NL-17-0058, Request to Revise Technical Specifications LCO 3.7.9 for a Change to Support Nuclear Service Cooling Water Transfer Pump Repairs
| ML17083B097 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/24/2017 |
| From: | Hutto J Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-17-0058 | |
| Download: ML17083B097 (22) | |
Text
~ Southern Nuclear J. J. Hutto Regulatory Affairs Director 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 5872 tel 205 992 7601 fax jjhutto@southernco.com lft41R 2 4 2017 Docket Nos.: 50-424 NL-17-0058 50-425 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant- Units 1 and 2 Request to Revise Technical Specifications LCO 3.7.9 for a Change to Support Nuclear Service Cooling Water Transfer Pump Repairs Ladies and Gentlemen:
Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company hereby requests an amendment to Vogtle Electric Generating Plant (VEGP) Unit 1 Operating License NPF-68 and Unit 2 Operating License NPF-81. The proposed change revises Technical Specifications (TS)
Limiting Condition for Operation (LCO) 3.7.9, "Ultimate Heat Sink (UHS)" to extend the Completion Time to restore one inoperable nuclear service cooling water (NSCW) basin transfer pump from 31 days to 46 days. In addition, a new Condition is added to address two inoperable NSCW basin transfer pumps.
The proposed amendment is needed because the 31 day Completion Time is not adequate to remove an NSCW basin transfer pump from service for refurbishment during normal operation. In addition, the proposed amendment is needed to avoid an unnecessary shutdown in the event of two inoperable NSCW basin transfer pumps. SNC requests approval of the proposed license amendment by August 15, 2017, to support the planned refurbishment of the 1A NSCW transfer pump, as well as future maintenance activities. The proposed change would be implemented 90 days after issuance of the amendment. contains a description of the proposed change, the supporting engineering analysis and the no significant hazards determination. Enclosure 2 contains the marked-up TS pages, and provides the clean-typed TS pages. Enclosure 4 contains the marked-up TS Bases pages marked to show the proposed change for information only.
This letter contains no NRC commitments.
If you have any questions, please contact Ken McElroy at 205.992.7369.
U. S. Nuclear Regulatory Commission NL-17-0058 Page 2 Mr. J. J. Hutto states he is Regulatory Affairs Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.
Respectfully submitted,
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J. J. Hutto )
Regulatory Affairs Director
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JJH/kgl/lc to and subscribed before me this Zll-~ay of {JI) a rc...,h , 2017.
My commission expires: 1/z./z.0/8 I
Enclosures:
- 1. Description and Assessment of Proposed Change
- 2. Marked-Up Technical Specifications Pages
- 3. Clean-Typed Technical Specifications Pages
- 4. Marked-up Technical Specification Bases Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bast, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President- Fleet Operations Mr. M.D. Meier, Vice President- Regulatory Affairs Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. B. J. Adams, Vice President- Engineering Mr. D. D. Sutton, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. M. D. Orenak, NRR Senior Project Manager- Vogtle 1 & 2 Mr. M. F. Endress, Senior Resident Inspector- Vogtle 1 & 2 State of Georgia Mr. R. E. Dunn, Director- Environmental Protection Division
Vogtle Electric Generating Plant- Units 1 and 2 Request to Revise Technical Specifications LCO 3.7.9 for a Change to Support Nuclear Service Cooling Water Transfer Pump Repairs Enclosure 1 Description and Assessment of Proposed Change
Enclosure 1 Description and Assessment of Change 1.0 Summary Description Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company hereby requests an amendment to Vogtle Electric Generating Plant (VEGP) Unit 1 Operating License NPF-68 and Unit 2 Operating License NPF-81. The proposed change would revise Technical Specifications (TS} Limiting Condition for Operation (LCO) 3.7.9, "Ultimate Heat Sink (UHS)" to extend the Completion Time of one inoperable nuclear service cooling water (NSCW) basin transfer pump from 31 days to 46 days. In addition, a new Condition is added to address two inoperable NSCW basin transfer pumps.
The proposed amendment is needed because the 31 day Completion Time is not adequate to remove an NSCW basin transfer pump from service for refurbishment during normal operation.
In addition the proposed amendment is needed to avoid an unnecessary shutdown in the event of two inoperable NSCW basin transfer pumps.
2.0 Detailed Description
2.1 System Description
The NSCW transfer pump is a column type design which is over 80 feet in length. There are numerous sets of seismic restraint pins spaced along the length of the pump. These pins fit into matching loops embedded into the wall of the NSCW tower basin. The alignment of these pins is so precise that the pump column mating flanges are line scribed (match marked) prior to disassembly so that when the columns are reassembled the pins and loops realign. Even with this precaution, divers are sometimes required to enter the water, loosen the column bolts, shimmy the pin into the loop and then retighten the column bolts. The seismic pins are roughly but not exactly 180 degrees apart on their respective flanges. When the pumps were installed approximately 30 years ago, the mating loops to the seismic pins were welded to the basin walls with the existing pump in place. Because of this custom fit, each pump is unique to its own basin and as a result removal and replacement is challenging.
The NSCW system provides cooling water for the containment coolers, control building essential chiller condensers, various engineered safety features (ESF) pump coolers, standby diesel generator jacket water coolers, and the component cooling water (CCW) and auxiliary component cooling water (ACCW) heat exchangers. The NSCW system transfers the heat removed from these systems to the Ultimate Heat Sink (UHS). The UHS consists of the NSCW mechanical draft cooling towers. Two 100-percent capacity redundant NSCW towers are provided for each generating unit, with one tower associated with each train of the NSCW system. Each NSCW tower consists of a basin containing the UHS water and an upper structure in which the NSCW heat loads are transferred to the atmosphere. The combined storage capacity of the two tower basins per unit provide sufficient cooling for at least 30 days, with no makeup water, assuming two-train operation for 1 day and single-train operation for the remaining 29 days. The design is based upon maximum conditions of dry and wet bulb temperatures as they affect peak basin temperature, tower evaporation losses and basin capacity.
E1-1 to NL-17-0058 Description and Assessment of Change The UHS provides a heat sink for process and operating heat from safety related components during a transient or accident, as well as during normal operation. This is done by utilizing the NSCW system and the Component Cooling Water (CCW) system. Each redundant NSCW tower consists of a basin that contains the UHS water supply and an upper structure that contains four individual fan spray cells where the heat loads are transferred to the atmosphere.
Each spray cell contains one safety-related temperature controlled fan. Instrumentation is provided for monitoring basin level and water temperature. The tower basins each contain a safety-related transfer pump to permit the use of the combined storage capacity of the basins.
The combined storage capacity of two tower basins provides greater than a 30 day cooling water supply assuming the worst combination of meteorological conditions and accident heat loads which maximize the tower heat load, basin temperature, and evaporative losses.
2.2 Current Technical Specification Requirements TS 3.7.9 requires the UHS to be OPERABLE in Modes 1, 2, 3, and 4. SR 3.7.9.4 requires verification of the NSCW basin transfer pumps in accordance with the lnservice Testing Program.
With one NSCW basin transfer pump inoperable, Action D requires either restoring the inoperable basin transfer pump to Operable status within 8 days or implementing an alternative method of basin transfer within 8 days and restoring the inoperable basin transfer pump to Operable status within 31 days. A Note to the 31 day Completion Time provides a one-time only allowance to restore the inoperable basin transfer pump to Operable status within 77 days.
This allowance was only permitted until January 23, 2017, during Vogtle Unit 2, Cycle 19.
The LCO 3.7.9 Bases state that the UHS is required to be OPERABLE and is considered OPERABLE if it contains a sufficient volume of water at or below the maximum temperature that would allow the NSCW to operate for at least 30 days following the design basis LOCA without the loss of net positive suction head (NPSH) and without exceeding the maximum design temperature of the equipment served by the NSCW. In order to meet these requirements, two NSCW tower basins are required OPERABLE with the following:
- 1. Basin water level must be ~ 80.25 feet as measured from the bottom of the basin,
- 2. Basin water temperature must be :::; gooF,
- 3. Two OPERABLE trains of NSCW tower fans/spray cells, each train with the required number of fans/spray cells, and
2.3 Need for Amendment Sometimes it is necessary to perform the pump refurbishment. Additional time is needed because of the complexity of the refurbishment which includes: decoupling the motor, removal of electrical and cooling water connections, removal of physical interferences within the cooling tower, removal of the pump from the cooling tower via a roof plug, sending the pump off site for refurbishment, installing the refurbished pump in the cooling tower, mounting the motor to the pump casing, making all the electrical and cooling water connections, running the motor E1-2 to NL-17-0058 Description and Assessment of Change uncoupled, coupling the motor to the pump, alignment, and finally performing a coupled run of the motor and pump.
The typical duration for a NSCW transfer pump refurbishment includes approximately 4 days for removal, 21 days for refurbishment, and 6 days for reinstallation. The work is estimated to take all 31 days of the Completion Time for LCO Condition 3.7.9., Required Action 0.2.2. Recent refurbishments have taken between 33 and 37 days. The 15 day increase in Completion Time is requested to cover uncertainties in the refurbishment schedule.
The proposed amendment is needed because the 31 day Completion Time is not adequate to remove an NSCW basin transfer pump from service for refurbishment during normal operation.
A new Condition is added to address two inoperable NSCW basin transfer pumps to avoid an unnecessary shutdown in the event of two inoperable NSCW basin transfer pumps.
2.4 Proposed Technical Specification Change TS 3.7.9, Condition D The proposed change revises TS 3.7.9, Condition D and Required Actions. Required Action 0.1 and associated Completion Time are being deleted because restoring the NSCW basin transfer pump to Operable status (i.e., restoring the LCO) is always an option per LCO 3.0.2.
Required Action 0.2.1 Completion is being relabeled as 0.1.
Required Action 0.2.2 is being relabeled as 0.2, the Note above the Completion Time which currently states "A one-time change of the Completion Time to 77 days is permitted until January 23, 2017 during Vogtle Unit 2, Cycle 19." is being deleted and the Completion Time is being changed from 31 days to 46 days.
TS 3.7.9, ConditionE The proposed change also adds a new Condition E to address two inoperable NSCW basin transfer pumps and existing Condition E and associated Required Actions are being relabeled and renumbered accordingly. Proposed Required Action E.1 requires implementing one alternate method of NSCW basin transfer within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and proposed Required Action E.2 requires restoring one NSCW basin transfer pump to Operable status within 8 days.
The safety function of the UHS can be maintained for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with both NSCW basin transfer pumps inoperable because there is adequate capacity in each NSCW tower basin for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of an accident assuming the worst combination of meteorological conditions and accident heat loads. Following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, a method of transferring water to the applicable basin is needed to ensure the UHS can provide adequate cooling for at least 30 days. Also, the proposed 24-hour Completion Time is needed to allow time to implement one alternate method.
This Completion Time is considered acceptable based on the NSCW basin capacity, the fact that the procedures will be initiated to establish an alternate method of basin transfer, and the low probability of an event during this brief period.
A Completion Time of 8 days is proposed to restore one NSCW transfer pump to Operable status to limit the time a credited method of basin transfer is unavailable and is considered E1-3 to NL-17-0058 Description and Assessment of Change reasonable based on the availability of alternate methods, the time available before basin transfer function is required under the worst-case accident assumptions, and the low probability of an accident occurring during this time period.
3.0 Engineering Analysis 3.1 Defense-in-Depth During the time both NSCW transfer pumps are out of service, the required fans, basin level, and basin temperature are maintained within the limits of the TS. Consequently, should an event occur requiring the NSCW system and the UHS, either train is capable of performing its safety function of providing cooling water for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with no basin transfer capability.
With one Operable NSCW train or an alternate method of basin transfer capability, the UHS is capable of providing the safety function up to 30 days, assuming no additional failures. This is inherent in the current TS 3.7.9, Required Action D.2.1, in that a compensatory measure for an alternate method of basin transfer is required to be implemented within 8 days; if such method is not available, the current 31 day Completion Time (CT) cannot be used. In such a situation, an 8 day CT would be in effect per current TS 3.7.9, Required Action D.1. If the 8 day CT is not met, the unit is placed in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Although not required, additional methods of basin transfer capability are available (in addition to the required alternate method per the current 3.7.9 Required Action D.2.1) and can be implemented to provide water to the affected NSCW cooling tower basin thereby providing additional defense-in-depth with both NSCW transfer pumps out of service.
3.2 Safety Margins The proposed TS change is consistent with the principle that sufficient safety margins are maintained based on the following:
Codes and standards (e.g., American Society of Mechanical Engineers (ASME), Institute of Electrical and Electronic Engineers (IEEE) or alternatives approved for use by the NRC) are met. The proposed change is not in conflict with approved codes and standards relevant to the NSCW system.
The NSCW system and the UHS have sufficient capacity to function for design basis accidents. Assuming no additional failures, the FSAR acceptance criteria for the design events will be met should such an event occur during the time that one or both NSCW transfer pumps are out of service.
3.3 Compensatory Measures To satisfy the requirements for current TS 3.7.9, Required Action D.2.1, an alternate method of basin transfer is implemented within 8 days to allow 31 days to restore an inoperable NSCW transfer pump. The alternate method utilizes an NSCW pump from the opposite train, the NSCW cross-tie fill connection, and a 6 inch hose staged for routing along the ground to the affected NSCW cooling tower. This compensatory measure ensures that a 30-day inventory of NSCW water is available during a design basis accident.
E1-4 to NL-17-0058 Description and Assessment of Change A simplified drawing of a typical train of the NSCW system, which shows the alternate method of basin transfer, is provided at the end of this enclosure.
The alternative means for NSCW water transfer consist of routing a six inch fire hose from the opposite NSCW cooling tower basin to the affected NSCW cooling tower basin. The fire hose is connected to the opposite NSCW train cross pumping flange and routed to the affected NSCW cooling tower basin.
SNC has an outstanding action in the corrective action program to provide detailed actions for the alternative transfer source in a procedure, which will be completed prior to implementation of the proposed change. The actions instruct maintenance personnel to implement the alternative source transfer in the field and give operators clear instructional guidance in the event of an occurrence when the transfer system is called upon to perform its function. The actions involved for implementing the alternative transfer source include connecting a fire hose to NSCW piping and valve manipulation to allow water flow to the affected NSCW cooling tower. No additional maintenance or operator training is required.
3.4 Maintenance Rule Control It is not expected that additional out-of-service time for an NSCW transfer pump will adversely affect the performance of the NSCW transfer pumps or the NSCW system. The NSCW transfer pumps are included under the VEGP Maintenance Rule Program and function to transfer NSCW water between cooling water basins. Since the function of the pumps is to operate during a design basis accident (DBA) and the pumps are on standby the majority of the time, Maintenance Rule unavailability hours are exempt. The reliability of the pumps is tracked by quarterly 1ST testing. If adverse conditions exist, then 1ST testing is increased to monthly testing until the problem is identified and resolved. If the pre-established reliability performance criteria for the NSCW transfer pumps are exceeded, the pumps are evaluated for the 10 CFR 50.65(a)(1) actions, which requires increased management attention and goal setting in order to restore their performance to an acceptable level.
3.5 Risk The risk is low when an NSCW transfer pump is inoperable because current TS 3.7.9, Required Acton D.2.1 (proposed Required Action D.1) requires for the compensatory measures to be implemented within 8 days. Additionally, newTS 3.7.9, Required Action E.1 also requires for the compensatory measures to be implemented within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Shutting down the reactor to repair one or both NSCW basin transfer pumps with the subsequent start-up would introduce unnecessary transition risk. The VEGP NSCW system and the UHS are modeled in the Probabilistic Risk Assessment (PRA model). However, the NSCW transfer pumps are not included in the PRA model. This license amendment has been reviewed with respect to risk for VEGP. There is no impact on the core damage frequency (CDF) or large early release frequency (LEAF) as modeled in the PRA for VEGP as a result of this license amendment.
Existing capabilities provide reasonable assurance of successful water transfer by the necessary time, considering potential equipment problems that could broadly affect NSCW equipment (e.g., a fault in the affected train electrical distribution system). Repair capabilities and available supplemental equipment to ensure successful water transfer are provided as follows.
E1-5 to NL-17-0058 Description and Assessment of Change Repair Capabilities: NSCW cooling tower basin transfer is only needed in the event of a Design Basis Accident. Any needed repairs are completed expeditiously. Additionally, the electrical power to the Operable NSCW train is protected per plant procedures for the duration of the extension and work is limited to further ensure the reliability of the opposite train power.
Supplemental Equipment: If supplemental equipment is needed to transfer water from basin to basin, an already identified pump (hydraulically driven submersible pump) with sufficient pump head and comparable flow is available onsite. This pump is capable of pumping water from the bottom of either basin to the desired basin utilizing a separate already identified mechanical power source (diesel- hydraulic power skid). The use of supplemental equipment will be described in the operational guidance included in the procedure which governs the alternate means of transfer. This represents a defense-in-depth strategy which does not rely on like power sources to facilitate basin transfer.
4.0 Regulatory Analysis 4.1 Applicable Regulatory Requirements The design of the NSCW system and the Ultimate Heat Sink satisfies the criteria of 10 CFR 50.36, Technical Specifications", paragraph (c)(2)(ii), Criterion 3, which states the following:
"(ii) 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:
Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier."
The NSCW system and the Ultimate Heat Sink are described in the VEGP FSAR Sections 9.2.1 and 9.2.5.
The design of the NSCW System and the Ultimate Heat Sink satisfies the requirements of 10 CFR 50, Appendix A, General Design Criteria 44 which states, in part:
Criterion 44- Cooling Water "A system to transfer heat from structures, systems, and components important to safety, to an ultimate heat sink shall be provided. The system safety function shall be to transfer the combined heat load of these structures, systems, and components under normal operating and accident conditions.
Suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure."
E1-6 to NL-17-0058 Description and Assessment of Change Regulatory Position C.1 of RG 1.27 states the following with respect to cooling capacities of less than 30 days:
A cooling capacity of less than 30 days may be acceptable if it can be demonstrated that replenishment or use of an alternate water supply can be effected to assure the continuous capability of the sink to perform its safety functions, taking into account the availability of replenishment equipment and limitations that may be imposed on "freedom of movement" following an accident or the occurrence of severe natural phenomena.
4.2 No Significant Hazards Evaluation Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company hereby requests an amendment to Vogtle Electric Generating Plant (VEGP) Unit 1 Operating License NPF-68 and Unit 2 Operating License NPF-81. The proposed change would revise Technical Specifications (TS) Limiting Condition for Operation (LCO) 3.7.9, "Ultimate Heat Sink (UHS)", to extend the Completion Time to restore one inoperable nuclear service cooling water (NSCW) basin transfer pump from 31 days to 46 days. In addition, a new Condition is added to address two NSCW basin transfer pumps.
Southern Nuclear Operating Company (SNC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment", as discussed below:
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed amendment does not affect accident initiators or precursors nor adversely alter the design assumptions, conditions, and configuration of the facility. The proposed amendment does not alter any plant equipment or operating practices with respect to such initiators or precursors in a manner that the probability of an accident is increased.
The proposed amendment extends the time one NSCW basin transfer pump is allowed to be inoperable and provides remedial action requirements when two NSCW basin transfer pumps are inoperable. The proposed amendment does not involve a physical change to the NSCW system, nor does it change the safety function of the NSCW system or the equipment supported by the NSCW system. The UHS will remain capable of responding to a design basis event during the period of time both NSCW basin transfer pumps are unavailable. Additionally, an alternate method of NSCW cooling tower basin transfer will be implemented prior to the need for the transfer function during an accident when one or both NSCW basin transfer pumps are inoperable. As a result, the proposed amendment does not alter assumptions relative to the mitigation of an accident or transient event. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
E1-7 to NL-17 -0058 Description and Assessment of Change
- 2. Does the proposed change create the possibility of a new or different accident from any accident previously evaluated?
Response: No With respect to a new or different kind of accident, there are o proposed design changes to the NSCW system, cooling tower basin transfer system, or UHS; nor are there any changes in the method by which safety related plant structures, systems, and components perform their specified safety functions. The proposed amendment will not affect the normal method of plant operation or revise any operating parameters. No new accident scenarios, transient precursor, failure mechanisms, or limiting single failures will be introduced as a result of this proposed change.
The proposed amendment does not alter the design or performance of the NSCW system, cooling towers, basin transfer system, or UHS. The proposed amendment extends the time one NSCW basin transfer pump is allowed to be inoperable ad provides remedial actions when two NSCW basin transfer pumps are inoperable. The compensatory measures when two NSCW basin transfer pumps are inoperable are consistent with the compensatory measures allowed when one NSCW basin transfer pump is inoperable.
No changes are being proposed to the procedures that operate the plant equipment and the change does not have a detrimental impact on the manner in which plant equipment operates or response to an actuation signal.
Therefore, the proposed change will not create the possibility of a new or different accident previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The margin of safety is related to the ability of the fission product barriers to perform their design functions during and following an accident. These barriers include the fuel cladding, the reactor coolant system, and the containment. The performance of these fission product barriers will not be affected by the proposed change.
The proposed amendment extends the time one NSCW basin transfer pump is allowed to be inoperable and provides remedial action requirements when two NSCW basin transfer pumps are inoperable. The UHS will remain capable of responding to a design basis event during the extended time one inoperable NSCW basin transfer pump is unavailable and the brief period of time the NSCW basin transfer function is unavailable. An alternate method of NSCW cooling tower basin transfer will be implemented prior to the need for the transfer function during an accident. For these reasons, the NSCW system and the UHS will continue to be capable of transferring the combined heat load of structures, systems, and components important to safety under normal and accident conditions.
Therefore, the margin to the onsite and offsite radiological dose limits are not impacted by the proposed amendment and, thus the proposed change does not involve a significant reduction in a margin of safety.
E1-8 to NL-17-0058 Description and Assessment of Change 4.3 Conclusions 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 issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 Environmental Assessment SNC has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released off site, or (iii) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criteria 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 to be prepared in connection with the proposed amendment.
E1-9 to NL-17-0058 Description and Assessment of Change VEGP Unit 2 Simplified NSCW Drawing Basin B Basin A
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/.self! P~MP PUMPS PUMPS 6"
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fff 2,6,4 7_ 1,5,3 Pipe
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\I 1 T T J 24" Header 24" Header p 6" Pipe 6" 2HV-11651 I ~
Pipe (Butterfly Valve) Temporary 6" Fire Hose Project Project Class Class (approximately 330 feet) 313 424 NSCWB 2HV-11651 is a 6" flanged locked closed butterfly valve. The upstream side is project NSCWA Loads class 313 (Safety/Seismic) and the downstream side flange is project class 424 (Non Loads Safety/ Non Seismic). A non safety 6 inch flange with fire hose connection will be installed in the event that cross fill is needed. The normal NSCW header pressure is 120 PSIG and fire hose working pressure is 150 PSIG.
E1-10
Vogtle Electric Generating Plant- Units 1 and 2 Request to Revise Technical Specifications LCO 3.7.9 for a Change to Support Nuclear Service Cooling Water Transfer Pump Repairs Enclosure 2 Marked-Up Technical Specification Pages
UHS 3.7.9 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D. One NSCW basin D.1 Restore the transfer 8 days transfer pump pump to OPERABLE inoperable. status.
Q-..2-rl- Implement an alternate 8 days method of basin transfer.
AND NOTE D.2~ Restore the transfer A one time only pump to OPERABLE change of the status. Completion Time to 77 days is permitted until January 23, 2017 during Vogtle Unit 2, Cycle 19.
463+ days Vogtle Units 1 and 2 3.7.9-2 Amendment No. +79-(Unit 1)
Amendment No. +ea-(Unit 2}
UHS 3.7.9 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. Two NSCW basin E.1 lm(21ement an alternate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> transfer (2Um(2s method of basin transfer ino(2erable. for one NSCW basin transfer (2Um(2.
AND E.2 Restore one NSCW 8 days basin transfer (2Um(2 to OPERABLE status.
ef. Required Action and f.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND OR f.2 -------------NOTE------------
LCO 3.0.4.a is not UHS inoperable for applicable when entering reasons other than MODE4.
Conditions A, B, C, SF-OJ. ---------------------------------
or E.
Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Vogtle Units 1 and 2 3.7.9-3 Amendment No . .:t79-(Unit 1)
Amendment No. +e&-(Unit 2}
Vogtle Electric Generating Plant- Units 1 and 2 Request to Revise Technical Specifications LCO 3.7.9 for a Change to Support Nuclear Service Cooling Water Transfer Pump Repairs Enclosure 3 Clean-Typed Technical Specification Pages
UHS 3.7.9 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D. One NSCW basin D.1 Implement an alternate 8 days transfer pump method of basin transfer.
AND D.2 Restore the transfer 46 days pump to OPERABLE status.
E. Two NSCW basin E.1 Implement an alternate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> transfer pumps method of basin transfer inoperable. for one NSCW basin transfer pump.
AND E.2 Restore one NSCW 8days basin transfer pump to OPERABLE status.
F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND OR F.2 -------------NOTE------------
LCO 3.0.4.a is not UHS inoperable for applicable when entering reasons other than MODE4.
Conditions A, B, C, D, or ---------------------------------
E.
Be in MODE4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Vogtle Units 1 and 2 3.7.9-2 Amendment No. (Unit 1)
Amendment No. (Unit 2)
Vogtle Electric Generating Plant- Units 1 and 2 Request to Revise Technical Specifications LCO 3.7.9 for a Change to Support Nuclear Service Cooling Water Transfer Pump Repairs Enclosure 4 Marked-Up Technical Specification Bases Pages
UHS B 3.7.9 BASES (continued)
ACTIONS If one or more NSCW basins have a water temperature and/or water level not within the limits, action must be taken to restore the water temperature and level to within the limits within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of an accident occurring during the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the considerable cooling capacity still available in the basin(s), and the time required to reasonably complete the Required Action.
If one NSCW cooling tower has one required fan/spray cell inoperable when operating in the four fan/spray cell required region of Figure 3. 7 .9-1 , action must be taken to restore the inoperable fan/spray cell to OPERABLE status within 7 days.
The 7-day Completion Time provides an acceptable time for evaluating and repairing problems with a fan/spray cell without allowing the plant to remain in an unacceptable condition for an extended period of time, and is reasonable due to the availability of the redundant OPERABLE NSCW cooling tower, and due to the low probability of an event requiring all four NSCW cooling tower fans/spray cells .
If one NSCW cooling tower has one or more required fan(s)/spray cell(s) inoperable for reasons other than Condition B, action must be taken to restore the inoperable fan(s)/spray cell(s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of an accident occurring during the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the number of available fans/spray cells , and the time required to reasonably complete the Required Action.
0.1 0.2.1 and 0.24 I I If one NSCW basin transfer pump is inoperable, action must be taken to restore the pump to OPERABLE status or implement an alternate method of transferring the water fFGm to the affected cooling tower basin within 8 days and . If an alternate method is utilized, astion still must be taken to restore the transfer pump to OPERABLE status within 46J4 days.
(continued)
Vogtle Units 1 and 2 B 3.7.9-3 REVISION a+
UHS B 3.7.9 BASES ACTIONS 0.1. D.2.1. and 0.2.,..2. (continued)
The Completion Times are reasonable based on the low probability of an accident occurring during the time allowed to restore the pump or implement an alternate method, the availability of alternate methods, and the amol:IRt of time available te-before the basin transfer the water from oRe basiR to the etReffunction is required under the worst case accident assumptions.
E.1 and E.2.
If two NSCW basin transfer pumps are inoperable. an alternate method of transferring water to at least one cooling tower basin must be implemented within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least one NSCW basin transfer pump restored to OPERABLE status within 8 days.
The safety function of the UHS can be maintained for a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with both NSCW basin transfer pumps inoperable and no alternate method of transferring water from one cooling tower basin to the other. An alternate method of transferring water to the applicable basin must be implemented within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to ensure the UHS can provide adequate cooling for at least 30 days.
The Completion Time of E.1 is provided to allow time to implement an alternate method and is considered acceptable based on the remaining NSCW cooling tower basin capacity. the fact that procedures will be initiated to establish an alternate method of basin transfer. and the low probability of an event occurring during this brief period.
The Completion Time of E.2 is reasonable based on the availability of alternate methods. the time available before the basin transfer function is required under the worst case accident assumptions. and the low probability of an accident occurring during this time allowed to restore one NSCW basin transfer pump to OPERABLE status.
(continued)
Vogtle Units 1 and 2 B 3.7.9-4 REVISION~
UHS B 3.7.9 BASES (continued)
ACTIONS F.1 and F.2 If the Required Actions of Conditions A, B, C, ef-.0. or E are not completed within their associated Completion Times or if the UHS is inoperable for reasons other than described in Conditions A, B, C, ef-D, or E. the unit must be placed in a MODE in which overall plant risk is reduced . To achieve this status, the unit must be placed in at least MODE 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.
Required Action E.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
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.
(continued)
Vogtle Units 1 and 2 B 3.7.9-5 REVISION~