NL-18-1302, License Amendment Request for Technical Specification Improvement to Revise Actions for One Steam Supply to Turbine Driven Auxiliary Feedwater Pump Inoperable Using the Consolidated Line ...

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License Amendment Request for Technical Specification Improvement to Revise Actions for One Steam Supply to Turbine Driven Auxiliary Feedwater Pump Inoperable Using the Consolidated Line ...
ML18353B056
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 12/19/2018
From: Gayheart C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-18-1302
Download: ML18353B056 (24)
v • d • e


Text

3535 Colonnade Parkway

.. Southern Nuclear Cheryl A. Gayheart Regulatory Affairs Director Birmingham, AL 35243 205 992 5316 tel 205 992 7601 fax cagayhea@southernco com DEC 1 9 2018 NL-18-1302 Docket Nos.: 50-424 50-425 U.S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington , D. C. 20555-0001 Vogtle Electric Generating Plant- Units 1 and 2 License Amendment Request for Technical Specification Improvement to Revise Actions for One Steam Supply to Turbine Driven Auxiliary Feedwater Pump Inoperable using the Consolidated Line Item Improvement Process Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90 of Title 10 of the Code of Federal Regulations (1 0 CFR), Southern Nuclear Operating Company (SNC) is submitting a request for an amendment to the technical specifications (TS) for Vogtle Electric Generating Plant (VEGP),

Units 1 and 2.

The proposed amendment establishes Conditions, Required Actions, and Completion Times in the TS for the Condition where one steam supply to the turbine driven Auxiliary Feedwater (AFW) pump is inoperable concurrent with an inoperable motor driven AFW train. In addition, this amendment establishes changes to the TS that establish specific Actions: ( 1) for when two motor driven AFW trains are inoperable at the same time and; (2) for when the turbine driven AFW train is inoperable either (a) due solely to one inoperable steam supply, or (b) due to reasons other than one inoperable steam supply. The change is consistent with NRC-approved Technical Specification Task Force (TSTF) Traveler, TSTF-412, Revision 3, "Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable." The availability of this technical specification improvement was announced in the Federal Register on July 17, 2007 as part of the consolidated line item improvement process (CLIIP). provides a description of the proposed changes and confirmation of applicability. provides the existing TS pages marked-up to show the proposed changes. provides the clean typed TS pages to show the proposed changes. provides the existing TS Bases pages marked-up to reflect the proposed changes (information only).

U.S. Nuclear Regulatory Commission NL-18-1302 Page 2 SNC requests approval of the proposed license amendment by December 31,2019. The proposed changes will be implemented within 90 days of issuance of the amendment.

This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611 .

I declare under penalty of perjury that the foregoing is true and correct. Executed on the

\q'fb.- day of December 2018.

Respectfully submitted, art Director, Regulatory Affairs Southern Nuclear Operating Company CAG/tle/scm

Enclosures:

1. Description and Assessment
2. VEGP Technical Specification Marked Up Pages
3. VEGP Technical Specification Clean Typed Pages
4. VEGP Technical Specification Bases Marked Up Pages (Information Only) cc: Regional Administrator, Region II NRR Project Manager- VEGP 1 and 2 Senior Resident Inspector- VEGP 1 and 2 State of Georgia Environmental Protection Division RType: CVC7000

Vogtle Electric Generating Plant - Units 1 and 2 License Amendment Request for Technical Specification Improvement to Revise Actions for One Steam Supply to Turbine Driven Auxiliary Feedwater Pump Inoperable using the Consolidated Line Item Improvement Process Enclosure 1 Description and Assessment to NL-18-1302 Description and Assessment Description and Assessment

1.0 DESCRIPTION

The proposed license amendment establishes a new Completion Time for Technical Specifications Section 3.7.5 where one steam supply to the turbine driven AFW pump is inoperable concurrent with an inoperable motor driven AFW train. This amendment also establishes specific Conditions and Action requirements: (1) for when two motor driven AFW trains are inoperable at the same time, and; (2) for when the turbine driven AFW train is inoperable either (a) due solely to one inoperable steam supply, or (b) due to reasons other than one inoperable steam supply.

The changes are consistent with NRC approved lndustryfTechnical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-412, Revision 3, "Provide Actions for One Steam Supply to Turbine Driven AFW Pump Inoperable." The availability of this technical specification improvement was announced in the Federal Register on July 17, 2007 (72 FR 39089) as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Southern Nuclear Operating Company (SNC) has reviewed the safety evaluation published on July 17, 2007 (72 FR 39089) as part of the CLIIP. This verification included a review of the NRC staffs evaluation as well as the supporting information provided to support TSTF-412, Revision 3. SNC has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Vogtle Electric Generating Plant (VEGP), Units 1 and 2, and justify this amendment for the incorporation of the changes to the VEGP Technical Specifications.

2.2 Optional Changes and Variations SNC is not proposing any variations or deviations from the technical specification changes described in TSTF-412, Revision 3, or the NRC staffs model safety evaluation published in the Federal Register on July 17, 2007 (72 FR 39089).

3.0 REGULATORY ANALYSIS

A description of the proposed change and its relationship to applicable regulatory requirements and guidance was provided in the Notice of Availability published on July 17, 2007 (72 FR 39089) .

3.1 No Significant Hazards Determination SNC has reviewed the proposed no significant hazards consideration determination published on July 17, 2007 as part of the CUI P. SNC has concluded that the proposed determination presented in the notice is applicable to VEGP and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a) .

E-1 to NL-18-1302 Description and Assessment 3.2 Verification and Commitments There are no new regulatory commitments associated with this proposed change.

4.0 ENVIRONMENTAL EVALUATION SNC has reviewed the environmental evaluation included in the model safety evaluation published in the Federal Register on July 17, 2007 (72 FR 39089) as part of the CLIIP. SNC has concluded that the NRC staff's findings presented in that evaluation are applicable to VEGP and the evaluation is hereby incorporated by reference for this application.

E-2

Vogtle Electric Generating Plant - Units 1 and 2 License Amendment Request for Technical Specification Improvement to Revise Actions for One Steam Supply to Turbine Driven Auxiliary Feedwater Pump Inoperable using the Consolidated Line Item Improvement Process Enclosure 2 VEGP Technical Specification Marked Up Pages

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

N 0 TE --------------------------------------------------------

LCO 3.0.4b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Turbine driven AFW A.1 Restore affected 7 days train inoperable due to equipment to OPERABLE one inoperable steam status. OR supply.One steam supply to turbine driven In accordance with AF'l!J pump inoperable. the Risk Informed Completion Time OR Program

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

Only applicable if MODE 2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

(continued)

Vogtle Units 1 and 2 3.7.5-1 Amendment No. +88 (Unit 1)

Amendment No. 4 (Unit 2)

AFWSystem 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable for reasons OPERABLE status.

other than Condition A. OR In accordance with the Risk Informed Completion Time Program C. Turbine driven AFW C.1 Restore the steam suggly to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> train inogerable due to the turbine driven train to one inogerable steam OPERABLE status.

sugply.

OR AND C.2 Restore the motor driven 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> One motor driven AFW AFW train to OPERABLE train inoperable. status.

GD. ----------NOTES---------- GD.1 Restore AFW trains to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

1. Not applicable when OPERABLE status.

second AFW train OR intentionally made inoperable. In accordance with

2. The following the Risk Informed Section 5.5.22 Completion constraints are Time Program applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two AFW trains inoperable for reasons other than Condition C.

9£.. Required Action and G£,.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 fef--of Condition A, AND B, Q._or GD not met.

G£..2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued)

Vogtle Units 1 and 2 3.7.5-2 Amendment No. 4-88 (Unit 1)

Amendment No. 4 (Unit 2)

AFWSystem 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME eE. Three AFW trains -------------NOTE-------------

inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status .

Initiate action to restore Immediately one AFW train to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 ----------------------------NOTE------------------------

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each AFW manual, power operated, and In accordance with automatic valve in each water flow path, and in the Surveillance both steam supply flow paths to the steam turbine Frequency Control driven pump, that is not locked, sealed, or Program otherwise secured in position , is in the correct position .

(continued)

Vogtle Units 1 and 2 3.7.5-3 Amendment No. ~ (Unit 1)

Amendment No. 4-7+ (Unit 2)

Vogtle Electric Generating Plant

  • Units 1 and 2 License Amendment Request for Technical Specification Improvement to Revise Actions for One Steam Supply to Turbine Driven Auxiliary Feedwater Pump Inoperable using the Consolidated Line Item Improvement Process Enclosure 3 VEGP Technical Specification Clean Typed Pages

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFWtrains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

N0 T E------------------------------------------------------

LCO 3.0.4b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Turbine driven AFW A.1 Restore affected 7 days train inoperable due to equipment to OPERABLE one inoperable steam status. OR supply .

In accordance with OR the Risk Informed Completion Time

NOTE------------ Program Only applicable if MODE 2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

(continued)

Vogtle Units 1 and 2 3.7.5-1 Amendment No. (Unit 1)

Amendment No. (Unit 2)

AFW System 3.7.5 ACTIONS _(continued_}_

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable for reasons OPERABLE status.

other than Condition A OR In accordance with the Risk Informed Completion Time Program C. Turbine driven AFW C.1 Restore the steam supply to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> train inoperable due to the turbine driven train to one inoperable steam OPERABLE status.

supply.

OR AND C.2 Restore the motor driven 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> One motor driven AFW AFW train to OPERABLE train inoperable. status.

D. -----------NOTES---------- D.1 Restore AFW trains to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

1. Not applicable when OPERABLE status.

second AFW train OR intentionally made inoperable. In accordance with

2. The following the Risk Informed Section 5.5.22 Completion constraints are Time Program applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two AFW trains inoperable for reasons other than Condition C.

E. Required Action and E.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 of Condition A, AND B, C, or D not met.

E.2 Be in MODE4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued)

Vogtle Units 1 and 2 3.7.5-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Three AFW trains F.1 -------------NOTE-------------

inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore Immediately one AFW train to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 ------------------------------NOTE--------------------------

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation .

Verify each AFW manual, power operated , and In accordance with automatic valve in each water flow path, and in the Surveillance both steam supply flow paths to the steam turbine Frequency Control driven pump, that is not locked, sealed, or Program otherwise secured in position, is in the correct position.

(continued)

Vogtle Units 1 and 2 3.7.5-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

AFWSystem 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.2 ----------------------NOTE--------------------------

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after ;::: 900 psig in the steam generator.

Verify the developed head of each AFW pump at In accordance with the flow test point is greater than or equal to the the Surveillance required developed head. Frequency Control Program SR 3.7.5.3 ------------------------------N0 TE ----------------------------

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation .

Verify each AFW automatic valve that is not In accordance with locked, sealed, or otherwise secured in position the Surveillance actuates to the correct position on an actual or Frequency Control simulated actuation signal. Program (continued)

Vogtle Units 1 and 2 3.7.5-4 Amendment No. (Unit 1)

Amendment No. (Unit 2)

AFWSystem 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.4 ----------------------NOTES----------------------------

1. Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after 2:: 900 psig in the steam generator.
2. AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each AFW pump starts automatically on an In accordance with actual or simulated actuation signal. the Surveillance Frequency Control Program SR 3.7.5.5 Verify that each AFW pumphouse ESF supply fan In accordance with starts and associated dampers actuate on a the Surveillance simulated or actual actuation signal. Frequency Control Program SR 3.7.5.6 Verify that the ESF outside air intake and exhaust In accordance with dampers for the turbine-driven AFW pump the Surveillance actuate on a simulated or actual actuation signal. Frequency Control Program Vogtle Units 1 and 2 3.7.5-5 Amendment No . (Unit 1)

Amendment No. (Unit 2)

Vogtle Electric Generating Plant - Units 1 and 2 License Amendment Request for Technical Specification Improvement to Revise Actions for One Steam Supply to Turbine Driven Auxiliary Feedwater Pump Inoperable using the Consolidated Line Item Improvement Process Enclosure 4 VEGP Technical Specification Bases Marked Up Pages (Information Only)

AFW System B 3.7.5 B 3. 7 PLANT SYSTEMS B 3.7.5 Auxiliary Feedwater (AFW) System BASES BACKGROUND The AFW System automatically supplies feedwater to the steam generators to remove decay heat from the Reactor Coolant System upon the loss of normal feedwater supply. The AFW pumps take suction through separate and independent suction lines from the condensate storage tank (CST) (LCO 3. 7.6._

"Condensate Storage Tank (CST)")} and pump to the steam generator secondary side via separate and independent connections to the main feedwater (MFW) piping outside containment. The steam generators function as a heat sink for core decay heat. The heat load is dissipated by releasing steam to the atmosphere from the steam generators via the main steam safety valves (MSSVs) (LCO 3.7.1 , "Main Steam Safety Valves (MSSVs)") or atmospheric relief valves (LCO 3.7.4, "Atmospheric Relief Valves (ARVs}"). If the main condenser is available, steam may be released via the steam dump valves and recirculated to the CST.

The AFW System consists of two motor driven AFW pumps and one steam turbine driven pump configured into three trains. The pumps are equipped with independent recirculation lines to prevent pump operation against a closed system. Each motor driven AFW pump is powered from an independent Class 1E power supply and feeds two steam generators, although each pump has the capability to be realigned by local manual valve alignment to feed other steam generators. The steam turbine driven AFW pump receives steam from two main steam lines upstream of the main steam isolation valves. Each of the steam feed lines will supply 100% of the requirements of the turbine driven AFW pump. The turbine driven AFW pump supplies a common header capable of feeding all steam generators with DC powered control valves actuated to the appropriate steam generator by the Engineered Safety Feature Actuation System (ESFAS). Thus, the requirement for diversity in motive power sources for the AFW System is met.

The AFW System is capable of supplying feedwater to the steam generators during normal unit startup, shutdown, hot standby, transient, and accident conditions.

(continued)

Vogtle Units 1 and 2 B 3.7.5-1 Rev. 1 11/97

AFW System B 3.7.5 BASES BACKGROUND The AFW System is designed to supply sufficient water to the (continued) steam generator(s) to remove decay heat with steam generator pressure at the setpoint of the MSSVs. Subsequently, the AFW System supplies sufficient water to cool the unit to RHR entry conditions, with steam released through the ARVs .

The AFW System actuates automatically on steam generator water level-low-low by the ESFAS (LCO 3.3.2. "Engineered Safety Feature Actuation System (ESFAS) Instrumentation"). The system also actuates on loss of offsite power, safety injection, or trip of all MFW pumps.

The AFW System is discussed in the FSAR, Subsection 10.4.9 (Ref. 1).

APPLICABLE The AFW System mitigates the consequences of any event with SAFETY ANALYSES loss of normal feedwater.

The design basis of the AFW System is to supply water to the steam generator to remove decay heat and other residual heat by delivering at least the minimum required flow rate to the steam generators at pressures corresponding to the lowest steam generator safety valve set pressure plus 3% .

In addition, the AFW System must supply enough makeup water to replace steam generator secondary inventory lost as the unit cools to MODE 4 conditions . Sufficient AFW flow must also be available to account for flow losses such as pump recirculation and line breaks. The OPERABILITY of the AFW system in MODE 4 is not assumed in the safety analysis.

The limiting Design Basis Accidents (DBAs) and transients for the AFW System are as follows :

a. Feedwater Line Break (FWLB); and
b. Loss of MFW, and
c. Loss of non-emergency AC power to the plant auxiliaries.

(continued)

Vogtle Units 1 and 2 B 3.7.5-2 REVISION 4J

AFW System B 3.7.5 BASES APPLICABLE In addition, the minimum available AFW flow and system SAFETY ANALYSES characteristics are serious considerations in the analysis (continued) of a small break loss of coolant accident (LOCA) .

The AFW System design is such that it can perform its function following an FWLB between the MFW isolation valves and containment, combined with a loss of offsite power following turbine trip, and a single active failure of the steam turbine driven AFW pump. In such a case, the ESFAS logic may not detect the affected steam generator if the backflow check valve to the affected MFW header worked properly. One motor driven AFW pump would deliver to the broken MFW header (limited by flow restrictor installed in the AFW line) until the problem was detected, and flow terminated by the operator. Sufficient flow would be delivered to the intact steam generators by the other AFW line and the redundant AFW pump.

The analyses of the events discussed in UFSAR Sections 15.2.6, "Loss of Nonemergency AC Power to the Plant Auxiliaries," and 15.2.7, "Loss of Normal Feedwater Flow," assume that both motor driven AFW pumps provide auxiliary feedwater flow to all four steam generators. The limiting single failure in the analyses of these events is the failure of the turbine-driven AFW pump.

The ESFAS automatically actuates the AFW turbine driven pump and associated power operated valves and controls when required to ensure an adequate feedwater supply to the steam generators during loss of power. DC power operated valves are provided for each AFW line to control the AFW flow to each steam generator.

The AFW System satisfies the requirements of Criterion 3 of 10 CFR 50.36 (c)(2)(ii).

LCO This LCO provides assurance that the AFW System will perform its design safety function to mitigate the consequences of accidents that could result in overpressurization of the reactor coolant pressure boundary. Three independent AFW pumps in three diverse trains are required to be OPERABLE to ensure the availability of RHR capability for all events accompanied by a loss of offsite power and a single failure. This is accomplished by powering two of the pumps from independent emergency buses.

The third AFW pump is powered by a different means, a steam driven turbine supplied with steam from a source that is not isolated by closure of the MSIVs. The steam supply valves (1/2HV-3019 and 1/2HV-3009) for the turbine driven AFW pump are powered (continued)

Vogtle Units 1 and 2 B 3.7.5-3 REVISION ~

AFW System B 3.7.5 BASES LCO from 125 V MCCs 1/2AD1M and 1/2BD1M, respectively. Suction (continued) header valve 1/2HV-5113, pump block valve 1/2HV-5106, and discharge header valves 1/2HV-5120, 5122, 5125, and 5127 are powered from 125 V MCC 1/2CD1M. If 125 V MCC 1/2AD1M or 1/2BD1 M becomes inoperable, the affected steam supply valve is to be considered inoperable. If both 1/2AD1M and 1/2BD1M become inoperable, the turbine driven AFW train is to be considered inoperable. If 125 V MCC 1/2CD1M becomes inoperable, the turbine driven AFW train is to be considered inoperable.

The AFW System is configured into three trains. The AFW System is considered OPERABLE when the components and flow paths required to provide redundant AFW flow to the steam generators are OPERABLE. This requires that the two motor driven AFW pumps be OPERABLE in two diverse paths, each supplying AFW to separate steam generators. The turbine driven AFW pump is required to be OPERABLE with redundant steam supplies from each of two main steam lines upstream of the MSIVs, and shall be capable of supplying AFW to any of the steam generators. The piping, valves, instrumentation, and controls in the required flow paths also are required to be OPERABLE. The AFW pumphouse ESF supply fans and associated dampers must be OPERABLE to support operation of the motor driven pumps, and the ESF outside air intake and exhaust dampers must be OPERABLE to support operation of the turbine driven pump.

On Unit 1, at least one SG sample automatic isolation valves is required for the turbine driven AFW system to be OPERABLE.

The failure of all four SG sample automatic isolation valves to automatically close on an actuation signal will prevent the turbine driven AFW system from meeting its safety function. However, manual isolation of at least one of the SG sample flow paths will allow the turbine driven AFW system to meet its intended safety function in the event of INOPERABLE SG sample automatic isolation valves.

On Unit 2, the failure of all four SG sample automatic isolation valves will not prevent the turbine driven AFW system from meeting its safety function. The margins of the turbine driven AFW system are sufficient to meet accident analyses when up to four SG sample automatic isolation valves are not ORERABLE.

The SG sample automatic isolation valves are not required for the motor driven AFW system to meet its intended safety function on either unit. The margins of the motor driven AFW system are sufficient to meet accident analyses when up to four SG sample automatic isolation valves are not OPERABLE.

(continued)

Vogtle Units 1 and 2 B 3.7.5-4 REVISION ~

AFW System B 3.7.5 BASES LCO Although the AFW System can be used in MODE 4 to add to SG (continued) inventory when the SG is being used to support RCS operability requirements in accordance with LCO 3.4.6, the LCO does not require the AFW System to be OPERABLE in MODE 4.

APPLICABILITY In MODES 1, 2, and 3, the AFW System is required to be OPERABLE in the event that it is called upon to function when the MFW is lost.

In MODE 4 the AFW System may be used for heat removal via the steam generators, but is not required since the RHR System is available in this MODE.

In MODE 5 or 6, the steam generators are not normally used for heat removal, and the AFW System is not required.

ACTIONS A Note prohibits the application of LCO 3.0.4b to an inoperable AFW train . There is an increased risk associated with an AFW train inoperable and the provisions of LCO 3.0 .4b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance .

If one of the two steam supplies to the turbine driven AFW train is inoperable due to one inoperable steam supply, or if turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days.

The 7 day Completion Time is reasonable, based on the following reasons:

a. For the inoperability of a steam supply to the turbine driven AFW pump due to one inoperable steam supply, the 7 day Completion time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program (Ref. 3).

(continued)

Vogtle Units 1 and 2 B 3.7.5-5 REVISION ~

AFW System B 3.7.5 BASES ACTIONS A.1 (continued)

b. For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling, the 7 day Completion time is reasonable due to the minimal decay heat levels in this situation. A Risk Informed Completion Time cannot be applied in MODE 3.
c. For both the inoperability of a steam supply line to the turbine driven pump due to one inoperable steam supply and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling, the 7 day Completion time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps; and due to the low probability of an event requiring the use of the turbine driven AFW pump. A Risk Informed Completion Time cannot be applied in MODE 3.

Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turbine driven AFW pump in MODE 3 to when the unit has not entered MODE 2 following a refueling. Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical.

With one of the required AFW trains (pump or flow path) inoperable for reasons other than Condition A, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. 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 redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA occurring during this time period. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

C.1 and C.2 With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Assuming no single active failures when in this condition, the (continued)

Vogtle Units 1 and 2 B 3.7.5-6 REVISION ~

AFW System B 3.7.5 BASES ACTIONS C.1 and C.2 (continued) accident (a FWLB or MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG. In this condition the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis due to the potential for the remaining AFW pump feeding a faulted SG.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time is reasonable based on the remaining OPERABLE steam supply to the turbine driven AFW pump, the availability of the remaining OPERABLE motor driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine driven AFW pump.

GD.1 and C.2 If two AFW trains are inoperable for reasons other than Condition C, the Required Action is to restore the inoperable AFW trains to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to regain a method of decay heat removal. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is acceptable because it minimizes risk while allowing time for restoration of at least one train. Alternatively, a Risk Informed Completion Time can be determined.

The CONDITION is modified by two Notes. The first Note states it is not applicable when the second AFW train is intentionally made inoperable. ::r:A+s-Required Action D.1 is not intended for voluntary removal of redundant systems or components from service. The Required Action is intended only when the second AFW train is found inoperable with one AFW train already inoperable, or if two AFW trains are found inoperable at the same time. The second Note indicates the parts of Section 5.5.22, "Risk Informed Completion Time Program", which are applicable to this LCO Condition. The Risk Informed Completion Time for this LCO Condition can be no longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Ref. 3}.

In MODE 4, AFW is not required since RHR is available.

gE.1 and E.2 When the Required Actions of Conditions A, B, Q.._or G-Q_cannot be completed within the required Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <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 />.

(continued)

Vogtle Units 1 and 2 B 3.7.5-7 REVISION 48

AFW System B 3.7.5 BASES ACTIONS E.1 and E.2 (continued)

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.

In MODE 4, AFW is not required since RHR is available.

If all three AFW trains are inoperable, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status.

Required Action E.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition.

(continued)

Vogtle Units 1 and 2 B 3.7.5-8 REVISION 4S

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