ML18313A239

(Vcsns), Unit 1 - Technical Specification Bases Revisions Updated Through October 2018

ML18313A239
Person / Time
Site:	Summer
Issue date:	11/09/2018
From:	Lippard G South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML18313A239 (9)

Text

A SCANA COMPANY George A. Lippard Vice President, Nuclear Operations 803.345.4810 November 9, 2018 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 TECHNICAL SPECIFICATION BASES REVISIONS UPDATED THROUGH OCTOBER 2018 In accordance with Virgil C. Summer Nuclear Station (VCSNS) Unit 1 Technical Specifications (TS) 6.8.414, South Carolina Electric & Gas Company, acting for itself and as agent for South Carolina Public Service Authority, submits revisions to the TS Bases.

This update includes changes to the TS Bases since the previous submittal in December 2017.

The enclosed changes revised by Bases Revision Notices (BRN)18-001, BRN 18-002, BRN 18-003 and BRN 18-004 were implemented under the provision of 10 CFR 50.59. Changes are annotated by vertical revision bars and the BRN number at the bottom of the affected TS Bases page.

If you have any questions or require additional information, please contact Michael Moore at (803) 345-4752.

WCM/GAL/bb Attachment I: Summary of Bases Changes Attachment II: Technical Specification Bases Revisions Updated Through October 2018 c:

J. E. Addison W. K. Kissam J. B. Archie J. H. Hamilton G. J. Lindamood W. M. Cherry C. Haney S. A. Williams NRC Resident Inspector K. M. Sutton NSRC RTS (RR 8925, LTD 338)

File (813.20)

PRSF (RC-18-0120)

V. C. Summer Nuclear Station

• P. 0. Box 88

• Jenkinsville, South Carolina

• 29065

• F (803) 941-9776

• www.sceg.com

Document Control Desk Attachment I RR 8925 RC-18-0120 Page 1 of 2

SUMMARY

OF BASES CHANGES BRN No.18-001 TS Amendment No. 204 Description of Change: An administrative change was made to the Bases for Technical Specification (TS) subsection 3/4.6.1.1, "Reactor Building Spray System," correcting it to read 3/4.6.2.1. The typographical error in the numbering sequence was introduced during submittal of license amendment request (LAR) 08-00162.

Reason and Basis for Change: TS Bases subsection 3/4.6.2.1 was inadvertently submitted to the NRC in LAR 08-00162 as TS Bases subsection 3/4.6.1.1. The numbering sequence error was subsequently issued under License Amendment No. 204. The sequencing number change was a typographical error and did not change the order or the context of the information provided within the TS Bases subsection.

BRN No.18-002 Description of Change: This change relocated information from Technical Specifications Information / Relocation (TSR)-1011 to TS Bases section 3/4.1.3, "Movable Control Assemblies." The change was initiated by VCSNS Change Management Plan Number CR-10-00870, "Eliminate Technical Specification Interpretations." This change eliminated TSR-1011 and relocated the information to TS Bases section 3/4.1.3. The change also resulted in a new TS Bases page, B 3/4 1-5.

Reason and Basis for Change: This change implemented Action 019 of VCSNS Change Management Plan Number CR-10-00870 by relocating the information in TSR-1011 and eliminating the TSR. The relocated information from TSR-1011 was incorporated into TS Bases section 3/4.1.3. The information provided in the TSR-1011 summarized actions already captured in TS Surveillance Requirements 3/4.1.1.1, "Boration Control" and SR 3/4.1.3.6, "Control Rod Insertion Limits." The change was an administrative change that relocated information previously captured in TSR-1011 and incorporated it into the TS Bases section 3/4.1.3. The change was administrative nature and did not change TS Applicability, Actions, or Surveillance Requirements.

BRN No.18-003 Description of Change: This change relocated information captured in TS interpretation TSR-1003 by incorporating the information into TS Bases section 3/4.4.0, "Applicability" and deleting the TSR. The change was implemented under Action 010 of Change Management Plan Number CR-10-00870 with the relocated information incorporated into subsection 3.0.3 of TS Bases 3/4.0, "Applicability." The relocated information provided in the TSR was amplifying information regarding how to interpret the requirements of TS 3.0.3 regarding shutdown allowances. Examples were provided to assist plant operators and staff on how to calculate shutdown time allowances.

Reason and Basis for Change: This change relocated information from Technical Specifications Information / Relocation (TSR)-1003 to TS Bases section 3/4.0, "Applicability" subsection 3.0.3.

The change was initiated by Action 010 of VCSNS Change Management Plan Number

Document Control Desk Attachment I RR 8925 RC-18-0120 Page 2 of 2 CR-10-00870, "Eliminate Technical Specification Interpretations." The information in TSR-1003 provided amplifying details to TS Bases subsection 3.0.3 concerning shutdown allowances.

The change activity relocated this amplifying information captured in TS interpretation TSR-1003 from TS and incorporated the information into the TS Bases. The change was administrative nature and did not change TS Applicability, Actions, or Surveillance Requirements.

BRN No.18-004 Description of Change: This change relocated information captured in TS interpretation TSR-1035 by incorporating the information into TS Bases 3/4.8, "Electrical Power Systems."

The change was initiated by Action 014 of Change Management Plan Number CR-10-00870 to eliminate TSR-1035 from TS and relocate the information to TS Bases subsection 3/4.8.2.1, "DC Sources Battery Capacity." The activity was administrative in nature by incorporating amplifying information to TS Bases 3/4.8.2.1 regarding the operability of safety related batteries XAD-1A-ED and XAS-1B-ED when in a 58-cell configuration.

Reason and Basis for Change: This change relocated information from TSR-1035 to TS Bases section 3/4.8.2.1, "DC Sources Battery Capacity." The change was implemented under Action 014 of VCSNS Change Management Plan Number CR-10-00870, "Eliminate Technical Specification Interpretations." To meet the intent of the Change Management Plan, TSR-1035 was eliminated and the information relocated to TS Bases 3/4.8.2.1. The relocated information was provided amplifying information to the TS Bases concerning operability of safety related batteries XAD-1A-ED and XAS-1B-ED when in a 58-cell configuration. The activity was administrative in nature and did not change TS Applicability, Actions, or Surveillance Requirements.

Document Control Desk Attachment II RR 8925 RC-18-0120 Page 1 of 6 TECHNICAL SPECIFICATION BASES REVISIONS UPDATED THROUGH OCTOBER 2018 Revision Notice #

Date Approved Paaes Affected BRN 18-001 07/25/18 B 3/4 6-3 BRN 18-002 08/02/18 B 3/4 1-5 BRN 18-003 10/08/18 B 3/4 0-1 B 3/4 0-2 BRN 18-004 10/08/18 B 3/4 8-4

CONTAINMENT SYSTEMS BASES 3/4.6.1.7 REACTOR BUILDING VENTILATION SYSTEM The 36-inch containment purge supply and exhaust isolation valves are required to be closed during plant operation since these valves have not been demonstrated capable of closing during a LOCA or steam line break accident. Maintaining these valves closed during plant operations ensures that excessive quantities of radioactive materials will not be released via the containment purge system. To provide assurance that the 36-inch valves cannot be inadvertently opened, they are sealed closed in accordance with Standard Review Plan 6.2.4 which includes mechanical devices to seal or lock the valve closed, or prevent power from being supplied to the valve operator.

The use of the containment purge lines is restricted to the 6 inch purge supply and exhaust isolation valves since unlike the 36 inch valves the 6 inch valves will close during a LOCA or steam line break accident and therefore the site boundary dose guidelines of 10 CFR 100 would not be exceeded in the event of an accident during purging operations.

Periodic leakage integrity tests for purge supply and exhaust isolation valves with resilient material seals will be performed in accordance with the Containment Leakage Rate Testing Program.

3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS 3/4.6.2.1 REACTOR BUILDING SPRAY SYSTEM The OPERABILITY of the reactor building spray system ensures that reactor building depressurization and cooling capability will be available in the event of a steam line break. The pressure reduction and resultant lower containment leakage rate are consistent with the assumptions used in the accident analyses.

The reactor building spray system and the reactor building cooling system are redundant to each other in providing post accident cooling of the reactor building atmosphere. However, the reactor building spray system also provides a mechanism for removing iodine from the reactor building atmosphere and therefore the time requirements for restoring an inoperable spray system to OPERABLE status have been maintained consistent with that assigned other inoperable ESF equipment.

Management of gas voids is important to Containment Spray System OPERABILITY.

SUMMER-UNIT 1 B 3/4 6-3 Amendment No. 135, 204, BRN 18-001

REACTIVITY CONTROL SYSTEMS BASES 3/4.1.3.6 CONTROL ROD INSERTION LIMITS The limits on control banks sequence, overlap, and physical insertion as defined in the COLR, must be maintained because they serve the function of preserving power distribution, ensuring that the SDM is maintained, ensuring that ejected rod worth is maintained, and ensuring adequate negative reactivity insertion is available on trip. The overlap between control banks provides more uniform rates of reactivity insertion and withdrawal and is imposed to maintain acceptable power peaking during control bank motion.

If the control banks are found to be out of sequence or in the wrong overlap configuration, they must be restored to meet the limits. If control bank sequence or overlap configuration is not in accordance with the COLR, while in Modes 1 or 2, then verify SDM perTS 3.1.1.1 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or comply with the associated TS 3.1.1.1 action statements.

Operation beyond the LCO limits is allowed for a short time period in order to take conservative action because the simultaneous occurrence of either a LOCA, loss of flow accident, ejected rod accident, or other accident during this short time period, together with an inadequate power distribution or reactivity capability, has an acceptably low probability.

If the above action cannot be completed within the associated completion times, the plant must be brought to HOT STANDBY, where the LCO is not applicable. The allowed completion time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, for reaching HOT STANDBY from full power conditions in an orderly manner and without challenging plant systems.

SUMMER - UNIT 1 B 3/4 1-5 Amendment No. BRN 18-002

3/4.0 APPLICABILITY BASES The specification of this section provide the general requirements applicable to each of the Limiting Conditions for Operation and Surveillance Requirements within Section 3/4.

3.0.1 This specification defines the applicability of each specification in terms of defined OPERATIONAL MODES or other specified conditions and is provided to delineate specifically when each specification is applicable.

3.0.2 This specification defines those conditions necessary to constitute compliance with the terms of an individual Limiting Condition for Operation and associated ACTION requirement.

3.0.3 This specification delineates the measures to be taken for circumstances not directly provided for in the ACTION statements and whose occurrence would violate the intent of the specification. For example, Specification 3.5.2 requires two independent ECCS subsystems to be OPERABLE and provided explicit ACTION requirements if one ECCS subsystem is inoperable. Under the requirements of Specification 3.0.3, if both of the required ECCS subsystems are inoperable, within one hour measures must be initiated to place the unit in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. As a further example, Specification 3.6.2.1 requires two Reactor Building Spray Systems to be OPERABLE and provides explicit ACTION requirements if one spray system is inoperable. Under the requirements of Specification 3.0.3, if both of the required Reactor Building Spray Systems are inoperable, within one hour measures must be initiated to place the unit in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN in the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The phrase "within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action shall be initiated to place the unit in a MODE in which the specification does not apply..." shall be interpreted as follows: Within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of entering LCO 3.0.3, action shall be taken to prepare the plant for an orderly shutdown. This may include activities such as reviewing procedures, conducting pre-job briefings and calling in additional personnel. An actual power reduction is allowed but not required during this 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Action shall be taken to reduce turbine generator load to ensure that the plant is in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The load reduction shall be at a rate determined by the Shift Manager and shall be a controlled reactor shutdown. The total permissible time from initial entry into LCO 3.0.3 until the unit enters HOT STANDBY is therefore 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.

Shutdown Time Allowance: It is acceptable to initiate and complete a reduction in OPERATIONAL MODES in a shorter time interval than required by the allowable out-of-service time specified in an ACTION Statement and then to add the unused portion of this allowable out-of-service time to that provided for operation in a lower OPERATIONAL MODE. A stated allowable out-of-service time shall be applicable regardless of the OPERATIONAL MODE in which the inoperability is discovered. However, the times provided for achieving a reduction in OPERATIONAL MODES shall not be applicable if the inoperability is discovered in a lower OPERATIONAL MODE.

Voluntary entry into 3.0.3 shall not be made except in circumstances where entry will result in an overall improvement in plant safety.

SUMMER-UNIT 1 B 3/4 0-1 Amendment No. BRN 18-003

APPLICABILITY BASES For example, Technical Specification 3.6.2.1 requires two independent reactor building spray systems be OPERABLE in MODES 1,2,3 and 4. The ACTION Statement for this LCO states: "With one reactor building spray system inoperable, restore the inoperable spray system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore the inoperable spray system to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />." This ACTION Statement provides up to 156 (72 + 6 + 48 + 30) hours to achieve COLD SHUTDOWN if a reactor building spray system is discovered inoperable while in MODES 1 or 2.

If the inoperability is discovered in MODE 1 and HOT STANDBY is reached in 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, 140 ([72 + 6 - 16] + 48 + 30) hours remain before being required to attain COLD SHUTDOWN (MODE 5).

If the inoperability is discovered in MODE 3, the 6-hour interval provided for achieving HOT STANDBY cannot be added to the 72-hour, 48-hour, and 30-hour intervals. Therefore, COLD SHUTDOWN would have to be attained within 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> (72 + 48 + 30).

If the inoperability is discovered in MODE 4, neither the 6-hour interval nor the 48-hour interval can be added to the 72-hour and 30-hour intervals. Therefore, COLD SHUTDOWN would have to be attained within 102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br /> (72 + 30).

3.0.4 This specification provides that entry into an OPERATIONAL MODE o other specified applicability condition must be made with (a) the full complement of required systems, equipment or components OPERABLE and (b) all other parameters as specified in the Limiting Conditions for Operation being met without regard for allowable deviations and out of service provisions contained in the ACTION statements.

The intent of this provision is to insure that facility operation is not initiated with either required equipment or systems inoperable or other specified limits being exceeded.

Exceptions to this provision have been provided for a limited number of specifications when startup with inoperable equipment would not affect plant safety. These exceptions are stated in the ACTION statements of the appropriate specifications.

4.0.1 Technical Specification 4.0.1 establishes the requirement that surveillance requirements (SR) must be met during the MODES or other specified conditions in the Applicability for which the requirements of the LCO apply, unless otherwise specified in the individual SRs. This specification is to ensure that surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits.

Failure to meet a SR within the specified frequency, in accordance with 4.0.2, constitutes a failure to meet an LCO.

SUMMER - UNIT 1 B 3/4 0-2 Amendment No. BRN 04 001 BRN 18-003

ELECTRICAL POWER SYSTEMS BASES A.C. SOURCES. D.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS (Continued)

The Surveillance Requirement for demonstrating the OPERABILITY of the Station batteries are based on the recommendations of Regulatory Guide 1.129, "Maintenance Testing and Replacement of Large Lead Storage Batteries for Nuclear Power Plants," February 1978, and IEEE Std 450-1987, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations."

Both Class 1E 125 Vdc System batteries XBA1A-ED and XBA1B-ED have sufficient capacity and voltage to ensure operability of essential (ESF) Class 1 E AC equipment/components with a reduced battery size of 58 cells, providing Technical Specification limits are maintained.

When a determination is made that an individual battery cell is inoperable and the inoperable cell needs to be removed from service, the battery is considered to be inoperable until the inoperable cell is removed from the battery either by bypassing the inoperable cell with a jumper or complete disconnection and removal of the inoperable cell. Justification of operability with 58 cells connected is based on the results of evaluations documented by G/C Calculations DC-832-005 (Revision 5), DC-832-010 (Revision 4), DC-832-016 (Revision 0); VCSNS DC08320-005 and DC08320-020; and FSAR Section 8.3.2.1.3.

Verifying average electrolyte temperature above the minimum for which the battery was sized, total battery terminal voltage and float charge, connection resistance values and the performance of battery service and discharge tests ensures the effectiveness of the charging system, the ability to handle high discharge rates and compares the battery capacity at that time with the rated capacity.

Table 4.8-2 specifies the normal limits for each designated pilot cell and each connected cell for electrolyte level, float voltage and specific gravity. The limits for the designated pilot cells float voltage and specific gravity, greater than 2.13 volts and.015 below the manufacturer's full charge specific gravity or a battery charger current that had stabilized at a low value, is characteristic of a charged cell with adequate capacity. The normal limits for each connected cell for float voltage and specific gravity, greater than 2.13 volts and not more than.020 below the manufacturer's full charge specific gravity with an average specific gravity of all the connected cells not more than.010 below the manufacturer's full charge specific gravity, ensures the OPERABILITY and capability of the battery.

Operation with a battery cell's parameter outside the normal limit but within the allowable value specified in Table 4.8-2 is permitted for up to 7 days. During this 7 day period: (1) the allowable values for electrolyte level ensures no physical damage to the plates with an adequate electron transfer capability; (2) the allowable value for the average specific gravity of all the cells, not more than.020 below the manufacturer's recommended full charge specific gravity, ensures that the decrease in rating will be less than the safety margin provided in sizing; (3) the allowable value for an individual cell's specific gravity, ensures that an individual cell's specific gravity will not be more than.040 below the manufacturer's full charge specific gravity and that the overall capability of the battery will be maintained within an acceptable limit; and (4) the allowable value for an individual cell's float voltage, greater than 2.07 volts, ensures the battery's capability to perform its design function.

SUMMER - UNIT 1 B 3/4 8-4 Amendment No. 38, 115, 137, 164, 178, BRN 18-004