Convert the SQN Current Technical Specifications (CTS) to the Improved Standard Technical Specifications (ISTS), NUREG 1431, Revision 4.0;

• Adoption of specific Risk Informed Initiatives.

(will be discussed in more detail in following slides) 6 TVA Nuclear Power Group

II. Project Description (continued)

Current Status of Phases

• Phase 1 Initial Planning - complete

• Phase 2 LAR Development - schedule for completion Summer 2013

• Phase 3 Support of NRC Review and Approval (Targeted to begin Summer 2013)

• Phase 4 Implementation (Target - Fall 2014) 7 TVA Nuclear Power Group

II. Project Description (continued)

Approach The development of the SQNs ITS Conversion LAR, followed both the TSTF-GG-13-01 ITS Conversion Guidance and the TVA LAR process.

8 TVA Nuclear Power Group

II. Project Description (continued)

SQN ITS Submittal Contains

• Current Tech Spec markup

• Discussion of Changes

• ISTS and ISTS Bases markup

• Justification for Deviation from the ISTS

• No Significant Hazard Consideration

• Supporting Information 9 TVA Nuclear Power Group

II. Project Description (continued)

Approved Travelers Adopted TSTF-411 Surveillance Test Extensions for Components of Reactor Protection System TSTF-418 RPS and ESFAS Test Times and Completion Times TSTF-490 Deletion of E Bar Definition and Revision to RCS Specific Activity Tech Spec TSTF-522 Revise Ventilation System Surveillance Requirements to Operate for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per Month 10 TVA Nuclear Power Group

II. Project Description (continued)

Risk Informed Initiatives TSTF-425 The proposed change relocates all periodic Surveillance Frequencies from the Technical Specifications and places the Frequencies under licensee control in accordance with a new program, the Surveillance Frequency Control Program (SFCP).

TSTF-427 A new Technical Specification Limiting Condition for Operation (LCO) Applicability rule, LCO 3.0.9, and its associated Bases, has been provided to address non-technical specification degraded barriers that cannot provide their protective function(s) for Technical Specification systems.

TSTF- 446 WCAP-15791 provides the technical justification for extending the Completion Times, for Technical Specification (TS) 3.6.3, Containment Isolation Valves, also referred to as the allowed outage time (AOT), from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> (7 days). Containment isolation valves that cannot demonstrate acceptable results for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />, shorter times are considered and evaluated. The current Completion Times are generally insufficient to respond to containment isolation valve inoperability, perform trouble shooting activities and perform preventative maintenance activities at power.

11 TVA Nuclear Power Group

II. Project Description (continued)

Support of NRC Review and Approval utilizing LIC-601 NRR Office Instruction

• Acceptance Review

- Information not provided under oath or affirmation

- Acceptance Review Meeting

• Main Review Phase

- RAI Communications and Use of an ITS Database

• Issue Resolution and Submission of Revisions by Licensee

• SE Preparation, Document Routing, and Issuance 12 TVA Nuclear Power Group

II. Project Description (continued)

Current Status of LAR

• Open Items are being addressed and dispositioned

• Verification of validation sources is in progress per the TVA LAR process

• PORC package review is in progress and final LAR review is scheduled

• NSRB package review is in progress and final LAR review is scheduled 13 TVA Nuclear Power Group

III. Discussion Topics CTS SQN Near Term LAR Submittals

• SQN Ice Condenser Ice Weight Change LAR (SQN-TS-12-04),

scheduled for submittal in mid to late June 2013.

• SQN Ultimate Heat Sink Temperature Limitation/Essential Raw Cooling Water Alignment Change LAR (TS-SQN-13-01 and 13-02),

scheduled for submittal in late July 2013.

• SQN Diesel Fuel Oil Required Seven Day Volume Change LAR (TS SQN-13-03), scheduled for submittal in mid July 2013.

14 TVA Nuclear Power Group

III. Discussion Topics (continued)

Licensee Identified Items which may require a Formal Technical Branch Review

- Heat Flux Hot Channel Factor (ITS 3.2.1)

- Nuclear Enthalpy Rise Hot Channel Factor (ITS 3.2.2)

- Atmospheric Relief Valves (ITS 3.7.4)

- AC Sources - Operating (ITS 3.8.1)

- Distribution Systems - Operating (ITS 3.8.9) 15 TVA Nuclear Power Group

III. Discussion Topics (continued)

NRC Resources and 2013/2014 Schedule/LIC-601

- SQN is making a concerted effort to keep changes in-scope and will provide an updated list at the time the LAR is submitted of those items that may require formal technical branch review.

- SQN looks forward to utilizing the guidance provided in LIC-601 Improved Technical Specification Conversion Amendment Review Procedure to support consistent and efficient reviews.

- ITS implementation date anticipated to occur within 6 months of SE.

16 TVA Nuclear Power Group

IV. Summary I. Purpose of Meeting II. Project Description III.Discussion Topics 17 TVA Nuclear Power Group

QUESTIONS?

18 TVA Nuclear Power Group

Sequoyah Nuclear Plant ITS - Electrical Systems June 4, 2013

ITS - Electrical Systems Agenda:

Purpose of Proposed Changes Sequoyah Electrical Design Current Technical Specifications Proposed Technical Specifications Summary ITS - Electrical Systems Purpose of Proposed Changes In parallel with the ITS Conversion submittal, TVA has evaluated actions that would be required in order to facilitate the scheduling of maintenance activities on the 6.9 kV and 480 V Shutdown Boards at Sequoyah Nuclear Plant (SQN).

The proposed changes to the SQN Technical Specifications include provisions in Section 3.8.1, AC Sources - Operating, and Section 3.8.9, Distribution Systems - Operating, such that, with the associated unit operating in Mode 1, 2, 3, or 4 and the opposite unit shutdown in Mode 5 or 6 or defueled, one of the shutdown units 6.9 kV Shutdown Boards and the normally connected 480 V Shutdown Boards may be taken out of service for up to 7 days.

ITS - Electrical Systems Sequoyah Electrical Design

• Unit 1 modifications scheduled for 2013 refueling outage.

ITS - Electrical Systems Sequoyah Electrical Design ITS - Electrical Systems Sequoyah Electrical Design The onsite Class 1E AC Electrical Distribution System supplies electrical power to two power trains shared between the two units.

The core cooling and containment cooling system loads (e.g., Safety Injection (SI) pumps, Auxiliary Feedwater (AFW) pumps, Residual Heat Removal (RHR) pumps, Centrifugal Charging pumps, Containment Spray (CS) pumps, and Air Return System (ARS) fans) are unitized to the respective unit's 6.9 kV Shutdown Boards.

Some safety-related systems (e.g., Essential Raw Cooling Water (ERCW), Component Cooling (CCS), Emergency Gas Treatment (EGTS), Auxiliary Building Gas Treatment (ABGTS), Control Room Emergency Ventilation (CREVS), and Control Room HVAC (CRACS))

are shared between the units.

The AC sources for the shared loads are distributed across both unit's Shutdown Boards.

However, the impacts of an inoperable offsite power source or DG on an opposite unit's Shutdown Board differ from the impacts of an inoperable offsite power source or DG on an associated unit's Shutdown Board, due to the loads powered from the respective board.

ITS - Electrical Systems Sequoyah Electrical Design - Major Loads 6.9 kV 6.9 kV 6.9 kV 6.9 kV Shutdown Shutdown Shutdown Shutdown Board 2B-B Board 2A-A Board 1B-B Board 1A-A Unit 2 loads: Unit 2 loads: Unit 1 loads: Unit 1 loads:

SI pump 2B-B SI pump 2A-A SI pump 1B-B SI pump 1A-A AFW pump 2B-B AFW pump 2A-A AFW pump 1B-B AFW pump 1A-A RHR pump 2B-B RHR pump 2A-A RHR pump 1B-B RHR pump 1A-A Charging pump 2B-B Charging pump 2A-A Charging pump 1B-B Charging pump 1A-A Cont. Spray pump 2B-B Cont. Spray pump 2A-A Cont. Spray pump 1B-B Cont. Spray pump 1A-A Przr Htr Grps 2B-B, 2C Przr Htr Grps 2A-A, 2D Przr Htr Grps 1B-B, 1C Przr Htr Grps 1A-A, 1D Shared loads: Shared loads: Shared loads: Shared loads:

ERCW pumps P-B, M-B ERCW pumps R-A, K-A ERCW pumps L-B, N-B ERCW pumps J-A, Q-A CCS pump 2B-B* CCS pump 2A-A* CCS pump 1B-B* CCS pump 1A-A*

CCS pump C-S* ARS fan 2A-A* ARS fan 1B-B* CCS pump C-S* (Alt. Fdr.)

ARS fan 2B-B* ABGTS fan A-A* EGTS fan B-B* ARS fan 1A-A*

ABGTS fan B-B* 125 V Vital Batt Chrgr III* CR AHU B-B* EGTS fan A-A*

125 V Vital Batt Chrgr IV* 120 V Vital Invrtrs: 1-III, 2-III* 125 V Vital Batt Chrgr II* CR AHU (A-A)

• 120 V Vital Invrtrs: 1-IV, 2-IV* 120 V Vital Invrtrs: 1-II, 2-II* 125 V Vital Batt Chrgr I*

120 V Vital Invrtrs: 1-I, 2-I*

• 480 V ITS - Electrical Systems Current Technical Specifications LCO 3.8.1.1 As a minimum, the following AC electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system, and

b. Four separate and independent diesel generators (DGs). . .

APPLICABILITY: MODES 1, 2, 3, and 4.

ITS - Electrical Systems Current Technical Specifications ACTIONS:

a. With one offsite circuit inoperable restore offsite circuit within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

b. With DGs 1A-A and/or 2A-A or 1B-B and/or 2B-B inoperable restore DGs within 7 days.

c. With one offsite circuit and one DG inoperable restore one of the inoperable sources within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

d. With two offsite circuits inoperable restore one offsite source within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

e. With either DGs 1A-A and/or 2A-A inoperable simultaneously with 1B-B and/or 2B-B inoperable, restore either:

1) 1A-A and 2A-A, or 2) 1B-B and 2B-B. . . within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

ITS - Electrical Systems Proposed Technical Specifications LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Four diesel generators (DGs) capable of supplying the onsite Class 1E AC Electrical Power Distribution System.

APPLICABILITY: MODES 1, 2, 3, and 4.

ITS - Electrical Systems Proposed Technical Specifications - Draft Highlighted portions of ITS Action A reflect CTS Action a requirements for the restoration of inoperable offsite power source(s), with the exception that inoperable offsite power sources to Shutdown Board 2A-A or 2B-B (with offsite power sources to Shutdown Boards 1A-A and 1B-B operable) are addressed in Condition C.

ITS - Electrical Systems Proposed Technical Specifications - Draft Highlighted portions of ITS Action B reflect CTS Action b requirements for the restoration of inoperable DG(s), with the exception that inoperable DGs on Shutdown Boards 2A-A and 2B-B (with DGs on Shutdown Boards 1A-A and 1B-B operable) are addressed in Condition D.

ITS - Electrical Systems Proposed Technical Specifications - Draft Highlighted portions of ITS Action E reflect CTS Action d requirements for the restoration of an inoperable offsite circuit.

ITS - Electrical Systems Proposed Technical Specifications - Draft Highlighted portions of ITS Action F reflect CTS Action c requirements for the restoration of either an inoperable offsite power source or a DG, with the exception that combinations involving inoperable offsite power sources and/or DGs to Shutdown Board 2A-A or 2B-B (with offsite power sources and DGs to Shutdown Boards 1A-A and 1B-B operable) are addressed in Conditions G, H or I.

ITS - Electrical Systems Proposed Technical Specifications - Draft Highlighted portions of ITS Action J reflect CTS Action e requirements for the restoration of one train of inoperable DGs.

ITS - Electrical Systems Proposed Technical Specifications - Draft ITS Action C contains requirements for an inoperable offsite power source to Shutdown Board 2A-A or 2B-B (with offsite power sources to Shutdown Boards 1A-A and 1B-B operable).

Requires declaring required features with no offsite power available inoperable 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of concurrent inoperable redundant feature, or 7 days from time offsite power source declared inoperable.

ITS - Electrical Systems Proposed Technical Specifications - Draft ITS Action D contains requirements for an inoperable DG to Shutdown Board 2A-A or 2B-B (with DGs to Shutdown Boards 1A-A and 1B-B operable).

Requires declaring required features supported by the inoperable DG inoperable 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of concurrent inoperable redundant feature, or 7 days from time DG declared inoperable.

ITS - Electrical Systems Proposed Technical Specifications - Draft ITS Action G contains requirements related to a combination of an inoperable offsite power source to Shutdown Board 2A-A or 2B-B with an inoperable Unit 1 DG (with the offsite power sources to Shutdown Boards 1A-A and 1B-B operable).

Require Action for declaring required features supported by the inoperable DG or offsite circuit inoperable with concurrent inoperable redundant feature are addressed in ACTIONS A, B, C, and D, as applicable.

ITS - Electrical Systems Proposed Technical Specifications - Draft ITS Action H contains requirements related to a combination of an inoperable offsite power source to Shutdown Board 1A-A or 1B-B with an inoperable Unit 2 DG (with DGs 1A-A and 1B-B operable).

Require Action for declaring required features supported by the inoperable DG or offsite circuit inoperable with concurrent inoperable redundant feature are addressed in ACTIONS A, B, C, and D, as applicable.

ITS - Electrical Systems Proposed Technical Specifications - Draft ITS Action I contains requirements related to a combination of an inoperable offsite power source and DG to Shutdown Board 2A-A or 2B-B (with the offsite power sources and DGs to Shutdown Boards 1A-A and 1B-B operable).

Require Action for declaring required features supported by the inoperable DG or offsite circuit inoperable with concurrent inoperable redundant feature are addressed in ACTIONS A, B, C, and D, as applicable.

Note requires entering Conditions and Required Actions of LCO 3.8.9 when 6.9 kV Shutdown Board 2A-A or 2B-B is de-energized.

ITS - Electrical Systems Current Technical Specifications LCO 3.8.2.1 The following AC electrical boards shall be OPERABLE and energized with tie breakers open between redundant boards:

6900 Volt Shutdown Board 1A-A 6900 Volt Shutdown Board 1B-B 6900 Volt Shutdown Board 2A-A 6900 Volt Shutdown Board 2B-B 480 Volt Shutdown Board 1A1-A 480 Volt Shutdown Board 1A2-A 480 Volt Shutdown Board 1B1-B 480 Volt Shutdown Board 1B2-B 480 Volt Shutdown Board 2A1-A 480 Volt Shutdown Board 2A2-A 480 Volt Shutdown Board 2B1-B 480 Volt Shutdown Board 2B2-B 120 Volt A.C. Vital Instrument Power Board Channels 1-I and 2-I 120 Volt A.C. Vital Instrument Power Board Channels 1-II and 2-II 120 Volt A.C. Vital Instrument Power Board Channels 1-III and 2-III 120 Volt A.C. Vital Instrument Power Board Channels 1-IV and 2-IV APPLICABILITY: MODES 1, 2, 3, and 4.

ITS - Electrical Systems Current Technical Specifications ACTION:

a. With less than the above compliment of AC boards OPERABLE and energized, restore the inoperable boards to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. . .

ITS - Electrical Systems Current Technical Specifications LCO 3.8.2.3 The following DC vital battery channels shall be energized and OPERABLE:

CHANNEL I Consisting of 125 VDC board I, 125 VDC battery bank No. I and a full capacity charger.

CHANNEL II Consisting of 125 VDC board II, 125 VDC battery bank No. II and a full capacity charger.

CHANNEL III Consisting of 125 VDC board III, 125 VDC battery bank No. III and a full capacity charger.

CHANNEL IV Consisting of 125 VDC board IV, 125 VDC battery bank No. IV and a full capacity charger.

APPLICABILITY: MODES 1, 2, 3, and 4.

ITS - Electrical Systems Current Technical Specifications ACTION:

a. With one 125 VDC board inoperable, restore the inoperable board to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. . .

ITS - Electrical Systems Proposed Technical Specifications LCO 3.8.9 Train A and Train B AC, vital DC, and AC vital electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ITS - Electrical Systems Proposed Technical Specifications ITS - Electrical Systems Proposed Technical Specifications ITS - Electrical Systems Summary Changes to the SQN TSs are required to facilitate 6.9 kV and 480 V Shutdown Board maintenance activities.

Additional Actions for inoperable AC power sources (or de-energized boards) on the opposite unit have been developed.

The new LCO 3.8.1 Actions will require declaring required features supported by the inoperable AC power source inoperable when redundant features are also inoperable, with a backstop of 7 days.

The new LCO 3.8.9 Actions will require declaring the required features supported by the de-energized board inoperable immediately.