ML20090E088
| ML20090E088 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/02/1992 |
| From: | GEORGIA POWER CO. |
| To: | |
| Shared Package | |
| ML20090E071 | List: |
| References | |
| NUDOCS 9203090244 | |
| Download: ML20090E088 (22) | |
Text
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ATTACHMENT 1 V0G1LE ELECTRIC GENERATING PLANT PROPOSED CHANGE TO TECHNICAL SPEClflCATION 3.4.4 RELIEF VALVES l
9203090244 920302 PDR ADOCK 05000424 P
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ATTACHMENT 1 ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT CHANGE 10 TECHNICAL SPEciflCATION 3.4.4 BASl$ FOR PROPOSED CHANGE Etongled Chanael The following changes are proposed for Technical Specification (TS) 3.4.4 to address power-operated relief valve and block valve reliability.
1.
Change "All power-operated relief valves (PORVs)" to "Both power-operated relief valves (PORVs)" in the limiting condition for operation (LCO) statement.
2.
In action statement a., change *With one or more PORV(s) inoperable" to "With one or both PORV(s) inoperable." Additionally in action statement a.,
to "or close the associated change "or close the associated block valve (s?lo;c"k valve (s);".
block valve (s) with power maintained to the b 3.
In action statement b., change 'With one or more PORV(s) inoperable" to
- With one or both PORV(s) inoperable."
4.
In action statement b.2, change *With no PORVs OPERABLE" to *With both PORVs inoperable".
5.
In action statement c. replace the previous statement with the following:
"With one or both block valve (s) inoperable, within I hour restore the block salve (s) to OPERABLE status or ) lace its associated PORV(s) in manual control.
Restore at least one )1ock valve to OPERABLE status within the next hour if both block valves are inoperable; restore any remaining inoperable block valve to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; otherwise, 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 /> and in 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 />."
The following insert is proposed to be added to the bases section of Technical Specification 3/4.4.4.
The PORV(s) are equipped with automatic actuation circuitry and manual control capability.
No credit is taken for accident mitigation by automatic PORV operation in the analyses for H0DE 1, 2, and 3 transients.
The PORV(s) are considered OPERABLE in either the manual or automatic mode. The automatic mode is the preferred configuration since pressure relieving capability is provided without reliance on oper' tor action.
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ATTACitMENT 1 ENCLOSURE 1 (CONTINVED)
V0G1LE ELEC1RIC GENERATING PLANT CllANGE TO 1ECllNICAL SPEClflCATION 3.4.4 BASIS FOR PROPOSED CilANGE DAlli Enclosure A to GL 90-06 discusses the staff positions resulting from the resolution of Generic issue 70.
The technical findings and regulatory analysis are discussed in NUREG-1316.
In their discussion, the NRC staff indicated that, over a period of time, the role of power-operated relief valves had changed such that instead of a pressure relieving function, the PORVs performed one, or more, of the following safety-related functions:
1.
Mitigation of steam generator tube rupture accident, 2.
Low-temperature overpressure protection of the reactor vessel during startup and shutdown, or 3.
Plant cooltown.
At Vogtle Electr'c Generating Plant (VEGP), the PORVs and block valves are safety-grade. V,ile at many plants licensed earlier the valves are not safety-grade.
Based upon their studies, the NRC staff proposed changes to Technical Specification 3/4.4.4, " Relief Valves" to make it consistent with the safety-related function of the PORVs. At VEGP, many of these changes had already been incorporated into the Technical Specifications, although the wording was slightly different.
To provide a consistent approach to the Technical Specifications, it was decided to incorporate the proposed wording changes, which were editorial, into the VEGP format.
Two of the changes pro)osed by the Generic Letter are more than editorial. The first changes the Tecinical Specifications to specify that power be maintained to the block valve when the PORV is declared inoperable due to excessive seat leakage. Maintaining
)ower to the block valve makes it easier for the operator to establish feed and 21eed operations in a timely manner. The second adds a new requirement to action statement c. which requires that the PORY be placed in manual control when its associated block valve is inoperable.
These changes provide the additional level of flexibility and protection recommended by the generic letter and result in requirements that are the same as suggested by it.
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ATTACHMENT 1 ENCLOSURE 2 V0GTLC ELECTRIC GENERATING PLANT CHANGE 10 TECHNICAL SPEClflCATION 3.4.4 10 CFR 50.92 EVALVATION Pursuant to 10 CFR 50.92, Georgia Power Company (GPC) has evaluated the attached proposed amendment and has determined that operation of the facility in accordance with the proposed amendment would not involve significant hazards considerations.
futekaround Based on a study of the role of power-operated relief valves, the NRC published Generic letter 90-06.
This generic letter proposed revisions to the Technical Specifications that provide protection from inadvertent opening of power-operated relief valves without precluding their use for manual operation during an emergency.
The proposed changes implement the changes recommended by Generic letter 90-06.
Some of the changes, such as the use of the term 'all" instead of "both" are purely editorial because only two valves are involved.
The editorial changes provide for wording that is consistent with the proposed wording of the generic letter.
Analysis The design for VEGP has two safety-grade PORVs and two safety-grade block valves.
Therefore, changing the wording from "all" to "both" or from "one or more" to "one or both" is purely editorial and has no effect on safety.
The revised action statement a. will specifically add the requirement to maintain power to the closed block valves when the PORVs are experiencing excessive leakage.
The current Technical Specification allows the valve to be closed with or without maintaining power to the block valve.
By maintaining power to the block valves, the block valves can be readily opened from the control room, and the PORVs can be utilized for controlling reactor pressure.
Closure of the block valves establishes reactor coolant pressure boundary (RCPB) integrity for a PORV that has excessive seat leakage. No credit is taken for the PORV for protecting from overpressure events since overpressure protection is provided by the pressurizer code safety valves.
The revised action statement allows continued plant operation with the block valves closed and power maintained to the block valves.
This permits operation of the plant for a limited period of time not to exceed the next refueling outage (Mode 6) so that maintenance can be performed on the PORVs to eliminate the seat leakage condition. This does not change the effect of the Technical Specification on plant safety, because it specifically requires an action that is currently allowed by the Specification.
Since the blocked valve and its associated power supply are safety-grade, inadvertent opening of a block valve is not expected.
Therefore, maintaining power to the block valve will not significantly change the probability of any accident.
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ATTACHMENT 1 ENCLOSURE 2 (CONTINUED)
V061LE ELECTRIC GENERATING PLANT CHANGE TO TECHNICAL SPECirlCATION 3.4.4 10 CFR 50492 EVALVA110N The change to action statement c. establishes action requirements consistent with the function of the block valv9s.
The block valves' main function is to isolate a PORV.
The current Technical Specification allows the operator to either close and remove power from the inoperable block valve or close and remove power from the PORV and its associated solenoid valve.
The revision replaces the previous choice with a requirement to place the PORV in manual.
Placing the PORV in manual will prevent PORV opening except by deliberate o)erator action.
This avoids the potential for a stuck-open PORV at a time that tie block valves are inoperable.
The time allowed to restore the block valves to operable status is the same as in the current Technical Specification and is based upon the time limit for inoperable PORVs in action statements b.l. and b.2., since the PORVs are not capable of performing their automatic function when placed in manual control.
The PORVs and their controls are safety-grado components.
Placing a PORV in manual rather than closing it and removing power does not significantly affect the probability of inadvertent PORV operation, but it does improve the ability of the operator to use the valve if it is needed.
Therefore, the probability or consequences of previously analyzed accidents are not significantly altered by this revision to the Technical Specification.
Placing the PORVs in manual control allows the use of the PORVs in the manual mode to control reactor coolant system pressure or establish feed and bleed operation if the block valves are inoperable.
The modified action statement does not specify closure of the block valves, because if such action is taken it may not be possible to reopen the block valves.
Likewise, it does not specify either the closure of the PORV, because it would not likely be open, or the removal of power from the PORV. When a block valve is inoperable,
) lacing the PORV in manual control is sufficient to preclude the potential for laving a stuck-open PORV that could not be isolated because of an inoperable block valve.
In GL 90-06, a new surveillance requirement 4.4.4.3 was proposed to demonstrate the operability of the emergency power supply for the PORVs and block valves by manually transferring motive and control power from the normal to the emergency sower bus. At VEGP, the block valves are powered from safety-related, 480-V ausses, which are also tied to the diesel generators.
Additionally, the FORVs are electrically solenoid operated, and the solenoids for the PORVs are powered from the Class IE 125-Vdc system. The normal power supplies are from Class IE sources, and no emergency power supply transfer is required.
Therefore, a new surveillance requirement is not needed.
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ATTACitMENT 1 ENCLOSURE 2 (CONTINUED) r V0 GILE ELECTRIC GENERATING PLANT CllANGE 10 TECHNICAL SPECiflCATION 3.4.4 10_ffR 50.92 EVALVATION The change to bases page B 3/4 4-3 clarifies PORV operability requirements.
If one PORV is inoperable due to causes other than excessive seat leakage, the PORV must be restored to operable status within I hour or the associated block valve must be closed and power removed from the block valve.
The accident analyses for VEGP takes no credit for the actuation of PORVs for overpressure protection.
The only conditions analyzed are those where the actuation of the PORVs would make operation more severe.
The pressurizer code safety valves are assumed to provide overpressure protection.
The PORVs can be considered operable in either the manual or automatic mode.
By maintaining power to the block valve, the PORV can be manually opened from the control room.
This condition was analyzed in NUREG/CR-5230.
In this study, feed and bleed cooling of the primary system was evaluated as an alternative measure for removing decay heat.
The study indicated that current Technical Specifications which require that the block valves be closed with power removed upon discovering that a PORV has excessive seat leakage make it unlikely that feed and bleed operations could be initiated in a timely manner.
It was proposed that the Technical Specifications require that power be maintained to the block valvo, thus increasing the likelihood that timely feed and bleed operations could be initiated from the control room.
Georgia Power Company has determined that the proposed Technical Specification changes are applicable to VEGP and will increase the likelihood of timely establishment of feed and bleed operation.
ik1LLllL 1.
The proposed Technical Specification changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because maintaining power to the bicek valve is already allowed by the Technical Specifications and ) lacing PORVs in the manual mode will prevent opening of the PORV, whic1 is equivalent to the action currently allowed by the Technical Specification. This makes it easier for the operator to estabitsh feed and bleed operations if necessary.
The remainder of the changes are editorial.
2.
The proposed Technical Specification does not create the possibility of a new or different kind of accident from any accident previously evaluated because there are no changes or modifications to the design of the plant.
The only changes are operational in nature; e.g., keeping power maintained I
to the block valve, therefore, the types of accidents previously evaluated have not changed, and no new types of transients or accidents are introduced.
3.
The proposed change does not involve a significant reduction in a margin of safety because the revised actions are equivalent or more restrictive than currently allowed by the Technical Specifications.
Studies have shown that operating in accordance with the proposed Technical Specifications will result in a reduction in the probability of core melt, thus improving the margin of safety.
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ATTACHMENT 1 ENCLOSURE 2 (CONTINUED)
V0GTLE ELECTRIC GENERATING PLANT CHANGE TO TECHNICAL SPECif1 CAT 10N 3.4.4 10 CFR 50.92 EVALUATION Conclusion Based on the preceding analyses, GPC has determined that the proposed change to the Technical Specifications does not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.
Therefore, GPC concludes that the proposed change meets the requirements of 10 CFR 50.92(c) and does not involve a significant hazards consideration.
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ATTACHMENT 1
[NCLOSURE 3 V0GTLE ELECTRIC GEhcRATING PLANT CHANGE TO TECHNICAL SPECiflCATION 3.4.4 i
INSTRVLUpf1LFOR INCORPORATION Etmay.g, Bag Insert Paat 3/4 4-9* and 3/4 4-10 3/4 4-9* and 3/4 4-10 0 3/4 4-3 and B 3/4 4-4*
8 3/4 4-3 and D 3/4 4-4*
- Overleaf-page containing no change.
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REACTOR COOLANT SYSTEM 3/4,4.4 RELIEF VALVES LlHITING CONDITION FOR OPERATION ty n, 3.4.4 -Al-1 power-operated relief valves (PORVs) and their associated block valves shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3.
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ACTION:
/ ' ' " !n L V,1 /u dG With one or *1 4ere-PORV(s) inoperable,(\\because of excessive seat a.
leakege, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restoreithe PORV(s) to OPERABLE status or close the associated block valve (s); otherwise, 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 /> and in 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 />.
b.
With one or *Le nere.PORV(s) inoperable due to causes other than exces-sive seat leakage, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORV(s) to OPERABLE status or close the associated block valve (s) and remove power from the block valve, and 1.
With only one PORV OPERABLE, restore at least a total of two PORVs to OPERABLE status within the following 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be 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 /> and in 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 />, or
- int, in< m ui!n 2.
With-no PORVs SPERABLE, restore at least one PORV 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 /> or be 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 /> and 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 />.
LA c.
With one or more-block valve (s) inoperable, within 1 hour-(-1-)- restore the block valve (s) to OPERABLE status or 44ote-the block-value(s) eM eemove powee-from the block-valve (+}-op-slose-the-#0RV-and-remove-
-powe r-f rom - 4 t 5 -a s s oc i a te d -s ol eno i d - v a l vet-e nd -( 2 )-e pp ly-AG T10N-b---
-ebovera s -a pp rop r i a t e r-f o r-t he-i so l a ted-POAV(+)r-A le; w, e vii A 2.,c e, f-d.
The provisions of Specification 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.4.4.1 Each PORV shall be demonstrated OPERABLE at least once per 18 months by:
a.
Operating the valve through one complete cycle of full travel, and b.
Performing a CHANNEL CAllBRAT10N.
V0GTLE UNITS - 1 & 2 3/4 4-10 Amendment No. 21 (Unit 1)
Amendment No.
2 (Unit 2)
Insert for Page 3/4 4-10
... place its associated PORV(s) in inanual control.
Restore at least one block valve to OPERABLE status within the next hour if both block valves are ino3erable; restore any remaining inoperable block valve to OPERABLE status witiin 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />st otherwise, be in at-least 6101 STAliDBY 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 1101 $11U100Wii within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
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i IDB0!L10mMT synm DMLL 314dd_RLL11LVAYLS the power-operated relief valves (p0RVs) and steam bubble function to relieve RCS pressure during all design transients up to and including the design step load decrease with steam dump.
Operation of the p0RVs minimizes the undesirable opening of the spring-loaded pressurizer Code safety valves.
Each p0RV has a remotely operated block valve to provide a positive shutoff capability should a relief valve become inoperable.
31RL.31fldLKLlLRM10.M M
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lhe Surveillance Requirements for inspection of the steam generator tubes ensure that the structural integrity of this portion of the RCS will be main-tained.
The program for inservice inspection of steam generator tubes is based on a modification of Regulatory Guide 1.83, Revision 1.
Inservice lance of the conditions of the tubes in the event that there is evide mechanical damage or progressive degradation due to design, manufacturing errors, or inservice conditions that lead to corrosion.
of steam generator tubing also provides a means of characterizing the natureInservice insp and cause of any tube degradation so that corrective measures can be taken.
coolant will be maintained within thoso chemistry limits found to r negligible corrosion of the steam generator tubes.
If the secondary coolant chemistry is not maintained within these limits, localized corrosion may likely result in stress corrosion cracking.
plant operation would be limited by the limitation of steam generator tubeThe exten leakage between the Reactor Coolant System and the Secondtry Coolant System (primary-to-secondary leakage 500 gallons per day per steam generator).
Cracks having a primary-to-secondary leakage less than this limit during during normal operation and by postulated accidents. operation will have a Operating plants have demonstrated that primary-to-secondary leakage of 500 gallons per day per steam generator can readily be detected by radiation monitors of steam generator
- blowdown, teakage in excess of this limit will require plant shutdown and an unscheduled inspection, during which the leaking tubes will be located and plugged.
Wastage-type defects are unlikely with proper chemistry treatment of the secondary coolant.
will be found during scheduled inservice steam generator tube examin plugging limit of 40% of the tubo nominal wall thickness. Plugging will Steam generator tube inspections of operating plants have demonstrated the capability to reliably detect degradation that has penetrated 20% of the original tube wall thickness, s
V0GitE tmlls - 1 & 2 B 3/4 4 3
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j Insert for Page B 3/4 4-3 i
The PORVs are equipped with automatic actuation circuitry and manual control capability.
No credit is taken for accident mitigation by automatic PORV operation in the analyses for MODE 1, 2, and 3 transients.
The PORV(s) are considered OPERABLE in either the manual or automatic mode.
The automatic mode is the preferred configuration, since pressure relieving capability is provided without reliance on operator action.
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ATTACHMENT 2 V0GTLE ELECTRIC GENERATING PLANT PROPOSED CHANGE TO TECHNICAL SPLClflCATION 3.4.9.3 COLD OVERPRESSURE PROTECTION SYSTEMS
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ATTACliMENT 2
[NCLOSURE 1 V0GTLE ELECTRIC GENERAllNG PLANT CHANGE 10,ECilNICAL SPECIFICATION 3.4.9.3 BASIS FOR PROPOSLO CHANGE Ergoosed Chanagi 1he following changes are proposed for Technical Specification (TS) 3.4.9.3 to address cold overpressure protection devices.
1.
In the LC0 statement change "At least one of the following Cold Overpressure Protection Systems shall be OPERABLE" to "At least one of the following groups of Cold Overpresssure Protection Devices shall be 0PERABLE when the reactor coolant system (RCS) is not depressurized through a vent sath capable of relieving at least 670 gpm water flow at 470 psig." T11s constitutes an editorial change since the statement for the vent path was relocated from LCO statement c.
2.
Change LCO statement c. from "The Reactor Coolant System (RCS) depressurized with an RCS vent capable of relieving at least 670 gpm water flow at 470 psig." to "One RHR SRV and one PORV with setpoints as described above."
3.
Change action statement a. from "With one PORV and one RHR suction relief valve inoperable, either restore two PORVs or two RHR suction relief valves to OPERABLE status within 7 days or dearessurize and vent the RCS as specified in Specification 3.4.9.3.c asove, within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />." to "In H0DE 4, with only one PORV or one RHR SRV OPERABLE, restore one additional valve to OPERABLE status within the next 7 days or depressurize and vent the RCS, as specified in 3.4.9.3 above, within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />."
4.
Add a new action statement b. which states, "In MODES 5 and 6, with only one PORY or one RHR SRV OPERABLE, restore one additional valve to OPERABLE status within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or depressurize and vent the RCS, as specified in 3.4.9.3 above, within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
5.
Hove the current action statement b. to action statement c.
Change "With both PORVs and both RHR suction relief valves inoperable, depressurize and vent the RCS as specified in Specification 3.4.9.3.c. above, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />." to "In MODES 4, 5, or 6 with none of the PORVs or RHR SRVs OPERABLE, de)ressurize and vent the RCS as specified in 3.4.9.3 above, within the next 8 Tours."
6.
Change action statement c. to action statement d. and change "In the event either the PORVs, the RHR suction relief valves, or the RCS vent (s) are used" to "In the event that the PORVs and/or RHR SRVs or the RCS vent (s) are used".
7.
Change action statement d. to action statement e.
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ATTACHMENT 2 ENCLOSURE 1 (CONTINUED)
V0GTLE ELECTRIC GENERATING PLANT CHANGE TO TECHNICAL SPECIFICATION 3.4.9.3 BASIS FOR PROPOSED CHAN01 Additionally, the bases for the cold overpressure prctection systems on page B 3/4 4-16 is being changed by replacing the first paragraph with the following:
The OPERABILITY of two PORVs, two RHR suction rolief valves, a PORV and RHR SRV, or an RCS vent capable of relieving at least 670 gpm water flow at 470 asig ensures that the RCS will be protected from pressure transients whic1 could exceed the limits of Appendix G to 10 CFR Part 50 when one or more of the RCS cold legs are less than or equal to 3500F.
The PORVs have adequate relieving capability to protect the ACS from overpressurization when the transient is limited to either:
(1) the start of an idle RCP with the secondary water temperature of the steam generator less than or equal to 500F above the RCS cold leg temperatures, or (2) the start of all three charging pumps and subsequent injection into a water-solid RCS.
The RHR SRVs have adequate n11eving capability to-protect the RCS from overpressurization when the transient is limited to either:
(1) the start of an idle RCP wi;h the scondary to primary water temperature difference of
. the steam generator less than or equal to 250F at an RCS temperature of 3500F and varies linearly to 500F at an RCS temperature of 2000F or less, or (2) the start of all three charging pumps, and subsequent injection into a water-solid RCS. A combination of a PORV and a RHR SRV also provides overpressure protection for the RCS.
The secons paragraph of the bases is also being revised by changing " Operation with a PORV setpoint less than or equal to the maximum setpoint ensures that the nominal 16 EFPY Appendix G reactor vessel NDT limits" to " Operation with a PORV setpoint less-than or equal to the maximum setpoint ensures that the nominal 13 EFPY for. Unit I and 16 EFPY for Unit 2 Appendix G reactor vessel NDT limits" Basis The proposed change will relocate the depressurizing of the reactor coolant system (RCS) through a RCS vent ' rom statement c. of the limiting condition for operation (LCO) to the initial LCO statement, which is an editorial change.
A new action statement c. will allow the combination of one residual heat removal (RHR) safety relief valve (SRV) and one PORV to be used for cold overpressure protection. An action statement is proposed for Modes 5'and 6 that decreases the allow out-of-se*vice time (A0T) from 7 days to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with only one valve avaiiable to provide cold overpressure protection.
This is consistent with the guidance of GL 90-06.
The revision to the bases restates the current Technical Specification limits l
for starting reactor coolant pumps. The. addition of 13 EFPY for Unit 1 is ar editorial revision unrelated to the changes proposed for Generic Letter 9G-06.
This change to the bases simply reflects the values that are already in the Technical Specifications.
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- ATTACitMENT 2 ENCLOSURE 2 V0GTLE ELECTRIC GENERATING PLANT CHANGE TO TECHNICAL SPECIFICATION 3.4.9.3 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company (GPC) has evaluated the attached proposed amendment and has determined that operation of the facility in accordance with the proposed amendment would not involve significant hazards considerations.
Backarquad Generic Letter 90-06 notes that with the exce; K' of a few plants, the low temperature overpressure protection (LU.v) s.' ems consist of either redundant PORVs or redundant safety relief "F st, in the residual heat removal system.
One of the exceptions noted was that newer Westinghouse plants (such as VEGP) have LTOP systems that consist of both redundant PORVs and redundant SRVs.
This allows two PORVs or two RHR SRVs or a combination of one '0RV and one SRV to provide redundant overpressure protection in Modes 4, 5, and 6.
The Technical S)ecification in enclosure B to GL 90-06 does not address plants such as VEGP t1at have four redundant LTOP channels.
Generic Letter 90-06 requested GPC to inform the NRC if it intended to follow the staff positions in enclosures A and 8 or if it intended to propose alternative measures.
This is the proposed alternative Technical Specification for VEGP.
Analysis The purpose of this Technical Specification is to assure that two trains of LTOP protection are in service in Modes 4, 5, and 6 unless the reactor coolant system is properly vented. The proposed Technical Specifications are consistent with the cold overpressure analyses that indicate that either one RHR SRVlor one PORV is capable of providing LTOP protection.
The proposed TS in GL 90-06 reduced the allowed out-of-service time to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when only one channel is available for cold overpressure protection in Modes 5 and 6.
The proposed VEGP Technical Specification also allows only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> out-of-service time when only one channel is available for cold overpressure protection in Modes 5 and 6.
The current VEGP Technical Specification allows the use of either two PORVs, two RHR SRVs, or an RCS vent to provide LTOP protection.
The proposed revised Technical Specification also allows the use of one PORV and one RHR SRV. One PORV and one RHR SRV is capable of providing redundant LTOP protection.
With only one channel of LTOP protection available in Mode 4, the revised specification will allow 7 days to provide a redundant operable channel of LTOP protection. With only one channel of LTOP protection available in Modes 5 or 6, the allowed operation time is reduced to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This is consistent with the guidelines in GL 90-06.
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ATTACHMENT 2 ENCLOSURE 2 (CON 11NUED)
V0GTLE ELECTRIC GENERATING PLANT CHANGE TO TECHNICAL SPECIFICATION 3.4.9.3 10 CfR 50.92 EVALVATION Results 1.
The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated because it will continue to provide redundant channels of LTOP protection and allows the additional use of one RHR SRV and one PORV for cold overpressure protection.
The allowed out-of-service time in Modes 5 and 6 is reduced to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from 7 days when only one channel is available.
These changes do not affect the probability of any initiating event.
Therefore, the probability of any previously evaluated accident is not affected.
Furthermore, cold overpressure protection will continue to be maintained in accordance with 10 CFR 50, Appendix G.
Theref;re, there is no effect on the consequences of any accident previously evaluated.
2.
The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated because cold overpressure protection is maintained.
No new modes of operation are involved, and no new failure modes will be created by the proposed change.
3.
The proaosed changes do not involve a significant reduction in a mergin of safety aecause the limits of 10 CFR 50, Appendix G will continue to be met, as before, under the existing requirements.
The allowed out-of-service time for the case where only one PORV or RHR SRV is available will be more restrictive under the proposed change, requiring corrective action or compensatory measures in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> rather than 7 days.
Therefore, there will be no reduction in any margin of safety.
Conclusion Based on the preceding analyses, GPC has determined that the proposed change to the Technical Specifications does not involve a significant increase in the probability or consequences of accidents previously evaluated, create the possibility of a new or different kind of accident from any previously evaluated,_ or involve a significant reduction in a margin of safety.
Therefore, GPC concludes that the proposed change meets the requirements of 10 CFR 50.92(c) and does not involve a significant hazards consideration.
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4 ATTACHMENT 2 ENCLOSURE 3 V0GTLE ELECTRIC GENERATING PLANT CHANGE TO TECHNICAL SPECIFICATION 3.4.9.3 JNSTRUCTION FOR INCORPORATION Remove Paae Insert Pace 3/4 4-33* and 3/4 4-34 3/4 4-33* and 3/4 4-34 B 3/4 4-15* and B 3/4 4-16 B 3/4 4-15* and B 3/4 4-16 Overleaf page containing no change.
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Eff_GTOR COOLANT SYSTEM COLD OVERPRESSURE PROTECTION SYSTEMS LIMITING CONDITION FOR OPERATION gro m 6 g m c,,
3.4.9.3 At least one of the followingTCold Overpressure Protection Systems-shall be OPERABLEp Lon g a.
Two power-operated relief valves (PORVs) with lift settings which vary with RCS temperature and which do not exceed the limits estab-lished in Figure 3.4-4a (Unit 1), Figure 3.4-4b (Unit 2), or b.
Two residual heat removal (RHR) suction relief valves each with a setpoint of 450 psig i 3%, or J 4 not t/.m y k a. 4 v
- c. "
e)feactorfoolant gystem (RCS)Adepressurized winien-RMlvent pa/
apabl.e__9Lralle.y_ing at least 670_gpm water flow at 470 psig.r~g i
One LWA -rK V e s,,, e TM V w a c s apau h as h,e ris e d J. ve.
APPLICABillTY: M0 DES 4, 5, and 6 with the reactor vessel head on.
ACTIO)fj:
a.
Wi th-one-PORV--a nd-one-RHR -s uc t i on-reli e f-val ve-i nope ra bl-er ither e
- restore two P4RVsar two RHR-suct4coreLief--valves-to-OPERABLE 4tus d
,fcg c.c wh insert within-7---days-or-depressurize-and-vent-tho-ES-as-spec 4f4ed---4e
-Specification-3dr9731cr b9ver ithin-the-next4-hour-s-,
a w
5.wct.s 4 s,cr c.4 nonee/ Me.. er sga cecu mc c..A.j ylth-betfr PORVs andLboth-RHR suet 4en-relief-valv,es-inoparab%
' depressurize and vent the RCS as specified in Specification 3.4.9.3/d,/
above,within8 Jog.
c 1A t wdhe
- s t \\'s d. -c,.
In the event +4tfer the PORVs, -the RHR sueHoft-reHef-vahes,- or the RCS vent (s) are used to mitigate an RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.8.2 within 30 days.
The report shall describe the circumstances initiating the transient, the effect of the PORVs, the RHR suction relief valves or RCS vent (s) on the transient, and any corrective action necessary to prevent recurrence.
e. _d, The provisions of Specification 3.0.4 are not applicable.
s-V0GTLE UNITS - 1 & 2 3/4 4-34
__..____-..._-._.__.._..__,__.______m 4
Insert Page 3/4 4-34
- a.
In MODE 4, with only one PORV-or one RHR SRV OPERABLE, restore one-additional-valve to OPERABLE status within the next 7 days-or depressurize and vent the RCS, as specified in 3.4.9.3 above, within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
- b.
In MODES 5_and 6, with only one PORV or one RHR SRV OPERABLE, restore one additional valve to OPERABLE status within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or depressurize and vent the RCS, as specified in 3.4.9.3 above, within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
I ft;\\wp\\techsp\\v\\),4 4F, pro
REACTOR COOLANT SYSTEM BASES PRESSURE /TEMPEPATURE LIMITS (Continued)
Although the pressurizer operates in temperature ranges above those for which there is reason for concern of nonductile failure, operating limits are provided to assure compatibility.of operation with the fatigue analysis i
performed in accordance with the ASME Code requirements.
COLD OVERPRESSURE PROTECTION SYSTEMS pp/m The-OPERABIHTY-of--two-PORVsy-two-RHR-suction-relief-valvess cr_an_.RCS_ vent _
,,t A # ;-apable-of-relieving-at-least-670-gpm-water-flow-at-470-psig-ensures-that-the n
RCS-wi l l-be -protected-f rom-pre s s ure-t ra ns i e n t s--wh i c h-c o ul d - exc eed--t he4i mi t s-
.af Appendix G4o 10uCFR Part-50when-one-or-more-of-the-RCS-cold-legs-are-less
-than-or-equal-to-3509Fr--Either-PORV-or-either RHR -suction-relief-valve has-adequate-reliev.ing capability _to-protect-the RCS-from-overpressurization-when-
.the-transient-is limited-to-eitheri-(-1)-the-start-of-an-idle-RCP-with-the-s ec o nd a ry-wa te r-t empe ra t u re-o f-t he-s team-g e ne ra to r-l e s 5-t ha n-o r-equa l-t o-5096 ebove-the-RCS-cold-leg---temperatures -on-(2)-the-start-of-all-three-charging.
r
--pumps-and subsequant injection-.irlaAwaten-solidlCSo The Maximum Allowed PORV Setpoint for the Cold Overpressure Protection System (COPS) is derived by analysis which models the performance of the COPS assuming various mass input and heat input tra'sients.
Operation with a PORV ud 16 EFPYj Appendix G reactor vessel NDT limits criteria will not be violated w Setpoint less than or equal to the maxirnum Setpoint ensures that the nominal 13ffff-
.,Tconsiderationfor-amaximumpressureovershootbeyondthePORVsetpointwhich can occur as a result of time delays in signal processing and valve opening, W *j" instrument uncertainties, and single failure.
To ensure that mass and heat input transients more severe than those assumed cannot occur, Technical Spec-ifications require lockout of all safety injection pumps while in MODES 4, 5, and 6 with the reactor vessel head installed and disallow start of an RCP if secondary temperature is more than 50 F above primary temperature.
Additional temperature limitations are placed on the startin'g of a Reactor Coolant Pump in Specification 3.4.1.3.
These limitations assure that the RHR system remains within its ASME design limits when the RHR relief valves are used to present RCS overpressurization.
The Maximum Allowed PORV Setpoint for the COPS will be updated based on the results of examinations of' reactor vessel material irradiation surveillance specimens performed as required by 10 CFR Part 50, Appendix H, and in accordance with the schedule in Table 16.3-3 of the VEGP FSAR.
3/4.4.10 STRUCTURAL INTEGRITY
)
The inservice inspection and testing programs for ASME Code Class 1, 2, and 3 components ensure that the structural integrity and operational readiness of these components will be maintained at an acceptable level throughout the life of the plant.
These programs are in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(g) except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).
V0GTLE UNITS - 1 & 2 B 3/4 4-16 Amendment No. 39 (Unit 1)
Amendment No. 19 (Unit 2)
Insert for Page B 3/4 4-16 The OPERABILITY of two PORVs, two RHR suction relief valves, a PORV and RHR SRV, or an RCS vent capable of relieving at least 670 gpm water flow at 470 psig ensures that the RCS will be protected from pressure transienM which could exceed the limits of Appendix G to 10 CFR Part 50 when one or more of the RCS cold legs are less than or + al to 3500F. The PORVs have adequate relieving capability to protect the KCS from overpressurization when the transient h, limited to either:
(1) the start of an idle RCP with the secondary water temperature of the steam generator less than or equal to 500F above the RCS cold leg temperatures, or (2) the start of all three charging pumps and subsequent injection into a water-solid RCS.
The RHR SRVs have adequate relieving capability to protect the RCS from overpressurization when the transient is limited to either:
(1) the start of an idle RCP with the secondary to primary water temperature difference of the steam generator less than or equal to 250F at an RCS temperature of 3500F and varies linearly to 500F at an RCS temperature of 2000F or less, or (2) the start of all three charging pumps and subsequent injection into a water-solid RCS. A combination of a PORV and a RHR SRV also provides overpressure protection for the RCS.
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