Letter Sequence Approval |
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EPID:L-2018-LLA-0081, License Amendment Request 17-001 Revision to Technical Specification 3.3.2. ESFAS Instrumentation (Approved, Closed) |
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Category:Memoranda
MONTHYEARML24019A0342024-01-30030 January 2024 Public Meeting Summary - 01-04-2024 - Comanche Peak LRA - Structures Monitoring Program ML23279A1052023-10-0606 October 2023 Memorandum from the Secretary to the Board and Parties ML22304A1912022-11-23023 November 2022 Aging Management Audit Plan Regarding the License Renewal Application Review ML22147A0932022-06-0606 June 2022 2021 Annual Assessment Public Meeting Summary ML21259A1492021-10-26026 October 2021 CPNPP, Unit Nos. 1 and 2 - Meeting Summary for Environmental Pre Submittal Meeting for Initial License Renewal Application on September 21, 2021 ML21259A1402021-10-0505 October 2021 Meeting Summary for Safety Pre Submittal Meeting for Initial License Renewal Application on September 21, 2021 ML21176A1292021-06-25025 June 2021 CPNPP FFD Inspection Doc Request 2021 ML21174A0942021-06-23023 June 2021 Reactor Trip on June 7, 2021 - Management Directive 8.3 Screening ML21140A3892021-05-24024 May 2021 Riv Column 1 EOC 2020 Public Meeting Summary ML21124A0052021-05-10010 May 2021 Memo for Environmental Pre-Submittal Meeting for Initial License Renewal Application ML19120A3382019-04-26026 April 2019 Memo to File Environmental Assessment and Finding of No Significant Impact for Luminant Generation Company, Llc'S Decommissioning Funding Plan Submitted in Accordance with 10 CFR 72.30(b) and 10 CFR 72.30(c) for Comanche Peak ISFSI ML18346A1832019-01-0606 January 2019 FO Closure Audit Summary ML18221A6322018-08-15015 August 2018 Eicb Safety Evaluation - Comanche Peak Nuclear Power Plant, Units 1 and 2, License Amendment Request to Revise Technical Specification 3.3.2 Engineered Safety Feature Actuation System Instrumentation Docket/Epid 000976/05000446/L-2018-LLA-0 ML18173A0082018-06-20020 June 2018 Cancelling Numerous Inspection Report Numbers ML16088A2042016-03-28028 March 2016 Memo T Bowers from s Ruffin, Technical Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations W/ Encl 2 (Template) ML16088A2052016-03-28028 March 2016 Enclosure 1 - (72.30 DFP Reviews to Be Completed 2015) - Memo T Bowers from s Ruffin, Technial Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations ML13045A4102013-02-15015 February 2013 2/28/13 Notice of Meeting Via Conference Call with Luminant to Discuss Generic Safety Issue 191, Assessment of Debris Accumulation on PWR (Pressurized-Water Reactor) Sump Performance, for Comanche Peak, Units 1 and 2 ML12299A4102012-11-0505 November 2012 Notice of Meeting with Luminant Generation Company, LLC, to Discuss Proposed License Request for Approval of Revised Spent Fuel Criticality Analysis to Update Comanche Peak, Units 1 and 2, Technical Specifications ML12306A3242012-11-0505 November 2012 Notice of Meeting with Luminant Generation Company LLC to Discuss Indirect License Transfers for Comanche Peak Nuclear Power Plant, Units 1 and 2 ML12286A2792012-10-18018 October 2012 Notice of Meeting with Luminant Generating Company LLC to Discuss Indirect License Transfers for Comanche Peak Nuclear Power Plant, Units 1 and 2 ML12216A2992012-08-27027 August 2012 9/13/12 Notice of Meeting with Luminant Generation Company LLC to Discuss Proposed License Request for Approval of Revised Spent Fuel Criticality Analysis to Update Comanche Peak, Units 1 and 2, Technical Specifications ML12191A1472012-07-11011 July 2012 8/6/12 Notice of Conference Call with Luminant to Discuss Proposed License Amendment Request to Revise TS 3.8.1, AC Sources - Operating, to Support Installation of Backup Transformer at Comanche Peak, Units 1 and 2 (TAC ME8615-ME8616) ML12171A1842012-06-11011 June 2012 6/26/12 Revised Notice of Meeting with Luminant Generation Company, LLC to Discuss Proposed License Amendment Request to Revise TS 3.8.1, AC Sources - Operating, to Support Installation of Backup Transformer at Comanche Peak, Units 1 and 2 ML1117302232011-06-29029 June 2011 Staff Review of the Comanche Peak Independent Spent Fuel Storage Installation Physical Security Plan and Verification of Additional Security Measures Incorporation ML1107401282011-03-15015 March 2011 3/17/11 Notice of Forthcoming Closed Meeting with Luminant Generation Company Via Conference Call to Discuss Generic Request for Additional Information Pertaining to Its Cyber Security Submittal ML1009105332010-04-0505 April 2010 U.S. Nuclear Regulatory Commission Staff Review of the Department of Homeland Security Consultation Reports ML1006010322010-03-0101 March 2010 Cy 2009 Baseline Inspection Completion ML0925404602009-09-10010 September 2009 Summary of Phone Call with Industry to Issues Related to Eccentricity of the Steam Generator Tube-to-Tubesheet Joints in the Finite Element Model Used for the Technical Basis of the Permanent Alternate Repair Criteria License Amendment Requ ML0919705782009-07-31031 July 2009 Summary of Category 1 Meeting with Luminant Generation Company LLC, Resolution of Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors ML0921000502009-07-31031 July 2009 Notice of Pre-Application Meeting with Luminant Generation Company LLC to Discuss Future Amendment Request to Revise Comanche Peak Units 1 and 2 Startup Transformer Completion Times ML0920203432009-07-22022 July 2009 Revised Conference Call with Luminant Generation Company, LLC, to Discuss Draft Request for Additional Information Re Generic Letter 2004-02, Dated May 11, 2009 ML0918207102009-07-0202 July 2009 Revised Notice of Meeting with Representatives of Luminant Generation Co., LLC, Comanche Peak to Discuss Draft Request for Information for Generic Letter 2004-02 Response ML0807400842008-03-14014 March 2008 Draft Regulatory Guide for Comment ML0724904812007-09-11011 September 2007 Notice of Meeting with Strategic Teaming and Resource Sharing (Stars) for Licensees of Comanche Peak, Diablo Canyon, Palo Verde, South Texas, and Wolf Creek Plants ML0720800042007-07-31031 July 2007 Memo to File Request for Additional Information Application for Order Approving Indirect Transfer of Control of Licenses & License Amendments to Reflect Proposed Licensee'S Name Change ML0713003582007-05-11011 May 2007 Notice of Meeting with Txu Generation Company LP, Regarding Proposed Transition to Westinghouse Methodology and Other Methodologies Specific to Comanche Peak Steam Electric Station (CPSES) and Power Uprate Application ML0630400142006-10-31031 October 2006 Notice of Forthcoming Meeting with Txu Generation Company, LP Re Radiological Consequences of Design-Basis Accidents for Comanche Peak Steam Electric Station ML0627202212006-10-13013 October 2006 Staff'S Review of the Revision to Technical Specification Surveillance Requirements 3.3.1.2 & 3.3.1.3, Reactor Trip System Instrumentation (RTS) ML0612805802006-06-30030 June 2006 Memo with Enclosures 1 and 2, - Trip Report Regarding Staff Observations Regarding Flume Testing of a Prototype Portion of the Proposed Replacement Suction Screen Design for the Comanche Peak Steam Electric Station ML0607302642006-03-0707 March 2006 Closure Memorandum: Issue for Resolution 2005-083: Evaluation: Part 21 - Engine Systems - Governor Drive Coupling Element ML0527802152005-10-0505 October 2005 Forthcoming Meeting with Txu Analytical Methodologies Supporting the Comanche Peak, Unit 1, Steam Generators Replacement Project ML0525803232005-09-15015 September 2005 Meeting with Strategic Teaming and Resource Sharing (Stars) for Licensees of Comanche Peak, Diablo Canyon, Palo Verde, South Texas, and Wolf Creek Plants ML0519301632005-07-14014 July 2005 Unit 2 - Closeout Letter for Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized-Water Reactors. ML0516003452005-06-14014 June 2005 Draft Information Memo - May 6 - May 27, 2005 ML0506104872005-03-23023 March 2005 Draft Information Memo - May 1, 2005 Thru May 27, 2005 ML0435701632005-01-24024 January 2005 Draft Information Memo - Inputs from March 2, 2004 Through March 31, 2004 ML0429402412004-10-25025 October 2004 Draft Information for June 1, 2004 to June 30, 2004 ML0426400682004-09-21021 September 2004 Draft Information Report from January 14 Thru February 26, 2004 ML0421103022004-08-19019 August 2004 Draft Information Memo for April, 2004 - Shirley ML0422602762004-08-12012 August 2004 Meeting Summary of the August 8, 2004 Public Workshop - Region IV Operator Licensing Feedback 2024-01-30
[Table view] Category:Safety Evaluation
MONTHYEARML23319A3872023-12-20020 December 2023 Issuance of Amendment Nos. 185 and 185 Regarding Implementation of Full Spectrum Loss-of-Coolant Accident (Fsloca) Methodology ML23313A0732023-12-0606 December 2023 Issuance of Amendment Nos. 184 and 184 Regarding Revision to Technical Specifications to Implement WCAP-17661-P-A, Rev. 1, Improved Roac and CAOC Fq Surveillance Technical Specifications ML23237B4282023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Enclosure 2, Draft Conforming License Amendments ML23237B4302023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Enclosure 4, Safety Evaluation for Transfer of Licenses and Draft Conforming License Amendments (EPID L-2023-LLM-0000) (Public) ML23198A3212023-07-27027 July 2023 Authorization and Safety Evaluation for Proposed Alternative RV-1 ML22192A0072022-08-22022 August 2022 Issuance of Amendment Nos. 183 and 183 Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-505, Revision 2 ML22194A0592022-07-14014 July 2022 Correction to Amendment Nos. 182 and 182 to Revise Technical Specifications to Adopt TSTF-577, Revision 1, Revised Frequencies for Steam Generator Tube Inspections ML22129A0722022-05-16016 May 2022 Review of Quality Assurance Program Changes ML22077A8412022-03-24024 March 2022 Proposed Alternative SNB-3 for the Snubber Inservice Program Third Interval Extension ML21321A3492022-02-24024 February 2022 Issuance of Amendment Nos. 182 and 182 to Revise Technical Specifications to Adopt TSTF-577, Rev. 1, Revised Frequencies for Steam Generator Tube Inspections ML21322A1032021-12-0707 December 2021 Proposed Alternative for the Continued Use of a Risk-Informed Process for the Selection of Class 1 and 2 Piping Welds for Inservice Inspection ML21132A0892021-06-0909 June 2021 Issuance of Amendment Nos. 181 and 181 Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-567, Rev. 1, Add Containment Sump TS to Address GSI - 191 Issues ML21061A2172021-05-19019 May 2021 Issuance of Amendment Nos. 180 and 180 to Authorize Revision of Certain Emergency Action Levels of the Emergency Plan ML21103A0392021-04-23023 April 2021 Issuance of Amendment Nos. 179 and 179 the Adoption of Technical Specifications Task Force Traveler, TSTF-569, Revision 2, Revise Response Time Testing Definition (EPID L-2020-0147) ML21015A2122021-02-12012 February 2021 Issuance of Amendment Nos. 178 and 178 Regarding One-Time Revision to Technical Specifications 3.7.8 Station Service Water System (Ssws) and 3.8.1 AC Sources - Operating ML21022A1622021-02-0808 February 2021 Proposed Alternative to the Requirements of the ASME OM Code to Extend the Inservice Testing Program Interval for Certain Check and Relief Valves (EPID L-2020-LLR-0096 (COVID-19)) ML20346A0192021-02-0101 February 2021 Issuance of Amendment Nos. 177 and 177 Regarding Revision to Technical Specifications 3.8.1, AC Sources - Operating ML21021A1002021-02-0101 February 2021 Proposed Alternative to the Requirements of the ASME OM Code to Extend the Inservice Testing Program Interval for Certain Snubbers (EPID L-2020-LLR-0095 (Covid 19)) ML21013A1282021-01-28028 January 2021 Approval of Proposed Alternative to the Requirements of the ASME Code to Extend the Third Inservice Inspection Interval (EPID L-2020-LLR-0092 (COVID-19)) ML21021A0022021-01-28028 January 2021 Approval of Proposed Alternatives 1A4-1 and 1A4-2 from Certain Requirements of 10 CFR 50.55a for Inservice Inspection of Nuclear Power Plants ML20282A7092020-11-17017 November 2020 Proposed Alternative to the Requirements of the ASME Omcode to Extend the Inservice Testing Program Interval for Certain Snubbers (EPID L-2020-LLR-0060 (COVID-19)) ML20281A4722020-11-0404 November 2020 Use of Later Code Edition to the Requirements of the ASME OM Code ML20255A1002020-10-0707 October 2020 Proposed Alternative to the Requirements of the ASME OM Code to Extend the Inservice Test Program Interval for Certain Check and Relief Valves (EPID L-2020-LLR-0061 and EPID L-2020-LLR-0062 (COVID-19)) ML20223A3492020-08-31031 August 2020 Issuance of Amendment Nos. 175 and 175 Regarding One-Time Revision to Technical Specification 3.7.19, Safety Chilled Water ML20226A0132020-08-17017 August 2020 Use of Later Code Edition to the Requirements of the ASME Code ML20167A3182020-07-0606 July 2020 Issuance of Amendment Nos. 174 and 174 Regarding Revision to Technical Specifications to Adopt TSTF-563, Revision 0 ML20108E8782020-04-17017 April 2020 Issuance of Amendment Nos. 173 and 173 Revision to TS 5.5.9, Unit 1 Model D76 and Unit 2 Model D5 Steam Generator (SG) Program (Exigent Circumstances) ML20054A2762020-02-27027 February 2020 Approval of Change to the Quality Assurance Program as Described in the Comanche Peak Nuclear Power Plant Final Safety Analysis Report ML19267A0182019-11-0404 November 2019 Issuance of Amendment Nos. 172 and 172 to Revise Augmentation Times and Emergency Response Organization Staffing for the Emergency Plan ML18304A4872018-11-30030 November 2018 Issuance of Amendments 171 and 171 Regarding Revision to Technical Specifications for Engineered Safety Feature Actuation System Instrumentation ML18267A3842018-10-25025 October 2018 Issuance of Amendment Nos. 170 and 170 Revision to Technical Specification 3.8.4, DC Sources - Operating, Condition B (Exigent Circumstances) ML18221A6322018-08-15015 August 2018 Eicb Safety Evaluation - Comanche Peak Nuclear Power Plant, Units 1 and 2, License Amendment Request to Revise Technical Specification 3.3.2 Engineered Safety Feature Actuation System Instrumentation Docket/Epid 000976/05000446/L-2018-LLA-0 ML17129A0242017-06-29029 June 2017 Comanche Peak Nuclear Power Plant, Units 1 and 2 - Issuance of Amendment Nos. 169 and 169 Re: Administrative Change to Licensee Name (CAC Nos. MF8933 and MF8934) ML17074A4942017-04-13013 April 2017 Issuance of Amendment Nos. 168 and 168 Adoption of TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing ML17095A2512017-04-0707 April 2017 Request for Alternative 2B3-1 Re Examination of Reactor Vessel Closure Head Penetration Nozzles ML16334A1732016-12-14014 December 2016 Comanche Peak Nuclear Power Plant, Units 1 And 2; Safety Evaluation Regarding Implementation Of Mitigating Strategies And Reliable Spent Fuel Pool Instrumentation Related To Orders EA-12-049 And EA-12-051 ML16179A4052016-07-11011 July 2016 Relief Request Nos. B-9, B-3, B-10, and B-11 for Piping Welds, Second 10-year Inservice Inspection Interval ML16137A0562016-06-14014 June 2016 Issuance of Amendment Nos. 166 and 166, Request to Revise Emergency Action Levels Based on Nuclear Energy Institute (NEI) 99-01, Revision 6 ML16096A2662016-05-0606 May 2016 Redacted Letter, Order, Safety Evaluation, and Draft Conforming Amendments, Application for Order Approving Direct and Indirect Transfer of Licenses and Conforming License Amendments ML16096A2642016-05-0606 May 2016 Draft Conforming Amendments, Application for Order Approving Direct and Indirect Transfer of Licenses and Conforming License Amendments ML16074A0012016-03-14014 March 2016 Relief Request 1B3-3, Alternative for Reactor Pressure Vessel Cold Leg Weld Inspection Frequency from Not to Exceed 7 Years to 9 Years for the Third 10-Year Inservice Inspection Interval ML16063A0012016-03-11011 March 2016 Relief Request No. B-15, C-2, and C-4 for Welds in the RPV and Containment Spray and Residual Heat Removal Heat Exchanger Shells, Second 10-year Inservice Inspection Interval ML16011A0732016-01-19019 January 2016 Relief Request T-1; Alternative to the ASME OM Code Frequency Specifications for Inservice Testing for the Third 10-Year IST Interval ML15309A0732015-12-30030 December 2015 Issuance of Amendment Nos. 165 and 165, Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, to Increase ILRT Test Interval from 10 to 15 Years and Type C Tests from 60 to 75 Mos ML15259A0042015-10-30030 October 2015 Relief Request 1B3-4, Alternative for Reactor Pressure Vessel Head Penetration Weld Inspection Frequency (from 10 to 15 Years), Third 10-Year Inservice Inspection Interval ML15257A2422015-09-18018 September 2015 Relief Request 2A3-1, from ASME Code Section XI Requirements, Risk-Informed Process for Selection of Class 1 and Class 2 Piping Weld Examinations, Third 10-Year Inservice Inspection Interval ML15257A2402015-09-15015 September 2015 Relief Request 2C3-1, from ASME Code, Section XI Requirements Reactor Pressure Vessel Leak-Off Flange for the Third 10-Year Inservice Inspection Interval ML15090A1042015-04-0303 April 2015 Relief Requests B-7, B-12, and B-13 - Steam Generator Head-to-Tube Sheet Welds for the Second 10-Year Inservice Inspection Interval ML15008A1332015-02-24024 February 2015 Issuance of Amendment Nos. 164 and 164, Revise Technical Specification 3.8.1 for a 14-Day Completion Time for Offsite Circuits ML14183A3422014-09-0808 September 2014 Issuance of Amendment Nos. 163 and 163 to Revise License Condition Related to Approval of Revised Cyber Security Plan Implementation Schedule 2023-09-28
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August 15, 2018 MEMORANDUM TO: Robert J. Pascarelli, Chief Plant Licensing Branch 4 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Rossnyev D. Alvarado, Acting Chief /RA/
Instrumentation and Controls Branch Division of Engineering Office of Nuclear Reactor Regulation
SUBJECT:
EICB SAFETY EVALUATION - COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (CAC/DOCKET/EPID 000976/05000445/L-2018-LLA-0081 and 000976/05000446/L-2018-LLA-0081)
Responsible PM: Margaret Watford Review Branch: EICB Review Status: COMPLETE By letter dated March 29, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18102A516), Vistra Operations Company, LLC (Vistra OpCo, the licensee) submitted a license amendment request (LAR) to revise the Comanche Peak Nuclear Power Plant, Units 1 and 2 (NPF-87 and NPF-89, respectively) Technical Specifications (TS).
The proposed changes would revise TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," by adding a note to Table 3.3.2-1 to change the applicability when the automatic auxiliary feedwater (AFW) actuation due to the trip of all main feedwater (MFW) pumps is required to be operable. In this amendment request, the licensee proposed to modify the Mode 2 applicability so that the AFW actuation is only required to be operable, [w]hen one or more Main Feedwater Pump(s) are supplying feedwater to steam generators.
The Instrumentation and the Controls Branch (EICB) has reviewed the instrumentation and controls aspects of the requested amendment. The EICB review, as discussed in the enclosed safety evaluation, determined the requested change is acceptable. This memorandum completes EICB review under EPID No. L-2017-LLA-0388.
Enclosure:
As stated CONTACT: Huda Akhavannik, NRR/DE/EICB Norbert Carte, NRR/DE/EICB (301) 415-5253 (301) 415-5890
ML18221A632 OFFICE: NRR/DE/EICB NRR/DE/EICB NRR/DE/EICB: BC NAME: HAkhavannik NCarte RAlvarado DATE: 07/16/2018 07/16/2018 08/15/2018 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR THE LICENSE AMENDMENT TO REVISE TECHNICAL SPECIFICATION 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION VISTRA OPERATIONS COMPANY, LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 446
1.0 INTRODUCTION
By letter dated March 29, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18102A516), Vistra Operations Company, LLC (Vistra OpCo, the licensee) submitted a license amendment request (LAR) to revise the Comanche Peak Nuclear Power Plant, Units 1 and 2 (NPF-87 and NPF-89, respectively) Technical Specifications (TS).
The proposed changes would revise TS 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation," by adding a note to Table 3.3.2-1 to change the applicability when the automatic auxiliary feedwater (AFW) actuation due to the trip of all main feedwater (MFW) pumps is required to be operable. Currently, the TS Table 3.3.2-1 requires automatic AFW Actuation from a Trip of both MFW Pumps to be operable in Modes 1 and 2. In this amendment request, the licensee proposed to modify the Mode 2 applicability so that the AFW actuation is only required to be operable, [w]hen one or more Main Feedwater Pump(s) are supplying feedwater to steam generators. This modification of applicability in Mode 2 limits the potential for a low power, overcooling transient due to inadvertent AFW actuation before the main feedwater pumps have established sufficient feed flow.
2.0 REGULATORY EVALUATION
The three subsections below describe: (1) the system being changed, (2) the proposed change, and (3) the regulatory requirements applicable to the change.
2.1 System Description The AFW System is designed to provide a secondary side heat sink for the reactor in the event that the normal feedwater system is not available. The AFW system has two motor driven pumps and a turbine driven pump. The normal source of water for the AFW System is the condensate storage tank.
The design basis events which impose AFW safety function requirements are: (1) loss of all AC power to plant auxiliaries, (2) loss of normal feedwater, (3) steam generator fault in either the feedwater or steam lines, and (4) small break loss of coolant accidents. These design basis events assume AFW automatically starts on a low-low steam generator level, station blackout, or safety injection. Section 3.0, Technical Evaluation, of the application states that the anticipatory AFW actuation function, which corresponds to Function 6.g of Table 3.3.2-1, is not credited in the accident analysis.
Enclosure
A trip of all MFW pumps is an indication of a loss of normal feedwater and the subsequent need for some method of heat removal to bring the reactor back to no load temperature and pressure.
Each turbine-driven MFW pump is equipped with two pressure switches (one in Train A and one in Train B) on the oil line for the speed control system. A trip signal from both MFW pumps anticipatory trip circuit would actuate the motor-driven AFW pumps to ensure that at least one steam generator is available with a water supply to act as the heat sink for the reactor.
Section 2.1, System Design and Operation, of the application describes the current operation for entering Mode 2 then transitioning to Mode 1. Currently, when entering Mode 2, the AFW system is in service to control and maintain steam generator level through motor-driven AFW pumps. At approximately 2 percent rated thermal power (RTP), a MFW pump is reset and placed into service. During the process of placing one MFW pump in service, the non-operating MFW pump is tripped by the pressure switches, which actuate the motor-driven AFW automatic start on loss of both MFW pumps, thereby placing the anticipatory automatic start circuit in a half trip condition (one-out-of-two inputs to the start logic satisfied). The MFW pump is considered to be in service when its flow is sufficient to maintain steam generator level and the AFW pumps are placed in standby. After entering Mode 1, the second MFW pump is reset and placed into service (approximately at 50 percent RTP), and the anticipatory automatic start circuit is no longer in a half trip condition (i.e., logic is restored to two-out-of-two).
The licensee states in Section 2.3, Reason for Proposed Change, of the application that if the first MFW pump being placed into service were to trip while the motor-driven AFW pump has not yet been placed in standby, an AFW automatic start would send a start signal to both motor-driven AFW pumps and cause the flow control valves to the steam generators to "trip-to-auto" which opens them to 100% demand. This results in the potential for a low power, overcooling transient.
2.2 Description of Proposed Change This amendment requests adding a new footnote d to Function 6.g of Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation. Footnote d modifies Mode 2 applicability so that the AFW actuation is required [w]hen one or more Main Feedwater Pump(s) are supplying feedwater to steam generators. The associated TS Bases will be updated to state, Function 6.g must be OPERABLE in MODE 1, and MODE 2 when the MFW pump(s) are feeding the steam generators and the AFW system has been placed in standby for auto-startIn MODE 2, when the MFW pump(s) are not feeding the steam generators, this function is not required as the AFW system is operating to feed the steam generators and does not require the auto-start from this function.
This amendment requests changes to the limiting conditions for operation (LCOs) with respect to the mode of applicability. In particular, in Mode 2, the AFW actuation is required to be OPERABLE only when the MFW pump(s) are supplying water to the steam generators.
2.3 Applicable Regulatory Requirements The NRCs requirements related to the content of the TSs are contained in Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.36. The regulations in 10 CFR 50.36(c) require that the TSs include LCOs. As specified in 10 CFR 50.36(c)(2)(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility.
Appendix A to 10 CFR Part 50 list the General Design Criteria for Nuclear Power Plants (GDC):
GDC 20, Protection system functions, requires the protection system to be designed to initiate automatically the operation of appropriate systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences.
GDC 22, Protection system independence, requires that, [d]esign techniques, such as functional diversity or diversity in component design and principles of operation, shall be used to the extent practical to prevent loss of the protection function.
GDC 29, Protection against anticipated operational occurrences, requires that protection systems be designed to assure an extremely high probability of accomplishing their functions in the event of anticipated operational occurrences.
3.0 TECHNICAL EVALUATION
3.1 Technical Specification Changes The amendment requests that the anticipatory AFW automatic start function should not be required to be operable prior to the MFW pump establishing sufficient feed flow to maintain steam generator level and prior to the AFW system being placed in standby for automatic start.
That is, this proposed change request removes the anticipatory AFW automatic start function, before the MFW pump is supplying water to the SGs. This is being requested to minimize the possibility of an inadvertent actuation of the AFW automatic start function when it is neither required by plant conditions nor desired for stable plant control.
Section 3, Technical Evaluation, of the application describes that, if actuated, the automatic start function sends a start signal to both motor-driven AFW pumps and causes the flow control valves to the steam generators to trip-to-auto, opening them to 100 percent demand. This 100 percent demand flow may not be prudent because during the period of time between entering Mode 2 and the first MFW pump supplying feedwater to steam generators, the motor-driven AFW pumps are already feeding the steam generators with flow controlled by the operator.
Therefore, modifying the requirement for automatic start of the motor-driven AFW pumps to be required only when one or more MFW pump(s) are feeding steam generators, limits the potential for an inadvertent AFW actuation thereby limiting the potential for a low power, overcooling transient. In the event of a loss of the MFW pump in Mode 2, an AFW actuation would automatically occur on a low-low SG trip signal for applicable design basis events (DBEs) that require the AFW function to mitigate the event consequences. Therefore, the NRC staff determines that the proposed TS changes continue to meet the 10 CFR 50.36.
3.2 Compliance with GDCs 20, 22, and 29 Requirements As required by GDC 20, the automatic initiation of an appropriate system is necessary to assure acceptable fuel design limits when normal feedwater flow is lost. For this modification, the automatic start on low-low steam generator water level of the turbine-driven AFW pump assures acceptable fuel design limits are maintained when normal feedwater flow is lost.
As required by GDC 22, to prevent loss of the heat sink protective function, the credited actuation function corresponding to the steam generator low-low water level will actuate the turbine-driven AFW pumps.
As required by GDC 29, the ESFAS continues to maintain functionality in the event of anticipated operational occurrences (when the protective function is needed). Although the auto-start function from the anticipatory motor-driven AFW actuation circuit is removed, it is done while AFW from the motor-driven pumps is already feeding the steam generators. In the event of an operational occurrence, the steam generator low-low water level for the turbine-driven AFW pumps will actuate.
4.0 CONCLUSION
The NRC staff concludes the proposed change to add new footnote d to Table 3.3.2-1 is acceptable because it reduces the likelihood of inadvertent overcooling during startup by preventing the automatic start of all AFW pumps with flow control valves opening to 100 percent demand while the flow control is being controlled by the operator prior to the MFW pumps supplying water to the steam generators during Mode 2. Additionally, either operator control or the automatic low-low steam generator water level signal would start the AFW pumps if needed to ensure an adequate secondary side heat sink. Staff finds that this change meets the regulatory requirements described in 10 CFR 50.36 and GDCs 20, 22, and 29 as described in section 2.3 of this SE. Therefore, the staff finds the proposed change acceptable.