ML20210L777
| ML20210L777 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/13/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20210L774 | List: |
| References | |
| NUDOCS 9708210306 | |
| Download: ML20210L777 (5) | |
Text
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-T UNITED STATES u
3 NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 306eH001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.137 TO FACILITY OPERATING LICENSE NO. NPF-12 SOUTH CARGLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SE_RVICE AUTHORITY VIRGIL C. SUMMER NUCLEAR STATION. UNIT NO. 1 DOCKET NO. 50 395
1.0 INTRODUCTION
In its application dated *.ovember 14, 1995, as supplemented on July 11, 1996 and July 24, 1997, Souin Carolina Electric & Gas Company (the licensee) proposed that Technical Specification (TS) 3/4.8.4.2 for motor op? rated valves (MOVs) thermal overload Nuclear Station (VCSNS) protection and bypass devices at Virgil C. Sunrner be revised.
The >roposed TS amendment removes the limiting condition for operation (LCO), t1e surveillance requirement (SR), and Table 3.8-2 for the above mentioned MOV devices from the current TS and relocates them to VCSNS licensee controlled plant surveillance test arocedures (STPs), as implemented through station administrative procedures (SA)s). This change also removes a discussion of the operability of the MOV devices in the TS Bases Section B 3/4.8.4, along with any references to the MOV devices throughout the TS.
2.0 BACKGROUND
The function of thermal overload protection devices is to provide low overcurrent protection to the electrical power circuits of their associated equipment during plant operation.
However, under accident conditions the thermal overload protection devices are bypassed upon engineered safety feature actuation signals (ESFAS) to preclude any potential for thermal overload protection devices causing nuisance tripping of the associated loads, if severe overcurrent conditions developed (e.g., circuit faults), it would still be cleared by tripping of the upstream circuit breaker.
The purpose of TS 3/4.8.4.2 is to ensure the operability of the MOV devices by demonstrating specific design features that are committed in the final safety analysis report (FSAR) Appendix 3A, to comply with the recommendation of Regulator Guide (RG) 1,106, " Thermal Overload Protection for Electric Motors on Motor-erated Valves." The licensee finds that the removal of the above mentioned S is justified because:
(1) the licensee finds this amendment consistent with the efforts of NRC and the nuclear industry to simplify TS, as outlined in the July 22,1993 (58 FR 39132) Final Policy Statement on TS Improvements for Nuclear Power Reactors (final policy statement).
As stated in the final policy statement, if a requirement meets any one of the four criteria, it should be retained or included in the TS.
The requirement does gagg0gg gggg,3 l4, P
2 not meet any one of the four criteria in the final policy statement and.
therefore, need not be retained or included in TS: and (2) removal does not adversely affect the FSAR commitment to comply with RG 1.106, as its compliance will be maintained and controlled throuch the licensee controlled plantproceduresandchangeswillbeevaluatedbyI0CFR50.59 review.
RG 1.106 describes _ a method acceptable to the NRC staff in regard to the application of thermal overload protection devices that are-integral to the motor starter for electric motors on MOVs.
This method would ensure that the thermal overload protection devices will not needlessly prevent the motor from performing its safety related function.
3.0 EVALUATION The staff has reviewed the proposed removal of TS 3/4.8.4.2 for the MOV thermal overload protection and bypass devices at Summer and its evaluation follows.
3.1 Removal of LCO 3.8.4.2. SR 4.8.4.2. and Table 3.8 2 from TS 3/4.8.4.2 and its Discussion on the MOV Devices from the Plant TS Bases The licensee proposes to remove LC0 3.8.4.2, SR 4.8.4.2, and Table 3.8 2, which list MOVs, from TS 3/4.8.4.2 for the MOV thermal overload protection and bypass devices, and to remove its discussion on the M0V devices from the plant TS bases.
The removed TS relocated to the licensee provision and its MOV lists in Table 3.8 2 would be controlled plant procedures, which would continue surveillance, Other than the fact that any changes to those procedures would no longer require a license amendment, the licensee contends that the proposed TS changes do not adversely affect the FSAR commitment to comply with RG 1.106, as its compliance will be maintained and controlled through the licensee controlled plant procedures and changes will be__ evaluated by_10 CFR 50.59 review, in connection with relocating the TS provisions to licensee-controlled documents (e.g., plant operating procedures, the FSAR, and the quality CFR 50.36) plan), the final rule concerning the Technical Specifications (10 assurance was issued in the Federal Reaister on July 19. 1995. The rule outlines four criteria that must be used for relocating TS to other licensee-controlled documents.
However, the licensee's original submittal did not include the evaluation based on those criteria.
Upon the staff's request, by supplemental letter dated July 11, 1996, the licensee completed its evaluation -
and submitted the following information:
Criterion Installed instrumentation that is utad to _ detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.-
The licensee finds that those MOV thermal overload protection and bypass devices do not provide any function in the detection of pressure boundary leakage.
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Criterion 2 - A process variable, design feature, or operating restriction that is an initial condition of a design basis accident (DBA) or a transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The licensee finds that those thermal overload protection and bypass devices are not used to define an initial condition of a DBA or a transient analysis that impacts the integrity of fission product barriers.
Criterion 3 - A structure, system, or component that is part of the primary success )ath and which functions or actuates to mitigate a DBA or a transient that eitler assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The licensee finds that those thermal overload protection and by) ass devices are automatic functioning devices that are energized only when t1e associated equipment they protect are energized.
These devices serve as subcomponents for the electrical circuits of components that are part of the primary success path and do not directly function or actuate, in and of themselves, to mitigate a DBA or a transient in which a fission product barrier is assumed failed or challenged.
Criterion 4 - A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
Operating experience at VCSNS has shown that thermal overloads are highly reliable devices that have a minimal effect on equi) ment operability, and failure of the bypass device to function will not
)y itself, prevent the load from receiving power to operate.
On this basis. the licensee concludes that the thermal overload protection and bypass devices do not constitute components that are significant to the public health and safety.
On the basis of the staff's review of the licensee's response to criteria outlined by the TS final rule, the staff concludes that the pro)osed amendment to remove LC0 3.8.4.2. SR 4.8.4.2, and Table 3.8-2, which list 10Vs. from TS 3/4.8.4.2, and relocate them to the licensee-controlled plant procedures is acceptable. With removal of the SRs to plant STPs pursuant to 10 CFR 36(c)(3), the staff finds that facility operation will be within the safety limits and LCOs met, and are therefore no longer necessary in the TS. With the deletion of TS 3/4.8.4.2 the staff finds that a discussion of MOV devices is no longer necessary in the TS: therefore, the deletion of a paragraph discussing the operability of MOV devicer from the TS bases section is also acceptable.
Additionally, the licensee is meeting RG 1.106 for the MOV devices, as committed to by FSAR. Appendix 3A. and as irplemented through the plant's STPs. The STPs address actions corres>onding to the LCOs and the SRs of the existing TS. The implementation of ST)s is controlled through SAP 139.
" Procedure Development. Review. Approval, and Control." Any change to the
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procedures is further screened through SAP 107 "10 CFR 50.59 Unreviewed Safety Question Review Process." This review arocess is directed in SAP 630.
" Procedure / Commitment Accountability Program ()/ CAP)." to identify any commitments (i.e.. TS. FSAR, and RG etc.) that may adversely affect a procedure.
Consistent with the licensee's submittal dated November 14. 1995, as supplemented on July 11, 1996 and July 24, 1997. License Condition 2.K. and Appendix C have been added to the VCSNS license as discussed above.
During a tele conference on May 12. 1997, between the licensee and NRC, the licensee agreed to the license condition as discussed above.
3.2 Other Administrative Chanaes on Paae IX of the TS Index With the deletion of TS 3/4.8.4.2 the licensee finds that it is no longer necessary to refer to TS 3/4.8.4.2 on page IX of the TS Index, and a subse 8 23)quent page should be renumbered accordingly (i.e., from 3/4 8 22 to 3/4 The staff has reviewed these changes and finds that they involve no changes to the technical content. Therefore, the staff concludes that the proposed changes are acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the State of South Carolina official was notified of the proposed issuance of the amendment, The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant s
increase in individual or cumulative occupational radiation ex30sure.
The Commission has previously issued a proposed finding that tae amendment involves no significant hazards consideration. and there has been no public comment on such finding (60 FR 65684). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c M9).
Pursuant to 10 CFR 51.22(b). no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
On the basis of the staff's review of the licensee's response to criteria outlined by the TS final rule, the staff concludes that the pro)osed amendment to remove LC0 3.8.4.2. SR 4.8.4.2. and Table 3.8-2 which list iOVs. from TS 3/4.8.4.2, and relocate them to the licensee-controlled plant procedures is acceptable,
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-Additionally, the proposed TS changes do not adversely affect the FSAR commitment to com)1y with RG 1.106, as its compliance will be maintained and controlled throug1 the licensee controlled plant procedures, and changes will be evaluated by 10 CFR 50.59 review.
The guidance of RG 1.106 for the MOV devices, are committed to by the FSAR, Appendix 3A, and implemented through the plant's STPs.
The Commission has concluded, based on the considerations discussed above, that:. (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner. (2) such activities will be conducted in compliance with the Commission's regulations, and (3)-the issuance of the amendment will not be inimical to the comon defense and security or to the health and safety of the public.
Principal Contributors:
Peter Xang and Ed Tomlinson Date:
August 13, 1997