ML20098A486
| ML20098A486 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/22/1995 |
| From: | GEORGIA POWER CO. |
| To: | |
| Shared Package | |
| ML20098A482 | List: |
| References | |
| RTR-NUREG-1431 NUDOCS 9509260103 | |
| Download: ML20098A486 (46) | |
Text
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l f-bauS. g, }:Wo cuMI ~d thN M.S. ggg. g p,6 m 1 hour $ IM p,g fen. 9 chan d - TABLE 3.3-1 (Continued) ag Per-
> P-to in 2 ors j ACTION STATENENTS (Continued) ( _
f A6M ON '
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%ONEcR7Wo cono H; /. Below the P-6 (Intermediate Range Neutron Flux Interlock) i Channels / nog , Setpoint, restore the inoperable channeD)to OPERABLE status prior to increasing THERMAL POWER above the P-6 Setpoint, and p met- 4 pf,
! don D F jr Above the p.6 (Intermediate Range Neutron Flux Interlock)
! ONE channel . Setpoint but below 10% of RATED THERMAL POWER, r ;t;r. th:
L M pnop /bwcr in;;;rdh d::::' te ^"ER*"iE sta*": prier te increri";; 1 >p.4, M 4NO 'r"".t "^" a 2:. : ef "".Tra ~ r.".L "^" =. i 1 ;,;T; ,;, 4 - th th: :::t:r c' 0"EE"."LE e r r h : r k;; th 7. th; "ir.r--- - CONDJs Cl......eli 07;;;;,EE . . .i. _ ct & suspend all operations _involvino 23 positive reactivity changes. nE.c.bo.nne.I mopem.hte]. l C..O.N. - h. .- m.< . < _ _ . - - . , . . . . . , , , , .m .m __ Chrn:'. 07;;;^.^,L: 7.;;ir:----t. restore the inoperable channel E56d /O Uchfg 1 to OPERABLE status within 48 hours or open the Reactor Trip l' System Dreakers, suspend all operations invol deg-positive Igco9,3 1 i' [M Wlltr'p/td W4/gr
.50m reactivity changeg/anc verny valves .__ _ _ -
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' . _:;-: 12?" L" '70-are-closed-and-secured-in-position i' -
wtthin the nour, i i M NO 5 Jr. WithnochannelsOPERABLE,opentheReactorTripBreakers.] suspena asi operar.lons involvina nactr wa ==rr w i t v ch:=:c . ina ver4fy compitance with the SHUTDOWN MARGIN requirement Fj pyyo j,,, , k'fr Wi h; J Specification-3.1.1.1 or 311.2, as applicable, within our j j fEnh
- --- norg _..g and every 12 hours the,reafter.
;;-a to ;77, ;;;7 "*_-.
Verify-valves ;:^^ L' ;. ,
;- , , ,, g are closed-and- gg secured in positton within 4 hours and verified to-be closed
. o M ~ nda secveed_in-position every 14 days.' e i A e_r l
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--s r ----- r -- --- "-
4 l h (6EEINSER7p ' ' > - -
- ycogo{ a. The inoperable channel is placed in the tripped condition within 6 hours, and y #pTE n
- 26 COND M 73; . 4_ ._ ru__ n e g. u , ,,,,_,,,_ .. e __.. < r,,
channel may be bypassed for up to 4 hours for surveillance l 2 conD O gy testing ;;r 5,nifi..; ,,.. ".:.'..'.
^
A6M6N' 7 "i-th the -"-M,-of-OPERABLE-Ch .r.r.;.h . .; . .. U.... .... ... . - - - J l y CDND Q . Orrh ^nen"_r :;r -----+ , restore the inoperable channel to i i OPERABLE status within 6 hourt nr ha in =+ 1==e+ mT *:TaunaY within the next 6 hours: hn_..r fone channel may be bypassed for up to 4' 006 C,homfd ours for surveillance testing ;;. : ri ' ;ti;; '.2.'.-0, provided he_other channel is operable. * - g fh. g
- hACTf:: in dOODM V0GTLE UNITS - 1 & 2 3/4 3-7 Amendment No. 67 (Unit 1) 9509260103 950922 PDR ADOCK 05000424 P. PDR
l i l The following pages should be inserted behind the Enclosure 2 tab for Chapter 3.3, Volume 3. i
VEGP ITS Conversion Enclosure 2 - Discussion of Changes Chapter 3.3 - Instrumentation 3/4.3.1 RTS INSTRUMENTATION j l CHANGE l NUMBER SHE DISCUSSION j I functions appear on Table 3.3.1-1. This change is administrative and consistent with NUREG-1431. 59 A An individual annotation for response time ~ testing is made to each instrument function for which a response time is required. ! The ITS SR number for response time is included in the list'of l SRs for each function that requires this test. This change is ; administrative and is consistent with NUREG-1431. j 60 A Notes 1 and 4 of the VTS are incorporated into the individual ; SRs where appropriate in the ITS. This change is administrative , and is consistent with NUREG-1431. 61 LG In addition to the trip and neutron monitoring function, the source range high flux at shutdown alarm (HFASA) is used to ! mitigate an inadvertent boron dilution event by providing timely notification to the plant operator. The LCO, actions, and : ' surveillance requirements associated with this function have been ! i moved to a separate VEGP specific LCO 3.3.8, consistent with
- the intent of NUREG-1431 as expressed in the NUREG-1431 ;
i LCO Boron Dilution Protection System. VEGP does not have ; the Boron Dilution Protection System and relies instead on the alarm provided by the HFASA. The setpoint for the HFASA will be located in the Bases for LCO 3.3.8. ! 61a A The new Condition L for Source Range Instrumentation in Modes 3,4, and 5 with RTBs open is modified by a VEGP specific Note l that refers the user to LCO 3.3.8, High Flux at Shutdown Alarm , (HFASA). The addition of this Note is consistent with other
- j. NUREG-1431 Notes in the Plant Systems and Electrical Chapters that require entry into other LCOs when inoperable systems or ,
~ components in the current LCO affect Systems or components of , another LCO. In this case, the Source Range Instrument Channels are required operable to support the HFASA channels. I 61b LS8a The existing VEGP TS contain the requirement that valves 1208- f U4-175,1208-U4-176,1208-U4-177, and 1208-U4-183 be closed l t i Chapter 3.3 E2-19 September 11,1995 l i
VEGP ITS Conversion Enclosure 2 - Discussion of Changes Chapter 3.3 - Instrumentation , 3/4.3.1 RTS INSTRUMENTATION CHANGE NUMI3ER SiiE DISCUSSION and secured in position whenever the RCS is in Mode 5 with the loops not filled, Mode 6, and whenever less than the required source range instrumentation is operable. NUREG-1431 does not specify which valves must be closed, but rather that any valve used to isolate unborated water sources be closed and secure in position. It is implicit that the applicable valves are specified in plant procedures. VEGP proposes to adopt the NUREG-1431 requirements for isolating unborated water sources. This is a less restrictive change because the TS will no longer be specific as to which valves must be used to isolate unborated water sources. However, the change is acceptable because plant procedures will require that at least one valve in each flowpath from the reactor makeup water storage tank (RMWST) (the RMWST is the unborated water source at VEGP) to the suction of each charging pump be closed and secured in position. Administrative controls will ensure that these valves are maintained closed when required. The fact that the TS will j continue to require that the isolation valves be secured in ; position will ensure that the valves are not inadvertently opened. The existing VEGP TS requirements are overly restrictive on two counts:
- 1. Other valves besides the four specified in the TS can be used to effectively isolate the RMWST.
- 2. The four valves specified provide double isolation of each flowpath. This double isolation coupled with the requirement that each valve be secured in position would effectively require four operator errors to result in an unisolated flowpath. That is, the means used to secure the valves in position would have to be removed from both valves and both valves would have to be opened.
An acceptable level of safety is provided by requiring at least one valve in each flowpath be closed, coupled with the requirement that the valve (s) be secured in position and the administrative controls associated with securing the valve (s) in position. Chapter 3.3 E2-19a September 11,1995 m
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- .. e
. VEGP ITS Conversion Enclosure 2 - Discussion of Changes Chapter 3.3 - Instrumentation - 3/4.3.1 RTS INSTRI"WNTATION CHANGE NUMBER SHE: DISCUSSION 62 LS16a The " Applicable Modes" for the Reactor Trip System Interlocks P-' 7, P-8, P-9, P-10 and P-13 have been modified by footnotes that specify the applicability for the interlocks as above the respective interlocks.- Chapter 3.3 E2-19b - September 11,1995-
i The following pages should be inserted behind the Enclosure 3 tab for Chapter 3.3, Volume 3. l l
-. _- - ~ . . - . - - -.. - . - - .-- - - ._.-.. - _ _ _ _ _ _ _ . .
J , 'e ~* !
, VEGP ITS Conversion i Enclosure 3 - Significant Hazards Evaluations ;
i
- Chapter 3.3 - Instrumentation _
i o : 1- IV. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS , i' RTS . i 4
"LS8a" '
i . 1 The existing VEGP TS contain the requirement that valves 1208-U4-175,12M-U4-176,1208- . U4-177, and 1208-U4-183 be closed and secured in position whenever the rcd is in Mode 5 ! 4 with the loops not filled, Mode 6, and whenever less than the required source range > j instrumentation is operable. NUREG-1431 does not specify which valves must be closed, but j
- rather that any valve used to isolate unborated water sources be closed and secure in position. It -I i
- is implicit that the applicable valves are specified in plant procedures. VEGP proposes to adopt l f the NUREG-1431 requirements for isolating unborated water sources. This is a less restrictive i
. change because the TS will no longer be specific as to which (or how many) valves must be used 4 to isolate unborated water sources. However, the change is acceptable because plant procedures I will require that at least one valve in each flowpath from the reactor makeup water storage tank l
' (RMWST) (the RMWST is the unborated water source at VEGP) to the suction of each charging pump be closed and secured in position. Administrative controls will ensure that these valves !
are maintained closed when required. The fact that the TS will continue to require that the j '. isolation valves be secured in position will ensure that the valves are not inadvertently opened. l l The existing VEGP TS requirements are overly restrictive on two counts: l j 4 l . Other valves besides the four specified in the TS can be used to effectively isolate the i RMWST.
- 2. The four valves specified provide double isolation of each flowpath. This double isolation, coupled with the requirement that each valve be secured in position would ,
effectively require four operator errors to result in an unisolated flowpath. That is, the , 3 means used to secure the valves in position would have to be removed from both valves, l and both valves would have to be opened. , An acceptable level of safety is provided by requiring at least one valve in each flowpath be j + _ closed coupled with the requirement that the valve (s) be secured in position and the administrative controls associated with securing the valve (s)in position. ,
- 1. Does the proposed change involve a significant increase in the probability or consequences .,
of an accident previously evaluated? The new requirement for isolating unborated water sources will continue to provide an j acceptable level of safety. Requiring at least one valve in each flowpath to be closed and secured coupled with appropriate administrative controls will continue to ensure that the RMWST is isolated when required, thereby precluding an unplanned boron dilution event. , Therefore, there will not be a significant increase in the probability of an unplanned dilution ; event, and, since the unplanned dilution is precluded, no increase in the consequences. ! Chapter 3.3 E3-28a September 11,1995
VEGP ITS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.3 - Instrumentation 1 IV. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS RTS j "LS8a" i (continued) i I
- 2. Does the proposed change create the possibility of a new or different kind of accident from :
any accident previously evaluated? : The proposed change does not involve any new equipment or changes in the way the plant is ; operated. Therefore, the proposed change will not create the possibility of a new or different ; kind of accident from any accident previously evaluated. !
- 3. Does the proposed change involve a significant reduction in a margin of safety?
The proposed change will continue to provide adequate assurance that unborated water j sources will be isolated when required. The existing VEGP TS requirements were , unnecessarily prescriptive. Therefore, the proposed change does not involve a significant j reduction in a margin of safety. [ i i i l I l I e i i l t l Chapter 3.3 E3-28b September 11,1995
i I i l l l l l
)
The following page replaces the corresponding page behind the Enclosure I tab for Chapter 3.4, Volume 4.
l l t i I5
.3,4 REACTOR COOLANT SYSTEM (RCS) a ^^ 'T .f 00 5 NOT FILLED koc/; sa/w. used fa h'o/ak. unksW source.s sha/[
t
,3,4,0 < 1 be ser.und /n the c/asedpasilion.
. . . . , . ~ - . . . . . . . . . . . . . . . , . . . . .
~ l so p Ioops 1 LCD ..".1.'.0-
.}A. 8 Two residual heat removal (RHR) W shall be OPERABLE
- and e4- /
ieeve one RHR bee,e shall te in operation.** ":::t:r " ',; ; U tr "'
; ':?
l ('"". :T) m et.;;;:
' ^^^
- ^ IM,100 U 17 'l' , 1^ ^^ U " 17'"' : d - l 1"^0 U " - 1"" _ : ..'. ' ' :1. . .d .. .d _ . . m ...y.....e..
' KCS APPLICABILITY: MODE 5 with rn_t:r :::1;nt-loops not filled.
1 ACTION: one. toop inopero6le. I a. With '::- +k-- th: 2-- -"' n d RHR ini x 0"E"^"LE, immediately initiate corrective action to return the required RHR Ape 4es to
- OPERABLE status, n : r- ~ p nibi;_ ble O r loop 7-.-%s.retvirec( R4Q kops iMpaa
- b. Withino RHR-peen in operation, suspend all operations involving a reduction in boron concentration of the Reactor Cuolant System and 15b I00# / immediately initiate corrective action to return th; aq.i.;d RHR O W- cwe o/t. # etJ 7 o
4eeen len p toLoperation. OPEAA BLL S4chS ar1cl us l
- ' ' ",*"" "' - "n : _ r a ;; _
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;,'-",'s "~ ; ;";n" ,", n- ' -m"'
...,, .. . .. u- =xn W i th ":' - ,'1,7.,,.m"m ... , ...,,., .,. , .'.
,,mem . .__ ..____ l
- s. ..
position.%e- , and secured injposition, immediately close and secure ing L[/he cbsedJ
.~d".:::
di.2..:[ -{fhelased) NQCllY MC*'#If3l SURVEILLANCE REQUIREMENT 3 4.4.1.4.2.1 At least one RHR train shall be determined to be in operation and circulating reactor coolant at least once per 12 hours. 4.4.1.4.2.2 V;'.a 1200 U1 175, 1200 U' 17;ll, 1^ ^ ^ U1 17'? , ...J 1000 'J' 100 l c;11 _ . ' ' ' _ " ' - r d -d ~"~d 4-pe d ti - L,, ... .. ...;;1 ;;p.,f at least g once oer 31 days. Yetfy enelt eks-/&f i:scVaft.s wkreed' wo/er source.s i.s secura:lld //g j5f closed PacifiM n
*0ne RHR train may be inoperable for up to 2 hours for surveillance testing provided the other RHR train is OPERABLE and in operation. e RCS f 15 rninutt.s
**The RHR pump may be deenergized for t; t: 1 t.;.. provided: (1) no operations are permitted that would cause dilution of the " ::t:r C::1;nt Sy;t;;. boron l[o concentration, end (2) core outlet temperature is maintained at least 10 F below saturation temperaturennel(S) /lodraimd openfbcMuM4er redxe,lhe. ACJ
~
unte.f' volumt art- perr0He de
#"""ST d,2;t.;;;; v;1= : 120"-U1 170 ...J 1200 U4 administrative control provided the Reactor ' -
t System Coois in [1" may be open unde compliance ea+ withtheSHUTDOWNMARGINrequirementsofOp;;h[:.t flux at shutdown alarm is OPERABLE,d th a h m danr^ 'n
. ..;,t. ^ ;f Tet.im '. 1. [
t :f 2.20 tire: " E;n nd g g gj,j \ W I5b &p,NyfRNcQ} fog cheeicol} ' Amendment No. 28 (Unit 1) V0GTLE UNITS - 1 & 2 s/4 w-D I Amendment No. 9 (Unit 2) d
The following pages replace the corresponding pages behind the Enclosure 2 tab for Chapter 3.4, Volume 4.
VEGP ITS Conversion Enclosure 2 - Discussion of Changes Chapter 3.4 - Reactor Coolant System CHANGE NUMBER SilF DISCUSSION reformatted to conform to NUREG-1431, LCO 3.4.8. 15a LS15 Existing VTS SR 4.4.1.4.2.2 would be revised to delete the words "in position by mechanical stops." It is suflicient to require that the valves be closed and secured. It is not necessary to further specify that they be secured by mechanical stops. The method of securing the valves closed is not material so long as they are secured. 15b LS22 The requirement in existing VEGP TS 3/4.4.1.4.2 to isolate unborated water sources is retained in VEGP ITS LCO 3.4.8. The format of the LCO, actions, and surveillance requirements is being changed to be consistent with the format for the same requirement in VEGP ITS LCO 3.9.2. The applicable valve (s) will be listed in plant procedures. Note # in existing VEGP TS 3/4.4.1.4.2 would be revised to be consistent with the Note modifying VEGP LCO 3.9.2. The requirement is necessary to preclude a boron dilution event in Mode 5 with the RCS loops not filled as described in VEGP FSAR Section 15.4.6, while allowing use of the flowpath through the chemical mixing tank under administrative control. This change was determined to be less restrictive as described in SHE LS22. 16 M Existing VEGP TS Note ** to LCO 3.4.1.4.2 would be revised to conform to Note 1 of NUREG-1431, LCO 3.4.8. 16a LG Reference to the setpoint of the High Flux at Shutdown Alarm (HFAS A) is moved into the bases of the new HFASA LCO 3.3.8. The requirement to be operable remains in the TS. The discussion of operability for this alarm is in the Bases of the associated LCO (3.3.8) which is consistent with the conventions of NUREG-1431 for locating the details of a system's operability. 17 A Existing VEGP TS 3/4.4.3, " Reactor Coolant System - Pressurizer " would be revised and reformatted to conform to NUREG-1431, LCO 3.4.9. 17a M Consistent with NUREG-1431 the Pressurizer LCO 3.4.3 requirements for the pressurizer heaters are modified to require that two heater groups are capable of being Chapter 3.4 E2-5 September 11,1995 , l l _--.__-__--_---_-----------------------_-_-_-u
4 VEGP ITS Conversion Enclosure 2 - Discussion of Changes Chapter 3.4 - Reactor Coolant System
; CHANGE ; NUMBER SJIE DISCUSSION (
powered by an emergency bus. This is a more restlictive I requirement then currently licensed for VEGP.
; i 18 LS16 The surveillance interval for existing VTS SR 4.4.3.2 . ! ; would be revised from 92 days to 18 months.' This is based l on the recommendations of Generic Letter 93-05, "Line- l Item Technical Specifications Improvements to Reduce [
Surveillance Requirements for Testing During Power l Operation." VEGP does not use dedicated safety related ! i pressurizer heaters to maintain core subcooling during the long term following a loss of offsite power per NUREG- l 0737. Instead, two of the four groups of pressurizer heaters : are powered from non-Class 1E 480 V buses that are in i turn directly fed from the Class IE 4.16 kV buses. The , feeder breakers automatically open on a safety injection 1, 4 r i 't I h Chapter 3.4 E2-Sa September 11,1995
l i The following pages should be inserted behind the Enclosure 3 tab for Chapter 3.4, Volume 4. e i
l VEGP ITS Conversion , Enclosure 3 - Significant Hazards Evaluations ! Chapter 3.4 - Reactor Coolant System l IV. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS I CLS22" i i The existing VEGP TS contain the requirement that valves 1208-U4-175,1208-U4-176,1208- , U4-177, and 1208-U4-183 be closed and secured in position whenever the RCS is in Mode 5 i with the loops not filled, Mode 6, and whenever less than the required source range !
- instrumentation is operable. NUREG-1431 does not specify which valves must be closed, but rather that any valve used to isolate unborated water sources be closed and secure in position. It is implicit that the applicable valves are specified in plant procedures. VEGP proposes to adopt !
the NUREG-1431 requirements for isolating unborated water sources. This is a less restrictive ! 4 change because the TS will no longer be specific as to which (or how many) valves must be used to isolate unborated water sources. However, the change is acceptable because plant procedures ; will require that at least one valve in each flowpath from the reactor makeup water storage tank i d (RMWST) (the RMWST is the unborated water source at VEGP) to the suction of each charging l pump be closed and secured in position. Administrative controls will ensure that these valves ! are maintained closed when required. The fact that the TS will continue to require that the ! - isolation valves be secured in position will ensure that the valves are not inadvertently opened. : i The existing VEGP TS requirements are overly restrictive on two counts: i
- 1. Other valves besides the four specified in the TS can be used to effectively isolate i the RMWST. :
- 2. The four valves specified provide double isolation of each flowpath. This double {
4 isolation, coupled with the requirement that each valve be secured in position l
- would effectively require four operator errors to result in an unisolated flowpath. l
! That is, the means used to secure th valves in position would have to be removed ; from both valves, and both valves would have to be opened. [ S An acceptable level of safety is provided by requiring at least one valve in each flowpath be ;
- closed coupled with the requirement that the valve (s) be secured in position and the i i administrative controls associated with securing the valve (s)in position.
j- , J 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? l I The new requirement for isolating unborated water sources will continue to provide an ! acceptable level of safety. Requiring at least one valve in each flowpath to be closed and secured coupled with appropriate administrative controls will continue to ensure that the : RMWST is isolated when required, thereby precluding an unplanned boron dilution i event. Therefore, there will not be a significant increase in the probability of an l unplanned dilution event, and, since the unplanned dilution is precluded, no merease m :* the consequences. Chapter 3.4 E3-41 September 11,1995 l 1 c . _ . _ _ _ - _ _ _ _ _ . . . . _ _ - , . _ . _ . , , _ . ,
e VEGP ITS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.4 - Reactor Coolant System IV. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS "LS22" (continued)
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change does not involve any new equipment or changes in the way the plant is operated. Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
The proposed change will continue to provide adequate assurance that unborated water sources will be isolated when required. The existing VEGP TS requirements were unnecessarily prescriptive. Therefore, the proposed change does not involve a significant reduction in a margin of safety. 1 l Chapter 3.4 E3-42 September 11,1995 I
i t i The following pages replace the corresponding pages behind the Enclosure 4A tab for Chapter 3.4, Volume 4. , 4 i t I i k it ?
4 RCS Loops - MODE 5, Loops Not Filled l 3.4.8 3.4 REACTOR COOLANT SYSTEM (RCS) l
; 3.4.8 RCS Loops - MODE 5, Loops Not Filled 1
l LCO 3.4.8 Two residual heat removal (RHR) loops shall be OPERABLE and !
$be oY?w'ho 'me"sE* S!$S"t'cYnYrc "Yhph/on.
----------------------------NOTES---------------------- - --
- 1. All RHR pumps may be de-energized for s 15 minutes when switchin from one loop t another provided:
- a. e core outle temperature is maintained > 10*F 4
below saturation temperature. V
- b. No operations are permitted that would cause a
- reduction of the RCS boron concentration; and i
- c. No draining operations to further reduce the RCS ,
i water volume are permitted.
- 2. One RHR loop may be inoperable for s 2 hours for surveillance testing provided that the other RHR loop is y OPERABLE and in operation.
& knk l
mVakr.s 09 1/ 41446 noir, hNMrG/rg//bM*ll1 attcNhr flbnlN o/ ko/ W /he fond! Mf ANW3I'cl s./MAf der iin (
/ th //kce APPLICABILITY: DE ith RC loops not filled. A//M A4e S//prDowN 1
W/mvihof LCo.3,/,terftfj l ACTIONS f///fo/ Jbuhlod 0 % i,s (Z4ggg. - CONDITION REQUIRED ACTION COMPLETION TIME 9 A. One RHR loop A.1 Initiate action to Immediately 3 inoperable. restore RHR loop to OPERABLE status. (continued) t I uvu Na 3.4-17 %" a, es/26/72
\l.oyle Unliii} L l i
___ . .. -- .. .. .- - . . . - - , _ ~ - . _ . - - _---. . _ - - . i
! RCS Loops - MODE 5, Loops Not Filled j 3.4.8 j ACTIONS (continued) i CONDITION REQUIRED ACTION COMPLETION TIME
.i
! B. Required RHR loops B.1 Suspend all Immediately i inoperable. operations involving
- reduction in RCS j QR boron concentration.
4 No RHR loop in AHQ operation. B.2 Initiate action to Immediately restore one RHR loop to OPERABLE status j
- and operatio . ;
/o i
i SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. 12 hours i i SR 3.4.8.2 Verify correct breaker alignment and 7 days i indicated power are availab1 2 to the l reauired RHR oumo that is not in operation.
$ g 3,4,8. 3 %fd fW HFht M isostNZ M4datfAfnfAkQIV3Findt
} issecurtd M,Mo c/dled so,cl jim. 3$da1$ Of!*0fL VOl llig/ggc/jart~fD so ,s.i,u u.,u,,Ma c.1 3' * ".W,'A Ia,masahje uuW.soutsAt tief newn/ I
- in closedpuih'on. clased pasinon,
- ~ _ J C
i i
- i l -- ,C ST 3.4-18 mm f. O, 0?l20/rc.
YofitUni$S0Z-
l i The following pages replace the corre_;,onding pages behind the Enclosure 4B tab for Chapter 3.4, Volume 4. r i
INSERT FOR BASES PAGE B 3.4 The specified condition of Applicability " Loops not filled" is defined as the RCS water level below the reactor vessel flange (elevation 194 feet). It is in this specified condition of
- Applicability, where the smallest active volume for the RCS can occur during midloop operation.
Based on the smallest active volume considered for the boron dilution transient, it was
. determined that each valve used to isolate unborated water sources shall be secured closed in MODE 5 with the RCS loops not filled. At least one valve in each flowpath from the Reactor Makeup Water Storage Tank (RMWST) to the suction of each charging pump shall be closed and secured in position. The applicable valves will be controlled by plant procedures, which will ensure proper valve position. This action effectively isolates the unborated water source of the chemical and volume control system (CVCS) from the RCS, thereby precluding an
- uncontrolled boron dilution event in MODE 5 with the RCS loops not filled. However, the maximum possible flow rate from the RMWST, through the chemical mixing tank, to the suction -
of the charging pumps is sufficiently small that the applicable valve (s) can be allowed open under administrative control provided the applicable shutdown margin requirements of LCO
- 3.1.1 are met and the high flux at shutdown alarm is OPERABLE. Opening the applicable valve (s) is necessary to facilitate chemistry control of the RCS (Ref.1).
4 i }. 2
I RCS Loops - MODE 5, Loops Not Filled 1 B 3.4.8 l i BASES 4 LCO Note 1 permits all RHR pumps o be de-energized f # ## 3 (continued) s 15 minutes when switching om one loop to a r. The !
; circumstances for stopping th RHR pumps are to e limited !
i fo/eJ alhus vale /4 SDe, to situations when the o ge time is short and temperature ~ 4
//im Me gMMrT is maintained . The Note prohibits boron dilution imi or draining o ations when RHR forced flow is sto ed.
* '* dw#, I C 'd #
~!' girahr/her /0 Y be/wsafumfiM tt- ;
Note 2 allows one RHR loop to be inoperable for a per od of
- /N/a'<d /4e M s 2 hours, provided that the other loop is OPERABLE and in I ryitunse/s o/[ col /./ operation. This permits periodic surveillance tests to be l ,, ,jpg fpg7 performed on the inoperable loop during the only time when these tests are safe and possible.
l (/ w 0 / .s d u / ck w O b ! m - ! ! /s &EA4868.(odfM8#f h An OPERABLE RHR loop is comprised of an OPERABLE RHR pump oW/g.h/gf/utd/M&MW4 capable of providing forced flow to an OPERABLE RHR heat exchanger. RHR pumps are OPERABLE if they are capable of 0/sn is de/Iem/h lO.J.10) y
/%,y u,n,y #c emf'., being powered and are able to provide flow if required.
l i ofc wried lo He RCS \ as ner.e.53ory irr /4,s MaOf of cyres//#1 APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat l removal and coolant circulation by the RHR System. (g/f//c fuff/m/g/y -//e//ff 0[ #'I #d*!" Operation in other MODES is covered by
.(di/uliM /rMINrl. LCO 3.4.4, "RCS Loops - MODES 1 and 2";
I . LCO 3.4.5, "RCS Loops - MODE 3"; LCO 3.4.6, "RCS Loops - MODE 4"; LCO 3.4.7, "RCS Loops - MODE 5, Loops Filled"; ! LC0 3.9.5, " Residual Heat Removal (RHR) and Coolant Circulation - High Water Level" (MODE 6); and , ! LCO 3.9.6, " Residual Heat Removal (RHR) and Coolant ; 1 Circulation - Low Water Level" (MODE 6). i ACTIONS 8,d If only one RHR loop is OPERABLE and in operation, redundancy for RHR is lost. Action must be initiated to 1 restore a second loop to OPERABLE status. The immediate i i- Completion Time reflects the importance of maintaining the ;
- availability of two paths for heat removal.
i (continued) . C 5ia B 3.4-38 6. O, 00/00/02 1 YlglN ldAIN $ IMl b
.. ___ ..- J
._m..-~.- .
d 4 1 ' f RCS Loops - N00E 5, Loops Not Filled B 3.4.8 4 BASES :
, -ACTIONS .
B.1 and B.2 g ef,g.gf, mus+beiakhd ; (continued) / i If no requir RHR loops are OPERABLE or in operation,. rgoj - 3 except duri conditions permitted by Note ., all operations
. involving a reduction of RCS boron concentration must be i
J/fh.4q[s)fr.guMird164e suspended 7:;:fr:: '-ititti:: ;' actionPto '- -- T.;t:b f I c/,yec/are ircwen d Ot2?t 722t r:ti: Of an RHR loop to OPERABLE status and - operation. ?: n "'" tic: ;;;;ir:: f::::d ;tr::hti : f;r 4k - fnM'7#d
/t, he 4 M#NQM 4C//P4 3 55 5 I.'.S.C. ( [ : E d 55E5 b NelEInUiat U ompIetion Time reflects the importance of maintaining operation for rmtt/he /n hd heat removal. The action to restore must continue until one- !
l /Apred / /e.sseg a loop is restored to OPERABLE status and operation. I cho$'W!$N!"Ak- A v p<rc/Di'bi'kic5Whiilltk & l URVEILLANCE SR 3.4.8.1 < l C///" '#'f EQUIREMENTS L l amJAr This SR requires verification very 12 hours that one loop is in operation. Verificatio nelude flow rate,
- temperature, or pump status monitoring),(which help ensure 4
that forced flow is providing heat removal. The Frequency L of 12 hours is sufficient considering other indications and
- . alarms available to the operator in the control room to monitor RHR loop performance.
l , SR 3.4.8.2 l Verification that the required number of pumps are OPERABLE l ensures that aaditional pumps can be placed in operation, if L needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper [ breaker alignment and power available to the required pumps. ! The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown j to be acceptable by operating experience. C E f REFERENCES None.
'i, FSAd Sec/ ion lS. 'f, &
- M 3.% B.3 l %,1&rnm M He rey waa' He/w@
l Qie clo. red' (+tc/pf #forkko'is
- PSc wistpaetwe sit wicusitedonsiir#wi 6<t hh 3'fa em.,i Mri u, 4CD)
' Moots es/Hf Me ACS /oysnotJit/ec(, .%ce are vo/* M Qtt tyu/n/'l0 be- 3ectur/ th)>ds/first, GReft4Mcjof"-" ^ ^^ - -- JJ dry: B 3.4-39 0 ) lC WollT g$ c/ MSua Main 5/N5fN
- l i
j l 1
?
e 5 I The following page replaces the corresponding page behind the Enclosure 5 tab for Chapter 3.4, Volume 4 t l
VEGP ITS Conversion 1 Enclosure 5 - Justifications for Differences from NUREG-1431 Chapter 3.4 - Reactor Coolant System CIIANGE NUMBliR JUSTIFICATION range instmmentation as appropriate, and the specific water level can vary over the range of steam generator operating conditions so long as the highest point of the U-tubes remains covered. Plant procedures will provide the minimum indicated levels to ensure the U-tubes are completely submerged. 4a Condition C of RCS Loops Mode 4 is revised to clarify that the intent of the Condition is that b_qth required loops are inoperable. The NUREG-1431 wording is not clear. This clarification is consistent with the bases for this Condition. 5 Not Used. 6 The requirement to isolate unborated water sources would be added to VEGP ITS LCO 3.4.8 to be consistent with existing VEGP TS 3/4.4.1.4.2. This requirement is necessary to preclude a boron dilution event in Mode 5 with the RCS loops not filled as described in VEGP FSAR section 15.4.6. The format of the LCO and surveillance requirements is consistent with the format for the same requirements in NUREG-1431 LCO 3.9.2. Note 3 for VEGP ITS LCO 3.4.8 is the same as the Note for VEGP ITS LCO 3.9.2. 7 For VEGP the cold overpressure protection system (COPS) enable temperature is 350 F, the transition temperature between Modes 3 and 4. The COPS is required to be operable in Modes 4, 5, and 6 with the vessel head on to provide the necessary overpressure protection for low temperature operation. Therefore, Mode 4 should be deleted from the applicability of VEGP ITS LCO 3.4.10. I 8 The Note to the applicability of VEGP ITS LCO 3.4.10 should be deleted. At VEGP, the pressurizer code safeties are tested in Mode 3 on the way down for a refueling outage. If the valves are tested successfully, they remain in place awaiting startup. If the valves must be removed for maintenance, they are bench tested under conditions simulating actual operating ambient conditions. Therefore, the Note modifying the Applicability of NUREG-1431 LCO 3.4.10 (as it appears in the NUREG) is not applicable to VEGP. 9 At VEGP, there are two pressurizer power-operated relief valves (PORVs). These valves are safety-related DC solenoid-operated valves. Chapter 3.4 E5-2 September 11,1995
VEGP ITS Conversion Enclosure 5 - Justifications for l I Differences from NUREG-1431 Chapter 3.4 - Reactor Coolant System ! i CHANGE i NUMBER JUSTIFICATION f VEGP ITS LCO 3.4.11 has been marked up to reflect the VEGP design. , Since the valves are DC solenoid-operated, SR 3.4.11.3 is not applicable. i 1 i t i 5 i i i i 4 i i i l l l l I Chapter 3.4 E5-2a September 11,1995
The following page replaces the corresponding page behind the Enclosure I tab for Chapter 3.9, Volume 8.
. . , . . - . - - - - . - . . - ~ ~ . . . . . - . . . ~ . - , ~ . - ~.-_,.,n. - ~ n. ,.,.m, .,--,.wsw.pe- -
. _ . . . . . . _ , . . . , L 1.. 1 1 i ' Thus Lc_o Is RevlSED /Nro Lc.o 3. % /, Bo ren y u.o 3. s 2., untmedeL&ter Soon:c n a l"es- T ; i i 3.9 . j SM REFUELING OPERATIONS 3 3A. I 2/'.^.1 BORON CONCENTRATION S j ) LIMITING CONDITION FOR OPERATION [ ,
=A.coac_toicaxitg Twg COL 4.%et. stspec$eQ an _
3.9.1 The boron concentration f all-fi-1-leeoorti the Reactor Coolant. C - J . N System,end the refuelino canal nail be matntaineu p i ors - c.sur i..., o1 , e thythy'.pote-reptrictye of p folfowing rektivit, condi ions re Q , 4 usti.fm , ,, ,, , ,, , __ __ is., a , _. unboroded-
- ----+-=+4aa e' ;- -t-- t'.:: ,7 .;.;; . ;;ve 3 4 g3, .F'J _ .
0 { b. ^ b r:: r y.. L4.0 6 'ti;n:1?y, /alveT 1 ^^ = 17% L Z " 1??!. -^^ ., l.. ^^^
., . , ) l
- &f,2. ' hall be closed and secured in pos< tien. /
i i APPLICABILITY: MODE 6. I'01 'O ACTION
.. n c.,on+r._+,on nom.h 1.,,n .+ ,
- v ;
i g 3,g g , a. With th. T.; i :-::t: Of :. : d 5. ' ._ ::t ::thfhd, immediately. m i suspend all operations involvi 19ftf ALTERATIONS or positive 8- { p J reactivity chances and initiat nd continue boratiaa :t ...nur thanl __ ! I e or a solution ater than or equal to. l l [- ~~~~ 7000 ppe boron v. 't: -~ 6 - ? _ , , il K g is reduced to less than gto 3'9' l or equal to r the boron conce is restored to greater l sE@, ante , th equal to 2000 ppe, whichever is the mo ictive. 9 l denberieA l IS
- M JK Wkhvalves 100^ = 17;,1-^^ = 17N, lieo y,-le5, nu 1,.ee v, lo- l fj!s.t.(,p,,v not closed and secured in position, immediate1 close and secure in _
l j Gg . a.ncL $ Norrn SR3.9 I I ln 12. hours, t0 .syd'QYMy
;Y U~
Mk RVEILLANCE REQUIREMENTS _WhLE!/ e~Ve.veW
, . ?.1.1 'Tte boron oncentration " "h.
ChsES 45 ws+ hon fornotspecshect.on CDLR
"....... _ _ ; ' . , , ;. ;, ... .ud . . .. . . T . I ' r., f
\ .....' ;h:ll L G-isterminea-by-cheur ech-ens' vsos7a4 4eese once per 72 hours. p,3,gg
~
i 'SI's i ~' ~ ~ - " ' ' n Qer31 days. _ _ cs NOTE U ---- -- : n- "^^ "' 1?( ; . ' ^^^ "" 17' may be open under i i deinistrative control provided the Reactor Coolant System is in compliance i i IN with the requirements of Specification 3.9.1 and the hiah flux at shutdown j 3' T.2 alam is OPERABLEfwith a setpotnt or z.30 times background. For the purposal 13 cof snis specirication, the nigh fiux at shutdown aiars wiii de demonstrated
- LOPERABLE pursuant to Specification 4.9.2. '
4 ! L) seses sco a,t2. l
- V0GTLE UNITS - 1 & 2 3/4 9-1 Amendment No.28 (Unit 1) a I J ^- "- "t N .9 (Unit 2)
Iminn f/wpaMAnmMeggw.s c h ioe/nriv y % lt s%e sacHM of He- cAer3 hap 3
r i l 1 l t t e r The following pages replace the corresponding pages behind the Enclosure 2 tab for Chapter 3.9, Volume 8. I 9
VEGP ITS Conversion Enclosure 2 - Discussion of Changes Chapter 3.9 - Refueling Operations DISCUSSION OF CHANGES - CHAPTER 3.9 ) i This enclosure contains a brief discussion / justification for each marked-up change to the existing. ! Vogtle Electric Generating Plant (VEGP) Units 1 and 2 Technical Specifications (VTS). The j Change Numbers are referenced directly from enclosure 1 (VTS markup), and the referenced ; i Significant Hazard Evaluations (SHEs) are contained in enclosure 3. Some obvious . administrative changes to the VTS (i.e., format, presentation, and editorial changes made to ; conform to the Improved Technical Specifications (ITS) of NUREG-1431) are not discussed in l' this enclosure but are covered by the generic administrative SHE contained in enclosure 3. CHANGE-NUMBER SJ16 DISCUSSION ; t 1 M The requirements of thi.s specification are extended to include the reactor j cavity. This change is consistent with NUREG-1431. l 2 LG The LCO is reworded consistent with NUREG-1431 and some words are moved into the bases. < t 3 LG The boron concentration required for refueling is moved into the COLR. This change is consistent with NUREG-1431
!~
4 A Consistent with NUREG-1431 the last part of the LCO " uniform and sufficient.. " is deleted. The term uniform does not belong in this LCO ! since this LCO does not ensure a uniform boron concemration. The j technical specification requirements for the RHR system ensure mixing in the RCS not this specification. The remainder of the deleted LCO deals with meeting the more restrictive of two requirements. The LCO has been ;
- rewritten to contain only one requirement that encompasses both the former l requirements (see item 5 below). .
l l 5 A Consistent with NUREG-1431, the separate requirement for k,yis deleted. The boron concentration specified in the COLR will ensure this k,y value is ! l met and therefore both concentration and k,y requirements will be satisfied. , It is unnecessary to continue to specify the k,y value separately.
- 4. .
! 6 A Consistent with NUREG-1431, the section of the LCO regarding unborated water source isolation valves is moved into the new LCO 3.9.2, Unborated i
- Water Source Isolation Valves. ;
~ 7 LS6 Consistent with NUREG-1431, the list of valves is removed from the LCO. l The applicable valve (s) will be listed in plant procedures. 1 I L Chapter 3.9 E2-1 May 1,1995
I o I
- VEGP ITS Conversion Enclosure 2 - Discussion of Changes Chapter 3.9 - Refueling Operations .
d I'. CHANGE NUMBER SHE DISCUSSION i .
- 8 LG The current Action statement "a" is revised to be consistent with NUREG-
- 1431. The rate ofboration requirements are deleted. The safety analysis does not assume a rate of boration to return to the required concentration.
Instead of a specific rate of boration, a statement is placed in the bases that - recommends a highly concentrated source of boron be used to restore the '
- RCS to the required concentration as quickly as possible.
t c 9 A Consistent with NUREG-1431, Action statement "b" is revised and moved 2 into the new LCO for Unborated Water Source Isolation Valves as Condition A. The corresponding Action in the new LCO is modified by a e Note that clarifies the technical specification rules regarding entry into the Condition for each valve. l 10 M Consistent with NUREG-1431, the current Action statement b is revised to include additional requirements. The Action to immediately suspend Core Alterations is added. An Action to perform SR 3.9.1.1 (verify boron concentration in 12 hours) has also been added. The 12 hour time, although - different from NUREG-1431, is consistent with the current VEGP licensing 3 basis for the performance of this surveillance as required in Action
- statement b of current VEGP LCO 3.9.2. The addition of these actions
, provide assurance that if an unborated water source isolation valve is found 9 open (in violation of the LCO) the appropriate action is taken to secure Core i Alterations until boron concentration is verified. The new Condition
- containing these Actions is modified by a Note that requires the Action to L perform SR 3.9.1.1 (boron concentration verification) is completed any time
~
the Condition is entered. This requirement ensures boron concentration is verified, regardless of how fast the affected valve is closed, by preventing the Condition from being exited until Action A.3 is complete. I1 LG ~ ' Surveillance requirement 4.9.1.1 is revised consistent with NUREG-1431 (SR 3.9.1.1) to verify the boron concentration specified in the COLR. The prescriptive requirement describing procedural detail regarding how the boron concentration is verified (chemical analysis) is moved into the bases also consistent with NUREG-1431; 12 LS6 Surveillance requirement 4.9.1.2 is revised consistent with NUREG-1431 SR 3.9.2.1. The applicable valve (s) will be listed in plant procedures. Chapter 3.9 E2-2 May 1,1995
.. ; u VEGP ITS Conversion Enclosure 2 - Discussion of Changes Chapter 3.9 - Refueling Operations
- CHANGE-NUMBER S 1111 DISCUSSION 12a 'LS5 ' Existing VEGP surveillance 4.9.1.2 is revised to delete the words "in position by mechanical stops." It is sufficient.to require that the valves be closed and secured. It is not necessary to further specify that they be secured by mechanical stops. The method of securing the valves closed is -
not material so long as they are' secured. 13 LG' With the exception of the specific valve numbers, the VEGP specific footnote "#" is moved into LCO 3.9.2, Unborated Water Source Isolation Valves as a Note to the LCO. This note is consistent with the intent of the existing note in VEGP TS 3/4.9.1. The note allows valves in the flowpath from the RMWST, through the chemical mixing tank, to the suction of the charging pumps to be opened under administrative control if certain conditions are met. This note is the same as Note 3 in VEGP ITS LCO 3.4.8. Applicable valve (s) will be listed in plant procedures. Some details concerning the operability.of the high flux at shutdown alarm are moved into the bases description of the LCO Note. The movement of the discussion of equipment operaH!ity to the bases is consistent with the treatment of operability discu3sions in other NUREG-1431 technical specification bases. 14 LG The Nuclear Instrumentation LCO for MODE 6 is revised consistent with NUREG-1431. Applicable information is moved into the bases to describe instrument operability. Since in this Mode VEGP does not rely on the audible count rate for indication of a boron dilution event (unborated water source isolation valves are secured in closed position or high flux at shutdown alarm is operable) the requirement for the audible count rate is relocated from the technical specifications to plant procedures. 15 M The Action statement for two inoperable monitors is revised, consistent with , 1 NUREG-1431, to include an Action to initiate restoration of one monitor immediately. 16 LG Surveillance 4.9.2 is revised consistent with NUREG-1431. Instmment tag 4 numbers are moved into the bases as appropriate.
- l'7 LSI The Analog Channel Operational Test (ACOT) requirements for the source neutron flux monitors are deleted and a Channel Calibration requirement is added. This change is consistent with NUREG-1431. In Mode 6, the source range monitors are required for indication only, there are no precise setpoints associated with these instruments in this Mode. In this capacity, ;
Chapter 3.9 E2-3 September 11,1995
- _ = _ .- - .. . . - . - - . .
t VEGP ITS Conversion i Enclosure 2 - Discussion of Changes l ' Chapter 3.9 - Refueling Operations CHANGE ! l NUMBER SIJE DISCUSSION 1 the source range instrumentation is typically used to read a change in counts ; per second (CPS) relative to previous readings, not precise CPS indication. The source range instrumentation is monitored for significant changes in count rate which are important to evaluate the change in core status. Even l the accepted convention defining criticality only requires a slowly , I i i l l
)
l Chapter 3.9 E2-3a September 11,1995 !
- m. .
l i The following pages should be inserted behind the Enclosure 3 tab for Chapter 3.9, Volume 8. l
VEGP ITS Conversion Enclosure 3 - Significant Hazards Evaluations Chapter 3.9 - Refueling Operations IV. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS l "LS6" l l The existing VEGP TS contain the requirement that valves 1208-U4-175,1208-U4-176,1208-U4-177, and 1208-U4-183 be closed and secured in position whenever the RCS is in Mode 5 with the loops not filled, Mode 6, and whenever less than the required source range instrumentation is operable. NUREG-1431 does not specify which valves must be closed, but rather that any valve used to isolate unborated water sources be closed and secure in position. It is implicit that the applicable valves are specified in plant procedures. VEGP proposes to adopt the NUREG-1431 requirements for isolating unborated water sources. This is a less restrictive change because the TS will no longer be specific as to which (or how many) valves must be used to isolate unborated water sources. However, the change is acceptable because plant procedures will require that at least one valve in each flowpath from the reactor makeup water storage tank (RMWST) (the RMWST is the unborated water source at VEGP) to the suction of each charging pump be closed and secured in position. Administrative controls will ensure that these valves are maintained closed when required. The fact that the TS will continue to require that the isolation valves be secured in position will ensure that the valves are not inadvertently opened. The existing VEGP TS requirements are overly restrictive on two counts:
- 1. Other valves besides the four specified in the TS can be used to effectively isolate the RMWST.
- 2. The four valves specified p; ovide double isolation of each flowpath. This double isolation, coupled with the requirement that each valve be secured in position would effectively require four operator errors to result in an unisolated flowpath.
That is, the means used to secure the valves in position would have to be removed from both valves, and both valves would have to be opened. An acceptable level of safety is provided by requiring at least one valve in each flowpath be closed coupled with the requirement that the valve (s) be secured in position and the administrative controls associated with securing the valve (s) in position.
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
The new requirement for isolating unborated v/ater sources will continue to provide an acceptable level of safety. Requiring at least one valve in each flowpath to be closed and secured coupled with appropriate administrative controls will continue to ensure that the RMWST is isolated when required, thereby precluding an unplanned boron dilution event. Therefore, there will not be a sigr.ificant increase in the probability of an unplanned dilution event, and, since the unplanned dilution is precluded, no increase in the consequences. Chapter 3.9 E3-25 September 11,1995
I
. .. 1 VEGP ITS Conversion . >
Enclosure 3 - Significant Hazards Evaluations ; Chapter 3.9 - Refueling Operations l i IV. SPECIFIC SIGNIFICANT HAZARDS EVALUATIONS !
"LS6" ' 'l (continued) j
- 2. Does the proposed change create the possibility of a new or different kind of accident !
from any accident previously evaluated? ! The proposed change does not involve any new equipment or changes in the way the : plant is operated. Therefore, the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated. i
- 3. Does the proposed change involve a significant reduction in a margin of safety?.
f The proposed change will continue to provide adequate assurance that unborated water sources will be isolated when required. The existing VEGP TS requirements were unnecessarily prescriptive. Therefore, the proposed change does not involve a significant reduction in a margin of safety. t i I
?
f l l i i I I s l l l Chapter 3.9 E3-26 September 11,1995
t t The following page replaces the corresponding page behind the Enclosure 4A tab for Chapter 3.9, Volume 8.
L Ur. borated Water Source Isolation Valves 3.9.2 , 3.9 REFUELING OPERATIONS 3.9.2 Unborated Water Source Isolation Valves LCO 3.9.2 Each valve used to isolate unborated water sources shall be l os.e.1 p.gji t.ipn. Ajo rg - _ .--. ._- -- ._ 57n.s fk fim./k AM W.57]h I secured mitig aalminia in the 9_%u S heruc m of/Aec k 4 M t Che m ica l be 99ered && he confrol provadacL t.sa% APPLICABILITY: MODE 6. %"6Q'W'an a la m is o_ pee.nai.E,wiW__Spea6ca.
- bon j ACTIONS i
-------------------------------------NOTE------------------------------------
Separate Condition entry is allowed for each unborated water source isolation : valve. d . CONDITION REQUIRED ACTION COMPLETION TIME A. ---------NOTE--------- A.1 Suspend CORE Immediately Required Action A.3 ALTERATIONS. must be completed whenever Condition A E is entered. A.2 Initiate actions to Immediately secure valve in - One or more valves not closed position. secured in closed position. M I* A.3 Perform SR 3.9.1.1. Xhours (verifg boron cMMkn) 1 WOG STS 3.9-2 Rev. O, 09/28/92 i
The following pages replace the corresponding pages behind the Enclosure 4B tab for Chapter 3.9, Volume 8.
I
.. j i
3.9 REFUELING OPERATIONS . ! INSERTS :! INSERT 2 ;
' APPLICABLE SAFETY ANALYSIS SECTION OF 3.9.1 BASES [
PAGE B 3.9 ; Since the Unborated Water Source Isolation Valves LCO,3.9.2, requires the valve (s) used to ! isolate the unborated water sources to be secured in the closed position in MODE 6, the boron ; dilution events analyzed in this MODE are limited to a very small amount of unborated chemical ! solution that is allowed to enter the RCS for water chemistry quality control. The dilution flow , path is provided by the allowance to open (under administrative control) valves in the flowpath ( from the RMWST, through the chemical mixing tank, to the suction of the charging pumps. At ! all other times during Mode 6, at least one valve in each flowpath from the RMWST to the ; suction of each charging pump will be secured closed and any other chemical makeup solution which is required during refueling will be borated water supplied from the refueling water
- storage tank by the RHR pumps. A more detailed discussion of of the boron dilution event analyzed in this MODE is provided in the bases for LCO 3.9.2. ;
I
?
t 6 t I a i l i
, i 1
i 4 f n :
l i l Unborated Water Source Isolation Valves ! B 3.9.2
> B 3.9 REFUELING OPERATIONS B 3.9.2 Unborated Water Source Isolation Valves BASES i BACKGROUND During MODE 6 operations, all ._ N N MN..Mn..'...frreactor g j ,j , g j4 2 makeup water sources containing unborated water that are .
connected to the Reactor Coolant System (RCS) must be<4eeed feldM i b"/'* N " N to prevent unplanned boron dilution of the reactor coolant. Mitsy ##ferS/orge, M The isolation valv4)must be secured in the closed position. ; 1 hQMnf,5 }oMe.tyc/IM The Of fflek and Volume Control System is capable of Che@mical 0/ M 'fd' supplying borated and unborated water to the RCS through l i 5M///< c/wofay)/,&*/sacems/ various flow paths. Since a positive reactivity add , j /d g,r///sney sf ' made by reducing the boron concentration is inappropriate ' fjdwr f ,/g gg, f, during MODE 6, isolation of all unborated water sources g gggg/, ! prevents an unplanned boron dilution. MehtU)toWbe (Ar/tdW t+ 4 L "" hof ece g/,Ak4d)Thepossibilityofaninadvertentborondilutionevent
,,umnouf**
SAFETY ANALYSES (Ref. 1) occurring during MODE 6 refueling operations is precluded by adherence to this LCO, which requires that I potential dilution' sources be isolated. Closing the ; required valves during refueling operations prevents the l flow of unborated water to the filled portion of the RCS. The valves are used to isolate unborated water sources. , These valves have the potential to indirectly allow dilution l i of the RCS baron concentration in MODE 6. By isolating ) R5c. unborated water sources, a safety analysis for an 1 , uncontrolled boron dilution accident in accordance with the i ! MEE 3 Standard Review Plan (Ref. 2) is not required for MODE 6. VEG P SPEClNC- . M/3'S '" * 'The RCS boron concentration satisfies Criterion 2 of the NRC
- Policy Statement.
l LCO This LCO requires that flow paths to the RCS from unborated i water sources be' isolated to prevent unplanned boron i h dilution during MODE 6 and thus avoid a reduction in SDM.1 l
** "Wk % 4occawplahat Of kJ/ sw sehe.seween c9,,t /mdin,u,4 e W 49 M6le I flowpoM, ,
1 (continued)
]
2 WOG STS S3.9-5 Rev. O,09/28/92 1 ;
F-3.9 REFUELING OPERATIONS INSERTS INSERT 1 LCO SECTION OF 3.9.2 BASES PAGE B 3.9-5 The LCO is modified by a Note that allows valves in the flowpath from the RMWST, through the chemical mixing tank, to the suction of the charging pumps to be opened under administrative control provided the reactor coolant system boron concentration is within the limit specified in the COLR and the high flux at shutdown alarm is OPERABLE. The high flux at shutdown alarm is not normally required OPERABLE in MODE 6, however for the purpose of meeting the requirement stated in this Note, the high flux at shutdown alarm is considered OPERABLE if the applicable surveillance requirements of LCO 3.3.8, High Flux at Shutdown Alarm and LCO 3.9.3, Nuclear Instmmentation are met. l I l 1 _i
. ~ + )
i l 3.9 REFUELING OPERATIONS INSERTS INSERT 3 APPLICABLE SAFETY ANALYSIS SECTION OF 3.9.2 BASES PAGE B 3.9-5 l 3 However, since this LCO is modified by a Note that allows a very small amount of unborated chemical solution to enter the RCS for the purpose of water chemistry quality control, a boron
; dilution event is analyzed in this MODE. The dilution flow path from the RMWST, through the chemical mixing tank, to the suction of the charging pumps is provided by the allowance to open (under administrative control) applicable Chemical and Volume Control System (CVCS) valves.
The maximum flow rate possible through this flow path is less than 3.5 gal / min which is approximately 3.0 percent of the limiting flow rate considered in the analysis for other Modes. At all other times during Mode 6, the valve (s) are secured closed and any other chemical makeup ' solution which is required during refueling will be borated water supplied from the refueling , water storage tank by the RHR pumps. Flow paths from the CVCS which could allow unborated . chemical makeup water in excess of 3.5 gal / min to reach the RCS are always isolated in MODE 6 by maintaining at least one valve secured closed in each applicable flow path. Since the maximum flow rate associated with the available dilution flow paths in Mode 6 is very small, the total time from initiation of event to the eventual complete loss of shutdown margin is significantly large compared to the minimum required operator action time. Therefore, a considerable amount of time is available for the operator to initiate and terminate procedures for > RCS water chemistry adjustments before potential loss of shutdown becomes a concern. Additionally, the high flux at shutdown (HFAS) alarm is required OPERABLE prior to the applicable CVCS valves being opened. The boron dilution event analysis specifically credits the HFAS alarm when these valves are open. The availability of the HFAS alarm ensures that the operator has a 30 minute warning to terminate the dilution before shutdown margin is lost. a d 1 0
= - - - - - -_ _ _d
... . _ . . . _ .._. _. . _. 1 -.
Unborated Water Source Isolation Valves B 3.9.2 , I BASES (continued) l APPLICABILITY In MODE 6, this LCO is applicable to prevent an inadvertent , boron dilution event by ensuring isolation of all sources of j unborated water to the RCS. For all other MODES, the boron dilution accident was analyzed and wa.s found to be capable of being mitigated. ACTIONS The ACTIONS table has been modified by a Note that allows . r separate Condition entry for each unborated water source The ACTIONS do isolation valve. rio{-appiyjoVa.)ve - inW(AwpaVh/hher Me A4W5T,/4ssf U Mt c4tnRe/tW/Kidj Continuation of CORE ALTERATIONS is contingent upon h4Rj/o#t Sac /yg maintaining the unit in compliance with this LCO. With any q valve used to isolate unborated water sources not secured in the closed position, all operations involving CORE
- /"Y ALTERATIONS must be suspended immediately. The Completion
*Miilrg/4WdWa#W Time of "immediately" for performance of Required Action A.1 l
. cogn/ inA: ark shall not preclude completion of movement of a component to i y/M/4 Nd ja a safe position.
H e LC o. Condition A has been modified by a Note to require that Required Action A.3 be completed whenever Condition A is entered. L.Z
- Preventing inadvertent dilution of the reactor coolant boron concentration is dependent on maintaining the unborated water isolation valv4) secured closed. Securin in the closed position ensures that the valvecannot @ g bethe valve @
t inadvertently opened. The Completion Time of "immediately" requires an operator to initiate actions to close an open valve and secure the isolation valve in the closed position immediately. Once actions are initiated, they must be continued until the valves are secured in the closed position. 9 (continued) WOG STS B 3.9-6 Rev. O,09/28/92
a s. .. 7 The following page replaces the corresponding page behind the Enclosure 5 tab for Chapter 3.9, Volume 8. 4
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l ,o . i VEGP ITS Conversion Enclosure 5 - Justifications for Differences from NUREG-1431 Chapter 3.9 - Refueling Operations JUSTIFICATIONS FOR DIFFERENCES FROM NUREG-1431 - CHAPTER 3.9 This enclosure contains a brief discussion / justification for each marked-up technical change to the NUREG-1431 Technical Specifications (TS) to make them Vogtle Electric Generating Plant Units 1 and 2 (VEGP) specific. The Change Numbers are referenced directly from enclosure 4A (NUREG markup). The NUREG-1431 markup also includes the accepted changes to Revision 0 of the NUREG resulting from the Industry /NRC Lead Plant process. The Industry /NRC changes are identified by change package number. The applicable change package includes the discussion / justification for these changes. CllANGE NUMBER JUSTIFICATION 1 A Note is added to the LCO of Specification 3.9.2, Unborated Water Source Isolation Valves. This Note is consistent with the current licensing basis of VEGP and appears as a footnote in the current technical specification for boron concentration,3/4.9.1. The Note allows valves in the flow path from the RMWST, through the chemical mixing tank, to the suction of the charging pumps to be opened under administrative control if certain conditions are met. This note is the same as Note 3 in VEGP ITS LCO 3.4.8. la The 4 hour Completion Time for LCO 3.9.2 Action A.3 is revised to 12 hours consistent with the current VEGP licensing basis time for this surveillance to be performed as stated in Action statement b of current VEGP LCO 3.9.2. The 4 hours allowed in the NUREG would not always provide sufficient time for chemistry to verify the results of a sample. In addition, the 12 hour time is acceptable based on the requirement for the source range monitors and the High Flux at Shutdown Alarm to be operable and provide indication / alarm of the core status. In addition, the SR number in the required action is annotated with a reference to explain what the SR is. 2 The 4 hour Completion Time to verify boron concentration when two source range monitors are inoperable for Required Action B.2 in LCO 3.9.3 is deleted. This change is consistent with the VEGP current licensing basis which only requires verification of boron concentration once per 12 hours under these circumstances. In addition, considering the volume of water involved, and assuming the boron concentration to be within the limit when the two source range channels become inoperable (as can be demonstrated by the previous performance of SR 3.9.1.1) and Core Alterations and positive reactivity additions are suspended (as required by Actions A.1 and A.2) the core reactivity will be stable and any changes in boron concentration will occur very slowly. Therefore, the need to verify boron concentration within 4 hours is unnecessary. Verification of boron concentration within 12 hours and every 12 hours Chapter 3.9 E5-1 September 11,1995 j}}