ML20217G644
| ML20217G644 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/13/1999 |
| From: | Beasley J SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20138G470 | List: |
| References | |
| LCV-1364, NUDOCS 9910210317 | |
| Download: ML20217G644 (11) | |
Text
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r J. Barnio Beasley.Jr P.E.
Southern Nuclear Mce P.esident Operating Company, Inc.
Vogtle Project 40 invemess Center Parkway P0. Box 1295 7,
Birmingham. Alabama 3E20:
Tel 205 992.7110 Fax 205 992.0403 r'r SOUTHERN COMPANY Energy to Serve Your World*'
October 13, 1999 LCV-1364
- Docket Nos.
'50-424 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:
REQUEST TO REVISE TECHNICAL SPECIFICATIONS REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM COMPLETION TIMES AND BYPASS TEST TIMES In accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (ShC) proposes to revi e the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications (TS) to permit relaxation of allowed bypass tes times and Completion Times for Limiting Conditior s for Operation (LCOs) 3.3.1, Reactor Trip System (RTS) Instrumentation and 3.3.2, Engineered Safety Features Actuation system (ESFAS)
Instrumentation. These relaxations are those that are ger.erically approved in WCAP 14333-P-A, Revision 1, "Probabilistic Risk Analysis of the R'.~ S and ESFAS Test Times and
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Completion Times".
Specifically, the amendment would al..w:
Completien Times of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for inoperable analog instruments e-Bypass times of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of analog channels
' Completion Times of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for an inoperable logic cabinet or master and slave relays e
The proposed changes to the Completion Times and bypass test times have an insignificant impact on plant safety. This conclusion applies to signals generated by the solid state
. protection system. from either 2 of 4 or 2 of 3 logic. The proposed changes have the net effect of avoiding unnecessary plant shutdowns and/or spurious actuations as opposed to a r
s.aall increase in risk due to increased signal unavailability while at power.
. The proposed changes and their basis are described in Enclosure 1. A no significant hazards 9910210317'991013 DR ADOCK O 424
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U. S. Nucle:r Rigulatory Commission LCV-1364 Page 2 i
l evaluation pursuant to 10 CFR 50.92 is provided in Enclosure 2. Marked-up TS and Bases pages and clean typed pages are provided in Enclosures 3 and 4, respectively. Enclosure 5 contains the determination of applicability of WCAP-14333 to Vogtle Units 1 and 2. addresses Tier 2 requirements as identified in WCAP-14333. Enclosures 5 and 6
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contain information proprietary to Westinghouse Electric Company. Enclosure 7 contains the Affidavit for Withholding, the proprietary information notice, and the copyright notice in accordance with the requirements of 10 CFR 2.790. Enclosure 8 contains non-proprietary versions of Enclosures 5 and 6.
Since the proposed changes are consistent with the generically approved changes of WCAP-14333-P-A, Revision 1, SNC requests a timely review of this submittal. Specifically, SNC requests approval of the proposed changes by January 31,2000 Mr. J. B. Beasley, Jr. states that he is a Vice President of Southern Nuclear Operating Company and is authorized to execute this oath on behalf of Southern Nuclear Operating Company and that, to the best of his knowledge and belief, the facts set forth in this letter are true.
SOUTHERN NUCLEAR OPERATING COMPANY By:
A
[
' [ 0. ii. Be(sley,'Jf Swont to and subscribed before me this dayof 0
,1999.
f b.
Notary P4blic My commission expires: // /0 Ch i
JBB/NJS - Basis for Proposed Changes - Significant Hazards Consideration Evaluation - Marked-up TS and Bases Pages - Clean Typed TS and Bases Pages - Applicability of WCAP-14333-P-A to Vogtle Units 1 and 2 - WCAP-14333 Implementation: Tier 2 Requirements - Affidavit for Withholding. Proprietary Information Notice, Copynght Notice - Non-proprietary versions
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' U. S. Nucl:ar Regulatory Commission LCV-1364 f..
Page 3 l
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Southern Nuclear Operating Company ' '
- xc:
Mr. M. Sheibani NORMS.
U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator r
- Mr. R. R. Assa, Project Idanager, NRR
- Mr. John Zeiler, Seni'.,r Resident Inspector, Vogtle State of Georgh 4
L. C. Barrett, Commissioner, Department of Natural Resources f
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l E: clos:re 1 Vogtl2 Electric G=:rzti;g Pi=t Request to Revise Technical Specifications
' Reactor Trip System and Engineered Safety Features Actuation System Completion Times and Bypass Test Times Basis for Proposed Changes Proposed Changes The proposed changes will extend the byoass tet ume for the analog channels and the completion times for the analog channels, logic cabinets, master relays, and slave relays. The following table summarizes the proposed changes.
Tech Spec Parameter Current Parar.eter Value Extended Parameter Value (hours)
(hours)
RTS & ESFAS Instrumentation (analog channels):
- Bypass Test Time 4
12
- Completion Time 6
72 Automatic Actuation Logic and Actuation Relays (logic cabinets, master e i slave relays):
- Compleuon Time 6
24 i
The impacted Technical Specifications are 3.3.1 and 3.3.2. Thejustification, basis and methodology for i
these changes are contained in:
e' WCAP-14333-P-A, Revision 1, "Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times" The NRC's Safety Evaluation is transmitted by:
Letter from T.H. Essig to L. Liberatori, dated July 15,1998,
Subject:
Review of Westinghouse e
Owners Group Topical Reports WCAP-14333P and WCAP-14334NP, Dated May 1995, "Probabihstic Risk Analysis of the RPS and ESFAS Test Times and Completion Times"(TAC NO.
M92782)
Basis for Proposed Changes to the Bypass Test Time and Completion Times WCAP-14333 P-A, Revision 1 provides the technical basis and methodology for extending the allowed bypass test and completion times listed above. A risk-informed approach was used tojustify these changes. The approach is consistent with that recommended by the Nuclear Regulatory Commission in Regulatory Guide 1.174 ("An Approach for Using Probabilistic Risk Assessment in Risk-Informed
' Decisions on Plant-Specific Changes to the Licensing Basis") and Regulatory Guide 1.177 ("An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications"). The approach provides an evaluation of the impact on plant risk which uses the three-tiered approach as presented by the NRC in Regulatory Guide 1.177. Tier 1, PRA Capability and Insights, assessed the impact of the proposed test time and completion time changes on core damage frequency, incremental conditional core damage probability, and large early release frequency. Tier 2, Avoidance of Risk-Significant Plant Configurations, considered potential risk-significant plant operating configurations. Tier 3, Risk-Informed Plant Configuration Control and Management, considers risk evaluations of configurations El-1 j
l Etclosure1 j
Vogtle Electric Ge= rating Pimt Requer,t to Revise Technical Spec!fications j
% actor Trip System and Engineered Safety Features Actuation System Completion Times and Bypass Test Times Basis for Proposed Changes when entered. For VEGP, the Tier 3 requirement is addressed by the Configuration Risk Management 4
Program as discussed in 5.5.18 of the VEGP TS.
j The results of the risk evaluation addressing Tier 1 requirements, presented in WCAP-14333, demonstrate I
. that the risk metrics meet the acceptance criteria provided in Regulatory Guides 1.174 and 1.177. That is:
The impact of the changes on core dnnage frequency is less than IE-06/yr.
The impact of the changes on large early release frequency is less than 1.0E-07/yr.
The incremental conditional core t'.amage probabilities for each test and maintenance configuration is less than SE-07.
From the results of the assessment supporting Tier 2 requirements it was concluded that the only test or maintenance configuration associated with the extended test and completion times that could have a significant impact on plant risk level is with a logic cabinet out of service. Therefore, Tier 2 restrictions need to be identified only for a logic cabinet out of service.
j As stated above, the VEGP Configuration Risk Management Program (CRMP), as required by VEGP TS 5.5.18, was developed to address.the Tier 3 requirement. The CRMP we.s incorporated into the VEGP TS with Amendments 100 and 78 (issued by the NRC on May 20,1998). These amendments approved an extended Completion Time of 14 days for the emergency diesel generators. In their Safety Evaluation for Amendments 100 and 78, the NRC staff determined with respect to Tier 3 requirements that SNC had j
' provided reasonable assurance that risk-significant plant equipment outage configurations will not occur while the plant is subjected to the extended EDG AOT."
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The NRC's Safety Evaluation for WCAP-14333 concludes that "the risk analysis in WCAP-14333P 1
supports the proposed TS changes and is acceptable, subject to the following conditions which must be addressed in referencing licensee's plan:-specific license amendment requests:
- 1. Confirm the applicability of the WCAP-14333P analyses for their plant.
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- 2. Address the Tier 2 and Tier 3 analyses including the CRMP (Configuration Risk Management Program) insights, by confirming that these insights are incorporated into the referenced licensee's decision making process before taking equipment out of service."
i implementation Requirements The requirements for the above conditions are addressed in Enclosures 5 and 6. Enclosure 5 discusses the applicability of the WCAP-14333 analysis to the Vogtle Electric Generating Plant (VEGP). Included is a statement of applicability that concludes "the \\VCAP-14333 analysis is consistent with VEGP plant design and operation, and the changes in WCAP-14333, consistent with the NRC's SER on the WCAP, are applicable to VEGP." addresses the Tier 2 requirements. The purpose of Tier 2 requirements are to ensure that the plant risk does not increase to unacceptable leveh if multiple components are out of service simultanecusly. Supporting analyses demonstrate that the only plant configuration with an appreciable impact on plant risk or a significant impact on the relative importance of other systems is the El-2 9
- Vogtle El:ctric Gen:rstirg Pirnt Request to Revise Technical Specifications Reactor Trip System and Engineered Safety Features Actuation System Completion Times and Bypass Test Times
. Basis for Proposed Changes configuration with a logic cabinet out of service. The restrictions on cone'urrent removal of equipment from service when a logic cabinet is out of service are discussed in Enclosure 6.
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El-3 i
Enclosur: 2 Vogtle El:ctric Gm: rating Plant Request to Revise Technical Specifications Reactor Trip System and Engineered Safety Features Actuation System Completion Times and Bypass Test Times Significant Hazards Evaluation Proposed Changes As required by 10 CFR 50.91 (a)(1), an analysis is provided to demonstrate that the proposed license
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amendment to implement the conclusions of WCAP-14333-P-A, Revision 1 does not involve a significant hazards consideration. The proposed license amendment would allow:
Completion Times of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for inoperable analog instruments e Bypass times of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for surveillance testing of analog channels
. - Completion Times of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for an inoperable logic cabinet or master and slave relays The specific changes are as follows:
LCO 3.3.1, RTS Instrumentation Affected Affected instrumentation Proposed Change Condition Condition D e
Power Range Neutron Flux NOTE - Bypass Test Time: 4 hrs
- 12 hrs High Required Action D.1.1:
6 hrs
- 72 hrs Required Action D.1.2:
12 hrs
- 78 brs Required Action D.2.1:
6 hrs
- 72 hrs Required Action D.3:
12 hrs -+ 7{ hrs Condition E e
Power Range Neutron Flux NOTE - Bypass Test Time: 4 hrs -+ 12 hrs Low Power Range Neutron Flux e
High Positive Rate Required Action E.1:
6 hrs
- 72 hrs Overtemperature AT e
Overpower AT e
Pressurizer Pressure High Required Action E.2:
12 hrs
- 78 hrs
+
Steam Generator Water Level-Low Low Condition M e
Pressurizer Pressure Low NOTES - Bypass Test Time:4 hrs
- 12 hrs Pressurizer Water Level-e Required Action M.1:
6 hrs
- 72 hrs R actor Coolant Flow -
+
Low Two Loops Undervoltage RCPs Reqc; red Action M.2:
12 hrs
- 78 hrs Underfrequency RCPs J
e Condition N Reactor Coolant Flow-NOTE - Bypass Test Time: 4 hrs
- 12 hrs e
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Low Single Loop Required Action N.1:
6 hrs
- 72 hrs Required Action N.2:
10 hrs
- 76 hrs j
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Vogtle Electric G rer: ting Pirnt Request to Revise Technical Specifications Reactor Trip System and Engineered Safety Features Actuation System Completion Times and Bypass Test Times Significant Hazards Evaluation LCO 3.3.1, RTS Instrumentation (continued)
Affected Affected instrumentation Proposed Change Condition Condition O Turbine Trip Low Fluid Oil NOTE - Bypass Test Time: 4 hrs
- 12 hrs Pressure Required Action O.1:
6 hrs -4 72 hrs Required Action O.2:
10 hrs -176 hrs Condition P Turbine Stop Valve Required Action P.1:
6 hrs -4 72 hrs Closure Required Action P.2:
10 hrs -+ 76 hrs Condition Q Safety injection input from Required Action Q.1:
6 hrs
- 24 hrs ESFAS Required Action Q.2:
12 hrs
- 30 hrs Condition T Reactor Trip Breakers New NOTE 3 providing additional bypass time for an RTB train.
LCO 3.3.2, ESFAS Instrumentation Affected Affected instrumentation Proposed Change Condition Condition C Automatic Actuation Logic Required Action C.1:
6 hrs
- 24 hrs and Actuation Relays Required Action C.2.1:
12 hrs -+ 30 hrs Required Action C.2.2:
42 hrs -+ 60 hrs Condition D Safety injection NOTE - Bypass Test Time: 4 hrs
- 12 hrs j
Containment Pressure -
High 1 Safety injection Pressurizer Pressure - Low Safety injection Steam Required Action D.1:
6 hrs -+ 72 hrs Line Pressure - Low Steam Line Isolation Containment Pressure -
High 2 Required Action D.2.1:
12 hrs
- 78 hrs Steam Line Isolation Steam Line Pressure -
Low Steam Line Isolation Steam Line Pressure Required Action D.2.2:
18 hrs -+ 84 hrs Negative Rate - High Auxiliary Feedwater Steam Generater Water Level-Low Lcw E2-2
Encirsurs 2 Vogtle Electric Generating Plint Request to Revise Technical Specifications Reactor Trip System and Engineered Safety Features Actuation System Completion Times and Bypass Test Times Significant Hazards Evaluation I
LCO 3.3.2, ESFAS Instrumentation (continued) l Affected Affected instrumentation Proposed Change Condition' I
Condition E.
Containment Spray NOTE - Bypass Test Time: 4 hrs -+ 12 hrs Containment Pressure Required Action E.1:
6 hrs -+ 72 hrs High - 3 Required Action E.2.1:
12 hrs -+ 78 hrs Required Action E.2.2:
18 hrs
- 84 hrs Condition G e - Steam Line isolation Required Action G.1:
6 hrs -+ 24 hrs Automatic Actuation Logic and Actuation Relays Required Action G.2.1:
12 hrs -+ 30 hrs
- Automatic Actuation Logic Required Action G.2.2:
.18 hrs
- 36 hrs and Actuation Relays Condition H e
Turbine Tnp and Required Action H.1:
6 hrs -+ 24 hrs Feedwater Isolation l
Automatic Actuation Logic Required Action H.2:
12 hrs -+ 30 hrs
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L and Actuation Relays Condition i.
Turbine Trip and NOTE - Bypass Test Time: 4 hrs -+ 12 hrs Feedwater Isolation Low RCS Tm '
Required Action 1.1; 6 hrs -+ 72 hrs e Turbine Tn.p and.
Feedwater Isolation SG Water Level-High High Required Action 1.2:
.12 hrs
- 78 hrs (P-14)
. Condition K e Semi-automatic NOTE - Bypass Test Time: 4 hrs -+ 12 hrs
. Switchover to Containment Required Action K.1:
6 hrs -+ 72 hrs Sump Refueling Water i
' Storage Tank - Low Low Required Action K.2.1:
12 hrs -+ 78 hrs Required Action K.2.2:
42 hrs
- 108 J
hrs l
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Vogtle El:ctric Grnerating Pint Request to Revise Technical Specifications Reactor Trip System and Engineered "afety Features Actuation System Completion Times and Bypass Test Times Significant Hazards Evaluation Evaluation Conformance of the proposed amendment to the standards for a determination of no significant hazards as defined in 10 CFR 50.92 is shown in the following:
- 1) The proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The reactor protection and engineered safety features functions are not initiators of any design basis accident or event erd therefore the proposed changes do not increase the probability of any accident previously evaluated. The proposed changes to the allowed Completion Times and bypass test times have an insignificant impact on plant safety based on the calculated CDF increase being less than 1.0E-06. Herefore, the proposed changes do not result in a significant increase in the consequences of an accident previously evaluated.
- 2) The proposed license amendment does not create the possibility of a new or different kind of accident
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from any accident previously evaluated.
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The proposed changes do not result in a change in the manner in which the RTS and ESFAS provide plant protection. The RTS and ESFAS will continue to have the same setpoints after the proposed changes are implemented. There are no design changes associated with the license amendment. The changes to Completion Times or increased bypass test times do not change any existing accident scenarios nor create any new or different accident scenarios. Therefore, the j
proposed changes do not create the possibility of a new or different kind of accident from any
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accident previously evtluated.
- 3) The proposed license amendment does nct involve a significant reduction in margin of safety.
I The proposed changes do not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The impact ofincreased allowed Completion Times and bypass testing times should result in an overall improvement in safety by reducing the potential for spurious reactor trips and spurious actuation of safety equipment. The longer allowed Completion Times and bypass test times for the analog channels will provide additional time before being required to place the channel in trip. With the channel in trip, the logic required to cause a reactor trip or a safety system actuation is reduced to 1 of 2 (for 2 of 3 i
logic) and to 1 of 3 (for 2 of 4 logic). With one channel tripned, the potential for a spurious actuation is increased. Leaving the channel in the bypass state for additional time does reduce the availability of signals to initiate component actuation for event mitigation when required, but as shown in WCAP-14333, the impact on plant safety is small due to the availability of other signals or operator action to trip the reactor or cause component actuation. Therefore, the longer allowed Completion Times and bypass test times should reduce the potential for inadvertent plant trips due to operator error or spurious actuation.
Conclusion Based on the preceding analysis it is concluded that operation of Vogtle Units 1 and 2 in accordance with E2-4 Vogtle Electric Genmting Plant Request to Revise Technical Specifications Reactor Trip System and Engineered Safety Features Actuation System Completion Times and Bypass Test Times Significant Hazards Evaluation the proposed amendment does not significantly increase the probability or consequences of any accident previously evaluated, does not create the possibility of a new or different kind of accident from any accident previously evaluated, nor involve a significant reduction in margin of safety. Therefore, the license amendment does not involve a Significant Hazards Consideration as defined in 10 CFR 50.92.
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